Court filing
Judgment — United States v. Tracy D. Wade (Dkt. 280, 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. 280 · 2025-05-27 · Docket on CourtListener
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO. 0:23-cr-60173-KMW
UNITED STATES OF AMERICA,
Miami, Florida
October 7, 2024
vs.
9:35 AM - 4:20 PM
CAROLYN DENISE WADE
TRACY D. WADE,
Volume 1
Defendants.
Pages 1 to 195
______________________________________________________________
TRANSCRIPT OF JURY TRIAL
BEFORE THE HONORABLE DONALD L. GRAHAM
UNITED STATES DISTRICT JUDGE
APPEARANCES:
FOR THE GOVERNMENT:
David A. Snider, Esquire
Adam Love, Esquire
DOJ-USAO
U.S. Attorney's Office,
Southern District of Florida
500 E. Broward Boulevard
Suite 7th Floor
Fort Lauderdale, Florida 33394
FOR THE DEFENDANT:
Johnny L. McCray, Jr., Esquire
400 East Atlantic Boulevard
Pompano Beach, Florida 33060
-and-
Daryl E. Wilcox, Esquire
5201 Southwest 18th Street
Plantation, Florida 33317
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STENOGRAPHICALLY REPORTED BY:
GLENDA POWERS, CRR
Official Court Reporter before:
The Honorable Donald L. Graham
United States District Court
James L. King Federal Justice Building
99 NE 4th Street
Miami, Florida 33132
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(Call to the Order of the Court.)
(Jury not present.)
THE COURT: Good morning, everyone. I am pleased that
we are all in place. I'm impressed given the weather scenario.
You may be seated at this time.
I know that Government counsel would like to remain
seated throughout the proceeding; is that correct?
MR. SNIDER: That's easier for me, Judge.
THE COURT: Yes, that's fine. So I'll give the defense
the option of handling it the way you would like.
Would you like for me to make an announcement, or do
you want to say something during your introduction?
MR. SNIDER: No.
Judge, I can stand. I'm going to stand for the
Government's opening statement.
I just meant my prolonged up-and-down. I mean, if I
could object without standing. Actually, I feel more
comfortable addressing the Court on my feet; so I'm going to
try to do that.
THE COURT: Well, make it comfortable for yourself.
You have the option of handling it any way you desire.
MR. SNIDER: I appreciate that, Your Honor. I am
feeling better than I was last week.
THE COURT: Fantastic.
There are a few preliminary matters I would like to
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address.
Counsel, if you would turn to page 9 of the indictment,
I'm a little confused. On page 8, you make reference to Counts
II and III, the wire fraud counts.
MR. SNIDER: Yes.
THE COURT: And on page 9, it references Counts I and
II.
MR. SNIDER: So that table is misnumbered. It should
say II and III. And I'm glad the Court caught that. I was
going to bring it up as well. I'm not sure how the Court wants
to handle it, but the wire fraud counts are Counts II and III.
Count II charges Defendant Tracy D. Wade alone. Count
III charges defendants, Carolyn Denise Wade and Tracy Wade.
Maybe defense will stipulate to a hand annotation
noting II and III as opposed to I and II on the copy that goes
back to the jury.
THE COURT: I will take that as a motion to make a
ministerial change to the indictment on page 9, changing Count
I to Count II and then Count III.
MR. SNIDER: Correct.
THE COURT: Is there an objection?
MR. McCRAY: Not from the defense, Judge, no.
THE COURT: All right. So the indictment that goes to
the jury, let's make sure that it is corrected, and let's show
it to opposing counsel and the Court before it is submitted to
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the jury.
A couple of items regarding voir dire; there is an
additional question that is not on the questionnaire.
MR. SNIDER: I'm sorry, Judge?
THE COURT: There is a question that is not on the
questionnaire that was submitted to the jury this morning for
filling out, and that question has to do with where they reside
within Miami-Dade County.
I'm concerned about the weather scenario, and I would
like to know where people live so that if we somehow find out
that there are extraordinary weather conditions in a certain
area, we'll be aware of it.
So what I may do is have the jurors stand and give us
their name and tell us what area of the county they live in,
and then the remaining questions and answers are on the
questionnaires, which you have access to.
Regarding the voir dire, I want you to take a quick
look at the Government's proposed voir dire. Of course, I'll
give you an opportunity to ask some questions.
With regard to Question 1, you can ask that general
question, or maybe not, whether punishment will be considered
is an instruction that I give the jurors, and so I'm not sure
that it's proper for this question to be asked the way it is
presented.
I suppose if you wanted to ask -- but I'm not sure you
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want to waste your time on this question since it's going to be
covered; but if you wanted to ask if the Court gives you an
instruction that you cannot consider punishment in any way in
determining the facts in the case, could you follow that
instruction?
If you want to ask it that way, fine. The way it's
presented in your proposed voir dire, I am not going to allow
it as it is.
MR. SNIDER: I like the Court's suggestion.
Thank you.
THE COURT: All right. Question 4 is fine.
Question 5, I don't care for the question the way it is
presented: [As read] "Does anyone feel that any current events
or any knowledge on personal views that you have about police?"
I'm not going to allow the question the way it is
presented.
I do ask this very similar question, frankly.
MR. SNIDER: Okay.
THE COURT: 6, 7, 8, 9 are fine.
As to Question 10, if you want to ask generally about
impartiality, you may, but the way it's presented in
Question 10, I will disallow.
A lot of the witnesses on the Government's witness list
and the exhibit list appear as they may be addressing the
404(b) issue, I'm not sure, but I want to make sure that you
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follow the Court's instruction and not go into any 404(b)
issues, as we discussed, until near the conclusion of the
defendant's case in chief, and then I can make a determination
as to the extent of which the 404(b) will be allowed.
MR. SNIDER: Yes. I understand the Court's ruling on
that, and the Government will not elicit any testimony
regarding EIDL loans. The Government's not going to touch upon
it in its opening statement.
And just so the Court has comfort, the only witness on
the Government's witness list who even has, I believe,
knowledge to testify about the EIDL loans that were noticed in
the 404(b) notice is Number 11, Rachel Dodd.
THE COURT: All right.
MR. SNIDER: The Witness Number 1, Althea Harris of the
SBA, her testimony is going to concern the Paycheck Protection
Program. She may say that EIDL was one of the other programs,
but she's not going to get into any substance about the 404(b)
that's been noticed.
THE COURT: Very well.
Just quickly regarding the instructions that the
defense proposed, the good faith defense, that can be an
appropriate instruction, but there has to be a factual basis
for it. So make sure you're familiar with the cases in that
regard. Usually, it requires some testimony from the defendant
before that instruction is given. So just keep that in mind.
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Take a look at the cases. When we get to the instruction
phase, we can discuss it, and the Court can make a decision.
MR. SNIDER: Your Honor, one point on that. I will
address this in more detail at the charge conference, but it's
the Government's position that that instruction on good faith
as a defense, to the extent that there is a foundation for it
that's been established, would only be applicable to a -- would
not be applicable to the charge of making a false statement to
the SBA.
THE COURT: We can discuss all that later.
MR. SNIDER: Okay.
THE COURT: Once we know what the foundation is, then
we can go to Step 2 and see if it's still an appropriate
instruction or not.
MR. SNIDER: Okay.
THE COURT: 2 matters with regard to Mr. and Mrs. Wade.
Mrs. Wade has been explained this previously, but I'm
going to go over it again.
The first question I have is whether there were any
offers made to the defense.
Do not tell me the substance of any offers. The simple
fact, were there offers made? And if there were offers made,
defense counsel can then advise the Court if they were
communicated to the defendants.
Government, were any offers made?
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MR. SNIDER: The United States made a plea offer to
Defendant Carolyn Wade prior to the grand jury returning the
superseding indictment.
THE COURT: All right.
MR. WILCOX: So it was made following the first trial,
which resulted in a mistrial, but before the grand jury
returned the superseding indictment, that there was a formal
plea offer extended.
The Government has not extended a plea offer to
Defendant Tracy Wade.
THE COURT: Defense, is that your understanding of the
status of any offers made?
MR. McCRAY: Yes, Judge, that's correct as relates to
Mrs. Wade, and no offer has been tendered regarding Mr. Wade.
THE COURT: And were the offers made for Mrs. Wade
tendered to her?
MR. McCRAY: Oh, yes, Judge. We sent her emails, and
we also discussed it.
THE COURT: All right. Fine.
The second issue is whether or not the sentencing
guidelines have been discussed in general with each defendant.
As you all know, none of us know what any guidelines will be,
if even applicable in the case, but just a general
understanding of how the guidelines function, has that been
explained to each defendant?
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MR. McCRAY: Yes, Judge, they have.
THE COURT: All right. Thank you.
Now, we have some weather issues upon us, and so I will
decide at later -- I originally planned to be in session until
4:00 p.m. each day, and we may very well do that today.
Tomorrow we may be in session until 3:00 p.m. in case we have
some serious wind issues and flooding issues in our area. It's
pretty difficult to predict that at this time, but we'll handle
that back here.
And also, counsel, you likely are aware that if the
schools are closed, the courts are closed.
MR. WILCOX: Yes, Judge.
THE COURT: So that's usually public information on the
TV, radio -- et cetera. So keep that in mind until we begin
each day; and, hopefully, we get through our trial with no
interruptions.
As we discussed previously, we will not be in session
on Friday and Monday is a federal holiday. I think that's the
11th. So we will not be in session Friday or Monday. And
we're hopeful we can get the case completed in the two-week
period.
MR. SNIDER: Your Honor --
THE COURT: I'm advised that we are somehow missing two
jurors. I always fail to understand how we miss jurors from
the 7th floor up to the 13th floor, but they are searching for
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them now; and, hopefully, they will be with us soon.
Yes, sir.
MR. SNIDER: It's just with respect to scheduling
tomorrow and the forecast, which none of us have a crystal
ball. It does seem like the weather -- well, that storm which
is predicted to hit the West Coast of Florida does seem like
it's going to hit sometime on Wednesday. So I think it's fair
to say that the weather is going to get worse as we get closer
to the middle of the week.
I bring this up just because out of the 12 witnesses on
the Government's witness list, seven are flying in from all
different parts of the country. We have a few witnesses from
California. We have a witness from Texas. We have a witness
from Denver, Colorado. We have a witness from Philadelphia.
And most -- some of those -- I think there's one witness that's
already arrived today -- or arrived yesterday. Most of the
witnesses are arriving today with anticipated testimony
tomorrow.
So to the extent that we can get as much of those
out-of-town witnesses completed tomorrow so that they can
hopefully fly get before the storm, that's the Government's
preference. If it's really bad tomorrow and we have to end
early, I understand, but to the extent that we can keep going
to at least get those out-of-town witnesses to finish with
their testimony, that will be helpful.
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THE COURT: We will do the best that we can. Of
course, a lot of that may depend on how concise your questions
are.
MR. SNIDER: Very well.
THE COURT: We will try to get as much as possible
tomorrow; and if we can go to 4:00, I'm happy to do that.
MR. SNIDER: Okay.
THE COURT: If it's flooding downtown, then it creates
some problems for us.
MR. SNIDER: Okay.
THE COURT: All right. Is there anything else I should
be aware of this morning?
How much time are you requesting for your opening
statements?
MR. SNIDER: The Government would like 40 minutes.
MR. McCRAY: Your Honor, on behalf of the Wades, we
have a witness that's subpoenaed. We put on there the 7th, but
we've spoken with him several times. We told him that we don't
anticipate that our case will commence until maybe next Tuesday
because Monday's a holiday. He insisted on coming today. He's
in the courtroom.
We told him that the subpoena -- with the subpoena, he
needed to be here next Tuesday, but he insisted on coming into
the courtroom. He is here now. He's in the back, sir.
MR. PEREZ: Your Honor --
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THE COURT: Just a minute, sir.
MR. McCRAY: I guess we're asking the Court if the
Court could explain to him that I can't give him a precise
time. We would like for him to be here on next Tuesday
morning. That's when we anticipate that this witness -- that's
when we said the defense's case will probably start around that
time.
I have his number. I've been staying in touch with
him.
THE COURT: Well, the Government indicated that it
wanted to finish its case on Thursday. Is that still your
understanding?
MR. SNIDER: It's my hope, desire, and my intention to
finish the Government's case in chief at some point on
Thursday.
THE COURT: Any ideas to what point? Like Thursday
morning or Thursday afternoon?
MR. SNIDER: Well, again, I guess there's so many
variables here, Judge. You know, obviously -- hopefully, the
Court stays open all week. If there's a closure because of the
schools, that's going to push us back. If we have to end early
tomorrow because of the weather, that's going to push us back.
If everything goes according to plan, then I would say we -- I
expect by midday, perhaps lunch on Thursday, but that's if
everything goes according to the plan.
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THE COURT: I understand. So that may have some
impact. If they finish by noon, hypothetically, on Thursday,
then...
MR. McCRAY: We can have our witnesses lined up to be
here after lunch on Thursday, Judge.
THE COURT: All right. Now, do you want to confer with
your witness? He stood up and started to walk down. I don't
know if there's an issue or not.
MR. PEREZ: Your Honor.
Yes, sir. Your name, please?
Come forward and speak into the microphone. Good
morning.
MR. PEREZ: Good morning, sir. I was subpoenaed to be
here at 9:00 today.
THE COURT: Yes, sir.
MR. PEREZ: So I'm here.
THE COURT: Yes, that's the way subpoenas work, sir.
MR. PEREZ: Right.
THE COURT: The lawyers advise the witnesses that we
will let you know how the progress of the trial is going.
MR. PEREZ: Yes.
THE COURT: The trial starts on October 7th, which is
today, and the lawyers subpoena all of the witnesses for
October 7th, but they have some lead time to let the witnesses
know more precisely when they should be here.
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MR. PEREZ: Okay.
THE COURT: So --
MR. PEREZ: The paper said 9:00.
THE COURT: I understand. You're here.
MR. PEREZ: And I came from Palm Beach.
Okay?
THE COURT: I think the attorney told you that you
didn't have to be here today; correct?
MR. PEREZ: No, he told me that, yes.
THE COURT: Yes. The attorney, Mr. McCray, told you
that --
MR. PEREZ: Just today, this morning.
THE COURT: Oh, you mean this morning?
MR. PEREZ: This morning, yeah.
THE COURT: All right. Did the witness know in
advance?
MR. McCRAY: Judge, we spoke to Mr. Perez extensively
on Friday. I think Mr. Smith spoke with him again. We told
him, but he says, "No, the subpoena says 7th; I'm going to be
here."
MR. PEREZ: Yes.
THE COURT: All right. But it's not --
MR. PEREZ: They served me, you know; so I'm here.
THE COURT: Listen to me. They served you, but then
they tell you, "You don't have to be here until a certain
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time."
The subpoenas always have the starting date of a trial
because we never know how the case is going. Sometimes it's
fast. Sometimes there's no trial. There are all sorts of
eventualities. So they serve you. It says the 7th. You're
here, but it's not likely you will be testifying today.
It's likely you will be testifying when the attorneys
give you -- they try to give you at least a day or so advance
notice: "Okay. Your testimony's going to be on Friday,"
hypothetically, or "Your testimony is going to be on Tuesday,
please be" -- we do that to try to not inconvenience the
witnesses as much as possible so that you don't have to come in
every day.
MR. PEREZ: I was supposed to work today. I lost --
THE COURT: Yes. But you understand what I'm saying,
sir?
MR. PEREZ: Yes.
THE COURT: All right. All right. So we appreciate
you being here, but stay in touch with Mr. McCray and his
staff, and they will give you more guidance so that you don't
have to be inconvenienced and miss work.
Okay?
MR. PEREZ: Can I say something?
THE COURT: Yes, sir.
MR. PEREZ: But I don't even know these people. That's
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what I'm saying.
THE COURT: You don't have to know them. They have
your phone number, and they have been in touch with you;
correct?
MR. PEREZ: Yes, because they subpoenaed me.
THE COURT: Right. So they don't misrepresent when you
should be here. So you don't have to know anyone, but they're
giving you the instructions, and they will let you know
specifically when you should be here.
If you want to come every day, that's up to you; but I
would suggest that you follow their instructions so that you're
not inconvenienced.
All right?
MR. PEREZ: Okay, Judge.
THE COURT: Thank you very much, sir.
MR. PEREZ: You're welcome.
THE COURT: Have a good day.
All right. I think we have everyone here, so we're
going to have jurors come in and be seated, and we'll get
started. Thank you.
(Prospective jurors entered courtroom at 10:00 a.m. )
COURTROOM DEPUTY: Everyone can be seated. Court is
back in session, the Honorable Donald L. Graham presiding.
THE COURT: Please raise your right hand, ladies and
gentlemen so you may be sworn.
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COURTROOM DEPUTY: Do you and each of you solemnly
swear or affirm that you will truly answer all questions
propounded to you touching upon your qualifications to serve as
a juror in this case about to be tried?
PROSPECTIVE JURY PANEL: Yes.
THE COURT: Be seated, please. And good morning,
ladies and gentlemen.
My name, as you heard, is Donald Graham, and I will be
the United States District Judge presiding over this case.
This is a criminal case, and we are about to start the
process known as voir dire. That's a French term which means
to speak the truth, and that is exactly what we would like for
you to do this morning.
We will be asking several questions, and we ask you to
listen to the question and respond as directly as you can and
that you be forthright and honest with your responses.
Our goal is to select jurors who can be fair and
impartial to the Government and to the defense. And that's
what we would like for you to help us do -- pick individuals
who can be fair and impartial.
Most of you know that we have some recent weather
events upon us; so we are going to act accordingly so we can
keep everyone safe. So for your information, just at the
beginning, you should know that if the schools are closed, the
courts are closed.
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So as you listen to the news, if you hear that the
Miami-Dade County schools are closed, then you know that we are
closed.
Now, we have several divisions in the Southern District
of Florida. This is the Southern District of Florida for
federal courts, and our jurisdiction is as far north as Vero
Beach and as far south as Key West. So each of those divisions
will have different rules.
So if the schools are closed in Key West, it doesn't
mean the schools are closed here. If the schools are closed in
Fort Pierce or Fort Lauderdale or West Palm Beach, the
Miami-Dade schools could be open. So listen carefully. The
Miami-Dade school is the guideline.
Now, we have a little authority ourselves as individual
judges; so we're going to monitor as well. And if there's any
particular flooding or anything that we think is dangerous,
then we may say, "Court is not in session," but we will have
everyone's phone number and email address and we will keep you
advised accordingly. Of course, again, and importantly, if the
Miami-Dade schools are closed, you know that the courts are
closed.
Now, for further information, not all of you will be
selected. Some of you will be. This Friday we will not be in
session. We'll be in session Monday through Friday --
Thursday, rather, hopefully, Monday through Thursday. So if
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you have some appointments or something that you need to do on
Friday, you know you will have the full day.
The courts are closed also next Monday, which is a
federal holiday. So Friday and Monday we will not be in
session. So keep that in mind as you schedule your events.
Now, as I said, this is a criminal case and this case
involves two defendants. The defendants who you will be
introduced to momentarily are Mr. Tracy Wade and Mrs. Carolyn
Wade, and this case involves, obviously, two defendants.
The law allows more than one defendant to be tried at
the same time. However, there are really two trials going on,
and you will have to make your factual findings with respect to
each defendant and each count. So when you retire to
deliberate, you consider the counts and the defendants
individually. So as I stated, two trials occurring
simultaneously, so please keep that in mind.
Now, I am going to give you some general information
about what this case involves so that you will be aware
generally of what's involved.
The lawyers this morning or early afternoon will be
making opening statements, and they will tell you what their
various positions are with respect to the evidence that you
will entertain in this case, but I'm going to tell you a little
bit about the counts now and what they involve.
Count I charges a conspiracy to commit wire fraud. A
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conspiracy is an agreement. That doesn't mean that you
actually committed the act. It means that there was a meeting
of the minds amongst two or more persons to do something the
law forbids. So Count I in this case is a conspiracy alleged
against both defendants. And this wire fraud alleges that
there was an agreement in the attainment of PPP loans. You may
have heard that term before.
PPP stands for Paycheck Protection Program loans.
These were loans and a loan program during the COVID period.
You'll hear more about that. But it's alleged that there was
an agreement amongst the defendants to obtain funds from the
PPP program by making false and fraudulent statements. That
would be Count I.
Count II alleges -- II and III, actually, allege what
we call substantive counts. That means it's not an agreement
to do something. It means that something was actually done.
So you have your conspiracy, and you have the substantive
counts. And Count II alleges that Mr. Wade obtained funds
fraudulently and Count III alleges that Mr. Wade and Mrs. Wade
obtained funds fraudulently.
So once again, you're going to consider each count and
each defendant, and we'll have a verdict form that you use to
indicate what your findings are once you complete your
deliberations.
Count IV alleges a conspiracy; that is an agreement to
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make false statements in connection with loans. And Count IV
is as against both defendants.
Count V alleges false statements were made to the Small
Business Administration. That's Count V as against Carolyn
Wade.
Count VI charges false statements were made to the SBA,
but the defendant in this case is Mr. Tracy Wade.
Count VII alleges false statements made to the SBA
involving Mr. Tracy Wade.
Count VIII, false statements to the SBA as to defendant
Carolyn Wade.
Count IX, false statements as against Carolyn Wade.
And Count X false statements as to Mr. Tracy Wade.
So those are the substantive counts. So you have some
conspiracy counts and some substantive counts.
Now, at the end of the case, I will give you your
instructions on the law. I will tell you what the law is in
this case, and you have to follow that law whether you agree
with it or not.
You know, we all have our own opinions about what the
law ought to be. I'm bound by that, too. I have my own
personal opinions, but when we're in a court of law, we have to
follow the law as it is.
I always tell prospective jurors if you have a problem
with the law, you need to contact your congressmen because they
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make the law that all of us are bound by; so please, keep that
in mind as we go through the process.
Now, at this time, ladies and gentlemen, I am going to
have the parties introduce themselves to you. First, you are
going to get introductions from the Government, that is counsel
and those who may be assisting the lead counsel. And in
addition, they are going to tell you the names of the witnesses
that may be called or may not be, but they will give you a list
and they will tell you who these witnesses are employed by.
Listen carefully because I will ask you if you know any
of the persons introduced, including the witnesses, and/or if
you have any close working relationship with any of the
employers referenced. So listen carefully to the introductions
from the Government; and then after their introductions, I will
allow the defense counsel to introduce themselves and their
clients to you as well.
MR. SNIDER: Thank you, Your Honor.
Good morning, prospective jurors. Here, my name is
David Snider. I'm an Assistant United States Attorney, and I
work for the U.S. Attorney's Office for the Southern District
of Florida. I represent the United States America in this
case.
With me are two other members of the prosecution team,
and I'm going to let them introduce themselves.
MR. LOVE: Good morning. My name is Adam Love. I work
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here at the United States Attorney's Office for the Southern
District of Florida, and I am also an Assistant United States
Attorney.
AGENT DIPIETRANTONIO: Good morning, everyone. My name
is Kelly Dipietrantonio. I'm a special agent with the FBI out
of the Miami field office.
THE COURT: All right.
MR. SNIDER: Thank you, Your Honor. And as Judge
Graham just mentioned, the Government has a number of witnesses
that it may call in this trial, and I'm going to go through
that list with you right now just to see if anyone is familiar
with any of these individuals.
The first person, her name is Althea Harris, and she
works for the U.S. Small Business Administration, which is
commonly referred to as the SBA.
The second witness is a Aman Thakral. He was
previously employed by a company called Oto Analytics, which
does business as Wombly.
The third witness or potential witness is Lindsey
Bergh. She works for a company called Persona Identities, Inc.
The next possible witness is Megan Musil. She works
for a company called Harvest Small Business Finance, LLC.
The next witness is Michael Friedman. He works for
SmartBiz Loans.
The next witness is Renee McClain, and she works for
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the Internal Revenue Service. It's called I.R.S.
The next witness is from AT&T, Linda Thomas. Linda
Thomas works for AT&T.
The next witness is Dion Morrow, and he works for
Verizon.
Next is Joanna Hely, and she works for Broward
Sheriff's Office.
Also from the Broward Sheriff's Office is Alexander
Rodriguez.
The next witness is Rachel Dodd. She works for the
U.S. Small Business Administration as well, the SBA.
The next possible witness is Haydee Rivero. Her name
is spelled H-A-Y-D-E-E, Haydee Rivero. And she was formerly
known before she was married as Haydee Granados.
And the last witness for the Government, potential
witness is as a Kelly Dipietrantonio from the FBI.
THE COURT: Thank you very much, counsel.
Ladies and gentlemen, I would like to ask you at this
time if you recognize the names of any of the persons mentioned
including counsel?
Do you recognize any of those names as someone you may
be familiar with?
I see one hand. All right.
We're going to pass the microphone to you.
THE COURT: Your name, please?
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PROSPECTIVE JUROR: My name is Sara Saba.
THE COURT: Saba. I'm looking at my chart. Ms. Diaz
is to your right; correct? Is that Ms. Diaz?
PROSPECTIVE JUROR: Yes.
THE COURT: All right. Thank you. Just making sure
our chart is accurate.
Ms. Saba, who are you familiar with?
PROSPECTIVE JUROR: I think this -- the attorney, the
district attorney -- I mean, the U.S. Attorney.
THE COURT: U.S. Attorney. And his name?
PROSPECTIVE JUROR: Was it David?
MR. SNIDER: David Snider.
PROSPECTIVE JUROR: I do Federal qui tam work.
THE COURT: I'm sorry, you do?
PROSPECTIVE JUROR: I do federal qui tam work.
THE COURT: All right.
PROSPECTIVE JUROR: Yeah, so I'm a plaintiff's lawyer,
and sometimes I bring on qui tam, and I have to reach out to
the U.S. Attorney's Office. So I think -- I don't know if
he's -- I'm familiar with his name or if -- I just deal with a
lot of different attorneys, and I don't want there to be any
conflict.
THE COURT: Do you recognize him by looking at him?
PROSPECTIVE JUROR: He doesn't really look familiar,
but I don't usually see them in person. Usually it's emails
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and phone calls for a decision.
THE COURT: And what is it that you do with the U.S.
Attorney's Office?
PROSPECTIVE JUROR: I'm a qui tam attorney,
whistleblower attorney.
THE COURT: Yes.
PROSPECTIVE JUROR: Okay.
THE COURT: Do you want to explain that to the members
of the jury who may not know what qui tam is?
PROSPECTIVE JUROR: Well, whenever there's a crime
against -- a fraud or false claim against the Government, then
what, as a U.S. citizen, we can do is bring a case through a
civil lawyer on behalf of the United States of America to go
ahead and collect on that.
THE COURT: All right. So you represent individuals in
civil cases; correct?
PROSPECTIVE JUROR: Correct.
THE COURT: All right. Now, having a working
relationship with the U.S. Attorney's Office, do you feel that
you could be a fair and impartial juror in this case, or do you
think that that could create some issues for you?
PROSPECTIVE JUROR: I think it may create an
impartiality, just at least the view of one.
THE COURT: All right. Thank you. You know, this is
the busiest trial district in the United States. I think we
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have five or six juries going on today; so there's plenty of
work here, and you're probably better suited for one of those
other cases. So at the appropriate time, we will excuse you.
Thank you.
Anyone else familiar with any of the parties mentioned
or have a close working relationship with any of the business
entities referenced? For example, the Small Business
Association? Oto Analytics? Persona Identities? Harvest
Business? SmartBiz Loans? The Internal Revenue Service?
AT&T? Verizon? The Broward Sheriff's Office?
Any of you have a working relationship with any of
those businesses, or whether or not you know any of the
witnesses or attorneys referenced?
If so, would you raise your right hand.
I see one hand. Do you want to pass the microphone and
have the gentleman give us a name.
PROSPECTIVE JUROR: My name is Lee Pivnik.
THE COURT: Yes, sir.
PROSPECTIVE JUROR: I don't have a current working
relationship with the SBA, but I did apply for -- the company I
was working at and also my family's company applied for
Paycheck Protection Loans. So I'm not sure if you want --
THE COURT: Say that again, please. I want to make
sure I'm clear.
PROSPECTIVE JUROR: I assisted in the application of
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PPP loans, and I'm not sure if that would qualify as
relationship with SBA.
THE COURT: We appreciate you telling us that. Let me
ask this question: Having some familiar with the PPP loans, do
you think that that would cause a problem with you being fair
to both sides, the defense and the Government?
PROSPECTIVE JUROR: I do not believe it would be
problem. It was important just to close.
THE COURT: Do you think you can listen to the evidence
and make decisions that are fair to both sides?
PROSPECTIVE JUROR: Yes.
THE COURT: All right. Thank you very much,
Mr. Pivnik.
PROSPECTIVE JUROR: Thank you.
THE COURT: All right. Anyone else?
Yes, Ms. Diaz.
PROSPECTIVE JUROR: I have a problem to understand all
you speaking in English. My English is very, very little or
very, very bad.
THE COURT: All right. I'm going to ask that a little
later; so I'll have you respond a little later during the voir
dire process.
Let me ask the question now: Have you understood
everything I was said this morning so far?
PROSPECTIVE JUROR: Repeat.
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THE COURT: Thank you. I think you answered my
question.
All right. Anyone -- all right. I see a hand in the
rear.
PROSPECTIVE JUROR: Hi. I'm Lisandra Alejo, and I have
the same problem as her. My English is not perfect. It's just
basic. In my work, I can understand, but I feel scared that I
cannot be, like, partial with all the information you provide
because I can not understand everything.
THE COURT: You know, nowadays no one speaks the King's
English anymore. And so far, have you understood what I have
said about two trials going on at the same time and that sort
of information?
PROSPECTIVE JUROR: I can say 50/50.
THE COURT: All right. We'll come back to you a little
later, and I want you to listen carefully and let me know if
you are understanding what's happening.
I think you speak pretty good English, frankly, but
we'll entertain again.
MR. WILCOX: Your Honor, the name of that prospective
witness, I missed it.
THE COURT: I was just getting ready to ask it. Your
name again, please.
PROSPECTIVE JUROR: Lisandra Alejo. I'm Number 45.
THE COURT: Somehow we have you in the wrong seat.
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Ms. Miller, would you stand, please?
PROSPECTIVE JUROR: Yes.
THE COURT: All right, Ms. Miller. Ms. Guia. Raphael.
Varela. McCray. Giraldo.
All right. Ms. Alejo, I'm going to have you go to the
far right seat. Somehow we have you in the wrong seat and on
the end; so the others may have to move down.
Yes. All right. I hope -- we'll find out. I hope we
have everyone in the proper seat.
All right. Anyone else? We have -- well, wait, I
think I see one hand in the -- I see, two hands. Let's try the
two hands in the spectator area first. Your name, please.
PROSPECTIVE JUROR: Olga Bustamante.
THE COURT: All right. Thank you.
PROSPECTIVE JUROR: I just want to say that my husband
has an SBA loan, and I don't know if I'm supposed to disclose
that.
THE COURT: Just the fact that your husband has an SBA
loan, the first question, was it an PPP loan or a different
type?
PROSPECTIVE JUROR: I'm not sure.
THE COURT: All right. Because your husband had a
loan, do you think that that would affect your ability to be
fair and impartial juror?
PROSPECTIVE JUROR: No, not at all.
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THE COURT: All right. Thank you. There was one
additional hand.
Yes, sir. Your name please.
PROSPECTIVE JUROR: My name is Michael Babitz. I'm
Juror 26.
THE COURT: Yes, sir.
PROSPECTIVE JUROR: I just wanted to say I'm an
attorney with USDIS. I have worked with many USAs previously.
Although, I have not worked with either of those two USAs.
THE COURT: All right. What relationship have you had
with other assistant U.S. Attorneys?
PROSPECTIVE JUROR: Been a subject matter expert in
immigration and worked closely with USAs making sure that they
understand the legal issues that are involved in cases that
they bring before the Court.
THE COURT: Are those immigration cases or --
PROSPECTIVE JUROR: Yes.
THE COURT: All right. Now, you work with the U.S.
Attorney's Office. Do you believe that that would have an
impact on your ability to be a fair and impartial juror?
PROSPECTIVE JUROR: I think that over all the years
that I've worked for the U.S. Attorney's Office, I have a huge
amount of respect for the professionals that work with them,
and, you know, that would color how I view things.
THE COURT: All right. So you're a lawyer; right?
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PROSPECTIVE JUROR: Correct.
THE COURT: So you know how the system works. So you
don't think you can put all of that aside and listen to the
evidence and make decisions based on the law independent of any
relationship with the U.S. Attorney's Office?
PROSPECTIVE JUROR: I would absolutely do my best to be
impartial and make decisions based on the specifics of the
case, but I just thought I needed to reveal my relationship.
THE COURT: Oh, no, you did the right thing. We want
to know, but I guess just delving a little further. If you
hear testimony presented only by the Government and you hear
testimony presented by the defense, even though you're going to
find out defense don't have to present testimony, but could you
listen to both sides and be fair to both sides? Or would you
be thinking, "Well, I work with the U.S. Attorney's Office, so
they get the tie vote?"
What are your thoughts in that regard?
PROSPECTIVE JUROR: I think I would -- honestly, I
would want to do the best that I could. I've had so many years
of working with the USAs, and I just believe that -- that I
have a huge amount of respect for them. I don't work directly
with the other side. So I would absolutely do the best that I
could to be impartial. I'm not a hundred percent sure that I
could.
THE COURT: All right. Thank you very much, sir.
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MR. McCRAY: Judge, may we approach sidebar, please?
THE COURT: All right. Come forward quickly, please.
(Sidebar.)
MR. McCRAY: This is John McCray on behalf of Mr. and
Mrs. Wade. Judge, we're going to ask for a mistrial at this
point. I ask that we have these jurors removed and bring us
some more jurors. This gentleman has stated twice in the
presence of the other jurors about the huge amount of respect
that he has with the USAs. Also, we just feel as though that's
probably tainted the jury.
THE COURT: Yes, sir, I understand your objection.
Your objection is overruled. We're making inquiries as to
whether persons can be fair. And if you want to ask some more
questions in that regard, you may during your opportunity to
question them.
And if you request, I'll ask the other jurors is there
anyone that feels the same way or something in that regard.
MR. McCRAY: I would make that request, judge.
THE COURT: Anything else?
MR. McCRAY: No, Judge. Thank you.
(Sidebar concluded.)
THE COURT: Anyone else in the spectator area on this
subject? I know that there's one hand in the box. So let's go
to --
PROSPECTIVE JUROR: Hello. My name is Jimmy Rivera,
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and I got -- I'm an accounting firm. I'm a partner. And I got
a partner in the office, and I applied for a PPP, and we got it
with the SBA. I just wanted to inform you of that.
THE COURT: So you applied for a PPP loan; so you're
familiar with the system?
PROSPECTIVE JUROR: Correct.
THE COURT: Is there anything about that that would
cause you to be unfair and not a person who can be impartial in
considering the evidence?
PROSPECTIVE JUROR: No. No.
THE COURT: You will listen to both sides?
PROSPECTIVE JUROR: Correct.
THE COURT: All right. Thank you. All right. We have
one -- go right ahead.
PROSPECTIVE JUROR: My name is Abigail Fisch. I as
well was independent at the time, and I had an SBA loan and
received a PPP. I can be impartial in that process. I also
want to be transparent. I'm not sure if I know Mr. Love or
just the name. So no personal relationship. Name sounds
familiar, but I just want to make sure.
THE COURT: You may know Mr. Love?
PROSPECTIVE JUROR: I don't know that I do. I just
know the name. I don't know -- I apologize, my husband is a
rabbi, and so oftentimes I'm exposed to a lot of names and a
lot of people, so I don't know if that's the case. That could
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be.
THE COURT: Is there a particular temple that you
attend where you would see Mr. Love?
PROSPECTIVE JUROR: There are two potential synagogues,
yes.
THE COURT: All right. Mr. Love, could you possibly be
the person?
MR. LOVE: Your Honor, thank you very much. I do not
recognize Juror Number 9, Ms. Fisch. No familiarity. And I
don't attend any temples here in the Miami-Dade area.
THE COURT: All right. Thank you. We have one more
juror.
PROSPECTIVE JUROR: Hi. My name is Yusdaliencys
Osorio. I say, too, my English is not very good. Oh, it's
pretty important this moment, but I don't understand
everything.
THE COURT: All right. How long have you been here in
the United States?
PROSPECTIVE JUROR: 10 years.
THE COURT: 10 years?
PROSPECTIVE JUROR: Yeah.
THE COURT: Do you work?
PROSPECTIVE JUROR: Yeah.
THE COURT: And where do you work?
PROSPECTIVE JUROR: I live in doctor office, but at
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this moment, I'm working at the school.
THE COURT: Do you speak English at the school?
PROSPECTIVE JUROR: My English is a little good, but I
think that this moment important that I don't understand
everything.
THE COURT: All right. Have you understood our
interchange, me speaking to you?
PROSPECTIVE JUROR: A little.
THE COURT: Just a little?
PROSPECTIVE JUROR: Yeah.
THE COURT: Sounds pretty good to me, but --
PROSPECTIVE JUROR: Just a little. My English is a
little.
THE COURT: Have you served as a juror previously?
PROSPECTIVE JUROR: No.
THE COURT: All right. We'll come back to you. We'll
see -- listen carefully, and I may ask you a little later once
I explain some of the legal principles which are very
important.
All right. So, ladies and gentlemen, you heard one
prospective juror say that he would be a little concerned about
being fair to both sides because he has worked with some of the
attorneys at the U.S. Attorney's Office, for example.
So is there anyone else who feels that way?
So just a few pointers, you know. When we have trials
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oft times there may be law enforcement officers who are
assisting the Government or sometimes assisting the defense,
and we advise jurors that just because of the status of a
person that doesn't make them any more believable than anyone
else.
You listen to the evidence. You compare the testimony
of the witnesses. And you use your common sense, and you make
your decisions about the veracity of a person in that regard
not because they may be a police officer or a doctor or a
lawyer or any other profession. We make decisions after
evaluating the testimony.
Now, I want to be sure that there is no one who thinks
that the U.S. Attorney's Office gets more credence than the
defense attorneys. Or some people may think I give more
credence to the defense attorneys compared to Government
counsel. We're trying to get referees who can call it right
down the middle.
So those of you who may have watched the Dolphin game
yesterday, you know when the referees make a call against the
home team, you hear a lot of boos in the spectator area, right?
That's because we're partisans. We want the home team to win.
We're not really too concerned if there's a foul or not. We
have an interest. That's being a partisan. We're trying to
pick referees. So that's the important point.
So just generally speaking, other than those we have
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already talked to, is there anyone who thinks they could not be
a fair and impartial referee?
If so, would you raise your right hand.
So let me give you another example. You heard
something about a potential witness working with the Internal
Revenue Service.
Now, some of us have to write a check every April 15th,
right, and you may not like the I.R.S., but that doesn't
necessarily mean you can't be fair and impartial to the
Government because they call a witness who works for the I.R.S.
That's the point we're trying to make. Our goal is to pick
fair and impartial persons just as if you would want a fair and
impartial person sit ting in judgment of a friend or relative
or you, yourself. You want to be fair. That's our goal to get
fair and impartial jurors.
So if you have an issue at all -- as I said, we've got
five juries going on today. We can have you go downstairs, and
maybe a civil case might be better for you. We won't be upset
if you're honest with us in that regard. So please keep those
pointers in mind.
So now, ladies and gentlemen, I would like to cover
some legal principles, and the first area is whether or not any
of you have served as a juror on a prior occasion. If you
served as a juror on a prior occasion, will you raise your
right hand. Okay, a few.
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If you recall, did you serve on a civil case or a
criminal case? How many served on a civil case? So civil
cases: Car accident, medical malpractice, that sort of thing,
contract dispute, many civil cases. And most of our civil
cases in state court are downtown in the courthouse, the
Dade County Courthouse on Flagler Street. The State criminal
cases are generally over on 12th Avenue, all right.
And federal cases could be in this complex because we
handle criminal and civil cases. So that may give you a
reminder.
Let me ask: How many have served as the foreperson of
a jury? If so, would you raise your right hand.
All right. We have one former foreperson.
How many have served on the military courts-martial?
If so, would you raise your right hand.
And how many of you have served on a grand jury? If
so, would you raise your right hand.
So I ask these questions so that we can explain the
different burdens of proof we have in our judicial system. And
I'm going to give you an opportunity, those of you who have
actually served on a jury to give us a little information about
your service. But if you serviced on a civil case, there was a
burden of proof that you had to follow, and that burden of
proof was by a preponderance of the evidence.
The term preponderance of the evidence means more
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likely than not. So the proponent or the plaintiff or the
person who's filing the civil lawsuit, they have to convince
you by a preponderance of the evidence in order to prevail more
likely than not.
Now, if we wanted to quantify that term, it would be
greater than 50 percent. They would have to satisfy you 50.1
percent or greater that their position is the correct position.
That's a civil case.
This is not a civil case. This is a criminal case.
And the burden of proof is much higher in criminal cases. Many
of you know the burden of proof in a criminal case is proof
beyond a reasonable doubt. That's the highest burden we have
in our judicial system, and that's because liberty is at stake.
So we want to have a higher burden of proof, and that's the
burden of proof that you will be utilizing in this case. And
during the instruction phase, I will give you specific
information as to how to define proof beyond a reasonable
doubt.
Now, I asked if some of you have served on a grand
jury? And Grand Juries utilize the lowest burden of proof.
Does anyone know what that burden of proof is in grand
jury service?
It's probably cause, something probably happened.
That's a lower burden than by a preponderance and substantially
lower than proof beyond a reasonable doubt. So keep that in
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mind as we go through this case.
Now, those of you who have prior jury service, we're
going to pass the microphone from left to right in each row;
and if you have prior jury service, there's some questions I
would like for you to answer.
If you have no prior jury service, simply pass the
microphone to the next person. You don't have to say anything.
So I would like to know if you served on a civil case or a
criminal case; if it was in state court or federal court; if
the jury reached a verdict -- and we don't want to know what
the verdict was, just yes or no, we reached a verdict, or yes
or no, you didn't reach a verdict; and if you served as the
foreperson, as one gentleman raised his hand, tell us that you
served as the foreperson.
So we're going to pass the microphone down the line.
And do you remember -- do you want me to repeat the questions
again or you got it the first time?
PROSPECTIVE JUROR: Repeat them again just in case.
THE COURT: All right.
PROSPECTIVE JUROR: Well, my name is Jose Ramos. I
served on a civil court, civil case down on Flagler Street.
THE COURT: Yes, sir.
PROSPECTIVE JUROR: And we reached a verdict.
THE COURT: All right.
PROSPECTIVE JUROR: And I wasn't the foreman. Is that
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it?
THE COURT: That's it, perfect. Next person. Anyone
else in the first row? Let's go now to the second row in the
box.
Anyone who has prior jury service? Anyone?
No.
All right. Let's go to the spectator area: First row,
anyone? No.
Your name first, please.
PROSPECTIVE JUROR: Yes, Olga Bustamante.
THE COURT: Yes.
PROSPECTIVE JUROR: I served in a civil, criminal,
and --
THE COURT: All right. Now, civil or criminal?
PROSPECTIVE JUROR: Civil once. Criminal in the state
criminal once, and in the federal criminal once.
THE COURT: All right. Welcome back.
PROSPECTIVE JUROR: And we had a verdict for all three.
THE COURT: Thank you.
PROSPECTIVE JUROR: My name is Hernan Vera. I served
as a juror foreman in a criminal case in state court Alachua
County.
THE COURT: And you arrived a verdict?
PROSPECTIVE JUROR: We reached a verdict.
THE COURT: Thank you. Anyone else in that row?
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PROSPECTIVE JUROR: Good morning. Tammie Williams,
civil case, Flagler. We did reach a verdict. Not a
foreperson.
THE COURT: Thank you.
PROSPECTIVE JUROR: Hi. Good morning. My name is
Cesar Gonzalez. Civil case. We reached a verdict.
THE COURT: In State court or Federal?
PROSPECTIVE JUROR: Civil.
THE COURT: State or federal?
PROSPECTIVE JUROR: Oh, State.
THE COURT: Yes, sir. Thank you.
PROSPECTIVE JUROR: Francia Espinosa. I served on a
criminal case in Miami-Dade.
THE COURT: All right. You served on a criminal case
in --
PROSPECTIVE JUROR: Criminal case, yes. It was a
mother of the decedent. It was here case. State.
THE COURT: State court or federal court?
PROSPECTIVE JUROR. State.
THE COURT: Thank you.
PROSPECTIVE JUROR: Hello. Good morning. My name is
Sandra Miller. I served in State criminal court. We did not
reach a verdict because -- we did not reach a verdict.
THE COURT: Don't tell us why. Your name again,
please?
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PROSPECTIVE JUROR: Sandra Miller, Juror 39. And also
civil State court. We did reach a verdict.
THE COURT: All right. And welcome back to you.
All right. Anyone else who has prior service who has
not had an opportunity to tell us about it?
Okay. All right. Let's go to some principles that
many of you are familiar with.
These are principles related to criminal cases. And
the first principle is that any person who is accused of a
crime is innocent, and you must presume innocence until you
start your deliberations at the very end of the case.
So as the defendants, Mr. Wade and Mrs. Wade, are
seated here today, you must presume that they are innocent of
the allegations in the indictment. And as stated, that
presumption of innocence remains in effect until you have heard
all of the evidence, received all of the instructions, and
listened to all of the arguments of counsel. At that time you
begin formulating innocence or guilt.
Now, is there anyone who believes they could not follow
that instruction on the law? If you think you cannot follow
that instruction, we want you to raise your right hand at this
time.
All right. The next principle, ladies and gentlemen,
is that a defendant -- they're called defendants. It's not
anything sinister. It's just the term we use to identify
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people who are charged with having committed an offense. And
that guilt of a person cannot be found guilty -- or the person
can't be found guilty unless guilt is proved beyond a
reasonable doubt. I've mentioned that previously, and we will
discuss it in more detail during the instruction phase.
Is there anyone who cannot fully accept this principle
of law? That is, that a defendant can't be found guilty unless
guilt is proved beyond a reasonable doubt? Anyone who can't
follow that instruction, raise your right hand.
Seeing no hands.
In our criminal justice system, the constitution states
that a defendant does not have to testify on his or her own
behalf unless they elect to do so, and you can't draw any
inferences from that. In other words, you can't say, "Well,
one defendant didn't testify; I wanted to hear from that
person, so I'm going to hold that against him." You can't do
that.
Individuals elect not to testify for many, many
different reasons; and you may not speculate about why a person
elected not to testify. Just keep in mind you make decisions
based on that which is presented to you, not whether the
defendant took the stand or not.
Now, if a defendant elects to take the stand, you use
the same rules in judging credibility, which I will talk to you
about a little later, but keep in mind a person doesn't have to
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testify. Is there anyone who believes they could not follow
that instruction on the law?
Now, in our system of justice a defendant can be found
guilty based upon evidence presented in open court. So a lot
of you may have had similar experiences. Some of you have been
involved with PPP loans on prior occasions. You can't consider
the outcome of that case or anything about another case, or
maybe you read something in the newspaper about PPP loans, or
maybe a television show or a movie or what have you, you can't
consider any of that. You have to block all of those things
out of your mind.
Now, I'm not saying you can't use your common sense,
but you must base your findings on evidence presented here in
open court in the presence of all of us and not something that
someone told you about a case or the other examples that I gave
you.
Is there anyone who thinks that they would not be able
to follow that instruction on the law?
We talked earlier about the law and the fact that we
have to follow the law as presented. We all have our notions
about what the law ought to be, and we talk to our friends
about it. When elections are coming up, some of the questions
are going to be about you think about a particular law, that's
perfectly fine; and in a democratic society, we should have
discussions about what the law ought to be and what Congress
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should implement or not as the law.
But when you're in a formal courtroom setting in the
trial of individuals, you must follow the law as I present it
to you. There are two judges in this courtroom. There's a
judge of the facts; that will be you if you are selected to
serve.
And then there's a judge of the law; that would be me;
and I will tell you what the law is in this case. And this is
important. You follow the law as presented.
Is there anyone who has such strong notions about what
the law ought to be that you might be inclined to follow that
law rather than what I tell you the law actually happens to be?
Is there anyone who has such strong notions?
All right. Seeing no hands.
We've talked extensively about people being impartial,
and I want you to keep that in mind. We're trying to select
persons who can be fair and impartial to both the defendants
and to the Government. That's what our justice system is all
about.
Now, I have told you a little bit about what the case
involves just generally. Let me tell you what the case does
not involve.
The case does not involve your own personal opinions
about different laws. Especially in this case, on the PPP
loans or whether someone has made a false or fraudulent
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statement. Those are all items that you must follow the law in
deciding. It has nothing to do about how I or you personally
think about any social problems or any laws or anything else.
Your job is as a referee to sit here and listen to the
evidence, the testimony of witnesses, the documents being
introduced, to review that, to listen to the witnesses and
determine their credibility. That's their believability. And
make a decision as a fair and just referee. That is your goal.
Now, this case will be tried this Monday, today,
through Thursday, and next week Tuesday through Friday. Now,
we may finish a little later. I don't think so. We may finish
a little earlier than those days. But we likely will take the
two week term. And hopefully we don't have any weather issues
which interrupts our schedule, but keep that in mind as I ask
whether anyone has any special or unique disabilities.
Sometimes we have individuals who have hearing issues,
and we have some special devices that we can provide. We can
try to resolve most problems. But some we need you to tell us
about, and we need you to tell us now. Do not wait until we
select jurors and then you raise your hand and say, "Oh, by the
way, I'm having a significant issue on Wednesday," because at
that time, it's too late for me to do anything about it after
you've been selected.
So if you have a special or unique problem, we want you
to tell us about it. Now, some of you told us earlier that you
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thought language might be an issue. So you've heard me explain
some of the legal principles and other matters.
I'd like to see if anyone still feels that they're
language problem -- that is, the ability to understand clearly
the English language is an issue such that you couldn't be fair
to the parties, raise your hand again.
Some of you -- we talked about this earlier. You may
have listened. It's not going to get any more complicated than
I have explained to you. This is not a highly technical case
with scientific principles, et cetera. So is there anyone who
believes that they have a language issue, we want you to raise
your right hand at this time.
All right, seeing no hands. I'm pleased that you
understand because we really do want you to serve.
Now, jury service is important. It's a condition of
citizenship. We have certain obligations as citizens. We
should vote. We should serve as a juror. The country makes
certain demands on us. Now, fortunately, we don't have the
draft system anymore, and those who are in our military
services are there because they choose to be there.
There was a time when people just got picked to go to
Vietnam or your parents to World War II or the Korean War,
et cetera. We're not going to make that kind of demand on you.
But we are going to ask you to serve and serve
willingly for the next few weeks as one of the duties you have
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as a citizen, and we want you to serve, and we want you to
serve willingly.
I know when you received the summons in the mail, some
of you probably hesitate, sigh and say, "Oh, my, we have to go
downtown; we're going to sit around."
You're not going to sit around. We start on time, and
we finish on time, and that's a promise I'll make to you. But
at the same time, we want you to be here on time so that you
can leave on time. So we want you to serve if selected.
Now, I see one hand. Yes, pass the microphone.
PROSPECTIVE JUROR: Good morning. Juror 14, Lourdes
Ermer. I may have an issue given the time that this jury might
take, the trial. I have a planned trip to attend a religious
retreat commencing next Friday, the 18th; and I would have to
leave by 3:00 at the latest. So if that's an issue then I --
THE COURT: All right. Your name again?
PROSPECTIVE JUROR: Lourdes Ermer.
THE COURT: All right, Ms. Ermer.
PROSPECTIVE JUROR: Thank you.
THE COURT: You must be out by 3:00 p.m. on the 18th,
and I'm -- if there's a problem, we'll be able to resolve it.
I don't think that's going to be a problem. I'm a little
concerned about the weather, but we'll see how that works out.
All right. I see one more hand in the box and then
we'll go to the spectator area, maybe two hands here. Yes.
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PROSPECTIVE JUROR: Good morning. I'm Juror Number 4,
Carolina Cuarezma. I might have an issue, too, this week
because I have family coming over today. They actually --
they're coming over from abroad, and we have plans this week to
go on vacation. Unfortunately, there's the weather, but we
already have plans, and I have family coming over today. As a
matter of fact, they're at the airport from where they're
coming from right now.
THE COURT: So I think what you're telling me is that
you would like to serve at a different time than this week?
PROSPECTIVE JUROR: Yes.
THE COURT: All right.
PROSPECTIVE JUROR: Please. Thank you.
THE COURT: All right. We will look forward to seeing
you soon.
PROSPECTIVE JUROR: And no, because I would like to
speak to him in private.
THE COURTROOM DEPUTY: She wants to speak in private
afterwards.
THE COURT: We hear you; and if we need to address that
further, we will have you come sidebar, all right.
Anyone else with a special -- remember your obligation
is to serve for next two weeks but special or unique issues,
we're willing to listen.
PROSPECTIVE JUROR: Juror Number 2, Israel Aragon
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Bravo. The only thing I have is just a doctor's appointment
today at 3:30; so I might sneak out by 3:00. That's the only
thing for the next two weeks.
THE COURT: Where is your appointment?
PROSPECTIVE JUROR: It's in Miami Beach. It's about
20 minutes away.
THE COURT: All right. We will keep that in mind. So
that means you would have to leave here by 3:00?
PROSPECTIVE JUROR: Yes.
THE COURT: Do you know how long your doctor's office
is open? In other words, do we have 4:00 or 4:15 or 4:30
appointments?
PROSPECTIVE JUROR: I think they might be open as late
as 5:00 perhaps.
THE COURT: All right. So here's what we will do.
During our break which we will take in a few minutes. Who is
ready for a restroom break?
Okay. Just one hand is enough. So give us your
doctor's name and office, and we will see if we can get a
little later appointment; but if we can't, then we'll work with
you. All right.
So we're going to oh -- I'm not sure if I should take
the break now or we'll entertain the questions. Some of you
look pretty serious when you raise your hand. Let's take a
short break now, use the facilities, come back as quickly as
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you can. And look at the seat you're in now. Be sure you come
back and sit in the seat that you're in now, and we will resume
as quickly as we can.
We are in recess.
(Prospective jurors exited courtroom at 11:17 a.m. )
(Recess taken from 11:17 a.m. to 11:36 a.m. )
(Prospective jury entered courtroom at 11:36 a.m. )
COURTROOM DEPUTY: Everyone can be seated. Everyone
can be seated. Court is back in session.
THE COURT: Please be seated. We are going to
continue. I was asking if anyone had a special or unique
situation that you should tell us about.
And we contacted your doctor's office, and we'll give
you some more particulars, but you're all set. You have to be
there by 4:30, and we're going to make sure you're there by
4:30.
All right. Any special -- I'm seeing too many hands.
All right. What's up?
PROSPECTIVE JUROR: Your Honor, just in case this trial
prolongs, extends more than two weeks, I have a trip planned
out for the 24th --
THE COURT: 24th?
PROSPECTIVE JUROR: -- just in case. Yes.
THE COURT: We're all in trouble if that happens.
PROSPECTIVE JUROR: I just thought I would ask. Thank
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you.
THE COURT: You're going to be fine, yes, sir.
Give us your name.
PROSPECTIVE JUROR: Abigail Fisch again. Next week is
another Jewish holiday, Sukkot. It begins on sundown on
Wednesday, the 8th, and goes until Thursday. My issue is my
children's school.
THE COURT: Wednesday night through --
PROSPECTIVE JUROR: Through Thursday would be the
issue.
THE COURT: So Wednesday is not a problem. It's
Thursday that's the problem. Not problem but other
obligations.
All right. Thank you. We'll work on that.
PROSPECTIVE JUROR: My issue is childcare. I drop off
my daughter and pick her up, and I have to be at her school at
3:00 every day.
THE COURT: No one else who can help you out?
PROSPECTIVE JUROR: No. My husband has patients and he
ends around 6:00.
THE COURT: Well, tell him your jury service is more
important.
All right. Thank you very much. Where is your child
or children in school? Is it nearby.
PROSPECTIVE JUROR: In South Miami.
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THE COURT: South Miami, all right. Thank you.
Yes.
PROSPECTIVE JUROR: Hi. Carla Trinidad -- similar. My
husband's traveling next week; and normally, my backup is my
mother-in-law, but she's in Texas until the 15th.
THE COURT: Thank you.
PROSPECTIVE JUROR: So I'm stuck.
THE COURT: Thank you, Ms. Trinidad.
PROSPECTIVE JUROR: Jimmy Rivera.
THE COURT: Just one moment. I will be right with you.
All right, yes, sir.
PROSPECTIVE JUROR: Yeah, I'm working at an accounting
firm, and I'm the owner, I'm a partner. And the due date of
taxes is the 15th for extensions, and that would be a conflict
for me. The 15th is the due date for the companies, 11-20s and
personal taxes.
THE COURT: The 15th of this month?
PROSPECTIVE JUROR: Yeah, we've got some appointments
for some customers.
THE COURT: All right. We'll get back with you. Thank
you for bringing that to our attention.
Yes.
PROSPECTIVE JUROR: Hi. My name is Samantha Loynaz.
I'm Number 6. Mine was also in case it gets extended. I'm
leaving the 24th, but that's -- I you said that probably
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wouldn't happen. So...
THE COURT: So the 24th is the issue?
PROSPECTIVE JUROR: Yes.
THE COURT: All right. And what is the problem?
PROSPECTIVE JUROR: I'm leaving on a trip. We have a
preplanned trip.
THE COURT: Vacation or --
PROSPECTIVE JUROR: Yes.
THE COURT: All right. We'll see what we can do.
Anyone else in the box?
Stand and give us your name.
PROSPECTIVE JUROR: Adrian Arvesu. I'm Number 29.
THE COURT: Yes, sir.
PROSPECTIVE JUROR: I will be joining the U.S. Army
Officer Program sometime by the end of year. If this case
extends beyond two weeks, I fear that I may not be able to
attend due to the fact that I have two physical fitness exams
for the Army scheduled this week.
THE COURT: We're not going to interfere with that for
sure.
PROSPECTIVE JUROR: Well, I also don't know when I'm
going to be called.
THE COURT: I understand.
PROSPECTIVE JUROR: I'm signing for my contract.
THE COURT: So if, at some point in time, an issue
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arises, bring it to our attention as soon as you possibly can.
PROSPECTIVE JUROR: Thank you.
THE COURT: Anyone that wants to go into the Army,
we're going to let you go.
Yes, sir.
PROSPECTIVE JUROR: It's no Army or children, but I'm a
working artist and that means my income is incredibly
unpredictable, but next week is the show I've been working
towards for a year and I've invested $10,000 towards it and
it's not done yet. So I slept about four hours this weekend.
And I fear that both the financial obligations of the show next
week and the fact that I am not in a great mental place for
myself right now, let alone taking the care this case needs, I
would like to request a postponement of service.
THE COURT: Where is your art show?
PROSPECTIVE JUROR: It's in the design district.
THE COURT: All right. And that's next week. Is there
a particular day or days?
PROSPECTIVE JUROR: It opens next Thursday and supposed
to begin installing it Monday.
THE COURT: All right. Thank you.
PROSPECTIVE JUROR: Thank you, Your Honor.
PROSPECTIVE JUROR: Mike Babitz. I have a similar
issue to the young lady that spoke previously next Thursday and
Friday is the Sukkot holiday, and I would be expected to be
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part of a religious service during those days.
THE COURT: All right, Mr. Babitz. Thank you.
Next.
PROSPECTIVE JUROR: Good morning, Your Honor. My name
is Susy Gomez, Juror 25. My only concern is I have a doctor's
appointment next Thursday at 8:30 a.m. I have rescheduled it
three times already, so that's my only concern.
THE COURT: All right. 8:30 next Thursday. And do you
know how long the appointment will be?
PROSPECTIVE JUROR: No more than an hour, half an hour
tops.
THE COURT: Where is it location-wise?
PROSPECTIVE JUROR: Kendall.
THE COURT: In Kendall. Kendall is a long journey
nowadays. I remember when it was 30 minutes. Not the case
anymore.
PROSPECTIVE JUROR: Thank you.
THE COURT: All right. Thank you. If you're selected,
be sure you keep us aware of your Thursday appointment. We can
handle that.
PROSPECTIVE JUROR: Hi. My name is Sheila Chung, 37.
I had plans to be away out of town next week, Friday, the 18th.
THE COURT: And is this vacation or --
PROSPECTIVE JUROR: Well, it's my granddaughter's first
birthday, so I had planned to be away for that.
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THE COURT: And will you by leaving on the 18th or --
PROSPECTIVE JUROR: I would be leaving Thursday night,
so I had planned not to be here on Friday.
THE COURT: And how far away are you traveling?
PROSPECTIVE JUROR: Melbourne. Hopefully, they're not
blown away.
THE COURT: All right. Thank you.
PROSPECTIVE JUROR: Good morning, Your Honor. Juror
Number 42, Jack Varela. I work for the Miami-Dade Aviation
Department, and I'm under a critical role, which is
communications. I handle communications for the airport. And
with the storm coming and facing all the flight delays and
cancellations, I -- it's going to be tough for me to stick
around for this.
I also have two boys, 12 and 13 that I drop-off in the
morning, two different schools across town. One Belen Jesuit
and the other at Miami Middle. I also care for my 95-year-old
mother who's in delicate condition right now, so that's my
situation.
THE COURT: All right. And your work-regulated issues
are this week, correct?
PROSPECTIVE JUROR: This week and -- well, for the most
part, yeah. A lot of flights get redirected. When the flights
up north get affected, we get affected down here; and it causes
a major problem at the airport, and I handle a lot of that.
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THE COURT: Do you know Mr. James St. Louis?
PROSPECTIVE JUROR: He sound familiar, yes.
THE COURT: Mr. St. Lewis was our former IT director
whom you-all took away from us.
PROSPECTIVE JUROR: We have Mr. Maurice Jenkins there.
I report to the director's office.
THE COURT: I have think about this one, but thank you.
PROSPECTIVE JUROR: Okay, thank you.
PROSPECTIVE JUROR: Good morning. Sandra Miller, Juror
Number 39. I'm currently working in a project for a company in
Mexico, in Mexico City. And I do have a flight to go back on
Saturday, the 12th. It's kind of important that I go back
because we're in the middle of a public tender that I do have
to finish paperwork for, and they are expecting me to be back
on Monday.
THE COURT: Cannot be back on Monday is what you said?
PROSPECTIVE JUROR: On Monday, yeah. So I booked a
flight to go back on Saturday, the 12th, I do have a flight.
THE COURT: Make sure you check with Mr. Varela to see
if you can actually get out on a plane.
PROSPECTIVE JUROR: Hopefully.
THE COURT: Okay, thank you.
PROSPECTIVE JUROR: My name is Laura Fernandez, Juror
Number 38. I have a preplanned trip for Monday that I had
planned for awhile.
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THE COURT: Is this vacation?
PROSPECTIVE JUROR: Yes. It's for three days. It's
not until Wednesday.
THE COURT: All right. We will take a look at that. I
have to tell you personal vacations go a little further down
the line, but we will see if we can accommodate you.
All right. Do we have anyone else who has an issue?
So let me tell you what our goal is.
We're going to try to finish this selection process by
1:00 so that those who are not selected I can excuse you, but
we'll have to see how we do. That's sort of my signal to the
lawyers to pick it up a little bit but do the best you can.
We are going to have the attorneys ask questions at
this time, ladies and gentlemen. Listen carefully to their
questions and try and respond as directly as you possibly can.
Keen in mind, we're trying to select those who can be fair and
impartial.
Government.
MR. SNIDER: Thank you, Your Honor. And good morning
again to all of the prospective jurors.
My first question is this: Does anyone have any
beliefs or convictions whether moral, religious, philosophical
or otherwise that you think would prevent you from being a fair
and impartial juror in this case, or that would make it
difficult for you to render a verdict based solely on the
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evidence that you hear in this case? Does anyone feel that
because of some particular belief they have that they wouldn't
be able to follow the Court's instruction and listen to the
evidence and render a verdict just based on the evidence?
Yes, ma'am. Can you identify yourself by your name.
PROSPECTIVE JUROR: Juror 40. Yes, it's just based off
ethical beliefs. So after hearing the case and hearing whether
there is evidence or not, I just believe ethically what was
done, whether it was predetermined or actually done itself, I
just don't think that that is the right thing to do. Me being
a business owner as well knowing the process that it takes, I
just don't feel like -- some people do it fairly. Some people
don't. So I don't think ethically I would be able to give a
correct answer.
MR. SNIDER: So you're saying you don't think based on
your own experiences in the business -- you said you're a
business owner?
PROSPECTIVE JUROR: Yes.
MR. SNIDER: So based on your experience as a business
owner, you don't think you will be able to put your personal
feelings aside to render an impartial verdict based on the
evidence?
PROSPECTIVE JUROR: That's correct.
THE COURT: Go ahead, I'm sorry.
MR. SNIDER: Is there a particular -- is there a way
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that you are -- you would mean one way or the other that makes
it difficult -- what is the way you think your beliefs --
PROSPECTIVE JUROR: Yeah, I believe it's wrong if
that's what you're asking me.
MR. SNIDER: What do you think is wrong?
PROSPECTIVE JUROR: The act of fraudulent and/or
misinformed information.
MR. SNIDER: Okay.
PROSPECTIVE JUROR: That was applied and also just the
act of fraud in general. I believe that as a business owner
when you're applying or when you're seeking a loan, in my own
experience, just providing the most honest information as
possible, whether you're able to obtain or not obtain, that's
what I would be having difficulty.
MR. SNIDER: You understand that the allegations and
the charges that the Court read are simply allegations.
PROSPECTIVE JUROR: Yes.
MR. SNIDER: And that all the defendants are presumed
innocent, and they remain innocent unless and until the
Government proves its case beyond a reasonable doubt. Do you
understand that?
PROSPECTIVE JUROR: I understand that.
THE COURT: Can you follow that instruction? In other
words, can you listen to the evidence and make a decision based
on the evidence, not on what with the charges are?
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PROSPECTIVE JUROR: I will try my best; but, ethically,
that's where I was coming from. Just knowing where I stand
personal reasons and my beliefs that will, I know, sway my
decision; but I will try based off the evidence. I just know
ethically I will be swayed.
THE COURT: Well, when you say ethically, ethically
means being fair to both sides.
PROSPECTIVE JUROR: My beliefs, my own ethical beliefs.
THE COURT: One moment, ma'am. Because someone is
charged with an offense doesn't mean they committed the
offense. As we discussed, the Government has to prove its case
beyond a reasonable doubt. Can you hold the Government to that
standard, or do you think you have some predetermined beliefs
because a person is charged?
PROSPECTIVE JUROR: I will try, but I -- I have
expressed my beliefs on the situation, but I will try as my
duty as a citizen, I understand.
THE COURT: Counsel.
MR. WILCOX: Your Honor, that was Juror Number 44?
PROSPECTIVE JUROR: I'm Number 40.
THE COURT: You may continue.
MR. SNIDER: Does anyone else have any very strong
moral, religious, philosophical beliefs that they don't think
they will be able to put aside and listen to the evidence and
follows the Court's instructions in order to reach a verdict?
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Okay. I see no other hands.
Has anyone ever themselves or a family member, someone
close to you been involved in a lawsuit or a court proceeding
before that a may include -- yes. Why don't we start over
here.
PROSPECTIVE JUROR: Sorry. I threw out my back this
morning. I'm an attorney, so I've been involved in many cases,
lawsuits. I've also been sued before, and I've also sued,
civilly.
MR. SNIDER: Anything about your career that you think
would affect your impartiality or ability to be impartial?
PROSPECTIVE JUROR: No.
MR. SNIDER: Let me just preface that by saying does
anyone who had any experience in the court, whether they were a
plaintiff, whether they were a defendant, based on your
experience, do you think that that would make it difficult for
you to be impartial in this case? That's really the gist of
what I'm asking.
Does anyone think you couldn't be impartial because of
their experiences with the court system?
Okay. Now, I'm going to ask whether you or a spouse of
yours or a close relative has had any deals with the following
agencies: The Federal Bureau of Investigation, the Broward
County Sheriff's Office, the U.S. Department of Justice, or any
other federal, state or local law enforcement agency? And my
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question is if you have had dealings -- and I know you provided
some information in response to this question, so you don't
have to repeat that. But anyone else who has had dealings with
those agencies, and I can read them again, that you think might
affect your impartiality?
Yes, ma'am.
PROSPECTIVE JUROR: My name is Carolina, Juror
Number 4. I used to work for the Department of MasterCard
International, and I used to deal with Secret Service and all
law enforcement. I was an agent regarding credit card fraud.
MR. SNIDER: How was your experience with that federal
agency, U.S. Secret Service?
PROSPECTIVE JUROR: They used to contact me to get
information and try to find -- to figure out who the owners of
the credit cards were in reference to the frauds that they
discovered that they were investigating.
MR. SNIDER: Sure.
PROSPECTIVE JUROR: So it was like a very close
relationship.
MR. SNIDER: And do you think because of that prior
experience and your relationship with the Secret Service that
you would not be able to be impartial in this case?
PROSPECTIVE JUROR: Probably, because of my cases, 99
or 100 percent, what they were doing, it was fraud. Actually,
what was done was actual fraud. It was like here that
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they're --
MR. SNIDER: Well, you understand that the two
defendants are presumed innocent.
PROSPECTIVE JUROR: Yes, I understand that.
MR. SNIDER: And they will prevail as innocent unless
the Government meets their case.
PROSPECTIVE JUROR: Right, but in my case both of them
are guilty.
MR. SNIDER: Right, but that doesn't affect -- has
nothing to do with this, does it?
PROSPECTIVE JUROR: I guess my brain is already...
MR. SNIDER: And you don't think you can follow the
Court's instructions?
PROSPECTIVE JUROR: It will be really hard because I've
dealt with that for many years. Like every time they send me a
list, you already know it was fraud.
MR. SNIDER: All right. How about anyone else? Again,
it's the FBI, Broward County Sheriff's Office. Anyone who
works for Broward County Sheriff's Office or a member of their
family?
Yes, sir.
PROSPECTIVE JUROR: Juror Number 42, Jack Varela. My
wife was a former prosecutor. I don't know if that's what
you're asking or if you're asking me if that's going to affect
the case.
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MR. SNIDER: I'm going to ask if whether your wife as
former prosecutor, would that render you impartial?
PROSPECTIVE JUROR: No, but originally you were asking
if we had any relationship to the FBI or agencies. My wife is
a former prosecutor in Lakeland, Florida.
MR. SNIDER: Where?
PROSPECTIVE JUROR: Lakeland, Florida. She's now a med
mal attorney. She's a partner with a major firm here in town.
MR. SNIDER: How long ago was your wife a prosecutor?
PROSPECTIVE JUROR: 20.
MR. SNIDER: You think that notwithstanding that you
could still be impartial?
PROSPECTIVE JUROR: Yeah, I guess.
MR. SNIDER: We want to make sure.
PROSPECTIVE JUROR: I think so, yes.
MR. SNIDER: You think so?
PROSPECTIVE JUROR: I was just letting you know because
you were asking if any family members or have relationships to
that, so I'm communicating to you that my wife was a former
prosecutor.
MR. SNIDER: I do appreciate that. Thank you.
THE COURT: You're 42, Mr. Varela, correct?
PROSPECTIVE JUROR: 42.
MR. SNIDER: Judge Graham referenced the Internal
Revenue Service when he was speaking earlier and noted that
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everybody usually around April 15th files taxes or pays some
taxes. So I'm assuming that most of you have had some
interaction with the Internal Revenue Service generally.
Has anyone had an experience with the Internal Revenue
Service that was so negative that they don't think that that
would allow them to be impartial in the case or that would
affect their ability to render a verdict just based on the
evidence?
Show of hands: Who owns maybe a small business?
And show of hands whether -- I don't know whether I
said small business. But is it a business with less than 25
employees?
For those small business owners, raise your hand if
anyone applied for an PPP loan?
PROSPECTIVE JUROR: Spouse as well?
THE COURT: I guess if you or your spouse, yes.
MR. SNIDER: Okay. Does your owning a small business
and having applied for an PPP loan, do you think that that
would make it difficult for you to be impartial in this case
and render a verdict just knowing that?
Does anyone have a difficult time with the Paycheck
Protection Program in applying for a loan? What was your
experience?
PROSPECTIVE JUROR: It was my first time filing --
THE COURT: One moment.
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PROSPECTIVE JUROR: -- for loans like this.
THE COURT: One moment.
PROSPECTIVE JUROR: Juror 28. It was my first time
having to file for a loan, but I was doing it for the nonprofit
I was the operations manager at and -- which I was new to that
role, but was able to figure it out. And then once I navigated
the program once successfully, I assisted my father in his
small business as well. Mine business is much too small. I
don't have employees, so I didn't apply for my own business.
But it was a complicated thing to read and understand.
Luckily, we were at the smaller price point. There was like
moments where it becomes more complex for higher loan amounts,
and we were in the smaller ones.
MR. SNIDER: You were in the smaller ones?
PROSPECTIVE JUROR: Yes.
MR. SNIDER: Was there something about -- were these
loans funded, do you remember?
PROSPECTIVE JUROR: Yes.
MR. SNIDER: Something about that experience that would
make you not be fair and impartial in this case?
PROSPECTIVE JUROR: No this would not effect my
impartiality.
MR. SNIDER: Has anyone else received, actually receive
PPP money, you or your spouse?
Did anyone go through the forgiveness process for these
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loans?
Anything about that process you think that would make
it difficult for you to be impartial in this case?
Has anyone else applied for any other form of relief
from the Government during the pandemic? Yes, ma'am.
PROSPECTIVE JUROR: I --
THE COURT: One moment.
PROSPECTIVE JUROR Sara, I think it's 19, Saba.
MR. SNIDER: Yes, ma'am.
PROSPECTIVE JUROR: Just the SBA, small business loan,
the emergency one.
MR. SNIDER: Was it the Economic Injury Disaster loan?
PROSPECTIVE JUROR: That's the one.
MR. SNIDER: Did you get a loan through that program?
PROSPECTIVE JUROR: Yes.
MR. SNIDER: Was there anything about the process that
you went through that you think would make it difficult for you
to be impartial in this case?
PROSPECTIVE JUROR: No, not at all.
MR. SNIDER: A show of hands: For those who have
applied for PPP loans, did anybody sign their loan applications
without reading them first?
Again, let's just go back to the tax question. It
seems like most everyone here has filed taxes at least once
before in their life. Has anyone every file their tax returns
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or having prepared them yourselves and haven't had a preparer
assist them with their tax returns, has anyone filed their tax
returns and signed them without reading them?
That's all from the Government.
Thank you.
THE COURT: Thank you. Defense?
MR. McCRAY: Thank you. I just have a few questions.
Let me introduce myself. I don't think the defense introduced.
So my name is Johnny McCray, Junior. I represent both the
accused in this case, Mr. Tracy Wade and also Ms. Carolyn Wade,
and this is my cocounsel, Mr. Daryl Wilcox, and our legal
assistant, Mr. Henry Smith. How are you-all doing today?
Okay. Just a few questions. I know counsel asked if
you-all ever filled out loan papers and didn't read them. Have
any of you-all ever signed legal documents and didn't read
everything? Be truthful with us now. Raise your hand.
Okay. So I see at least -- I think I saw at least six
hands. So what else?
Anyone here -- how many of you-all have ever signed a
lease and didn't read everything on the lease? Be truthful
now. The Judge said we're here to just to speak the truth.
Nobody's going to get in trouble, okay.
Now, let me go to Mr. Pivnik. How are you doing, sir?
You said you prepared PPP loans for your father, am I correct?
PROSPECTIVE JUROR: Yes.
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MR. McCRAY: And for a company that you work with?
PROSPECTIVE JUROR: Yes. A nonprofit that I was the
operations manager at. It was a team of two people, myself and
the director.
MR. McCRAY: Do you know if the director looked at all
of the documents that you prepared?
PROSPECTIVE JUROR: Yes. I also -- to that question
about signing and not reading, I didn't sign them either. I
would help them understand the process and navigate it, so...
MR. McCRAY: Okay. And you did your fathers?
PROSPECTIVE JUROR: Yes, helped him.
THE COURT: Would you agree that your father trusted
you?
PROSPECTIVE JUROR: We worked together on it. He's
more of a businessman than myself, but programs like this, he
wasn't familiar with and didn't know it existed.
MR. McCRAY: Okay. And he relied on your --
PROSPECTIVE JUROR: In finding it and knowing it, yes.
MR. McCRAY: You can have a seat. Thank you.
PROSPECTIVE JUROR: Of course.
MR. McCRAY: Now, I'm trying to find the name of the
gentleman who indicated that he had served on a jury in Alachua
County. Yes.
You stated today that it was a criminal jury. I
believe in the packet in the sheet that the Judge has given you
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previously you indicated it was a civil trial. Which was it?
Was it a criminal or civil trial?
PROSPECTIVE JUROR: It was civil.
MR. McCRAY: It was criminal. It wasn't civil.
PROSPECTIVE JUROR: Correct.
MR. SNIDER: Thank you. Now, several of you -- and I
don't want to go through each and every one of you, but let me
see by hands -- by your hand which of you actually served on a
criminal jury?
Okay. No one in the first.
Now, anything about that experience having served on a
jury, on a criminal jury, anything about that experience that
would affect your ability to be fair and impartial in this
case?
Hearing nothing, I guess nothing would affect your
ability.
What about the civil jurors? Who served on a civil
jury. Several of you, I saw you. Anybody about here?
Okay. Anything about that experience, those that
served or the civil jury that would affect you to be fair and
impartial in this case?
I believe it was Juror Number 40, Ms. -- was it Guya?
Guia? Yeah. Let's talk for a second. You talked about an
ethical belief. Do you -- and the Judge just talked this, but
do you understand that we have a constitution in this country?
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PROSPECTIVE JUROR: I understand.
MR. McCRAY: Do you understand that an individual who
is accused of a crime has the absolute constitutional right to
be presumed innocent? Do you understand that?
PROSPECTIVE JUROR: Yes, I do.
MR. McCRAY: What do you feel about the presumption of
innocence?
PROSPECTIVE JUROR: Can you reword the question?
MR. McCRAY: Yeah. Under the constitution individuals
have the right to be presumed innocent. Actually, they remain
innocent unless and until, as counsel has indicated, they prove
guilty beyond and the exclusion of a reasonable doubt. What
are your feelings about that?
PROSPECTIVE JUROR: I completely understand. I think
the Judge mentioned that before we went on the break. About,
you know, your civil duty as a citizen here in America.
However, just with my own internal belief and instinct, it's
just the way that I felt about the case, and I felt that I
should voice my opinion. That I will try my best to remain
flux -- or fair, I should say. However, I do have this
internal ethical believe in me that feels as though it's
swaying more one way than the other.
MR. McCRAY: I feel you, okay. Now, my question to
each of you is, is there anyone here who really -- you just
have a problem with the presumption of innocence? Is there
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anyone here who kind of waivers and vacillates when it comes to
the presumption of innocence? You just believe that it
shouldn't be that way? Anyone here?
No one.
There's several of you who have relatives and friends
and family members -- family members and relatives are the
same, but any of you-all here -- you all have indicated that
there are law enforcement officers that you know very well.
Anything about the relationship there that would put the Wades
at a disadvantage, that a law enforcement officer would be more
believable than, say, a civilian witness? Anyone here who
believes that?
I know Mr. Babitz talked about his -- he has a huge
respect for the U.S. Attorneys, I guess, who he knows, but
anyone here who would have a similar feeling with respect to
law enforcement officers? What about FBI, FBI agents are such
a higher level than regular state police or local police?
Anybody here who would tend to give a member of the FBI greater
weight, that person's testimony greater weight than that of a
civilian? Anyone?
Don't be bashful, please.
Okay. Anyone else here who may have prepared PPP loans
for other persons, be it family, friends, or others?
Okay. And that is Mr. Rivera, yes, sir.
PROSPECTIVE JUROR: Yes, sir.
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MR. McCRAY: Tell us about it.
PROSPECTIVE JUROR: I started paying about -- the first
five or six PPPs, and I received a phone call from the PPP
saying that I was conscious, I was preparing that, and that
scared me a little bit, and I started reading more about it,
but on the first when I started filling out all this paper, it
was really simple, really easy.
MR. McCRAY: Tell us about the phone call. I didn't
quite follow you.
PROSPECTIVE JUROR: Yeah. I received a phone call
because I applied for my company. I was a partner of a dental
office, and we applied for PPP there with the two W2 employees,
and the rest was contractors. And they called me and they
asked me if I applied for that, and I told them yes. And then
they asked me, Are applying for another persons or another
company. Yes, I prepare taxes, too. And they told me are you
sure about what you're doing, and that was --
MR. McCRAY: They didn't tell you not to do it?
PROSPECTIVE JUROR: No. Just to make sure write down
the correct, you know, answers, and the amounts. They were
concerned about the amounts.
MR. McCRAY: Okay. Anything about that experience that
would affect your ability to sit in this case?
PROSPECTIVE JUROR: No.
MR. McCRAY: Thank you, Mr. Rivera.
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Anyone else?
Now, the Court -- you heard use the word instructions.
Every understand what the word instruction means just in our
daily lives? Will somebody tell me? When somebody gives an
instruction, what is that?
Basically it's a directive or they want you to do
something, is that correct?
Well, an instruction in this context, in the Court
is -- basically, it's points of law. It's the law that the
Court will give you. Does everyone understands that you're
bound to follow that law? Everybody understand that?
Now, if I were to tell you that you are all jurors,
would you-all disbelieve that -- I'm sorry, that you-all are
judges, would you disbelieve that?
You-all are judges of the facts. Jurors are judges of
the facts. And basically, what you all would do is listen to
the everyday and you would determine what evidence to believe,
if any, who you want to believe, who you don't want to believe.
That's solely within your province.
Does everybody understand?
Judge, Judge Graham is the judge of the law. He is
going to give you the law. And it's the law that applies to
there case. You cannot invade his province, and he's not to
invade your province as the trier of fact in this case?
Does everybody understand that?
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Mr. Gonzalez, how you doing, sir?
PROSPECTIVE JUROR: Yes.
MR. MCCRAY: In your response to one of the questions
about family members who had been charged with a crime, I
believe you indicated that there was someone in your family, I
believe, who may have been a victim of fraud or charged with
fraud?
PROSPECTIVE JUROR: No. It was one person. He's --
MR. McCRAY: My writing is pretty bad. I know I saw
that. Thank you, I'm sorry. My apologies.
It was someone who indicated that a family member had
been -- first of all, let me just ask generally. Any of you or
your family members ever been a victim of fraud?
Let's start in the back. Anybody over here first?
PROSPECTIVE JUROR: Credit card, yeah.
MR. McCRAY: Credit card, okay. I hate walking, but
we'll start over here.
Is that Ms. Trinidad?
PROSPECTIVE JUROR: Yes, Uh-huh.
MR. McCRAY: Tell us about that, please.
PROSPECTIVE JUROR: Yes. So credit card more than
once. And then, actually, someone did file a fraudulent tax
return of my husband's social security number one year, so that
was fun.
MR. McCRAY: Anything about those experiences that
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would affect your ability to be fair in this case?
PROSPECTIVE JUROR: No.
MR. McCRAY: Anybody else over here? Over here? Yes,
Ms. Ermer.
PROSPECTIVE JUROR: Same thing, credit card fraud,
identity was stolen and charged up our cards, but I think I can
be impartial.
MR. McCRAY: You think you can?
PROSPECTIVE JUROR: Yeah, I'm sure I can.
MR. McCRAY: All right. Thank you, ma'am. What about
over here? Is it Mr. Gutierrez?
PROSPECTIVE JUROR: Yes, Armando Gutierrez.
MR. McCRAY: Okay, yes.
PROSPECTIVE JUROR: Credit card fraud and my sister got
her ID stolen. They opened up, I believe took out a loan and
another credit card, and I saw how all the suffering she went
through just trying to get that solved. No government entity
could help her. It seemed like all her resources were
dead-ends. So she had to just wait it out until -- I don't
know what agency was able to clear her name, help her credit
score come back.
MR. McCRAY: Anything about that unfortunate experience
that would affect your ability to serve in this case if you're
selected?
PROSPECTIVE JUROR: I mean, I'm not -- when it comes
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back to that kind of identity stuff, I -- it's so frustrating
that I'm so against it that I -- I would be leaning towards,
like, the person not commit ting the fraud.
MR. McCRAY: It's sad, but people sometimes do play
games. Do you agree with that?
PROSPECTIVE JUROR: Yeah.
MR. McCRAY: Thanks. Yes, Ms. Saba.
PROSPECTIVE JUROR: Gomez.
MR. McCRAY: Oh, Gomez, I'm so sorry.
PROSPECTIVE JUROR: I was also a victim of someone
filing taxes in my name twice actually, but it won't affect my
ability to be impartial.
MR. McCRAY: You can be fair and impartial?
Thank you.
PROSPECTIVE JUROR: Hi, Nicholas Mandri. Juror Number
27. Credit card fraud, and I don't know if it counts, but my
grandmother was once tricked into believing that I was somehow
in danger; and with my information, they sort of sent her into
a panic and she called me like 23 times to make sure I was safe
and then tried to take her money. I don't know if that counts
as fraud.
MR. McCRAY: Well, it's a form of fraud.
Thank you.
PROSPECTIVE JUROR: Just -- I had a family member that
had a financial advisor steal a lot of money from them.
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MR. McCRAY: Okay. Thank you, sir. Anything about
that that would affect you?
PROSPECTIVE JUROR: No.
MR. McCRAY: Were there arrests made in connection with
that?
PROSPECTIVE JUROR: No. There were not but there was
recovery.
MR. McCRAY: Okay. Thank you.
PROSPECTIVE JUROR: Good morning. Juror Number 33,
Geraldine Velarde. I also had the incident of somebody filing
tax returns under my name and my husband's.
MR. McCRAY: How long ago was that?
PROSPECTIVE JUROR: That was this year actually.
MR. McCRAY: This year? Has it been resolved? Was
there an arrest?
PROSPECTIVE JUROR: Yes.
MR. McCRAY: Did you-all find out who did it?
PROSPECTIVE JUROR: My husband was the one leading
everything. I don't have all the information.
MR. McCRAY: Anything about that unfortunate experience
that would affect your ability to sit on this jury?
PROSPECTIVE JUROR: No.
MR. McCRAY: Okay, thank you. Anybody else?
Now, in any criminal case, credibility is usually an
issue. What does the word "credibility" mean? Let's start
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over here. I will just ask: What does the word "credibility"
mean to you?
Someone other than a lawyer. Can you tell me what
"credibility" means?
PROSPECTIVE JUROR: Believable.
MR. McCRAY: Okay. Does anyone know what the word
"motive" means? Anybody? Motive? Yes, back in the back.
PROSPECTIVE JUROR: To have reason for.
MR. McCRAY: To have an underlying reason for
something?
Okay. Is there a correlation -- let me go to,
Ms. Ermer. Let me ask Ms. Ermer, so we can speed it up just a
little bit, do you believe there's a correlation between motive
and credibility?
PROSPECTIVE JUROR: Motive and credibility?
MR. McCRAY: Can motive affect one's credibility?
PROSPECTIVE JUROR: Yes, definitely.
MR. McCRAY: How do you believe?
PROSPECTIVE JUROR: Well, if you have a motive, let's
say to commit murder, that would affect your credibility to say
you didn't do it or you did do it or -- you know, to serve as
any other type of witness in that type of situation if you had
a motive.
MR. McCRAY: All right. Thank you. Now, one other
thing the Court is going to tell you and the Court at some
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point will give you an instruction on your duties as the trier
of fact. When the Court gives that to you, is there anybody
here who believes they will able to follow that? And that's
one of the things the Court is going to talk about, a witness's
interest in the case. Does everybody understand that? Would
you-all be able to follow that instruction when the Court gives
it to you?
Excuse me, Judge, I beg the Court's indulgence.
Thank you, Judge.
THE COURT: Thank you all very much. Ladies and
gentlemen, I am going to give the attorneys approximately seven
minutes or so to confer with one another, and then I'm going to
have them come into the jury room, which is in the corner of
the courtroom, and we will start the challenge process, which
means they will be able to give me their suggestions about
jurors, and we'll go through the list and make a decision as to
who the jurors will be, and at that point, I will excuse those
who have not been selected.
So while they confer and while we're in the back, I
will give you an opportunity to take a break and go outside and
refresh yourself, if necessary. And at some point in time, my
courtroom deputy will come and tell you to come back in and be
seated so that I can explain to you the list of those who will
serve.
So at this time, if you would like you may step outside
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or relax where you are, and we will be with you probably in
about 20 to 25 minutes. Thank you. We are in recess.
(Prospective jurors on recess at 12:28 p.m.)
THE COURT: All right. Counsel, at 12:35 I am asking
you to come into the jury room along with your clients if they
elect to come back. We are in recess.
(Recess taken at 12:29 p.m.)
THE COURT: All right. Ladies and gentlemen, we are
going to start the challenge process.
There are quite a few that, I think, are subject
challenges for cause. I'm going to go through these and have
you agree or not, and then I will have you exercise any
additional challenges for cause, and then we will look at those
that remain. The first two rows, Government first, defense
second; and we'll do the next two rows, defense first,
Government second; and then the last two rows, so Government,
defense, Government, as far as exercising your challenges.
Once we leave a two-row segment, there's no
back-striking; so those will be the permanent jurors if you
have not exercised a challenge.
So with regard to the first two rows, as far as
challenges for cause, I think Mr. Ramos -- no, Mr. Aragon had
the doctor's appointment on the beach, and we've had his
appointment rescheduled for 4:30 which means we need to leave
by 3:55 so that he can get over there, so just for your
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information.
Your thoughts about Mr. Ramos? Any challenges for
cause as to Ramos, Number 3?
All right, Mr. Cuarezma had issues being fair and
couldn't serve this week; so my thought is we should challenge
him, have him excused.
Any objection?
MR. SNIDER: That's Number 4.
MR. McCRAY: Not from the defense.
Ms. Loynaz has an issue on October 24th.
MR. SNIDER: I don't see that being an issue.
MR. McCRAY: I don't think so.
THE COURT: Number 9, Ms. Fisch has the Jewish holiday.
I'm inclined to excuse her.
MR. WILCOX: No objection.
MR. SNIDER: Next Thursday. Well, I thought we would
be finished by then.
MR. McCRAY: Are you serious?
MR. SNIDER: By next Thursday.
THE COURT: So what are you suggesting? That we not
excuse her for cause?
This is all we're doing now.
MR. SNIDER: Okay. We would like her on the jury.
THE COURT: So we will leave her alone.
Number 10 has childcare issues; so my thought is she
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should be excused.
Any objection?
MR. McCRAY: Not from the defense, Judge.
THE COURT: Ms. Trinidad, same issue, childcare. Any
objections?
MR. SNIDER: Not from the Government.
MR. WILCOX: We like her.
THE COURT: What am I going to do about her childcare
problem?
MR. WILCOX: What was exactly the nature of it?
THE COURT: She has to pick up her kids at what time?
Does anyone recall?
I'm sorry?
MR. SNIDER: She had childcare, and I wrote down she
has a mother that she's taking care of.
THE COURT: Do you want me to have her come in?
MR. MCCRAY: The mother's the backup.
MR. SNIDER: Quite right. The mother is in Texas which
is why the mother can't help out, and the Court said, "Why
can't we just get her?"
THE COURT: I'm proposing we excuse Ms. Trinidad.
MR. SNIDER: No objection.
THE COURT: Mr. Rivera is the accountant who has the
tax preparation issues. It says Wednesday is the tax deadline.
Your positions?
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MR. SNIDER: No objection as to cause.
MR. McCRAY: Judge, we're not agreeing to cause.
THE COURT: All right. I can have him come in, and the
primary question is whether or not this is a financial issue.
In other words, if he works for the county, he can stay. If
he's in a private accounting business where his income is
dependent upon being present, then I'm likely going to excuse
him.
Let's have Mr. Rivera come in, please.
Let's jump on over to Ms. Diaz. Ms. Diaz didn't say
anything about having the problem with Spanish the second time
I addressed it but she looked like -- I'm not sure she was all
there and whether she understood enough to even respond to the
question the second time around.
MR. SNIDER: I agree.
MR. McCRAY: I agree, Judge.
THE COURT: I'm inclined to excuse her.
MR. McCRAY: I think 13 has the same issue in terms of
not -- having an English problem.
MR. LOVE: Hers was stronger. Her ability to
understand was stronger, yeah.
THE COURT: I thought she understood what I was saying,
and she didn't express any issues the second time they were
given an opportunity to respond.
(Prospective Juror Rivera entered the courtroom.)
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THE COURT: We would like to ask you a few questions,
Mr. Rivera. You indicated that you have a tax business. Is
this a private business, or do you work for a corporation?
PROSPECTIVE JUROR: It's private. It's private. I'm a
partner.
THE COURT: So you receive your salary based upon your
clients; is that correct?
PROSPECTIVE JUROR: That's correct.
THE COURT: Do you think you could have enough time in
the afternoon to resolve your issues?
PROSPECTIVE JUROR: It's hard because I got -- like for
the corporations, most of them wait for the last minute, and
I'm really behind. I'm really behind.
THE COURT: All right. Thank you very much, sir.
(Prospective Juror Rivera exited.)
MR. SNIDER: Judge -- go ahead.
THE COURT: I'm going to excuse Mr. Rivera for cause.
MR. SNIDER: Judge, I want to ask, Number 9 who has the
Jewish holiday, I wanted to know whether she's unable to serve
on Thursday. If she is, then I have no objection to because
I'm concerned about the storm. What if we miss a day because
the Court is closed? I don't want to --
THE COURT: Actually, when I wrote it down, I was
thinking of this Thursday. Now you're telling me the holiday
will be the following Thursday.
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MR. SNIDER: I know for a fact it is because -- yeah.
So the question is whether -- I don't want to run into problems
next week certainly having gone through several days of trial.
THE COURT: I respect people wanting to take their
holiday. So if she remains on the jury, we're not going to be
in session on Thursday if we are in session.
MR. SNIDER: Okay. That's fine.
THE COURT: Next Thursday. So we would respect her
holiday and we just wouldn't be in session. We wouldn't be in
session on that day, which means we won't finish on that day.
If we were at the end of the case and the jury has to
deliberate -- now, there's one alternative. I can move her to
the end, as I'm going to, subject to another juror and she can
potentially be an alternate juror.
MR. SNIDER: That's fine, too.
THE COURT: Anyone disagree with that?
In other words, Shelby, Number 46, and if we get to
that point and we need a juror, then she could remain. That's
an alternative way, or we can be off Thursday. It's up to you
all. I want to finish by Friday. That's all I'm concerned
about.
What's your position?
MR. McCRAY: Judge, we will go with moving her back to
46.
THE COURT: We're going to move Number 9 to number --
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we will create a Lot Number 46 for Ms. Fisch so she's not to be
considered until the end.
Ms. Ermer has a problem with 3:00 p.m. on the 18th,
Number 14.
MR. McCRAY: She has a religious retreat, also, she
said.
THE COURT: I'm sorry.
MR. McCRAY: I wrote down she has a religious retreat.
MR. LOVE: Yeah, that was the 18th.
MR. SNIDER: She had to leave by 3:00. I don't think
that should be an issue if the Court wants to be done by them.
MR. McCRAY: We're okay with it, Judge. I don't think
it's for cause.
THE COURT: You don't have a problem with me excusing
her is what you're saying?
MR. McCRAY: Oh, no. I'm saying we should keep her.
THE COURT: All right. We talked about Ms. Diaz.
We're excusing her.
Ms. Saba, Number 18, what are your thoughts there? She
said, "I may have a bias."
MR. McCRAY: Judge, I think there's a reasonable doubt
about her ability to be fair just based upon her
representations. She said something about she represents
whistleblowers. I wrote down cause.
MR. SNIDER: Qui tam attorney.
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THE COURT: She's the qui tam. She said she may have a
biased. I'm inclined to excuse her.
MR. SNIDER: She also said she may know me but she
wasn't sure. I have no idea who for the record --
THE COURT: Maybe not personally.
MR. SNIDER: No.
THE COURT: Do you do qui tam work?
MR. SNIDER: No.
THE COURT: All right.
Next person, Ms. Gomez, who has a doctor's appointment
on Thursday morning -- I think we can work around that. We
would have to just start a little later. Number 25.
What's your position?
MR. WILCOX: Doctor's appointment 8:30 next Thursday.
THE COURT: It means we would have to start late.
What's your position? We should or --
MR. WILCOX: No, no.
THE COURT: -- should not excuse her?
Okay.
Mr. Babitz said he cannot be fair. I'm going to excuse
Mr. Babitz unless there's some objection.
Hearing none, let's go to Number 28, Mr. Pivnik, who
has the art show, and he's concerned about employment; so I'm
inclined to excuse him.
MR. SNIDER: Agree.
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MR. WILCOX: We liked him.
THE COURT: I'm sorry?
MR. WILCOX: Yes, we liked him.
THE COURT: You said you liked him. Well, does that
mean you don't have any objection to him being excused or you
do have an objection?
MR. WILCOX: I have an objection of him being excused
for cause.
Mr. McCray.
MR. McCRAY: Go ahead.
THE COURT: He's not disagreeing with you, but I'm
going to excuse him. It's an employment issue, and I'm
electing not to keep him here.
Ms. Chung -- I'm inclined to move her to a 47 spot.
She wants to be with her granddaughter in Melbourne on the
18th, which is the last day of the calendar.
Chung, Number 37 -- I either excuse her or move her to
the last slot to be considered an alternate.
What's your pleasure?
MR. WILCOX: I'm fine with that, Judge, making her 47.
MR. SNIDER: That's fine. No objection.
THE COURT: All right. So we will move her and make
her 47.
Ms. Miller has a work project, Number 39.
MR. WILCOX: Travel plans or something. That's what I
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have.
MR. McCRAY: Mexico City for a job.
THE COURT: Yes, a work project; so I'm inclined to
excuse Ms. Miller.
MR. SNIDER: No objection.
THE COURT: Defense?
MR. McCRAY: No objection.
THE COURT: I don't know what Ms. Guia is talking about
with her ethical issues, but I'm inclined to excuse her.
MR. McCRAY: Please.
THE COURT: I'm going excuse Ms. Guia.
Mr. Varela, who works at the airport, says he has an
important position with the flights, and given the weather, I'm
inclined to excuse Mr. Varela.
Any objection?
MR. McCRAY: No objection.
MR. SNIDER: No objection.
THE COURT: All right. Any additional challenges for
cause?
MR. SNIDER: Yes.
THE COURT: Yes, sir.
MR. SNIDER: Number 16, Judge. Number 16 is
Mr. Livette. Question Number 11 on his juror questionnaire
asked if you or your family has a close friend who's ever
worked for a law enforcement agency, and he wrote that he has a
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nephew that works for BSO, which means --
THE COURT: All right.
MR. SNIDER: I asked specifically that question during
my opportunity to voir dire, and he didn't disclose that he had
a family member that works for BSO. I'm concerned about the
veracity of that answer.
THE COURT: But you have to follow-up then if there's
something that causes you a problem. That's why I give you all
an opportunity to conduct voir dire.
MR. SNIDER: Sure. I didn't -- perhaps I didn't make
the connection at the time.
THE COURT: He says he has a nephew who works for BSO.
MR. SNIDER: No. It's the lack of -- when I asked the
question, he didn't say that he had a family member. It's
inconsistent with --
MR. McCRAY: Can we bring him in, Judge?
THE COURT: He had the same issue with a prospective
juror who had a conflict between the question on the
questionnaire and what was being asked you, and he followed up
and the witness responded.
MR. SNIDER: Understood.
THE COURT: You know, really, this -- I know you all
think that there may be some biases that float one way or the
other, but on that one, I don't know.
So you want me to bring him in?
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MR. SNIDER: Okay.
THE COURT: All right. Let's have Mr. Marceau Livette
come in.
MR. McCRAY: What was the exact question you asked?
MR. SNIDER: I was asking if anyone has any family
member -- it was one of the voir dire questions in front of me.
I was asking whether he had family or a close friend who's ever
worked for a law enforcement agency, and Broward Sheriff's
Office is one of the agencies.
THE COURT: All right. Any others? We're waiting.
MR. LOVE: Judge, we were talking a lot about travel.
38 also has a preliminary planned trip on Monday, Monday
through Wednesday.
THE COURT: Ms. Fernandez.
MR. LOVE: Yes, Judge.
THE COURT: I think that was the personal vacation.
MR. LOVE: I did want to highlight that because we were
talking about --
THE COURT: What was your --
MR. WILCOX: Had travel plans for Monday.
MR. McCRAY: What was the date?
MR. WILCOX: Monday.
MR. LOVE: Judge, I propose moving to 48.
THE COURT: All right. Let's take care of Mr. Livette.
(Prospective Juror Livette entered.)
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THE COURT: Mr. Livette, in your questionnaire, you
responded that you have a nephew who works for the Broward
County Sheriff's Office, is that correct or not?
PROSPECTIVE JUROR: He's a police officer.
THE COURT: I'm sorry?
PROSPECTIVE JUROR: He's a police officer.
THE COURT: We're trying to find out if the Broward
Sheriff's Office is somehow an issue in this case or even if
you find out that maybe one of the defendants or both work for
BSO, would that create a problem with you in fairness and
impartiality for both parties?
PROSPECTIVE JUROR: No.
THE COURT: Any follow-up questions?
MR. SNIDER: No.
(Mr. Livette exits.)
MR. WILCOX: Judge, I want to ask him one more
question.
THE COURT: There's no more challenges for cause to
entertain.
MR. WILCOX: I do want ask Mr. Livette one question,
and we'll let him go.
THE COURT: I just asked if you had any questions.
MR. WILCOX: I know, Judge.
THE COURT: He said he could be fair and impartial.
What is it that you want to ask?
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MR. WILCOX: I want to know why did he not hear
Mr. Snider when he asked the question.
THE COURT: All right. We're going to move on.
MR. WILCOX: All right.
THE COURT: If that's a request for further voir dire,
that request is denied.
MR. WILCOX: That's what it was.
THE COURT: All right.
Any other challenges for cause, either side? If not,
we're going to look at those that remain, 1 through 16, which
includes Mr. Livette.
Preemptory challenges, Government.
MR. SNIDER: Judge, I guess for Number 6, we would --
if it's not struck for cause, a peremptory on the same basis
that we just articulated.
MR. WILCOX: 16, Mr. Livette; right?
THE COURT: I'm sorry. I'm not following you. You
want to exercise a challenge for a peremptory challenge?
MR. SNIDER: Yes, Judge.
THE COURT: All right.
MR. WILCOX: I will make a Batson challenge to that.
THE COURT: What is the issue with Mr. Livette? Why do
you think he's being singled out? Based on race?
MR. WILCOX: Because he's the only African American I
believe in the first 16 people.
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MR. MCCRAY: African Haitian. He's a black person.
THE COURT: Okay. Let's just say it correctly.
MR. WILCOX: Well, okay.
THE COURT: Your basis?
MR. SNIDER: My basis is the same basis that I
articulated when I made the objection for cause. I'm concerned
about his truthfulness and his responses to the questionnaire
and not answering my question, so that's the race-neutral basis
in which I'm objecting.
THE COURT: The objection is overruled.
Additional peremptory challenges?
MR. MCCRAY: In the first two rows?
THE COURT: Yes, sir.
Government?
MR. SNIDER: 7.
THE COURT: Number 7 is Mr. Garcia. All right. Any
others as to 1 through 16, that remain, of course?
MR. SNIDER: No, Judge.
THE COURT: Defense, peremptory challenge 1 through 16?
MR. WILCOX: Number 2.
THE COURT: Number 2, Aragon is excused.
Any others?
MR. WILCOX: Your Honor.
THE COURT: Yes, sir.
MR. WILCOX: About Number 13, she had some problems.
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THE COURT: Number 13.
MR. WILCOX: Yes, Mrs. Osorio.
THE COURT: Number 13, peremptory. All right. So that
leaves Infante.
MR. SNIDER: Wait.
MR. WILCOX: I want to strike Lourdes Ermer.
THE COURT: Give me a number, please.
MR. McCRAY: Yes, Judge, Number 14.
THE COURT: All right. Excuse for peremptory. All
right.
Any others?
MR. SNIDER: Juror 1 is still in?
THE COURT: Yes.
Any additional peremptory challenges by the defense?
I need a decision, gentlemen.
MR. WILCOX: Your Honor, we're going to use our fourth
peremptory on Number 1.
THE COURT: Number 1. Okay.
Defense, 17 through 30.
Judge, we will strike Juror Number 22.
THE COURT: 22, Sebastian Ohanian, Number 22.
Additional peremptory challenges 17 through 30?
MR. WILCOX: 19.
THE COURT: 19 is Mr. Gutierrez.
MR. McCRAY: Judge, we are going up to 30; right?
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THE COURT: Correct.
MR. McCRAY: Number 29 for cause. Your Honor I
neglected to mention this. I know he's awaiting to be -- to
hear something from the military, and I'm just concerned about
whether or not he's going to be able to focus.
THE COURT: If he's called during the session, I'm
going to excuse him and an alternate would fill in that slot.
Government, 17 through 30.
MR. SNIDER: We will use a peremptory on 20, Judge.
THE COURT: 20, Esquia.
Any others?
MR. SNIDER: No.
THE COURT: We have 11 permanent jurors. Let's now go
31 through 45, but when we get to the first one you don't
challenge, that's going to be Number 12.
So peremptory challenges, Government?
MR. SNIDER: 35, Judge.
THE COURT: So you don't challenge Bolufe, that's 31?
MR. WILCOX: Number...
THE COURT: Both you of, are there any challenges to
31, Government?
MR. SNIDER: No.
THE COURT: Defense?
MR. McCRAY: Yes.
THE COURT: So defense exercises a peremptory as to 31.
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Let's look at 32.
Government?
MR. SNIDER: No.
THE COURT: Defense, Espinosa.
MR. McCRAY: Strike, Judge.
THE COURT: 32. All right.
33, Government?
MR. SNIDER: No objection.
THE COURT: Defense?
MR. McCRAY: Judge, we strike 33.
THE COURT: All right.
34, Gonzalez, Government?
MR. SNIDER: No objection.
THE COURT: Defense, Gonzalez?
This will be your last peremptory now, by the way.
MR. McCRAY: Judge, we strike Juror Number 34.
THE COURT: All right. Number 34. So you exercised
all of your peremptories.
Government, 35.
MR. SNIDER: We will use our peremptory.
THE COURT: I'm sorry.
MR. WILCOX: I raise another Batson challenge.
THE COURT: You exercised a challenge as to 35;
correct.
MR. WILCOX: Yeah, he did.
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THE COURT: I thought you said --
MR. SNIDER: Peremptory. He's challenging it.
THE COURT: That's as to 35.
MR. SNIDER: We're exercising a peremptory based on we
don't think that the prospective juror can be partial based on
her response to Question 9, which states that brother-in-law is
serving time in prison. She also indicated in Number 10 that
she has a close family member who's been a victim of robbery.
What else?
THE COURT: I'm not excusing her for those reasons. Is
that --
MR. SNIDER: Those are our race-neutral reasons.
THE COURT: See, the questionnaire allows you to get
information to further peruse it. So just on those statements,
I'm not going to excuse Juror Number 35. So, Juror Number 35
will be the 12th juror. All right.
Now, let's take a look at those that remain, and we'll
give you two challenges. Let's pick three alternates. The
first three that are not challenged will be our alternate
jurors. So we're going to start with Number 36.
Defense, what's your position to 36?
MR. McCRAY: Accept.
THE COURT: Government, 36?
MR. SNIDER: Accept.
THE COURT: All right. That's our first alternate.
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Now, to Laura Fernandez, Government?
MR. SNIDER: Judge, she's the one who has the trip
planned.
MR. LOVE: Can we move her to 48.
MR. McCRAY: Right. We did.
MR. LOVE: She's been moved.
THE COURT: We moved her to 48.
Next is Emmanuela Raphael.
Government?
MR. SNIDER: No objection.
THE COURT: Defense?
MR. WILCOX: No objection.
THE COURT: All right. That's Alternate 2.
Now, let's go to McCray.
Defense?
MR. McCRAY: Accept, Judge.
THE COURT: Government?
MR. SNIDER: No, we wanted to exercise a peremptory on
43.
THE COURT: I'm sorry, on 43? Okay.
44, Giraldo.
MR. WILCOX: Your Honor, now, Number 43, I believe
another African, we make a Batson challenge. I don't know if
you do them all --
THE COURT: Well, I do if there's a basis.
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MR. SNIDER: We don't know the race of the person. I
don't.
MR. McCRAY: You don't see out there?
MR. SNIDER: I have no idea what race this person is.
MR. McCRAY: Judge, she's of African descent.
MR. SNIDER: How do you know that? I don't write down
people's races.
MR. McCRAY: I didn't write it down either.
MR. SNIDER: And to memorize 40 some odd faces.
MR. WILCOX: What did she say here?
MR. SNIDER: I don't think this is an appropriate
Batson challenge, but if it is, I will give my reason.
THE COURT: What is the reason? They say it's based on
race. You say it's based on?
MR. SNIDER: On her having someone who works in
corrections. We don't think that person can be impartial.
THE COURT: She has someone who works in --
MR. SNIDER: A family -- I don't know if it's hers or
someone else. She says me, correction, health and services,
mother is even a corrections officer.
THE COURT: Let me look at 43.
MR. McCRAY: It appears she's a pharmacy tech.
THE COURT: Few family members have ever worked for law
enforcement. So she's saying she has, and correctional, health
service, which means --
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MR. LOVE: Her mother is a correctional officer.
That's how I read that.
THE COURT: It says "and mother."
MR. McCRAY: Mother's a correction officer.
MR. SNIDER: We can bring her in and ask her for
clarification.
Can we bring her in?
THE COURT: This is a Batson challenge. How many other
persons of African descent are on the jury?
MR. WILCOX: I believe the only person of
African American decent is Mr. Marceau Livette, Juror Number
16. And he's Haitian. I don't know.
MR. SNIDER: He's been struck.
MR. WILCOX: I'm sorry, that's right. We did strike
him. I'm sorry. I have to look.
MR. MCCRAY: Juror Number 30, I think her name is Veda
Ferris. She's of African descent, Judge.
THE COURT: Do we have all the persons on the jury who
were affiliated or worked for law enforcement who were not
challenged?
MR. SNIDER: I didn't think so.
MR. McCRAY: Yes, Judge, Juror Number 15, Mr. Schaffer.
His brother-in-law is captain with the Miami-Dade Police
Department, Stephen Schaffer, 15.
MR. LOVE: I think that was chaplain, though.
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THE COURT: I'm sorry?
MR. LOVE: Did you say captain or chaplain?
MR. MCCRAY: It says captain. Someone else is a
chaplain.
MR. WILCOX: Number 21.
MR. McCRAY: In addition, Judge, Ms. Bustamante's
either husband or -- I think her husband is with the City of
North Miami Police Department.
THE COURT: I'm not going to excuse her. She's the
15th juror, the third alternate. All right.
So when we go back out, I'm going to excuse everybody
for lunch, and announce those who have not been selected.
We'll come back in an hour, and we'll have our preliminary
instructions and opening statements.
(Prospective Juror Panel enters.)
THE COURT: Quickly, please. You can stand in the
area. I'm beginning to call names, quickly, please.
I am going to call those who have been selected, and
the courtroom deputy will show you where to be seated, and then
I'm going to excuse you for lunch.
Those who are not selected, I will be excusing in just
a moment.
So once we get everyone in:
Mr. Jose Ramos, please sit in Number 1, Seat Number 1.
Mario Aulicino, Number 2.
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Samantha Loynaz, Number 3.
Infante, Viviane Andreotti, Number 4.
Number 5, Stephen Joseph Schaffer.
Number 6, Olga Bustamante.
Number 7, Gabriel Sanchez.
Number 8, Hernan Vera.
Number 9, Susy Gomez.
Number 10, Mandri, Nicholas Mandri.
Number 11, Veda Ferris.
Number 12, Tammie Williams.
Next, Dimercurio, Dangela.
Emmanuela Raphael.
And Cachee McCray.
All right. Ladies and gentlemen, those of you who are
standing, I'm going to excuse you at this time.
Thank you very, very much for your service.
Please go to the 7th floor -- no, the 5th floor, and
they will give you further instructions. I suspect since it's
1:30, they probably are going to excuse you, but let them give
you directions.
Thank you very much, ladies and gentlemen, for
participating. Have a great afternoon. You're all excused.
Be safe, everyone.
(Prospective jurors are excused at 1:32 p.m. )
THE COURT: Ladies and gentlemen, I'm going to have you
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go into the jury room, and then the courtroom deputy will tell
you how to get downstairs to the cafeteria. We're going to
resume at 2:30 p.m.
I will give you instructions when you return. You will
be sworn, and the lawyers will present their opening
statements. We'll break at 4:00 p.m. So please go into the
jury deliberation room. You will see where you are. They will
show you how to get out and return here and be ready to proceed
at 2:30 p.m.
Thank you.
(Prospective jurors exited courtroom at 1:33 p.m. )
THE COURT: All right. Are there any additional
matters we should address before breaking for lunch?
MR. SNIDER: Your Honor, at the start of the first
trial, the Government moved into evidence all the exhibits to
which there was no objection. That moved things along very
nicely.
THE COURT: All right.
MR. SNIDER: And we are proposing to do the same for
any exhibits if there's no objection.
THE COURT: All right.
Defense, your position as to the exhibits except -- the
only thing that concerns me a little bit is with regard to the
exhibits related to the 404(B) witness.
MR. SNIDER: Yes.
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THE COURT: I'd rather not receive those until --
unless they are duplicative.
MR. SNIDER: I should have been clearer. With the
exception of the exhibits that the Government has noticed as
404(b) evidence that the Court has reserved ruling on -- and I
can tell you what those exhibit numbers are.
THE COURT: Well, why don't you tell the defense what
they are, and I will have you all return at 2:25, and then I
can receive those for which there are no objections.
MR. SNIDER: Thank you.
THE COURT: All right. Thank you, all. We are in
recess.
(Luncheon recess was taken from 1:35 p.m. to 2:25.)
(Jury not present.)
COURTROOM DEPUTY: All rise. Court is back in session.
2:33 p.m. Back on the record.
THE COURT: Be seated, please.
With regard to the witnesses, what have you all
decided?
MR. SNIDER: I'm sorry, the exhibits?
THE COURT: With regard to the exhibits, excuse me,
what have you all decided?
MR. SNIDER: Your Honor, the Government is moving into
evidence without objection from the defense all of the exhibits
with the following exceptions:
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Exhibits -- there is an objection, which I would like
the Court to take up now. I'm ready to address it. An
objection to Government Exhibits 165 --
THE COURT: 165.
MR. SNIDER: -- through 171. And --
THE COURT: One moment. 165 through 171.
Okay. This does appear to be SmartBiz records for --
looks like Wade Funeral Home --
MR. SNIDER: It's a PPP loan application for Wade
Funeral Home.
THE COURT: And is this the subject of the case in
chief --
MR. SNIDER: It is.
THE COURT: -- related to the indictment?
MR. SNIDER: Yes. The indictment, Your Honor, alleges
two things. The purpose of the conspiracy was for the
defendants and their coconspirators to unlawfully enrich
themselves by, among other things, making false statements to
obtain PPP loans and forgiveness of such loans from the SBA
lenders and submitting and causing the submission of PPP loan
applications that contained false and fraudulent information.
That was the purpose. And then the manner and means in
paragraph 24 --
THE COURT: Okay. One second. Which loan is 6781674?
MR. SNIDER: It is a PPP loan application submitted
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during the period of the conspiracy on behalf of Wade Funeral
Home that the Government is alleging contained false and
fraudulent statements.
THE COURT: And is this the loan that the Government
paid? Is this the $28,000?
MR. SNIDER: This is an unpaid loan. So we have --
there's two paid loans, each in the amount of $20,833. This is
an application that was declined seeking a PPP loan of
approximately $700,000 based on false and fraudulent
statements.
THE COURT: Is this loan referenced in particular in
the indictment?
MR. SNIDER: Not the loan number.
THE COURT: No, no, just -- the loan, the $700,000 loan
you said?
MR. SNIDER: We do -- it doesn't allege that level of
specificity. What we're alleging is a conspiracy to obtain
fraudulent --
THE COURT: Okay. Is it a hundred loans, or is it --
do you refer to the other loans specifically like loan number
or not?
MR. SNIDER: In the substantive counts, yes. This one
is not a substantive count. It is just evidence of the
conspiracy.
THE COURT: Let me hear the -- see, you have to put
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people on notice. That's what it's all about. So if you say a
conspiracy involving loans, it should indicate what loans we're
talking about.
MR. SNIDER: So just -- can I bring to the Court's
attention the Government -- I mean, in the 404(b) notice -- we
are not offering this as 404(b); but in that notice, what the
Government said was that the 404(b) that it was offering is
evidence that would be admissible to prove this charged
conduct; and we specifically said this loan, the loan number,
and the false information that was in this --
THE COURT: In the 404(b) notice?
MR. SNIDER: Yes, but not as 404(b). As --
THE COURT: One moment. One moment, sir.
MR. SNIDER: Sorry.
THE COURT: Is it in the 404(b) notice? That's the
question I'm asking.
MR. SNIDER: Yes, as to charged conduct.
THE COURT: Well, if it's in the 404(b) loan notice,
that would lead me to believe it's the 404(b). How would I
know otherwise?
MR. SNIDER: May I read?
THE COURT: Yes, sir.
MR. SNIDER: This is page three of Docket Entry 35:
The PPP loan applications related to Carolyn and Tracy Wade,
which defendants submitted and caused to be submitted in
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furtherance of one or more of the offenses alleged in the S1,
superseding indictment, include the following. It lists number
one, the $20,000 loan to Tracy Wade. Number 2, the $20,000
loan to Carolyn Wade. Number 3, the PPP loan application
created May 6th 2021, and assigned SmartBiz application number
6781674, hereinafter the Wade Funeral Home PPP application.
In the next paragraph, it states: The materially false
and fraudulent representations in the Tracy Wade PPP
application and Carolyn Wade PPP application and the Wade
Funeral Home PPP application include but are not limited to the
following. And in the paragraph -- the bullet relating to the
Wade Funeral Home PPP application states: The Wade Funeral
Home PPP application falsely represented, among other things,
that in 2020 Wade Funeral Home had 45 paid employees and gross
payroll of 3.3 million dollars.
The Wade Funeral Home PPP application was supported by
several fictitious documents, including a fake I.R.S. 941,
purportedly for the first quarter of 2020, and three fake
payroll documents. Based on these and other false
representations, the Wade Funeral Home PPP application
requested a PPP loan in the $701, 873.
The Wade Funeral Home PPP application was conditionally
approved by the SBA on May 26th, 2021, but ultimately declined
on June 6th, 2021. This is in the background of the 404(b)
notice.
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THE COURT: All right. May I see the document
because -- how is it captioned? Is it captioned 404(b)? Is
the caption of the pleading you're reading captioned 404(b)?
MR. SNIDER: Yes.
THE COURT: All right, may I see it, please?
MR. SNIDER: Mr. Love will hand it up.
MR. LOVE: Your Honor, may I approach?
THE COURT: Yes, sir.
(Documents tendered.)
THE COURT: Defense.
MR. WILCOX: Oh, I'm sorry, Your Honor.
THE COURT: May I hear from you on this subject?
MR. WILCOX: Yes, sir, Your Honor.
We did discuss this after the last status conference,
Mr. Snider and myself. And I raised the same concern as the
Court had. You make no reference of the $700,000 PPP loan. It
was an attempt -- allegedly an attempt by Mr. Wade to get a
$700,000 PPP loan. There's no specific reference in the
indictment.
When he filed his 404(b) notice, I sent him an email.
I asked him precisely which -- what evidence do you plan to
introduce pursuant to 404(b). He referenced the two EIDL
loans, which are those there and nothing else.
So I assumed that he wasn't bringing in the $700,000
back when I asked him about it pursuant to 404(b). After the
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status conference last week, he said, Oh, no, it's part of the
conspiracy.
I said, What do you mean it's part of the conspiracy?
There's no overt act. There's nothing mentioning his attempt
to get a $700,000 loan. So I told him we'd be objecting to
these exhibits, and we'd address it at trial.
THE COURT: All right.
MR. SNIDER: May I respond?
MR. WILCOX: May I --
THE COURT: Listen, I've heard enough, all right.
The notice makes reference to the 404(b). And if I
just read it and didn't know any better, I would think this is
the 404(b), and it's not referenced in the indictment. And so
for those reasons, at this time, I am sustaining the objections
to 165 through 171.
Bring the jury in, please.
All this other -- there's a way to resolve it. Put
them in the indictment to put them on notice what they're
charged with. That's one way of handling it. But this is --
this is how I interpret it, all right.
MR. SNIDER: Okay. Can I -- can I respond or no?
THE COURT: You can respond later. We have the jury
coming in.
MR. SNIDER: Okay.
THE COURT: But the ruling is the objection is
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sustained.
COURTROOM DEPUTY: All rise for the jury.
(Jury entered courtroom at 2:45 p.m. )
THE COURT: Have them sworn while they're standing.
COURTROOM DEPUTY: Please remain standing.
THE COURT: Please raise your right hands, ladies and
gentlemen.
COURTROOM DEPUTY: Do you and each of you solemnly
swear or arm that you will well and truly try the issues in
this case and render a true verdict according to the evidence
charged of this Court?
JURY PANEL: I do.
THE COURT: Be seated, please.
Members of the jury: Now that you have been sworn, I
would like to give you some preliminary instructions to guide
you in your participation in the trial.
It will be your duty to find from the evidence what the
facts are. You and you alone are the judges of the facts. You
will have to apply those facts to the law that I give you at
the very end of the case. And keep in mind, you must follow
that law whether you agree with it or not.
Nothing that I say during the course of the trial is
intended to indicate to you what the facts are. You and you
alone are responsible for making that determination.
If I make a comment to the lawyers or otherwise, I'm
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not trying to suggest to you what your verdict should be.
That's your responsibility.
The facts from which you will find the evidence in this
case and the facts that you will determine the case will
consist of the testimony of witnesses, documents received in
evidence, and other items that the Court receives, and any
facts that the lawyers may agree are, as we say, stipulate to.
Sometimes the lawyers stipulate to certain facts or
testimony to save time; and if there are stipulations, I will
announce them to you and then you may consider them.
Keep in mind, those stipulations will be produced.
Sometimes they are in writing included with the exhibits.
Certain things are not evidence and must not be considered by
you in any way.
In the very going of the case in just a few moments the
lawyers will present to you their opening statements. They are
going to tell you what they think the evidence is going to be,
and you will consider that. It's like a preview of what they
expect the evidence will be. But the actual evidence in the
case is the testimony and the exhibits received, not the
opening statements. You may consider them as guidance, so to
speak.
And at the closing of the case, the lawyers will
present what we call closing arguments. They will tell you
what they think the evidence was; but keep in mind, you make
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that determination. You're not to consider the closing
evidence nor the opening statements as the evidence in the
case.
And of course, the lawyers have to ask questions of
witnesses. It's not the question that's the evidence. It's
the answer to the question.
So if a lawyer asks, Is the sky blue; and the witness
says, No, the sky is red; it is not the question that's the
evidence. It's the witness's answer to the question.
Now, I'll tell you a little bit about credibility of
witnesses. So it's up to you the extent to which you believe a
witness. Just because a witness says something, that's not
necessarily how you will decide the issue. That is a question.
It's an answer. And you determine the credibility of the
witnesses.
When the lawyers pose objections to questions, it's
because they've made a determination that they think that this
is not a proper question.
If I overrule the objection to a question, it means
I've decided that the question is a proper one and there would
be a forthcoming answer.
If I sustain an objection to a question, it means I've
determined that's not a proper question; and, therefore, there
will be no answer to that question. A lawyer will go to the
next proper question.
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You should not be influenced by any ruling that I make
on an objection. I'm simply carrying out my responsibility as
the judge of the law. So don't count lawyer A had three
objections sustained, and lawyer B had six objections
sustained. That's not the point. And you must follow my
instructions.
Occasionally, sometimes items are received for a very
limited or specific purpose. If that occurs, I will give you
have an instruction telling you how to consider the evidence.
Anything that you see or hear outside of the courtroom
is not evidence. Your past experiences, as we discussed
earlier, is not evidence. The evidence will come on the
witness stand to my left and the documents that are received in
evidence.
Now, for your information, the lawyers have agreed that
certain items should be received as exhibits, and I'm receiving
them. Technically, a foundation has to be laid for each
exhibit.
So, for example, if an exhibit comes from a record of
an agency, they would have to call witnesses for the witnesses
to testify that these documents are kept in the ordinary course
of business, et cetera.
Rather than having to call these types of witnesses,
they have already agreed that many exhibits should be received,
because they've already done the background and they agree that
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the exhibits have been received; and I am receiving them
without the necessity of having to lay a foundation.
It saves us an inordinate amount of time, and I
certainly appreciate when lawyers can reach those agreements.
So when an exhibit is referred to as Exhibit 1, that
means it's in evidence because it has an exhibit and it's
Number 1, or 2, or 3. If an exhibit is marked for
identification, it hasn't been received and will not be before
you until it is received.
So if the Government refers a witness to Exhibit 10,
it's an exhibit. I've received it. It's Exhibit 10. But if
it's Exhibit marked for identification 10, I haven't received
it; and until such time as I do receive it, it will not be in
all of the exhibits that will be provided to you at the end of
the case.
We'll give you an exhibit list of all of those that
have actually been received in evidence.
Keep in mind, anything you see or hear outside of the
courtroom is not evidence and must not be considered by you.
There are two kinds of evidence: Direct evidence and
circumstantial evidence.
Direct evidence is direct proof of an assertion or a
fact, such as the testimony of an eyewitness, all right.
Circumstantial evidence is proof from facts in which
you may infer or conclude that other facts exist. So, for
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example, the lawyers like to use the example of you walking
outside and you see the grass is wet and the sidewalk is wet.
Well, you can infer that it rained, or maybe it was the
sprinkler. So that's an example of circumstantial evidence.
You may infer from certain facts that other things exist, but
you've got do decide whether you should make that inference.
Now, we talked a little about the credibility of
witnesses. This has to do with the believability of a
witness's testimony and how much of the witnesses' testimony
you should accept or reject.
At the very end of the case during the instruction
phase, I will give you some instructions to determine the
credibility. That is, the believability of the witness's
testimony. And I'll give you certain considerations. Like how
long did the witness have to observe what they testified about?
Do they have any personal interest in the outcome of the case?
I'll give you several tests, about seven, or eight, or nine to
help you determine the credibility of witnesses.
As you know, this is a criminal case; and there are
some rules that you must keep in mind.
First: The defendants are presumed innocent until
proven guilty beyond a reasonable doubt. An indictment
contains only accusations. Nothing more. The defendants start
out with a clean slate. The indictment itself proves nothing.
Second: Burden of proof is on the Government to prove
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its case beyond a reasonable doubt. The defendants have the
right to remain silent; and if they elect not to testify, then
the law prohibits you from considering that fact that they
didn't testify in reaching your determination.
And you know the Government has the burden of proving
its case beyond a reasonable doubt. Those are three important
factors for you to keep in mind.
Now, a few words about your conduct as jurors. First,
I instruct you that during the trial or after each day you are
not to discuss the case with each other or family members or
friends when you go home. Of course, they're going to want to
know what you're doing in downtown Miami. You're going to
simply tell them: I'm serving as a juror, and I can't discuss
the case at this time. Because the problem is, if you start
talking to people about the case, then you're not going to
remember who said what or when.
So just avoid talking about the case. This is not a
very lengthy case, and you'll have plenty of time to talk about
your experiences after the jury has reached a verdict. So keep
that in mind when we break for lunch or have a break during the
morning or afternoon session. Do not go in the jury room and
talk to each other about what you heard or saw.
The time to deliberate, as the term is referenced, is
after all of the evidence has been presented, all of the
arguments have been presented, and I've told you what the law
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happens to be. So please keep that in mind.
I have instructed the attorneys and the parties to have
no contact with you whatsoever. So if you happen to be coming
up on the elevator tomorrow morning and there's an attorney on
the elevator or maybe a witness from the prior day that you
recognize, that person will not speak to you or greet you.
They're not being rude. They have been told to have no
contact with you whatsoever. Because if someone sees you
talking to a witness, the first thing they're going to want to
know is what are you talking about, because you're not supposed
to have talking with others. So now, when that's reported to
me, I have to call each one in: What did you see? What did
you hear? It takes an inordinate amount of time.
So simply put, they will not be speaking to you and you
will not speak to them during the trial. This is very
important.
Do not read or listen to anything regarding this case.
We don't expect any pre-trial or post-trial or during-trial
publicity. As you know, in some cases they're highly
publicized, and there's news reports and radio reports and a
lot of information during the trial itself.
So if by chance -- which we don't anticipate; but if by
chance there was an article in the newspaper and you saw the
heading, do not read it. Radio, as you're driving in, if your
radio is on and there happens to be a report about this case,
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turn the radio off or change the station, or the television
news in the evening or morning. So keep this in mind. Don't
read or listen to anything regarding this case.
If anyone attempts to contact you or to talk to you
about this case, bring it to my attention at your first
available opportunity: The following morning, during the trial
after lunch, whatever the occasion may be.
Do not read or listen to anything which relates to this
case. In this new technological world with the internet and
iPhones and iPads and computers, there's all sorts of
information out in cyber world. Now, a lot of it's not even
true, all right. So don't try to do any investigation on your
own by looking up the names of witnesses or defendants or
lawyers, et cetera. Please, none of that relates to this case.
Everything you need to know we will tell you here in
open court. So no research or investigation on your own. This
is a big problem. We've had instances, not in this district in
particular, but some jurors blogging from the jury room. And
we did have an instance in this district where a juror brought
in a dictionary and started giving the jurors the definitions.
And of course, that case was deemed a mistrial after about six
or seven weeks of trial, which means that it has to start all
over again and a large waste of time and effort. So no
investigation, no Googling or use of devices, et cetera. This
is very, very important.
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Don't communicate with each other by email or otherwise
concerning this case. I can't emphasize these rules enough.
Now, if you are unsure about whether to engage in some
activity or not, that means there's a question about whether
it's proper, so don't do it. Bring it to my attention at your
first available opportunity, and I will give you some guidance
in determining whether or not you should proceed with the
information.
Do not form any opinion until all of the evidence has
been received, the closing statements, and my instructions to
you on the law.
Really until you know what the law is you really can't
make any decisions. You've heard evidence, but what's the law?
One without the other doesn't help, and that's why we both have
jobs in this case. You're the judges of the facts, and I will
serve as the judge of the law. Equally important.
If you would like to take notes, you may. I think you
have been provided with pads and pencils. So don't try to
write everything done; but if something significant or
important to you occurs, feel free to take a note. We will
preserve your notes in the jury room overnight. They will be
secured. No one will read them. And returned to you the
follow day. So if you want to take notes, feel free to do so.
Now, the trial is going to begin in just a few moments;
and the first thing that will happen is that the lawyers are
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going to present to you opening statements. They're going to
tell you what they expect the evidence is going to be.
As you know, it's not the actual evidence. Thereafter,
the Government will present what we call its case in chief.
And after the Government's case in chief, the defense have an
opportunity to present a case in chief, but they don't have any
burden of proof, so they don't have to present a case. They
don't have to present any evidence. As you know, they don't
have to testify. That will be their determination.
During each case in chief, the lawyer presenting their
case -- Government first, defense second -- they will ask
questions of witnesses, which we call direct examination,
followed by cross-examination from the opposing side, and
thereafter redirect examination to go over those matters raised
in the initial direct examination. Those are the three phases
for each witness. In some jurisdictions, they have direct and
cross and redirect and re-recross and on and on and on.
So in federal court, there are three stages: Direct,
cross, redirect. That ends the inquiry for each witness and
then the witness may be excused.
After each side has presented their case in chief, you
will hear the attorney announce they are resting their case.
That means they have concluded all of the evidence that they
want you to consider.
This is important because at the end of each case, I
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will entertain legal issues from the lawyers. So I will excuse
you while I entertain their arguments about these legal issues.
And after all of the legal issues have been presented, the
lawyers will present closing arguments. Government first,
defense second, and then the Government may give a closing
argument which is referred to as rebuttal argument reference
the defense. So Government, defense, Government. They each
will have a maximum number of minutes. And any time that the
Government may -- say, for example, if each side has a maximum
of 30 minutes and the Government's initial argument is 20
minutes, they would have ten minutes for their rebuttal. So
that's the way the process works.
Then after all the arguments, I will give you your
instructions on the law. I will give you a copy of those
instructions to read along and follow along with me as they are
presented.
Now, we have seating charts. I'm not sure everyone is
in the correct seats. So we have Mr. Ramos. We have
Ms. Aulicino. You should be in the Number 2 seat,
Ms. Aulicino. So I'm going to ask you to switch with Ms. --
Mr. Aulincino, all right. You're in the right seat.
Ms. Loynaz.
Ms. Infante.
Mr. Schaffer.
Ms. Bustamante.
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Ms. Sanchez -- Mr. Sanchez.
Ms. Rivera.
Ms. Gomez.
Mr. Mandri.
Ms. Ferris.
Are we missing, Ms. Williams?
JUROR: I'm Williams.
THE COURT: All right, I will have you move over one.
Then Dimercurio, move over one.
Raphael, and Ms. McCray.
Okay. I see a seat missing, I get nervous. We have
everyone here.
All right. Counsel, are you requesting any additional
instructions?
MR. SNIDER: No, Your Honor.
THE COURT: Defense, any additional preliminary
instructions?
MR. McCRAY: No, Judge.
THE COURT: Government, you may begin.
MR. SNIDER: Thank you, Your Honor.
GOVERNMENT'S OPENING STATEMENT
MR. SNIDER: May it please the Court.
THE COURT: Yes, sir.
MR. SNIDER: Members of the jury, good afternoon.
This case is about two law enforcement officers who
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lied to get loans from the Paycheck Protection Program during
the COVID 19 pandemic.
Those two law enforcement officers are the defendants
in this case: Mr. Tracy Wade and Mrs. Carolyn Wade. Carolyn
Wade and Tracy Wade are married. They have been for about nine
years.
In 2021 when this country was industrial grappling with
the effects of the COVID 19 pandemic on the economy, Carolyn
and Tracy Wade were employed full-time as deputy sheriffs with
the Broward Sheriff's Office, commonly known as BSO.
They were sworn officers in BSO's department of
detention, which operates the county jails and provides
security to its courthouses.
The evidence will show that from approximately May
through August of 2021, Carolyn and Tracy Wade applied for and
received Paycheck Protection Loans based on false information.
Specifically, Carolyn and Tracy Wade each received a PPP loan
in the amount of $20,833 for businesses that did not exist and
were based on income that was made up out of thin air.
A total of $41,666 went into the defendants' bank
account all based on lies.
Now, let's talk for a minute about the Paycheck
Protection Program. I know it came up during the voir dire
process, but I want to go through it again.
The Paycheck Protection Program, or PPP as it was
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commonly known, was a federal program. It was a federal
program that began at the start of the COVID pandemic, and it
had one objective; and that was to, as the name suggests,
protect paychecks. It was designed to put money in the hands
very quickly of small business owners so that those small
business owners could keep their employees employed during the
pandemic.
Now, PPP loans, the amount of the loan, that was
determined based upon the business's payroll, what the business
paid its employees because it a business was applying for a
loan to get money to keep its payroll going. It was designed
to protect paychecks.
Now, self-employed business owners -- for example, a
sole proprietor that is in business for himself or herself,
they could also apply for PPP loans. And when a sole
proprietor applied for a PPP loan, the amount of the loan was
based on what the sole proprietor paid themselves. Sole
proprietors pay themselves based on their income. So loans for
sole proprietors were based on the sole appropriate or
self-employed person's income, and there was a maximum. The
maximum was $20,833. And you'll hear in this case why that was
the maximum.
It was a formula that was based on a maximum income of
100,000. If you have at least 100,000, you have no more, you
can get a loan for 23,833 if you were self-employed, had your
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own business.
Now, the SBA partnered with private lenders to
administer this program, and many of those private lenders
partnered with third-party service providers. And what the
service providers did was they would host websites where a
small business owner could go to apply for a loan. And that
service provider would collect all the information through its
website and documents that were needed, and they would package
it all together for the lenders and the SBA to approve. And
the service provider that you're going to hear about in this
case was called Womply.
PPP loans were forgivable, but that was a separate
application process. If you received a PPP loan, you could
apply to have that loan forgiven if you spent the money on
payroll. You had to spend approximately 60 percent of the PPP
money on payroll in order for it to be eligible to be forgiven.
And if you apply and the SBA forgave the loan, you didn't have
to pay it back.
The PPP was a trust-based system. That's how it
worked. It relied on the truthfulness of the borrower to
supply truthful and accurate information in the PPP application
and any supporting documents. And the reason you will learn
that it was trust-based was because the SBA was trying to get
money out as quickly as possible to small businesses. So they
relied on the business owners to certify that all the
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information was true.
Tracy Wade and Carolyn Wade violated that trust when
they certified as true in their PPP loan applications that all
the information was true and all the supporting documents were
true when they knew it wasn't.
You will see in this case that each defendant made
multiple false certifications both to get the loans in the
first place and then to apply for forgiveness.
Let's talk a little bit more about these two loans.
Tracy Wade's PPP loan, again, $20,833. That was the maximum
that a sole proprietor could get.
His application was based on a business that didn't
exist. It was for a sole proprietor named Tracy Wade. The
business name was Tracy Wade. There was no business name Tracy
Wade, and it was based on income of $112,430 in 2019.
The evidence will show that was false, and Tracy Wade
knew that was false. He knew he didn't have a business named
Tracy Wade, and he knew there was no business named Tracy Wade
that made over $100,000 in 2019.
Tracy Wade's PPP loan application also included a false
tax document. That false tax document was called an I.R.S.
Form Schedule C. And in his application, the I.R.S. Form
Schedule C, which you will see, was for a business that didn't
exist named Tracy Wade and claimed income of over $100,000.
We're going to talk more about that fake Schedule C in a
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moment.
Carolyn Wade's PPP loan. She also got a loan for
$20,833, the maximum for a sole proprietor. That was based on
an application that she certified that the business name was
Carolyn Wade, and that that business made over $100,000 in
2019.
The evidence will show that was false and Carolyn Wade,
knew that was false. She knew she didn't have a business named
Carolyn Wade, and she knew there was no business named Carolyn
Wade that made over $100,000 in 2019. And just like Tracy
Wade's PPP loan application, Carolyn Wade's PPP loan
application also included a fake tax document, a fake Schedule
C for a fake business named Carolyn Wade with made up numbers
of over $100,000.
Now, after the defendants received their PPP loans in
approximately June of 2021, they applied to have those loans
forgiven. And in those forgiveness applications, they made
additional false statements and certified those false
statements as being true, including how they spent the money
and that they were entitled to the loans in the first place.
Let's talk for a moment about the charges in this case,
which are alleged in the indictment. The indictment charges
the defendants with four crimes:
Conspiracy to commit wire fraud; wire fraud; conspiracy
to make false statements to the SBA Administration, the SBA;
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and making false statements to the SBA.
The evidence will show that Carolyn Wade and Tracy Wade
committed those crimes together. A conspiracy is an agreement
between two or more persons to do something illegal, to do
something the law forbids. It is an agreement to carry out an
unlawful plan. And in this case, the defendants' plan was to
get PPP loans based on false information.
The evidence will show that Tracy and Carolyn Wade
participated in a conspiracy to get PPP loans based on false
information and a conspiracy to make false statements to the
SBA.
In addition to conspiring to commit those offenses, the
indictment alleges that the defendants carried out their plan
in what is called a scheme to defraud using interstate wires to
carry out that plan. And that is why the defendants are
charged with wire fraud.
Finally, the defendants are charged, each of them with
making false statements both in their PPP loan applications and
in the forgiveness application. Defendants made those false
statements in an SBA form and certified that the information
was true and then signed those forms through an electronic
signature called DocuSign.
In addition to the defendants working with each other
to commit these crimes, the evidence will show that Carolyn
Wade and Tracy Wade committed the crimes alleged in the
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indictment with other people, and those other people are called
co-conspirators. A co-conspirator whom Tracy Wade and Carolyn
Wade agreed with to obtain fraudulent PPP loans was a woman
named Haydee Rivero. And before she was married, she was known
as Haydee Granados.
Ms. Rivero and her husband, Edward Rivero, they know
the ways through the funeral home business. The Riveros own a
funeral home called Edward Funeral Home, and Mr. Wade owns a
funeral home called Wade Funeral Home.
2021, the Riveros and the Wades were friendly. They
socialized together, including at gathering at the Riveros'
home.
Haydee Rivero is not an accountant. Haydee Rivero has
no accounting background. You will hear she's not good at
math. She's not good at crunching numbers.
Since 2020, since they've owned the Rivero Funeral Home
she's worked at the funeral home doing administrative tasks;
and before that, she was a Spanish interpreter.
But in 2021, Haydee Rivero was involved in fraudulent
PPP loans for herself and many other people, including the
defendants, Tracy Wade and Carolyn Wade.
Now, Ms. Rivero is going to testify in this case as a
witness for the Government; and Ms. Rivero's testimony and
documents that you will see will establish that she is the
person who created the fake Schedule Cs that were included in
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the defendants' PPP loan applications.
Ms. Rivero's testimony and documents will also
establish that the defendants knew that Ms. Rivero created fake
Schedule Cs for them and uploaded them into their PPP loan
applications. Because the evidence is going to show that the
defendants engaged Ms. Rivero for that purpose. Specifically,
they paid her. They paid Ms. Rivero each $1,000, and they paid
Ms. Rivero -- Tracy Wade paid Ms. Rivero $1,000 via Zelle the
same day that he got his PPP loan money; and a few days later
when Carolyn Wade got her PPP money, she sent the Zelle to
Ms. Rivero for $1,000.
We expect that Ms. Rivero will explain how she created
these fake Schedule Cs for the defendants. And in so doing,
she will explain that the defendants never provided her with
any of their real tax information.
She will also explain the process through which she
uploaded these fake documents that she made into the PPP loan
applications -- remember, all done online -- for the
defendants.
And the way that that was done, the way that Ms. Rivero
got access to their PPP loan application on the Womply website
was through a one-time code auto generated that had to be sent
to her within ten minutes. And the reason that it had to be
sent to her, Womply sent that code you will hear to either the
phone number or the email in the application. So for Tracy
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Wade's application, that one-time code if you wanted to log in
either went to his email, Tracy Wade's email, or to his cell
phone number. And when you wanted to log into Carolyn Wade's
application, the one-time code got sent to Carolyn Wade's cell
phone or her email.
Many of these codes and the other information that
Ms. Rivero was taking from the defendants that was transmitted
from the defendants to Ms. Rivero was over the phone, and you
will see records of phone calls in this case. There were
approximately 28 phone calls between Mr. Wade and Ms. Rivero
during the period of the conspiracy. And you won't see in
those records any calls before May of 2021 or after August of
2021. 28 phone calls between Tracy Wade and Haydee Rivero.
And there were a few phone calls, a few between Carolyn Wade's
cell phone number and Ms. Rivero's cell phone number; but
primarily Mr. Wade you will hear was the point of contact.
In addition to explaining what Ms. Rivero did for the
defendants, Ms. Rivero is expected to testify that she was
involved in PPP loan applications for about 18 other people.
Some of those individuals that she was involved with were
members of her own family and some were friends, and you will
hear that Ms. Rivero created fake Schedule Cs for many of those
applications just as she did for the defendants.
Now, not all of these 18 applications that she was
involved with actually went through, okay. And for the ones
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where they weren't going through because they, for example, ran
into a technical issue, Ms. Rivero did not create a Schedule C.
But for the ones that were going to go through, she created a
Schedule C, and she was paid to do that. And just like Carolyn
and Tracy Wade paid her $1,000 each, Ms. Rivero received about
$1,000 or $2,000 for every other Schedule C that she
fraudulently created.
Ms. Rivero's testimony will also establish that with
respect to those other Schedule Cs that she created, again, out
of thin air, making up the numbers, every single one of the
individuals for whom she was doing that knew the Schedule Cs
were fake.
You will learn in this case that Ms. Rivero has pleaded
guilty. She has pleaded guilty to conspiracy to commit wire
fraud and make false statements to the SBA, and she pled guilty
to that crime for the fake Schedule Cs that she prepared for
Carolyn Wade and Tracy Wade and the others we just mentioned.
You will learn that Ms. Rivero pleaded guilty this last
month pursuant to a plea agreement with the United States. And
that plea agreement includes an agreement by Ms. Rivero to
cooperate with the Government. Part of her cooperation as set
forth in the plea agreement requires her to testify at trials
like this.
Now, it is up to you, members of the jury, the judge of
the facts, to evaluate and make the determination about
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Ms. Rivero's credibility.
It is true that Ms. Rivero has not been truthful
before: Making up fake tax documents to put in a Schedule C
application, that is not being truthful. It is also true that
Ms. Rivero got PPP loans for herself based on false information
that she knew was false. And you will hear that Ms. Rivero
once before met with the attorneys for Carolyn and Tracy Wade.
And at that meeting, she denied her involvement in this
conspiracy. She wasn't truthful with the attorneys for Carolyn
and Tracy Wade when she met with them.
But in this trial, you are not going to have to take
Ms. Rivero's word alone because you are going to have all of
the documents, all of the records that show that Carolyn Wade
and Tracy Wade were directly involved in their own PPP loan
applications and that Tracy Wade was also involved in his
wife's PPP loan application.
There is a digital record that you will see of
everything that happened online, and that evidence will show
beyond a reasonable doubt that Carolyn Wade and Tracy Wade knew
exactly what they were doing when they applied for these PPP
loans.
Let's talk about that evidence for a moment.
First, you are going to see records from Womply, the
service provider that had the website where these PPP loans
were applied for. Womply kept a digital record of all the
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activity on its website and, specifically, all the activity in
PPP loan applications, including the PPP loan applications for
the defendants.
These records will show you, among other things, every
time Carolyn Wade or Tracy Wade logged into Womply, made
changes to their application or uploaded documents, like bank
statements or linked a bank account so the lender would know
where to send the money to.
You're not going to see them uploading the fake
Schedule Cs because that was done by Ms. Rivero.
There are two-ways when you look at these records that
you can tell who is logging in and who is conducting the
activity on the website. One of those ways is by an IP address
and the other way is by the model of the device that was being
used, the model of the computer or the model of the cell phone
that was logging in. Because Womply kept track of both. It
kept track of IP address that were accessing this website.
They kept track, was able to keep track of the device that was
being used, the type of computer, the type of cell phone.
You're going to hear in this case what an IP address
is, but you can think of it like a landline number for a house.
The landline number identifies the location of a certain house.
IP is just sort of caller ID for Internet. It identifies a
particular internet connection that's being used to access a
website.
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You will see in this case that these IP addresses in
the PPP loan applications for Carolyn Wade and Tracy Wade,
those IP addresses are directly attributable, many of them,
directly attributable to the defendants.
You will see the defendants' IP address from their home
where they resided in 2021 together. You will see the IP
address from the Wade Funeral Home, Mr. Wade's business, and
you will see multiple IP addresses for Verizon wireless, which
was their cell phone carrier in 2021.
You will see activity in the PPP loan applications for
Carolyn and Tracy Wade from those IP addresses directly
attributable to the defendants. You will see them logging in,
making changes, uploading documents.
It shows, for example, that the PPP loan applications
for Tracy Wade's loan and Carolyn Wade's loan were started from
the IP an address that was then assigned to the Wade Funeral
Home.
As I mentioned, the cell phone devices, you will also
see in this data, you will learn what device Carolyn Wade had
at the time; you will learn the device that Tracy Wade had at
the time; and from the data, you will be able to see the
activity from those models in their respective PPP
applications.
Why does this matter?
It matters for a few reasons. One of which is that you
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are going to hear from a witness from Womply who worked at
Womply during the PPP and wrote a lot of the code for its
website. And that witness is expected to say that every time
there was a log-in to a PPP application, all of the information
that has be been previously entered is visible to the person
who logged in. And in this case, you will see that the
defendants logged into their PPP loan applications before
Ms. Rivero uploaded the Schedule C and afterwards.
Another reason that the defendants logged into their
PPP loan applications on the Womply website was to verify their
identity. And you will see records of that process.
That process includes the defendants taking selfies of
themselves from the left, from the center, from the right.
There's six pictures of Carolyn Wade doing that. There's six
pictures of Tracy Wade doing that. They also had to upload a
photo of their driver's license so that Womply using persona
services could verify the identify of the person who was
submitting the application.
You will see in that data, too, the device that was
used, model and the device that they held in front of their
face to take the selfies. The same device that you will see
logged into Womply's website.
Now, after the application process was completed on
Womply's website and after the identity was verified, the last
step in this process was signing the PPP loan applications.
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And part of that signing process was the initialing of
the certification that all the information was true, and that
process was done through DocuSign.
This was yet another point where the defendants saw
their PPP loan applications and the false information was in
there. Because when you sign a document via DocuSign, the
document you're signing is visible on the screen that you're
using. This didn't happen on the Womply's website. The way a
DocuSign, you're going to hear in this case begins is that the
documents you sign get e-mailed to the email of the applicant.
In this case, Tracy Wade or Carolyn Wade.
Now, Womply kept a copy of each PPP loan application
that the defendants submitted. And with those PPP loan
applications is a certificate from DocuSign. That certificate
shows who it was sent to, when it was sent, when it was viewed,
when it was signed, and the IP address that was used to view
and sign the PPP loan application.
Now, with respect to Tracy Wade, he viewed and signed
three separate PPP loan applications for his one loan.
Each one of those PPP loan applications had the false
information, the income over $100,000 and the fake business
named Tracy Wade. The reason he had to sign those three times
is because Womply had to send that application to three
different lenders. Every time it went to a different lender,
you had to sign the application again.
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DocuSign records will show you that the IP address that
Mr. Wade used to sign those all three times was a Verizon
wireless IP address. His cell phone provider at the time.
DocuSign records will show that Mr. Wade viewed the application
before he signed it and after he signed it.
The DocuSign records will show that Mr. Wade actually
received a copy of his executed PPP loan application with the
false information in it.
With respect to Carolyn Wade, she signed two of these
PPP loan applications via DocuSign because her application had
to go to two different lenders. Same thing.
You will see that Ms. Wade signed one of those on the
Verizon wireless network and the other one was signed at home.
Each time she signed it was, the document she was signing with
the false information was visible on her screen, including all
the certifications.
Same was true for the forgiveness. That was also
signed per DocuSign. So when the forgiveness applications with
the false information for the defendants to sign, that was on
their screens.
You also have in this case records from the Internal
Revenue Service, the I.R.S. You will have the defendants' tax
returns for certain years. And with respect to Carolyn Wade,
you will see in her 2019 tax return that she actually had filed
with the I.R.S. a Schedule C, but it wasn't for the business
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named Carolyn Wade. And it didn't represent over $100,000 of
income. It was for a business named One Step Ahead, and it
reported in 2019 on a Schedule C approximately $6,800. That is
not the Schedule C that Carolyn Wade used for her PPP loan
application.
You will see in Tracy Wade's individual tax return that
he had no Schedule C in 2019 or any other year for which we
have the records for him, because there was no business named
Tracy Wade.
You're also going to see tax returns from Wade Funeral
Home, and those will show you that there was no employment
taxes filed with the I.R.S. for that business, and there was no
expenses and salaries claimed in those tax returns for the
years 2018 or '19 or '20.
Finally, you're going to see bank records in this case,
and the bank records are going to show you three things.
Number one, they will show you, again, there was no
income from a business in Carolyn or Tracy Wade of over
$100,000 from either one in 2019.
Number two, they're gong to show you that $1,000 Zelle
payment the defendants made to Haydee Rivero on the date that
they received their PPP loan. You will see the PPP loan coming
in, then you will see the $1,000 Zelle going out to Haydee
Rivero from Mr. Wade and from Carolyn Wade.
The bank records are also going to show you what the
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defendants did with the money, the PPP money when they received
it, how they spent it.
The Paycheck Protection Program was designed to protect
paychecks. The evidence will show that the defendants knew
this. The evidence will also show that they didn't have
paychecks to protect.
The evidence in these bank records will show you that
because they didn't have paychecks to protect, they wrote phony
salary checks. They made them up.
Carolyn Wade wrote ten -- you will see, ten --
approximately ten salary checks to herself and to her husband
with the memo salary in the -- with the word "salary" in the
memo.
And you will see checks that Tracy Wade wrote not from
Wade Funeral Home to any employees, but from his personal joint
account with Carolyn Wade writing to Wade Funeral Home with the
word "payroll" in the memo.
The only time you will see in the bank records the
defendants wrote checks like this was after they received their
PPP loans. You will not see checks like this before and after
those loans were forgiven in August 2021, there were no other
checks like this.
Members of the jury, after you have considered all of
the evidence in this case, you are going to be instructed by
the Court on the law and the elements that the Government has
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to prove beyond a reasonable doubt.
And at that time we are going to ask you to return the
only verdict that is consistent with the evidence in this case,
and that is a verdict of guilty for Tracy Wade and a verdict of
guilty for Carolyn Wade.
Thank you.
THE COURT: Thank you. Defense?
DEFENDANTS' OPENING STATEMENT
MR. McCRAY: Good afternoon.
About three months ago Mr. and Mrs. Wade were indicted,
and eight or nine charges were brought against them. At that
time Mr. Wade and Ms. Wade entered pleas of not guilty; and as
a direct result of that, we're here today. This is their day
in court.
We talked about the presumption of innocence. We
talked about the Government having the burn of proving. Now
we're going to talk about what the evidence in this case will
show and perhaps what it won't show.
The Government's pivotal witness in this case, ladies
and gentlemen, is a lady by the name of Haydee Rivero -- Rivero
formerly known as Haydee Granados. You're going to hear
evidence that Haydee Granados entered into a fraudulent
relationship with a young man by the name of Jamel Hunter.
You're going to hear that she knowingly applied for two
PPP loans knowing that they were fraudulent, and she's --
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you're going to hear her say that. I expect she's going to say
that, Well, I did so because $20,000 was not a lot of money,
and I didn't think anybody would catch me. This is what you're
going to hear. This is the person whom the Government wants
you to believe.
You're also going to hear, ladies and gentlemen, that
Haydee, although she wasn't an accountant, that she was fluent.
She learned the tricks of the trade -- she's going to tell you
this. She learned the tricks of the trade from an
individual -- and I have given you his flame already,
Mr. Hunter, told her how to apply for these loans.
You're going to hear that he taught her, he told her to
go onto Womply's website, download some Schedule Cs, and you've
got to put some numbers in. You've got to have at least
$100,000 in there so that the recipients, the applicants can
receive the money.
And Haydee's payment was contingent upon her producing.
And you're going to see from the evidence that she didn't care
about anybody else. She just wanted to get the loan at all
costs.
The pivotal issue in this case and the evidence is
going to show you is there's only one fraudulent document, and
it's a Schedule C. And for those of you who don't know, you'll
learn during the trial, but a Schedule C basically is a tax
form which it lists the profits and the losses of a business.
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There was a fraudulent Schedule C in this case. There was.
Undisputed.
But who prepared it? Who uploaded it? You're going to
hear that it came from IP address 179. Whose device or
computer was it? It was Haydee. She's going to tell you this.
She is going to tell you that I prepared it, but she also is
going to tell you, Oh, but they knew about it.
You're not going to see any confessions or any text
messages -- and by the way, she's going to tell you that, Oh,
Mr. Wade and I had conversations over the phone and there was
text messages.
You're going to hear again, and the judge has already
told you, that the burden of proof is not on us. It's on the
FBI and the Department of Justice.
You're going to see -- or you're not going to see where
the FBI ever subpoenaed any text messages from those 18 other
people whose applications were completed or filled out or
attempted by Haydee Granados Rivero.
You're going to hear, ladies and gentlemen, that she
never asked Mr. Wade or Mrs. Wade for any tax information. She
ended up getting the login information. She had their
passwords to their computers. She had access to this
information. And so you're going to see that she filed this.
There's no question about this.
The question in this case is whether or not the
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Government can prove beyond and to the exclusion of a
reasonable doubt that Mr. Wade and Ms. Wade knew what this lady
was doing. Well, let me tell you something, what the evidence
is going to show.
You're going to see an email that was sent from
Ms. Wade to Haydee Granados giving her the information, the
legal, truthful, lawful information of a business that she had.
She had a side business. You're going to hear that
this lady was a deputy for 22 years, and she did side work.
She didn't make a lot of money, but she tried to help herself
and help her family. What you're going to hear, ladies and
yes, that she gave her an email and she gave her a check which
had "void" on it. We're going to introduce this into evidence.
Telling her the corporation of what she's supposed to file the
PPP loan, but unbeknownst to Ms. Wade and Mr. Wade, Haydee
Granados went on a frolic of her own. And what does she do?
Unbeknownst to them, she put in those documents
Ms. Wade, Carolyn Wade, as though she's a business. There's no
such business. It's never been a business.
But what's interesting about this case, the evidence is
going to show that in 2019, Ms. Wade filed her taxes. She did
a Schedule C. In that Schedule C, she admitted that she only
made six or seven thousand dollars. She had filed this with
the I.R.S. The I.R.S. has never challenged that because it was
legal.
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So it's going to be up to you to believe whether or not
you think this woman who's a police officer of 22 years is now
going to sometime later file a fraudulent Schedule C when a
good one is on file. You're going to hear I.R.S. has all kinds
of equipment. They could easily -- if two people claim a
child, the I.R.S. is going to find out about it.
So the Government is going to want you believe that she
filed a legitimate when she did, but she's going to go back
during the pandemic and file a bogus one when she has a
legitimate one on file. She's told this lady file this under
One Step Ahead Beauty Salon.
Haydee Granados, you're going to hear her say she
didn't like doing these PPP loans under business names.
You're going to hear her say that that's not what she
learned from Jamel Hunter. But you're also going to hear,
ladies and gentlemen, that Mr. Wade gave her the information
regarding his business, Wade Funeral Home. Unbeknownst to
Mr. Wade, what does Tracy Grenada (as spoken), what does she
do? She turns around and she files it in his name. He doesn't
have a business called Tracy Wade Funeral Home.
Well, ladies and gentlemen, what else is interesting
about this case?
The Government is going to talk about it. You're going
to have people from the SBA. You're going to have people from
Womply. Oh, this was basically a program to help business that
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was struggling, which it was. But we had thieves out there.
We're now trying to recoup the money.
Ladies and gentlemen, Haydee Granada (as spoken) is an
admitted thief. There were at least 18 other individuals with
whom she did business, or tried to do business. And what does
the Government do for her? The evidence is going to show this.
They charge her with one count, one count of conspiracy. But
these people who applied for a loan without the knowledge of
what this lady was doing, they got ten counts against them, but
they give their witness a sweetheart deal. The evidence is
going to show this. The evidence is going to show that
probably a month ago she went up, she raised her hand, Okay, I
lied.
She's charged with one count of conspiracy. Not 18
counts times the number of individual counts against those
individuals or regarding those individuals who she defrauded.
And you're not going to hear one shred of evidence from
the Government that they ever subpoenaed the phone records or
the business records of those other 18 people to see if Haydee
was telling them the full truth about those people. It's their
burden of proof, ladies and gentlemen.
You're going to hear, ladies and gentlemen, that Haydee
Rivero, all she wanted was money. You're going to hear that
her husband, Eduardo, was really the strong arm. You're going
to hear that Eduardo, although he wasn't actually doing the
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loans, they were out submitting business initially for Jamel
Hunter, and that's how the Wades applied for the PPP loans,
because they simply came and said, Listen, we just got two
loans, man, this guy, Jamel Hunter. At least that's what
they're going to say. That's what you're going to hear her
say.
But I'm going to tell you now that Mr. Wade is going to
take the stand and Wade is going to say that he never was told
anything about a Jamel Hunter doing PPP loans. That the only
thing that he was told was that Haydee, my wife, can do a loan
because, I guess they figured, the evidence will show that,
they could make mope because Jamel was making money. And
Mr. Wade trusted these people, because he knew -- he knew
Eduardo, the husband. He only knew Mrs. Granados Rivero
because of Eduardo.
You're going to hear her say that they -- Carolyn
didn't really know them and they didn't really know Carolyn.
They had a party at their home one time that Carolyn was there
because of her daughter, Carolyn brought her daughter. But she
had no involvement with these people. She didn't really know
these people.
Mr. Wade, you're going to hear him testimony that I
trusted them. They came and told me that they had gotten money
legitimately, and that's what I believed. All they wanted was
his passcode. They end up giving his -- the password to his
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computer and some other information. And as a result, later
on, a fake C -- Schedule C was prepared.
And you're going to hear the evidence. You're going to
hear that Mr. Wade found out about a fake Schedule C after his
wife's arrest. After his wife's arrest, that's the first time
when Mr. Wade ever heard that.
And ladies and gentlemen, you're going to hear us,
counsel has said, Oh, you're going to see activity on
computers. That still does not address the question of whether
or not Mr. and Mrs. Wade knew that Haydee Granada was a crook,
an admitted crook. She was a thief.
Ladies and gentlemen, in this particular case -- and
I've said it already -- conspiracy -- there are two counts of
conspiracy in this case, an agreement to do something unlawful.
There was no agreement to do anything unlawful. There was an
agreement for Ms. Haydee Rivero, Ms. Rivero to file PPP loans,
not to file a fake Schedule C.
There was never an agreement for -- and evidence is
going to show this -- that the Wades ever authorized them or
knew they were putting down fictitious business names. Well,
there are no fictitious business names when these people are
law enforcement officers and knew that something like that
could easily be determined or found out by the authorities.
Ladies and gentlemen, the Wades have entered a plea to
each of those counts, and I have them written out. I can't
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find them, but the Judge is going to go over each of those
counts with you, and I just wrote something out as to what the
evidence is going to show. It's very short, and then I'm going
to be seated.
And summarized as the way I see it. Eduardo Rivero
told Tracy Wade to create the account. The evidence is going
to show this, the Womply account. And give him -- being
Eduardo -- the username and password.
There was absolutely nothing fraudulent about Tracy and
Carolyn Wade creating an account and seeking a PPP loan. The
evidence is going to show that.
The sole fraudulent act in this case was the creation
of a fake Schedule C document and uploaded -- the uploading of
that fake Schedule C documents. Haydee Rivero, ladies and
gentlemen, has confessed to the FBI that she did both.
The only question is whether the defendants knew. Now,
what you're going to hear, I expect, from that witness stand,
is that Haydee Rivero doesn't want to go to prison. Haydee
Rivero doesn't want to have to pay back all this money that
she's made and that she's stolen.
What you're going to hear is that Haydee Rivero has to
testify in a fashion that pleases the Government. Because when
you look at this plea agreement -- and I expect you're going to
see a copy of it -- this contract that the Government has
entered into with Ms. Haydee Granada is that they -- the
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Government -- are the sole determiners of whether she's telling
the truth.
If they don't like the way she testifies, perhaps she's
going to prison. She may not with one count against her. You
never know.
But ladies and gentlemen, I expect that you're going to
receive an instruction from the jury (as spoken) that talks
about a person who is testifying under a plea agreement. You
must cautiously -- or you should cautiously scrutinize their
testimony.
So, ladies and gentlemen, jury duty is so important
because it affords the ordinary citizen the opportunity to come
in and serve as judges: Judges of the facts.
The constitution talks about a jury of your peers in a
cross-section of the community. Ladies and gentlemen, you are
that. We're asking you to listen to this evidence. You, as
the trier of fact, make that decision whether or not the
Government has excluded each and every reasonable doubt in this
case, and the Court is going to at the appropriate time read to
you the instruction on reasonable doubt.
Ladies and gentlemen, I thank you very much for your
attention in this case.
Thank you.
THE COURT: Thank you for your opening statements,
counsel.
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Ladies and gentlemen, we have just been advised that
the Dade County Public Schools will be closed on Wednesday,
which means that we are not in session on Wednesday. We will
be in session Tuesday and Thursday, hopefully, and back next
Tuesday, so you may plan accordingly.
Remember my instructions not to discuss the case in any
way, and I'll probably remind you at the end of each day not to
discuss the case, opening statements or otherwise, with anyone.
Thank you very much for your attention. We are in
recess up until 9:30 tomorrow morning. Now, for those of you
who don't travel in the downtown area that much, there's a lot
of traffic. So please plan to arrive 15 to 20 minutes early.
Say, like, around 9:10. We'll have coffee other light
refreshments for you. Tea and that sort of thing, I think.
Years ago they cut out the donuts and all of that, so as to
liquid beverages. And again, thank you for your attention, and
we look forward to seeing you tomorrow morning sharp at 9:30.
Have a great evening.
COURTROOM DEPUTY: All rise for the jury.
(Jury exited courtroom at 4:07 p.m. )
THE COURT: Be seated, please. So counsel, as you are
aware, our starting time is at 9:30.
MR. WILCOX: Yes.
THE COURT: So if you have an issue that needs to be
addressed, you need to let your opposing counsel know, and you
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need to be here about 9:10 or 9:15 so I can address the issue.
Because when we say we start at 9:30, that means the jury
should be walking through the door at 9:30. Not addressing
matters. I would like for you to raise those matters at the
end of the day so that we don't have to do it the following
morning. But if something occurs overnight, then let your
opposing counsel know and get here 10 or 15 minutes early so
that we can address those issues and be ready to start
promptly.
Are there any additional matters that we should
entertain?
MR. SNIDER: Yes, Your Honor. I just wanted some
clarity on the record here that the Court has received into
evidence all of the exhibits on the Government's list with the
exception of 165 to 171, which is --
THE COURT: Let us be very precise and clear.
MR. SNIDER: Okay.
THE COURT: So why don't you tell me -- I'm looking at
your exhibits list, Docket Entry 159.
MR. SNIDER: Yes.
THE COURT: And tell me what exhibits have been
received. And if you can, you could say page 1001 through 105
received and so on and so forth --
MR. SNIDER: Okay.
THE COURT: -- so that we are all clear.
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MR. SNIDER: So on page 2 of Docket Entry 159, the
Government's exhibit list.
THE COURT: How about page 1 first?
MR. SNIDER: Page 1 is a cover sheet.
THE COURT: Well, page 1 is one and page -- at least
mine has no number at the bottom of one and then it starts with
2.
MR. SNIDER: I'm looking at the ECF header, page 2 of
11, Docket Entry 159 at the top.
THE COURT: All right. Well, I'm a little unclear
because page 2 has page 3 of 11 at the top. So when I say
until --
MR. SNIDER: I think I can -- I'll clear this up.
THE COURT: Okay.
MR. SNIDER: On page -- on the first page of
Government's Exhibit list, which is -- the first page is page 2
of 11 on Docket Entry 159. I'm on Exhibits 100 through 105,
which include 102.1, 102.1E, 102.2, and 102.2E.
THE COURT: So let's look at the first page of the
exhibits themselves with 001 down to 105.
MR. SNIDER: Correct.
THE COURT: All right. Received. Those are offered?
MR. SNIDER: Offered.
THE COURT: Received without objection.
(Government's Exhibits 1 through 105, documents, were
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received into evidence.)
MR. SNIDER: Thank you.
THE COURT: Let's go to page 2.
MR. SNIDER: Page 2 of Government's Exhibit list,
Docket Entry 159, Government is offering Government's
Exhibit 106 through 117.1.
THE COURT: Received without objection.
(Government's Exhibits 106 through 117.1, documents,
received into evidence.)
MR. SNIDER: I'm now on page 3 of the Government's
exhibit list, Docket Entry 159, the Government is offering
Exhibits 118 through 132.
THE COURT: Received without objection.
(Government's Exhibits 118 through 132, documents,
received into evidence.)
MR. SNIDER: I'm now page 4 of the Government's witness
exhibit list filed with Docket Entry 159. The Government is
offering 133 through 148.
THE COURT: Received without objection.
(Government's Exhibits 133 through 148, documents,
received into evidence.)
MR. SNIDER: I'm now on page 5 of the Government's
Exhibit list, Docket Entry 159, the Government is offering
Exhibits 149 through 159.1.
THE COURT: Received without objection.
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(Government's Exhibits 149 through 159.1, documents,
received into evidence.)
MR. SNIDER: Now, on page 6 of Government's exhibit
list filed with Docket Entry 159, offering Government's
Exhibits 160 through 164E.
THE COURT: Received without objection.
(Government's Exhibits 160 through 164E, documents,
received into evidence.)
MR. SNIDER: Now, on page 7 of the Government's exhibit
list, Docket Entry 159.
THE COURT: Well, how about 200 to 202?
MR. SNIDER: I didn't see those, thank you.
So I'm offering Government's Exhibits 200, 201 and 202
on that page.
THE COURT: Received without objection.
(Government's Exhibits 200 through 202, documents,
received into evidence.)
MR. SNIDER: I'm now on page 7, offering Government's
Exhibits 203 through 307.
THE COURT: 203 to 307, received without objection.
(Government's Exhibits 203 through 307, documents,
received into evidence.)
MR. SNIDER: Now, on page 8 of the Government's exhibit
list, Docket Entry 159, offering Government's Exhibit 300
through 408E.
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THE COURT: Received without objection.
(Government's Exhibits 300 through 408E, documents,
received into evidence.)
MR. SNIDER: I'm now on page 9 of the Government's
exhibit list, Docket Entry 159, offering Government Exhibits
804 through 808E.
THE COURT: Received without objection.
(Government's Exhibits 804 through 808E, documents,
received into evidence.)
MR. SNIDER: I will note for the record that Government
Exhibits 900 through 907 are the -- is the evidence that the
Government set forth in its 404(b) notice, and the Court has
deferred ruling on the admissibility of those exhibits.
THE COURT: All right.
MR. SNIDER: I'm now on page ten of the Government's
exhibit list, Docket Entry 159, the -- at this time I'm going
to offer Government Exhibits 2000, 2001 and 2002. The summary
will wait until --
THE COURT: So 2000, 2001 and 2002?
MR. SNIDER: Correct.
THE COURT: All right.
MR. SNIDER: The summary we will wait until the
summary's prepared as we did in the last trial.
THE COURT: All right. Received that without
objection.
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MR. SNIDER: Thank you.
(Government's Exhibits 2000 through 2002, documents,
received into evidence.)
THE COURT: So when you get to your 1000.1, you can
show it to opposing counsel, and you can let me know your final
decision.
MR. SNIDER: Okay. Your Honor, I wanted to just
briefly be heard. I know the Court made a ruling before the
jury came in in the afternoon session on Government Exhibits
165 through 171. Here's my point, Judge.
I understand that -- that the loan relating -- the PPP
loan application relating to Wade Funeral Home, that loan
number was not set out in Count I, but neither was any other
loan in Count I.
What Count I alleges is that --
THE COURT: Other loans are referenced in the
indictment.
MR. SNIDER: Yes, in substantive counts, and I do --
THE COURT: All right. Substantive or otherwise, they
are in the indictment.
MR. SNIDER: Correct.
THE COURT: Your notice refers to 404(b). And the
common sense misunderstanding is this relates to 404(b), so
that's why I did not receive it.
MR. SNIDER: Well, I think either -- but the Government
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wasn't offering it as 404(b), but if the Court is treating it
as 404(b), then it was properly noticed, and the Government
should be allowed to offer it as 404(b).
THE COURT: I understand your argument, sir.
MR. SNIDER: I guess there's --
THE COURT: I've ruled.
MR. SNIDER: So that's not coming in and I can't --
THE COURT: Wait until I rule on the 404(b) issue.
That's when it becomes relevant.
MR. SNIDER: Okay, I see. So the Court -- okay. So I
understand now. The Court is treating Government Exhibits 165
through 171 as 404(b).
THE COURT: Yes, sir, as you caption in your notice to
the defense, so I have to rule on all 404(b) issues at the time
that we have discussed.
MR. SNIDER: Okay. All right. Very well.
THE COURT: All right.
MR. SNIDER: Yeah. I will just say the two witnesses
that would testify to those records, you have one set relating
to EIDL, which we addressed previously. That way this is
coming in from Denver, Colorado. And the witness that would
testify about the records in Government's Exhibits 165 through
171, which is the PPP application for Wade Funeral Home, that
witness is coming in from Texas.
We're not in court on Wednesday now. I guess the
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Government has no choice but to fly them in and then await the
Court's ruling.
THE COURT: Well, that's your decision. I don't have
anything to do with that.
MR. SNIDER: Okay, Judge, thank you.
THE COURT: We now have learned that we're out on
Wednesday, so we all have the schedule; and we lost a day. So
we'll make it up if we have to the following week, but,
hopefully, not. We shall see.
MR. SNIDER: Obviously, the Government's schedule in
its case in chief now is affected, and it's not clear that
we're going to be able to finish.
THE COURT: Well, of course. Of course. None of us
knew this was going to happen and -- so I'm not going to tell
you you have to shorten your time period for this instance of
us being out on Wednesday. We will just handle it as we best
can.
Yes, sir.
MR. WILCOX: Yes, Your Honor. One other thing. And I
don't suggest that Mr. Snider did not forward this when he said
he forwarded it.
But the grand jury's testimony of FBI Agent
Dipietrantonio -- we don't have it. At least I don't have it.
I can't retrieve it. I checked my emails. So I'll ask if we
can get that, that could be sent. Apparently, it gets encoded.
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I could probably figure out how to get into the encryption.
THE COURT: I'm not sure what that means. I'm not all
that technically savvy, Judge.
MR. WILCOX: I just need the transcript of the grand
jury testimony.
THE COURT: Oh, well, I don't know how to respond to
that because that was the Jencks Act that controls.
MR. WILCOX: Yes.
THE COURT: But what I do do if it's not produced in a
timely fashion, then I just continue the trial and say, "Put
the witness on direct and then cross, and then we'll come back
the next day." So he knows the Jencks Act. You know the
Jencks Act. And hopefully, you all will cooperate and get it
revealed timely.
MR. SNIDER: Your Honor, I just have to say this for
the record. The United States produced the transcript
Dipietrantonio's grand jury testimony on September 5th, 2024,
by email. That email was encrypted because the grand jury
testimony contains personal identifiable information. It has
to be encrypted or will not leave the DOJ server.
And I spoke with members of the defense team earlier
today when they told me that they weren't able to -- or they
don't have a copy of it, and I said I would print it. So I'm
not sure why they're raising it with the Court. I've complied
with the Jencks Act. I told them I would print them another
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company.
THE COURT: Thank you. Have a good day, everyone. We
will see you tomorrow morning not later than 9:30. You are
excused.
COURTROOM DEPUTY: All rise.
(Proceedings adjourned at 4:20 p.m. )
C E R T I F I C A T E
I hereby certify that the foregoing is an
accurate transcription of the proceedings in the
above-entitled matter reported by Glenda Powers and
transcribed by Patricia Bailey-Entin using Glenda Power's
stenographic notes.
DATE: 5/27/2025
/s/Patricia Bailey-Entin
PATRICIA BAILEY-ENTIN, RPR, FRP
Official Court Reporter
United States District Court
Southern District of Florida
James L. King Federal Justice Building
99 NE 4th Street
Miami, Florida 33132
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$
$1,000 [7] - 138:7,
138:8, 138:11,
140:5, 140:6,
147:20, 147:23
$10,000 [1] - 58:9
$100,000 [9] - 134:19,
134:24, 135:5,
135:10, 135:14,
145:21, 147:1,
147:19, 150:15
$112,430 [1] - 134:15
$2,000 [1] - 140:6
$20,000 [3] - 115:3,
150:2
$20,833 [5] - 113:7,
131:18, 132:21,
134:10, 135:3
$28,000 [1] - 113:5
$41,666 [1] - 131:20
$6,800 [1] - 147:3
$700,000 [6] - 113:9,
113:14, 116:16,
116:18, 116:24,
117:5
$701 [1] - 115:21
'
'19 [1] - 147:14
'20 [1] - 147:14
/
/s/Patricia [1] - 169:14
0
001 [1] - 161:20
0:23-cr-60173-KMW
[1] - 1:2
1
1 [18] - 1:7, 1:8, 5:20,
7:14, 99:10, 100:17,
100:19, 101:12,
101:17, 101:18,
108:24, 122:5,
122:7, 161:3, 161:4,
161:5, 161:25
10 [11] - 6:20, 6:22,
36:19, 36:20, 87:25,
104:7, 109:8,
122:10, 122:11,
122:12, 160:7
100 [2] - 67:24, 161:17
100,000 [2] - 132:24
1000.1 [1] - 165:4
1001 [1] - 160:22
102.1 [1] - 161:18
102.1E [1] - 161:18
102.2 [1] - 161:18
102.2E [1] - 161:18
105 [4] - 160:22,
161:17, 161:20,
161:25
106 [2] - 162:6, 162:8
10:00 [1] - 17:21
11 [7] - 7:12, 95:23,
102:13, 109:9,
161:9, 161:11,
161:17
11-20s [1] - 56:15
117.1 [2] - 162:6,
162:8
118 [2] - 162:12,
162:14
11:17 [2] - 54:5, 54:6
11:36 [2] - 54:6, 54:7
11th [1] - 10:19
12 [4] - 11:10, 60:15,
102:15, 109:10
12:28 [1] - 86:3
12:29 [1] - 86:7
12:35 [1] - 86:4
12th [4] - 40:7, 61:12,
61:18, 104:16
13 [5] - 60:15, 89:18,
100:25, 101:1, 101:3
132 [2] - 162:12,
162:14
133 [2] - 162:18,
162:20
13th [1] - 10:25
14 [3] - 51:11, 92:4,
101:8
148 [2] - 162:18,
162:20
149 [2] - 162:24, 163:1
15 [4] - 107:22,
107:24, 159:12,
160:7
159 [13] - 160:19,
161:1, 161:9,
161:17, 162:5,
162:11, 162:17,
162:23, 163:4,
163:10, 163:24,
164:5, 164:16
159.1 [2] - 162:24,
163:1
15th [7] - 39:7, 56:5,
56:14, 56:15, 56:17,
70:1, 108:10
16 [8] - 95:22, 99:10,
99:16, 99:25,
100:17, 100:19,
107:12
160 [2] - 163:5, 163:7
164E [2] - 163:5, 163:7
165 [8] - 112:3, 112:4,
112:6, 117:15,
160:15, 165:10,
166:11, 166:22
17 [3] - 101:19,
101:22, 102:8
171 [7] - 112:5, 112:6,
117:15, 160:15,
165:10, 166:12,
166:23
179 [1] - 151:4
18 [7] - 92:19, 139:19,
139:24, 151:16,
154:4, 154:14,
154:19
18th [8] - 1:20, 51:14,
51:20, 59:22, 60:1,
92:3, 92:9, 94:16
19 [5] - 72:8, 101:23,
101:24, 131:2, 131:8
1:00 [1] - 62:10
1:30 [1] - 109:19
1:32 [1] - 109:24
1:33 [1] - 110:11
1:35 [1] - 111:13
2
2 [17] - 8:13, 8:16,
52:25, 100:20,
100:21, 105:13,
108:25, 115:3,
122:7, 129:19,
161:1, 161:7, 161:8,
161:11, 161:16,
162:3, 162:4
20 [7] - 53:6, 69:10,
86:2, 102:9, 102:10,
129:10, 159:12
200 [3] - 163:11,
163:13, 163:16
2000 [3] - 164:17,
164:19, 165:2
2001 [2] - 164:17,
164:19
2002 [3] - 164:17,
164:19, 165:2
201 [1] - 163:13
2018 [1] - 147:14
2019 [9] - 134:15,
134:19, 135:6,
135:10, 146:24,
147:3, 147:7,
147:19, 152:21
202 [3] - 163:11,
163:13, 163:16
2020 [3] - 115:14,
115:18, 137:16
2021 [13] - 115:5,
115:23, 115:24,
131:7, 131:15,
135:16, 137:10,
137:19, 139:12,
139:13, 143:6,
143:9, 148:21
2024 [2] - 1:5, 168:17
203 [3] - 163:19,
163:20, 163:21
21 [1] - 108:5
22 [5] - 101:20,
101:21, 152:9, 153:2
23 [1] - 82:19
23,833 [1] - 132:25
24 [1] - 112:23
24th [5] - 54:21, 54:22,
56:25, 57:2, 87:10
25 [4] - 59:5, 70:11,
86:2, 93:12
26 [1] - 32:5
26th [1] - 115:23
27 [1] - 82:16
28 [4] - 71:3, 93:22,
139:10, 139:13
29 [2] - 57:12, 102:2
2:25 [2] - 111:8,
111:13
2:30 [2] - 110:3, 110:9
2:33 [1] - 111:16
2:45 [1] - 118:3
3
3 [6] - 87:3, 109:1,
115:4, 122:7,
161:11, 162:10
3.3 [1] - 115:15
30 [7] - 59:15, 101:19,
101:22, 101:25,
102:8, 107:16,
129:10
300 [2] - 163:24, 164:2
307 [3] - 163:19,
163:20, 163:21
31 [4] - 102:14,
102:18, 102:21,
102:25
32 [2] - 103:1, 103:6
33 [3] - 83:9, 103:7,
103:10
33060 [1] - 1:19
33132 [2] - 2:5, 169:18
33317 [1] - 1:21
33394 [1] - 1:17
34 [3] - 103:12,
103:16, 103:17
35 [7] - 102:17,
103:19, 103:23,
104:3, 104:15,
170
114:23
36 [3] - 104:20,
104:21, 104:23
37 [2] - 59:21, 94:17
38 [2] - 61:24, 97:12
39 [3] - 45:1, 61:10,
94:24
3:00 [8] - 10:6, 51:15,
51:20, 53:2, 53:8,
55:17, 92:3, 92:10
3:30 [1] - 53:2
3:55 [1] - 86:25
4
4 [6] - 6:11, 52:1, 67:8,
87:8, 109:2, 162:16
40 [5] - 12:15, 63:6,
65:20, 75:22, 106:9
400 [1] - 1:18
404(b [23] - 6:25, 7:1,
7:4, 7:12, 7:17,
111:5, 114:5, 114:6,
114:7, 114:11,
114:15, 114:18,
115:24, 116:2,
116:3, 116:20,
117:13, 164:12,
165:23, 166:1,
166:2, 166:8, 166:14
404(B [1] - 110:24
404(b) [8] - 114:12,
114:19, 116:22,
116:25, 117:11,
165:22, 166:3,
166:12
408E [2] - 163:25,
164:2
42 [4] - 60:9, 68:22,
69:22, 69:23
43 [4] - 105:19,
105:20, 105:22,
106:21
44 [2] - 65:19, 105:21
45 [3] - 30:24, 102:14,
115:14
46 [3] - 91:17, 91:24,
92:1
47 [3] - 94:14, 94:20,
94:23
48 [3] - 97:23, 105:4,
105:7
4:00 [4] - 10:5, 12:6,
53:11, 110:6
4:07 [1] - 159:20
4:15 [1] - 53:11
4:20 [2] - 1:6, 169:6
4:30 [4] - 53:11, 54:15,
54:16, 86:24
4th [2] - 2:4, 169:17
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5
5 [3] - 6:12, 109:3,
162:22
5/27/2025 [1] - 169:14
50 [1] - 41:6
50.1 [1] - 41:6
50/50 [1] - 30:14
500 [1] - 1:16
5201 [1] - 1:20
5:00 [1] - 53:14
5th [2] - 109:17,
168:17
6
6 [5] - 6:19, 56:24,
99:13, 109:4, 163:3
60 [1] - 133:15
6781674 [2] - 112:24,
115:6
6:00 [1] - 55:20
6th [2] - 115:5, 115:24
7
7 [7] - 1:5, 6:19,
100:15, 100:16,
109:5, 163:9, 163:18
7th [8] - 1:16, 10:25,
12:17, 14:22, 14:24,
15:19, 16:5, 109:17
8
8 [4] - 4:3, 6:19, 109:6,
163:23
804 [2] - 164:6, 164:8
808E [2] - 164:6, 164:8
873 [1] - 115:21
8:30 [3] - 59:6, 59:8,
93:14
8th [1] - 55:6
9
9 [11] - 4:2, 4:6, 4:18,
6:19, 36:9, 87:13,
90:18, 91:25, 104:6,
109:7, 164:4
900 [1] - 164:11
907 [1] - 164:11
941 [1] - 115:17
95-year-old [1] - 60:17
99 [3] - 2:4, 67:23,
169:17
9:00 [2] - 14:14, 15:3
9:10 [2] - 159:13,
160:1
9:15 [1] - 160:1
9:30 [6] - 159:10,
159:17, 159:22,
160:2, 160:3, 169:3
9:35 [1] - 1:6
A
a.m [6] - 17:21, 54:5,
54:6, 54:7, 59:6
Abigail [2] - 35:15,
55:4
ability [14] - 31:23,
32:20, 50:4, 66:11,
70:7, 75:13, 75:16,
78:23, 81:1, 81:23,
82:12, 83:21, 89:20,
92:22
able [19] - 47:17,
51:21, 57:16, 63:3,
63:13, 63:20, 64:13,
65:24, 67:22, 71:6,
81:20, 85:3, 85:6,
85:15, 102:5,
142:18, 143:21,
167:12, 168:22
above-entitled [1] -
169:11
abroad [1] - 52:4
absolute [1] - 76:3
absolutely [3] - 33:6,
33:22, 157:9
accept [5] - 46:6,
104:22, 104:24,
105:16, 123:10
access [4] - 5:16,
138:21, 142:24,
151:22
accessing [1] - 142:17
accident [1] - 40:3
accommodate [1] -
62:6
according [3] - 13:23,
13:25, 118:10
accordingly [3] -
18:22, 19:19, 159:5
account [6] - 131:21,
142:7, 148:16,
157:6, 157:7, 157:10
accountant [3] -
88:23, 137:13, 150:7
accounting [4] - 35:1,
56:12, 89:6, 137:14
accurate [3] - 26:6,
133:21, 169:10
accusations [1] -
123:23
accused [3] - 45:9,
73:10, 76:3
Act [4] - 168:7,
168:12, 168:13,
168:25
act [6] - 18:22, 21:2,
64:6, 64:10, 117:4,
157:12
activity [7] - 127:4,
142:1, 142:13,
143:10, 143:22,
156:8
actual [3] - 67:25,
119:19, 128:3
Adam [2] - 1:14, 23:25
addition [5] - 23:7,
108:6, 136:12,
136:23, 139:17
additional [12] - 5:3,
32:2, 86:13, 95:18,
100:11, 101:14,
101:22, 110:12,
130:13, 130:16,
135:18, 160:10
address [20] - 4:1, 8:4,
19:18, 52:20,
110:13, 112:2,
117:6, 142:13,
142:17, 142:20,
143:5, 143:7,
143:16, 145:16,
146:1, 146:3, 151:4,
156:9, 160:1, 160:8
addressed [3] - 89:12,
159:25, 166:20
addresses [4] - 143:1,
143:3, 143:8, 143:11
addressing [3] - 3:18,
6:24, 160:3
adjourned [1] - 169:6
administer [1] - 133:3
Administration [4] -
22:4, 24:14, 25:11,
135:25
administrative [1] -
137:17
admissibility [1] -
164:13
admissible [1] - 114:8
admitted [3] - 152:22,
154:4, 156:11
Adrian [1] - 57:12
advance [2] - 15:16,
16:8
advise [3] - 8:23,
14:19, 38:3
advised [3] - 10:23,
19:19, 159:1
advisor [1] - 82:25
affect [17] - 31:23,
66:11, 67:5, 68:9,
68:24, 70:7, 75:13,
75:15, 75:20, 78:23,
81:1, 81:23, 82:11,
83:2, 83:21, 84:16,
84:20
affected [3] - 60:24,
167:11
affiliated [1] - 107:19
affirm [1] - 18:2
affords [1] - 158:12
African [7] - 99:24,
100:1, 105:23,
106:5, 107:9,
107:11, 107:17
afternoon [8] - 13:17,
20:20, 90:10,
109:22, 124:21,
130:24, 149:9, 165:9
afterwards [2] - 52:19,
144:8
agencies [4] - 66:23,
67:4, 69:4, 97:9
agency [6] - 66:25,
67:12, 81:20, 95:25,
97:8, 121:20
AGENT [1] - 24:4
Agent [1] - 167:22
agent [2] - 24:5, 67:10
agents [1] - 77:16
ago [5] - 69:9, 83:12,
149:10, 154:12,
159:15
agree [10] - 22:18,
74:12, 82:5, 86:12,
89:15, 89:16, 93:25,
118:21, 119:7,
121:25
agreed [3] - 121:15,
121:24, 137:3
agreeing [1] - 89:2
agreement [17] - 21:1,
21:6, 21:11, 21:15,
21:25, 136:3, 136:5,
140:19, 140:20,
140:22, 156:14,
156:15, 156:16,
156:18, 157:23,
158:8
agreements [1] -
122:4
Ahead [2] - 147:2,
153:11
ahead [5] - 27:14,
35:14, 63:24, 90:16,
94:10
air [2] - 131:19, 140:10
airport [4] - 52:7,
60:11, 60:25, 95:12
Alachua [2] - 43:21,
74:22
Alejo [3] - 30:5, 30:24,
31:5
Alexander [1] - 25:8
171
allegations [3] -
45:14, 64:15, 64:16
allege [2] - 21:14,
113:16
alleged [5] - 21:4,
21:10, 115:1,
135:22, 136:25
allegedly [1] - 116:17
alleges [10] - 21:5,
21:14, 21:18, 21:19,
21:25, 22:3, 22:8,
112:15, 136:13,
165:15
alleging [2] - 113:2,
113:17
allow [4] - 6:7, 6:15,
23:15, 70:6
allowed [2] - 7:4,
166:3
allows [2] - 20:10,
104:13
alone [6] - 4:12, 58:13,
87:24, 118:18,
118:24, 141:12
already.. [1] - 68:11
Alternate [1] - 105:13
alternate [6] - 91:14,
94:18, 102:7,
104:19, 104:25,
108:10
alternates [1] - 104:18
alternative [2] - 91:12,
91:19
Althea [2] - 7:14,
24:13
AM [1] - 1:6
Aman [1] - 24:16
AMERICA [1] - 1:4
America [3] - 23:21,
27:13, 76:16
American [2] - 99:24,
107:11
amount [9] - 32:23,
33:21, 34:8, 113:7,
122:3, 125:13,
131:18, 132:8,
132:16
amounts [3] - 71:12,
78:20, 78:21
Analytics [2] - 24:17,
28:8
Andreotti [1] - 109:2
annotation [1] - 4:14
announce [3] -
108:12, 119:10,
128:22
announcement [1] -
3:11
answer [9] - 18:2,
42:5, 63:14, 96:6,
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120:6, 120:9,
120:14, 120:21,
120:24
answered [1] - 30:1
answering [1] - 100:8
answers [2] - 5:15,
78:20
anticipate [3] - 12:19,
13:5, 125:22
anticipated [1] - 11:17
apologies [1] - 80:10
apologize [1] - 35:23
appear [2] - 6:24,
112:7
APPEARANCES [1] -
1:12
applicable [3] - 8:7,
8:8, 9:23
applicant [1] - 145:10
applicants [1] -
150:15
application [44] -
28:25, 112:9,
112:25, 113:8,
115:4, 115:5, 115:6,
115:9, 115:10,
115:12, 115:13,
115:16, 115:20,
115:22, 133:13,
133:21, 134:12,
134:20, 134:22,
135:4, 135:11,
135:12, 136:19,
138:21, 138:25,
139:1, 139:4, 141:4,
141:16, 142:6,
144:4, 144:18,
144:23, 145:12,
145:17, 145:23,
145:25, 146:4,
146:7, 146:10,
147:5, 165:12,
166:23
applications [29] -
72:21, 112:21,
114:24, 134:3,
135:17, 136:18,
138:1, 138:5,
138:18, 139:19,
139:23, 139:24,
141:15, 142:2,
143:2, 143:10,
143:14, 143:23,
144:7, 144:10,
144:25, 145:5,
145:14, 145:19,
145:20, 146:10,
146:18, 151:17
applied [19] - 28:21,
35:2, 35:4, 64:9,
70:14, 70:18, 72:4,
72:21, 78:11, 78:12,
78:14, 131:15,
132:16, 135:16,
141:20, 141:25,
149:24, 154:8, 155:2
applies [1] - 79:22
apply [9] - 28:20, 71:9,
118:19, 132:15,
133:6, 133:14,
133:17, 134:8,
150:11
applying [4] - 64:11,
70:22, 78:15, 132:10
appointment [10] -
53:1, 53:4, 53:20,
59:6, 59:9, 59:19,
86:23, 86:24, 93:10,
93:14
appointments [3] -
20:1, 53:12, 56:18
appreciate [5] - 3:22,
16:18, 29:3, 69:21,
122:4
approach [2] - 34:1,
116:7
appropriate [6] - 7:22,
8:13, 28:3, 106:11,
132:19, 158:19
approve [1] - 133:9
approved [1] - 115:23
April [2] - 39:7, 70:1
Aragon [3] - 52:25,
86:22, 100:21
area [12] - 5:12, 5:14,
10:7, 31:12, 34:22,
36:10, 38:20, 39:22,
43:7, 51:25, 108:17,
159:11
argument [4] - 129:6,
129:10, 166:4
arguments [6] - 45:17,
119:24, 124:25,
129:2, 129:4, 129:13
arises [1] - 58:1
arm [2] - 118:9, 154:24
Armando [1] - 81:12
Army [4] - 57:14,
57:18, 58:3, 58:6
arrest [3] - 83:15,
156:5
arrests [1] - 83:4
arrive [1] - 159:12
arrived [3] - 11:16,
43:23
arriving [1] - 11:17
art [2] - 58:15, 93:23
article [1] - 125:23
articulated [2] - 99:15,
100:6
artist [1] - 58:7
Arvesu [1] - 57:12
aside [3] - 33:3, 63:21,
65:24
assertion [1] - 122:22
assigned [2] - 115:5,
143:16
assist [1] - 73:2
Assistant [2] - 23:19,
24:2
assistant [2] - 32:11,
73:12
assisted [2] - 28:25,
71:7
assisting [3] - 23:6,
38:2
Association [1] - 28:8
assumed [1] - 116:24
assuming [1] - 70:2
AT&T [3] - 25:2, 25:3,
28:10
Atlantic [1] - 1:18
attainment [1] - 21:6
attempt [3] - 116:17,
117:4
attempted [1] - 151:18
attempts [1] - 126:4
attend [4] - 36:3,
36:10, 51:13, 57:17
attention [8] - 56:21,
58:1, 114:5, 126:5,
127:5, 158:22,
159:9, 159:16
attorney [12] - 15:7,
15:10, 26:8, 26:9,
27:4, 27:5, 32:8,
66:7, 69:8, 92:25,
125:4, 128:22
Attorney [4] - 23:19,
24:3, 26:9, 26:10
Attorney's [12] - 1:15,
23:20, 24:1, 26:19,
27:3, 27:19, 32:19,
32:22, 33:5, 33:15,
37:23, 38:13
Attorneys [2] - 32:11,
77:14
attorneys [11] - 16:7,
26:21, 28:13, 37:23,
38:14, 38:15, 62:13,
85:11, 125:2, 141:7,
141:9
attributable [3] -
143:3, 143:4, 143:12
August [3] - 131:15,
139:12, 148:21
Aulicino [3] - 108:25,
129:19, 129:20
Aulincino [1] - 129:21
authorities [1] -
156:23
authority [1] - 19:14
authorized [1] -
156:19
auto [1] - 138:22
available [2] - 126:6,
127:6
Avenue [1] - 40:7
Aviation [1] - 60:9
avoid [1] - 124:17
await [1] - 167:1
awaiting [1] - 102:3
aware [6] - 5:12,
10:10, 12:12, 20:18,
59:19, 159:22
awhile [1] - 61:25
B
Babitz [6] - 32:4,
58:23, 59:2, 77:13,
93:20, 93:21
back-striking [1] -
86:19
background [3] -
115:24, 121:25,
137:14
backup [2] - 56:4,
88:17
bad [3] - 11:22, 29:19,
80:9
Bailey [2] - 169:11,
169:14
BAILEY [1] - 169:15
Bailey-Entin [2] -
169:11, 169:14
BAILEY-ENTIN [1] -
169:15
ball [1] - 11:5
bank [8] - 131:20,
142:6, 142:7,
147:15, 147:16,
147:25, 148:7,
148:18
base [1] - 47:13
based [39] - 33:4,
33:7, 46:21, 47:4,
62:25, 63:4, 63:6,
63:15, 63:19, 63:21,
64:24, 65:4, 66:15,
70:7, 90:6, 92:22,
99:23, 104:4, 104:5,
106:13, 106:14,
113:9, 115:19,
131:16, 131:19,
131:21, 132:9,
132:17, 132:18,
132:19, 132:23,
133:19, 133:23,
134:12, 134:15,
172
135:3, 136:7, 136:9,
141:5
bashful [1] - 77:21
basic [1] - 30:7
basis [7] - 7:22, 99:14,
100:4, 100:5, 100:8,
105:25
Batson [5] - 99:21,
103:22, 105:23,
106:12, 107:8
Beach [5] - 1:19, 15:5,
19:7, 19:11, 53:5
beach [1] - 86:23
Beauty [1] - 153:11
becomes [2] - 71:12,
166:9
BEFORE [1] - 1:10
beg [1] - 85:8
began [1] - 132:2
begin [5] - 10:14,
45:18, 58:20,
127:24, 130:19
beginning [2] - 18:24,
108:17
begins [2] - 55:5,
145:9
behalf [5] - 12:16,
27:13, 34:4, 46:13,
113:1
behind [2] - 90:13
Belen [1] - 60:16
belief [3] - 63:2, 75:24,
76:17
beliefs [9] - 62:22,
63:7, 64:2, 65:3,
65:8, 65:13, 65:16,
65:23
believability [3] - 49:7,
123:8, 123:13
believable [3] - 38:4,
77:11, 84:5
believes [5] - 45:19,
47:1, 50:11, 77:12,
85:3
Bergh [1] - 24:20
best [8] - 12:1, 33:6,
33:19, 33:22, 62:12,
65:1, 76:19, 167:16
better [4] - 3:23, 28:2,
39:18, 117:12
between [6] - 84:13,
96:18, 136:4,
139:10, 139:13,
139:14
beverages [1] -
159:16
beyond [15] - 41:12,
41:17, 41:25, 46:3,
46:8, 57:16, 64:20,
65:12, 76:12,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 172 of
195
123:22, 124:1,
124:6, 141:19,
149:1, 152:1
bias [1] - 92:20
biased [1] - 93:2
biases [1] - 96:23
big [1] - 126:17
birthday [1] - 59:25
bit [8] - 20:24, 48:20,
62:12, 78:5, 84:13,
110:23, 120:10,
134:9
black [1] - 100:1
block [1] - 47:10
blogging [1] - 126:18
blown [1] - 60:6
blue [1] - 120:7
bogus [1] - 153:9
Bolufe [1] - 102:18
booked [1] - 61:17
boos [1] - 38:20
borrower [1] - 133:20
bottom [1] - 161:6
Boulevard [2] - 1:16,
1:18
bound [3] - 22:21,
23:1, 79:11
box [4] - 34:23, 43:4,
51:24, 57:10
boys [1] - 60:15
brain [1] - 68:11
Bravo [1] - 53:1
break [9] - 53:16,
53:17, 53:23, 53:25,
76:15, 85:20, 110:6,
124:20
breaking [1] - 110:13
briefly [1] - 165:8
bring [15] - 4:10,
11:10, 26:18, 27:12,
32:15, 34:6, 58:1,
96:16, 96:25, 107:5,
107:7, 114:4,
117:16, 126:5, 127:5
bringing [2] - 56:21,
116:24
brother [2] - 104:6,
107:23
brother-in-law [2] -
104:6, 107:23
brought [3] - 126:19,
149:11, 155:19
Broward [11] - 1:16,
25:6, 25:8, 28:10,
66:23, 68:18, 68:19,
97:8, 98:2, 98:7,
131:10
BSO [5] - 96:1, 96:5,
96:12, 98:10, 131:10
BSO's [1] - 131:11
Building [2] - 2:4,
169:17
bullet [1] - 115:11
burden [15] - 40:23,
41:10, 41:11, 41:12,
41:14, 41:15, 41:20,
41:21, 41:24,
123:25, 124:5,
128:7, 151:13,
154:21
burdens [1] - 40:19
Bureau [1] - 66:23
burn [1] - 149:16
busiest [1] - 27:25
Business [6] - 22:4,
24:14, 24:22, 25:11,
28:7, 28:9
business [64] - 24:18,
28:6, 63:11, 63:16,
63:17, 63:19, 64:10,
70:9, 70:11, 70:13,
70:17, 71:8, 71:9,
72:10, 89:6, 90:2,
90:3, 121:22, 132:5,
132:6, 132:9,
132:10, 132:13,
132:14, 133:1,
133:6, 133:25,
134:12, 134:14,
134:17, 134:18,
134:23, 135:4,
135:5, 135:8, 135:9,
135:13, 137:7,
143:7, 145:21,
146:25, 147:2,
147:8, 147:12,
147:18, 150:25,
152:7, 152:8,
152:18, 152:19,
153:13, 153:17,
153:20, 153:25,
154:5, 154:19,
155:1, 156:20,
156:21
business's [1] - 132:9
businesses [3] -
28:12, 131:18,
133:24
businessman [1] -
74:15
Bustamante [4] -
31:13, 43:10, 109:4,
129:25
Bustamante's [1] -
108:6
BY [1] - 2:1
C
Cachee [1] - 109:13
cafeteria [1] - 110:2
calendar [1] - 94:16
California [1] - 11:13
caller [1] - 142:23
cancellations [1] -
60:13
cannot [8] - 6:3, 30:8,
45:20, 46:2, 46:6,
61:16, 79:23, 93:20
captain [3] - 107:23,
108:2, 108:3
caption [2] - 116:3,
166:13
captioned [3] - 116:2,
116:3
car [1] - 40:3
card [8] - 67:10,
80:15, 80:16, 80:21,
81:5, 81:14, 81:16,
82:16
cards [2] - 67:15, 81:6
care [6] - 6:12, 58:13,
60:17, 88:15, 97:24,
150:18
career [1] - 66:10
carefully [6] - 19:12,
23:10, 23:13, 30:16,
37:17, 62:14
Carla [1] - 56:3
Carolina [2] - 52:2,
67:7
Carolyn [60] - 4:13,
9:2, 20:8, 22:4,
22:11, 22:12, 73:10,
114:24, 115:4,
115:9, 131:4, 131:8,
131:15, 131:17,
134:2, 135:2, 135:5,
135:7, 135:9,
135:11, 135:13,
136:2, 136:8,
136:24, 137:2,
137:21, 138:10,
139:3, 139:4,
139:14, 140:4,
140:17, 141:7,
141:9, 141:13,
141:19, 142:5,
143:2, 143:11,
143:15, 143:19,
144:14, 145:11,
146:9, 146:23,
147:1, 147:4,
147:18, 147:24,
148:10, 148:16,
149:5, 152:18,
155:16, 155:17,
155:18, 155:19,
157:10
CAROLYN [1] - 1:7
carried [1] - 136:13
carrier [1] - 143:9
carry [2] - 136:5,
136:15
carrying [1] - 121:2
CASE [1] - 1:2
case [166] - 6:4, 7:3,
9:23, 10:6, 10:20,
12:19, 13:6, 13:11,
13:14, 16:3, 18:4,
18:9, 18:10, 20:6,
20:9, 20:18, 20:23,
21:4, 22:7, 22:16,
22:18, 23:22, 27:12,
27:20, 33:8, 35:25,
39:18, 40:1, 40:2,
40:22, 41:8, 41:9,
41:11, 41:15, 42:1,
42:8, 42:9, 42:18,
42:21, 43:21, 44:2,
44:6, 44:13, 44:14,
44:16, 44:17, 45:11,
47:7, 47:15, 48:8,
48:20, 48:21, 48:23,
48:24, 49:9, 50:9,
54:19, 54:23, 56:24,
57:15, 58:13, 59:15,
62:24, 63:1, 63:7,
64:20, 65:11, 66:17,
67:22, 68:6, 68:7,
68:25, 70:6, 70:19,
71:20, 72:3, 72:18,
73:10, 75:14, 75:21,
76:18, 78:23, 79:23,
79:24, 81:1, 81:23,
83:24, 85:5, 91:11,
98:8, 112:11,
118:10, 118:20,
119:4, 119:15,
119:20, 119:23,
120:3, 122:15,
123:11, 123:16,
123:19, 124:1,
124:6, 124:10,
124:14, 124:15,
124:17, 124:18,
125:17, 125:25,
126:3, 126:5, 126:9,
126:14, 126:21,
127:2, 127:15,
128:4, 128:5, 128:6,
128:7, 128:10,
128:11, 128:21,
128:22, 128:25,
130:25, 131:4,
132:21, 133:11,
134:6, 135:21,
136:6, 137:22,
139:9, 140:13,
142:20, 143:1,
173
144:6, 145:9,
145:11, 146:21,
147:15, 148:24,
149:3, 149:17,
149:19, 150:21,
151:1, 151:25,
152:20, 153:22,
156:12, 156:14,
157:12, 158:19,
158:22, 159:6,
159:8, 167:11
cases [17] - 7:23, 8:1,
27:16, 28:3, 32:14,
32:16, 40:3, 40:4,
40:5, 40:7, 40:8,
40:9, 41:10, 45:8,
66:7, 67:23, 125:19
catch [1] - 150:3
caught [1] - 4:9
caused [1] - 114:25
causes [2] - 60:24,
96:8
causing [1] - 112:20
cautiously [2] - 158:9
cell [9] - 139:2, 139:4,
139:15, 142:15,
142:19, 143:9,
143:18, 146:3
center [1] - 144:13
certain [11] - 5:11,
15:25, 50:16, 50:18,
119:8, 119:13,
121:16, 123:5,
123:14, 142:22,
146:23
certainly [2] - 91:3,
122:4
certificate [2] - 145:14
certification [1] -
145:2
certifications [2] -
134:7, 146:16
certified [4] - 134:3,
135:4, 135:18,
136:20
certify [2] - 133:25,
169:10
Cesar [1] - 44:6
cetera [6] - 10:14,
50:10, 50:23,
121:22, 126:14,
126:24
challenge [15] - 85:14,
86:9, 86:20, 87:5,
99:18, 99:21,
100:19, 102:15,
102:18, 103:22,
103:23, 105:23,
106:12, 107:8
challenged [3] -
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 173 of
195
104:19, 107:20,
152:24
challenges [15] -
86:11, 86:13, 86:17,
86:22, 87:2, 95:18,
98:18, 99:9, 99:12,
100:11, 101:14,
101:22, 102:16,
102:20, 104:18
challenging [1] -
104:2
chance [2] - 125:22,
125:23
change [2] - 4:18,
126:1
changes [2] - 142:6,
143:13
changing [1] - 4:18
chaplain [3] - 107:25,
108:2, 108:4
charge [3] - 8:4, 8:8,
154:7
charged [13] - 46:1,
65:10, 65:14, 80:4,
80:6, 81:6, 114:8,
114:17, 117:19,
118:11, 136:16,
136:17, 154:14
charges [9] - 4:12,
4:13, 20:25, 22:6,
64:16, 64:25,
135:21, 135:22,
149:11
chart [2] - 26:2, 26:6
charts [1] - 129:17
check [3] - 39:7,
61:19, 152:12
checked [1] - 167:24
checks [6] - 148:9,
148:11, 148:14,
148:19, 148:20,
148:22
chief [9] - 7:3, 13:14,
112:12, 128:4,
128:5, 128:6,
128:10, 128:21,
167:11
child [2] - 55:23, 153:6
childcare [5] - 55:15,
87:25, 88:4, 88:8,
88:14
children [2] - 55:24,
58:6
children's [1] - 55:7
choice [1] - 167:1
choose [1] - 50:20
Chung [3] - 59:21,
94:14, 94:17
circumstantial [3] -
122:21, 122:24,
123:4
citizen [5] - 27:12,
51:1, 65:17, 76:16,
158:12
citizens [1] - 50:16
citizenship [1] - 50:16
City [3] - 61:11, 95:2,
108:7
civil [31] - 27:13,
27:16, 39:18, 40:1,
40:2, 40:4, 40:9,
40:22, 41:2, 41:8,
41:9, 42:8, 42:21,
43:12, 43:14, 43:15,
44:2, 44:6, 44:8,
45:2, 75:1, 75:2,
75:3, 75:4, 75:17,
75:20, 76:16
civilian [2] - 77:11,
77:20
civilly [1] - 66:9
claim [2] - 27:11,
153:5
claimed [2] - 134:24,
147:13
clarification [1] -
107:6
clarity [1] - 160:13
clean [1] - 123:24
clear [6] - 28:24,
81:20, 160:16,
160:25, 161:13,
167:11
clearer [1] - 111:3
clearly [1] - 50:4
clients [3] - 23:16,
86:5, 90:7
close [9] - 23:12, 28:6,
29:8, 66:3, 66:22,
67:18, 95:24, 97:7,
104:8
closed [14] - 10:11,
18:24, 18:25, 19:2,
19:3, 19:9, 19:10,
19:20, 19:21, 20:3,
90:22, 159:2
closely [1] - 32:13
closer [1] - 11:8
closing [6] - 119:23,
119:24, 120:1,
127:10, 129:4, 129:5
closure [1] - 13:20
co [2] - 137:2
co-conspirator [1] -
137:2
co-conspirators [1] -
137:2
Coast [1] - 11:6
coconspirators [1] -
112:17
cocounsel [1] - 73:11
code [5] - 138:22,
138:24, 139:1,
139:4, 144:2
codes [1] - 139:6
coffee [1] - 159:13
collect [2] - 27:14,
133:7
color [1] - 32:24
Colorado [2] - 11:14,
166:21
comfort [1] - 7:9
comfortable [2] -
3:18, 3:20
coming [15] - 12:20,
12:23, 47:22, 52:3,
52:4, 52:6, 52:8,
60:12, 65:2, 117:23,
125:3, 147:22,
166:7, 166:21,
166:24
commence [1] - 12:19
commencing [1] -
51:14
comment [1] - 118:25
commit [7] - 20:25,
82:3, 84:20, 135:24,
136:12, 136:24,
140:14
committed [5] - 21:2,
46:1, 65:10, 136:3,
136:25
common [3] - 38:7,
47:12, 165:23
commonly [3] - 24:15,
131:10, 132:1
communicate [1] -
127:1
communicated [1] -
8:24
communicating [1] -
69:19
communications [2] -
60:11
community [1] -
158:15
companies [1] - 56:15
company [10] - 24:17,
24:20, 24:22, 28:20,
28:21, 61:10, 74:1,
78:11, 78:16, 169:1
compare [1] - 38:6
compared [1] - 38:15
complete [1] - 21:23
completed [4] - 10:20,
11:20, 144:23,
151:17
completely [1] - 76:14
complex [2] - 40:8,
71:12
complicated [2] -
50:8, 71:10
complied [1] - 168:24
computer [4] - 142:15,
142:19, 151:5, 156:1
computers [3] -
126:10, 151:22,
156:9
concern [4] - 7:15,
59:5, 59:7, 116:15
concerned [11] - 5:9,
37:21, 38:22, 51:23,
78:21, 90:21, 91:20,
93:23, 96:5, 100:6,
102:4
concerning [1] - 127:2
concerns [1] - 110:23
concise [1] - 12:2
conclude [1] - 122:25
concluded [2] - 34:21,
128:23
conclusion [1] - 7:2
condition [2] - 50:15,
60:18
conditionally [1] -
115:22
conditions [1] - 5:11
conduct [4] - 96:9,
114:9, 114:17, 124:8
conducting [1] -
142:12
confer [3] - 14:6,
85:12, 85:19
conference [3] - 8:4,
116:14, 117:1
confessed [1] -
157:15
confessions [1] -
151:8
conflict [3] - 26:22,
56:14, 96:18
confused [1] - 4:3
Congress [1] - 47:25
congressmen [1] -
22:25
connection [4] - 22:1,
83:4, 96:11, 142:24
conscious [1] - 78:4
consider [11] - 6:3,
20:14, 21:21, 47:6,
47:10, 119:10,
119:18, 119:21,
120:1, 121:9, 128:24
considerations [1] -
123:14
considered [6] - 5:21,
92:2, 94:18, 119:13,
122:19, 148:23
considering [2] - 35:9,
124:3
174
consist [1] - 119:5
consistent [1] - 149:3
conspiracy [25] -
20:25, 21:1, 21:4,
21:17, 21:25, 22:15,
112:16, 113:1,
113:17, 113:24,
114:2, 117:2, 117:3,
135:24, 136:3,
136:9, 136:10,
139:11, 140:14,
141:9, 154:7,
154:14, 156:13,
156:14
conspirator [1] -
137:2
conspirators [1] -
137:2
conspiring [1] -
136:12
constitution [4] -
46:11, 75:25, 76:9,
158:14
constitutional [1] -
76:3
contact [6] - 22:25,
67:13, 125:3, 125:8,
126:4, 139:16
contacted [1] - 54:13
contained [2] -
112:21, 113:2
contains [2] - 123:23,
168:19
context [1] - 79:8
contingent [1] -
150:17
continue [3] - 54:11,
65:21, 168:10
contract [3] - 40:4,
57:24, 157:24
contractors [1] -
78:13
controls [1] - 168:7
conversations [1] -
151:10
convictions [1] -
62:22
convince [1] - 41:2
cooperate [2] -
140:21, 168:13
cooperation [1] -
140:21
copy [6] - 4:15,
129:14, 145:12,
146:7, 157:24,
168:23
corner [1] - 85:13
corporation [2] - 90:3,
152:14
corporations [1] -
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195
90:12
correct [29] - 3:7,
4:20, 9:13, 15:8,
17:4, 26:3, 27:16,
27:17, 33:1, 35:6,
35:12, 41:7, 60:21,
63:14, 63:23, 69:22,
73:24, 75:5, 78:20,
79:7, 90:7, 90:8,
98:3, 102:1, 103:24,
129:18, 161:21,
164:20, 165:21
corrected [1] - 4:24
correction [2] -
106:19, 107:4
correctional [2] -
106:24, 107:1
corrections [2] -
106:16, 106:20
correctly [1] - 100:2
correlation [2] -
84:11, 84:13
costs [1] - 150:20
counsel [23] - 3:6, 4:2,
4:25, 8:23, 10:10,
23:5, 23:6, 23:15,
25:17, 25:20, 38:16,
45:17, 65:18, 73:13,
76:11, 86:4, 130:13,
156:8, 158:25,
159:21, 159:25,
160:7, 165:5
Count [23] - 4:12,
4:18, 4:19, 20:25,
21:4, 21:13, 21:14,
21:18, 21:19, 21:25,
22:1, 22:3, 22:4,
22:6, 22:8, 22:10,
22:12, 22:13,
165:13, 165:14,
165:15
count [8] - 20:13,
21:21, 113:23,
121:3, 154:7,
154:14, 158:4
country [4] - 11:12,
50:17, 75:25, 131:7
Counts [3] - 4:3, 4:6,
4:11
counts [19] - 4:4, 4:11,
20:14, 20:24, 21:15,
21:18, 22:14, 22:15,
82:16, 82:20,
113:22, 154:9,
154:15, 156:13,
156:25, 157:2,
165:18
County [10] - 5:8,
19:2, 40:6, 43:22,
66:24, 68:18, 68:19,
74:23, 98:3, 159:2
county [3] - 5:14,
89:5, 131:12
couple [1] - 5:2
course [12] - 5:18,
12:2, 19:19, 74:20,
100:17, 118:22,
120:4, 121:21,
124:11, 126:21,
167:13
Court [45] - 2:2, 2:3,
3:1, 3:18, 4:9, 4:10,
4:25, 6:2, 7:9, 8:2,
8:23, 13:2, 13:3,
13:20, 19:17, 32:15,
64:16, 79:2, 79:8,
79:10, 84:25, 85:2,
85:4, 85:6, 88:19,
90:22, 92:11, 111:5,
112:2, 116:16,
118:11, 119:6,
130:22, 148:25,
158:19, 160:13,
164:12, 165:8,
166:1, 166:10,
166:11, 168:24,
169:15, 169:16
court [23] - 17:22,
22:22, 40:5, 42:9,
42:21, 43:21, 44:7,
44:18, 44:22, 45:2,
47:4, 47:14, 54:9,
66:3, 66:14, 66:20,
111:15, 126:16,
128:18, 149:14,
166:25
COURT [411] - 1:1,
3:3, 3:9, 3:20, 3:24,
4:6, 4:17, 4:21, 4:23,
5:5, 6:11, 6:19, 7:13,
7:19, 8:10, 8:12,
8:16, 9:4, 9:11, 9:15,
9:19, 10:2, 10:13,
10:23, 12:1, 12:5,
12:8, 12:11, 13:1,
13:10, 13:16, 14:1,
14:6, 14:15, 14:17,
14:19, 14:22, 15:2,
15:4, 15:7, 15:10,
15:13, 15:15, 15:22,
15:24, 16:15, 16:18,
16:24, 17:2, 17:6,
17:15, 17:17, 17:24,
18:6, 24:7, 25:17,
25:25, 26:2, 26:5,
26:10, 26:14, 26:16,
26:23, 27:2, 27:6,
27:8, 27:15, 27:18,
27:24, 28:18, 28:23,
29:3, 29:9, 29:12,
29:15, 29:20, 30:1,
30:10, 30:15, 30:22,
30:25, 31:3, 31:14,
31:18, 31:22, 32:1,
32:6, 32:10, 32:16,
32:18, 32:25, 33:2,
33:9, 33:25, 34:2,
34:11, 34:19, 34:22,
35:4, 35:7, 35:11,
35:13, 35:21, 36:2,
36:6, 36:11, 36:17,
36:20, 36:22, 36:24,
37:2, 37:6, 37:9,
37:11, 37:14, 37:16,
42:19, 42:22, 42:24,
43:2, 43:11, 43:14,
43:17, 43:19, 43:23,
43:25, 44:4, 44:7,
44:9, 44:11, 44:14,
44:18, 44:20, 44:24,
45:3, 51:16, 51:18,
51:20, 52:9, 52:12,
52:14, 52:20, 53:4,
53:7, 53:10, 53:15,
54:10, 54:22, 54:24,
55:2, 55:8, 55:11,
55:18, 55:21, 56:1,
56:6, 56:8, 56:10,
56:17, 56:20, 57:2,
57:4, 57:7, 57:9,
57:13, 57:19, 57:23,
57:25, 58:3, 58:15,
58:17, 58:21, 59:2,
59:8, 59:12, 59:14,
59:18, 59:23, 60:1,
60:4, 60:7, 60:20,
61:1, 61:3, 61:7,
61:16, 61:19, 61:22,
62:1, 62:4, 63:24,
64:23, 65:6, 65:9,
65:18, 65:21, 69:22,
70:16, 70:25, 71:2,
72:7, 73:6, 74:12,
85:10, 86:4, 86:8,
87:13, 87:20, 87:24,
88:4, 88:8, 88:11,
88:16, 88:21, 88:23,
89:3, 89:17, 89:22,
90:1, 90:6, 90:9,
90:14, 90:17, 90:23,
91:4, 91:8, 91:16,
91:25, 92:7, 92:14,
92:17, 93:1, 93:5,
93:7, 93:9, 93:15,
93:18, 94:2, 94:4,
94:11, 94:22, 95:3,
95:6, 95:8, 95:11,
95:18, 95:21, 96:2,
96:7, 96:12, 96:17,
96:22, 97:2, 97:10,
97:14, 97:16, 97:19,
97:24, 98:1, 98:5,
98:7, 98:13, 98:18,
98:22, 98:24, 99:3,
99:5, 99:8, 99:17,
99:20, 99:22, 100:2,
100:4, 100:10,
100:13, 100:16,
100:19, 100:21,
100:24, 101:1,
101:3, 101:7, 101:9,
101:13, 101:18,
101:21, 101:24,
102:1, 102:6,
102:10, 102:13,
102:18, 102:20,
102:23, 102:25,
103:4, 103:6, 103:9,
103:11, 103:14,
103:17, 103:21,
103:23, 104:1,
104:3, 104:10,
104:13, 104:23,
104:25, 105:7,
105:11, 105:13,
105:17, 105:20,
105:25, 106:13,
106:17, 106:21,
106:23, 107:3,
107:8, 107:18,
108:1, 108:9,
108:16, 109:25,
110:12, 110:18,
110:21, 111:1,
111:7, 111:11,
111:17, 111:21,
112:4, 112:6,
112:11, 112:14,
112:24, 113:4,
113:11, 113:14,
113:19, 113:25,
114:11, 114:13,
114:15, 114:18,
114:22, 116:1,
116:5, 116:8,
116:10, 116:12,
117:7, 117:10,
117:22, 117:25,
118:4, 118:6,
118:13, 130:8,
130:16, 130:19,
130:23, 149:7,
158:24, 159:21,
159:24, 160:16,
160:18, 160:21,
160:25, 161:3,
161:5, 161:10,
161:14, 161:19,
161:22, 161:24,
162:3, 162:7,
162:13, 162:19,
162:25, 163:6,
175
163:11, 163:15,
163:20, 164:1,
164:7, 164:14,
164:19, 164:21,
164:24, 165:4,
165:16, 165:19,
165:22, 166:4,
166:6, 166:8,
166:13, 166:17,
167:3, 167:6,
167:13, 168:2,
168:6, 168:9, 169:2
Court's [9] - 6:9, 7:1,
7:5, 63:3, 65:25,
68:13, 85:8, 114:4,
167:2
courthouse [1] - 40:5
Courthouse [1] - 40:6
courthouses [1] -
131:13
courtroom [17] -
12:21, 12:24, 17:21,
48:2, 48:4, 54:5,
54:7, 85:14, 85:22,
89:25, 108:19,
110:1, 110:11,
118:3, 121:10,
122:19, 159:20
COURTROOM [10] -
17:22, 18:1, 52:18,
54:8, 111:15, 118:2,
118:5, 118:8,
159:19, 169:5
courts [6] - 10:11,
18:25, 19:6, 19:20,
20:3, 40:14
courts-martial [1] -
40:14
cover [2] - 39:21,
161:4
covered [1] - 6:2
COVID [4] - 21:9,
131:2, 131:8, 132:2
create [6] - 27:21,
27:22, 92:1, 98:10,
140:2, 157:6
created [8] - 115:5,
137:25, 138:3,
138:12, 139:22,
140:3, 140:7, 140:9
creates [1] - 12:8
creating [1] - 157:10
creation [1] - 157:12
credence [2] - 38:13,
38:15
credibility [16] - 46:24,
49:7, 83:24, 83:25,
84:1, 84:4, 84:14,
84:15, 84:16, 84:20,
120:10, 120:14,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 175 of
195
123:7, 123:13,
123:18, 141:1
credit [10] - 67:10,
67:15, 80:15, 80:16,
80:21, 81:5, 81:14,
81:16, 81:20, 82:16
crime [5] - 27:10,
45:10, 76:3, 80:4,
140:16
crimes [4] - 135:23,
136:3, 136:24,
136:25
criminal [28] - 18:10,
20:6, 40:2, 40:6,
40:9, 41:9, 41:10,
41:11, 42:9, 43:12,
43:14, 43:15, 43:16,
43:21, 44:13, 44:14,
44:16, 44:22, 45:8,
46:11, 74:24, 75:2,
75:4, 75:9, 75:12,
83:24, 123:19
critical [1] - 60:10
crook [2] - 156:10,
156:11
cross [5] - 128:13,
128:17, 128:19,
158:15, 168:11
cross-examination [1]
- 128:13
cross-section [1] -
158:15
CRR [1] - 2:2
crunching [1] - 137:15
crystal [1] - 11:4
Cs [9] - 137:25, 138:4,
138:13, 139:22,
140:9, 140:11,
140:16, 142:10,
150:13
Cuarezma [2] - 52:2,
87:4
current [2] - 6:13,
28:19
customers [1] - 56:19
cut [1] - 159:15
cyber [1] - 126:11
D
Dade [11] - 5:8, 19:2,
19:12, 19:13, 19:20,
36:10, 40:6, 44:13,
60:9, 107:23, 159:2
daily [1] - 79:4
Dangela [1] - 109:11
danger [1] - 82:18
dangerous [1] - 19:16
Daryl [2] - 1:20, 73:11
data [3] - 143:19,
143:21, 144:19
DATE [1] - 169:14
date [5] - 16:2, 56:13,
56:15, 97:21, 147:21
daughter [3] - 55:16,
155:19
David [4] - 1:13,
23:19, 26:11, 26:12
days [6] - 49:12,
58:18, 59:1, 62:2,
91:3, 138:9
dead [1] - 81:19
dead-ends [1] - 81:19
deadline [1] - 88:24
deal [3] - 26:20, 67:9,
154:10
dealings [2] - 67:1,
67:3
deals [1] - 66:22
dealt [1] - 68:15
decedent [1] - 44:17
decent [1] - 107:11
decide [3] - 10:4,
120:13, 123:6
decided [3] - 111:19,
111:22, 120:20
deciding [1] - 49:2
decision [10] - 8:2,
27:1, 49:8, 64:24,
65:4, 85:16, 101:15,
158:17, 165:6, 167:3
decisions [7] - 29:10,
33:4, 33:7, 38:8,
38:10, 46:20, 127:13
declined [2] - 113:8,
115:23
deemed [1] - 126:21
DEFENDANT [1] -
1:18
defendant [17] - 7:24,
9:21, 9:25, 20:10,
20:13, 21:22, 22:7,
22:10, 45:24, 46:7,
46:12, 46:15, 46:22,
46:23, 47:3, 66:15,
134:6
Defendant [3] - 4:12,
9:2, 9:10
defendant's [1] - 7:3
Defendants [1] - 1:8
defendants [53] -
4:13, 8:24, 20:7,
20:9, 20:14, 21:5,
21:11, 22:2, 45:12,
45:24, 48:17, 64:18,
68:3, 98:9, 112:17,
114:25, 123:21,
123:23, 124:1,
126:13, 131:3,
135:15, 135:23,
136:13, 136:15,
136:17, 136:19,
136:23, 137:21,
138:3, 138:6,
138:13, 138:14,
138:19, 139:7,
139:8, 139:18,
139:23, 142:3,
143:4, 143:12,
144:7, 144:9,
144:12, 145:4,
145:13, 146:19,
147:21, 148:1,
148:4, 148:19,
157:16
defendants' [5] -
131:20, 136:6,
138:1, 143:5, 146:22
DEFENDANTS' [1] -
149:8
defense [49] - 3:9,
4:14, 4:22, 7:21, 8:6,
8:20, 8:23, 9:11,
18:18, 23:15, 29:6,
33:12, 33:13, 38:2,
38:14, 38:15, 73:6,
73:8, 86:14, 86:15,
86:17, 87:9, 88:3,
95:6, 100:19,
101:14, 101:19,
102:23, 102:25,
103:4, 103:9,
103:14, 104:21,
105:11, 105:15,
110:22, 111:7,
111:24, 116:10,
128:5, 128:11,
129:5, 129:7,
130:16, 149:7,
166:14, 168:21
defense's [1] - 13:6
deferred [1] - 164:13
define [1] - 41:17
definitely [1] - 84:17
definitions [1] -
126:20
defraud [1] - 136:14
defrauded [1] - 154:16
delays [1] - 60:12
deliberate [3] - 20:14,
91:12, 124:23
deliberation [1] -
110:7
deliberations [2] -
21:24, 45:11
delicate [1] - 60:18
delving [1] - 33:10
demand [1] - 50:23
demands [1] - 50:18
democratic [1] - 47:24
denied [2] - 99:6,
141:8
Denise [1] - 4:13
DENISE [1] - 1:7
dental [1] - 78:11
Denver [2] - 11:14,
166:21
department [1] -
131:11
Department [6] -
60:10, 66:24, 67:8,
107:24, 108:8,
151:14
dependent [1] - 89:7
DEPUTY [10] - 17:22,
18:1, 52:18, 54:8,
111:15, 118:2,
118:5, 118:8,
159:19, 169:5
deputy [5] - 85:22,
108:19, 110:1,
131:9, 152:9
descent [3] - 106:5,
107:9, 107:17
design [1] - 58:16
designed [3] - 132:4,
132:11, 148:3
desire [2] - 3:21,
13:13
detail [2] - 8:4, 46:5
detention [1] - 131:12
determination [7] -
7:3, 118:24, 120:1,
120:17, 124:4,
128:9, 140:25
determine [6] - 49:7,
79:17, 119:4,
120:14, 123:12,
123:18
determined [3] -
120:23, 132:9,
156:23
determiners [1] -
158:1
determining [2] - 6:4,
127:7
device [8] - 142:14,
142:18, 143:19,
143:20, 144:19,
144:20, 144:21,
151:4
devices [3] - 49:17,
126:24, 143:18
Diaz [6] - 26:2, 26:3,
29:16, 89:10, 92:17
dictionary [1] - 126:20
different [12] - 11:12,
19:8, 26:21, 31:19,
40:19, 46:19, 48:24,
52:10, 60:16,
176
145:24, 146:11
difficult [8] - 10:8,
62:25, 64:2, 66:16,
70:19, 70:21, 72:3,
72:17
difficulty [1] - 64:14
digital [2] - 141:17,
141:25
Dimercurio [2] -
109:11, 130:9
Dion [1] - 25:4
DIPIETRANTONIO [1]
- 24:4
Dipietrantonio [3] -
24:5, 25:16, 167:23
Dipietrantonio's [1] -
168:17
dire [11] - 5:2, 5:17,
5:18, 6:7, 18:11,
29:22, 96:4, 96:9,
97:6, 99:5, 131:23
direct [9] - 122:20,
122:22, 128:12,
128:15, 128:16,
128:18, 149:13,
168:11
directions [1] - 109:20
directive [1] - 79:6
directly [7] - 18:15,
33:21, 62:15,
141:14, 143:3,
143:4, 143:11
director [3] - 61:3,
74:4, 74:5
director's [1] - 61:6
disabilities [1] - 49:15
disadvantage [1] -
77:10
disagree [1] - 91:16
disagreeing [1] -
94:11
disallow [1] - 6:22
Disaster [1] - 72:12
disbelieve [2] - 79:13,
79:14
disclose [2] - 31:16,
96:4
discovered [1] - 67:16
discuss [8] - 8:2, 8:10,
46:5, 116:14,
124:10, 124:13,
159:6, 159:8
discussed [7] - 7:2,
9:18, 9:21, 10:17,
65:11, 121:11,
166:15
discussions [1] -
47:25
dispute [1] - 40:4
DISTRICT [3] - 1:1,
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1:1, 1:11
district [5] - 26:9,
27:25, 58:16,
126:17, 126:19
District [9] - 1:15, 2:3,
18:9, 19:4, 19:5,
23:20, 24:2, 169:16,
169:16
DIVISION [1] - 1:2
divisions [2] - 19:4,
19:7
Docket [14] - 114:23,
160:19, 161:1,
161:9, 161:17,
162:5, 162:11,
162:17, 162:23,
163:4, 163:10,
163:24, 164:5,
164:16
doctor [2] - 36:25,
38:9
doctor's [8] - 53:1,
53:10, 53:19, 54:13,
59:5, 86:23, 93:10,
93:14
document [9] - 116:1,
134:21, 135:12,
145:6, 145:7,
146:14, 150:22,
157:13
documents [33] -
49:5, 73:15, 74:6,
115:17, 115:19,
116:9, 119:5,
121:13, 121:21,
133:8, 133:22,
134:4, 137:24,
138:2, 138:17,
141:3, 141:13,
142:6, 143:13,
145:10, 152:17,
157:14, 161:25,
162:8, 162:14,
162:20, 163:1,
163:7, 163:16,
163:21, 164:2,
164:8, 165:2
DocuSign [10] -
136:22, 145:3,
145:6, 145:9,
145:14, 146:1,
146:4, 146:6,
146:10, 146:18
Dodd [2] - 7:12, 25:10
DOJ [2] - 1:14, 168:20
DOJ-USAO [1] - 1:14
dollars [2] - 115:15,
152:23
Dolphin [1] - 38:18
Donald [3] - 2:3,
17:23, 18:8
DONALD [1] - 1:10
done [12] - 21:16,
58:10, 63:9, 67:25,
92:11, 121:25,
127:19, 138:18,
138:20, 142:10,
145:3
donuts [1] - 159:15
door [1] - 160:3
doubt [17] - 41:12,
41:18, 41:25, 46:4,
46:8, 64:20, 65:12,
76:12, 92:21,
123:22, 124:1,
124:6, 141:19,
149:1, 152:2,
158:18, 158:20
down [17] - 3:16, 14:7,
31:7, 38:17, 42:15,
42:21, 60:24, 62:5,
78:19, 88:14, 90:23,
92:8, 92:24, 106:6,
106:8, 156:20,
161:20
download [1] - 150:13
downstairs [2] -
39:17, 110:2
downtown [5] - 12:8,
40:5, 51:5, 124:12,
159:11
draft [1] - 50:19
draw [1] - 46:13
driver's [1] - 144:16
driving [1] - 125:24
drop [2] - 55:15, 60:15
drop-off [1] - 60:15
due [3] - 56:13, 56:15,
57:17
duplicative [1] - 111:2
during [28] - 3:12,
21:9, 29:21, 34:14,
41:16, 46:5, 53:16,
59:1, 72:5, 96:3,
102:6, 113:1,
118:22, 123:11,
124:9, 124:20,
125:15, 125:18,
125:21, 126:6,
128:10, 131:1,
131:23, 132:6,
139:11, 144:2,
150:24, 153:9
during-trial [1] -
125:18
duties [2] - 50:25,
85:1
duty [4] - 65:17, 76:16,
118:17, 158:11
E
e-mailed [1] - 145:10
early [5] - 11:23,
13:21, 20:20,
159:12, 160:7
easier [1] - 3:8
easily [2] - 153:5,
156:23
East [1] - 1:18
easy [1] - 78:7
ECF [1] - 161:8
Economic [1] - 72:12
economy [1] - 131:8
Eduardo [6] - 154:24,
154:25, 155:14,
155:15, 157:5, 157:8
Edward [2] - 137:6,
137:8
effect [2] - 45:15,
71:21
effects [1] - 131:8
effort [1] - 126:23
EIDL [5] - 7:7, 7:11,
7:16, 116:22, 166:20
eight [2] - 123:17,
149:11
either [10] - 32:9, 74:8,
94:17, 99:9, 106:8,
108:7, 138:24,
139:2, 147:19,
165:25
elect [4] - 46:13,
46:18, 86:6, 124:2
elected [1] - 46:20
electing [1] - 94:13
elections [1] - 47:22
electronic [1] - 136:21
elects [1] - 46:23
elements [1] - 148:25
elevator [2] - 125:4,
125:5
elicit [1] - 7:6
eligible [1] - 133:16
email [12] - 19:18,
116:20, 127:1,
138:25, 139:2,
139:5, 145:10,
152:5, 152:12,
168:18
emails [3] - 9:17,
26:25, 167:24
emergency [1] - 72:11
Emmanuela [2] -
105:8, 109:12
emphasize [1] - 127:2
employed [7] - 23:9,
24:17, 131:9, 132:6,
132:13, 132:20,
132:25
employees [7] - 70:12,
71:9, 78:12, 115:14,
132:6, 132:10,
148:15
employers [1] - 23:13
employment [3] -
93:23, 94:12, 147:11
encoded [1] - 167:25
encrypted [2] -
168:18, 168:20
encryption [1] - 168:1
end [16] - 11:22,
13:21, 22:16, 31:7,
45:11, 57:15, 91:11,
91:13, 92:2, 118:20,
122:14, 123:11,
128:25, 155:25,
159:7, 160:5
ended [1] - 151:21
ends [3] - 55:20,
81:19, 128:19
enforcement [13] -
38:1, 66:25, 67:10,
77:8, 77:10, 77:16,
95:25, 97:8, 106:24,
107:19, 130:25,
131:3, 156:22
engage [1] - 127:3
engaged [1] - 138:6
English [11] - 29:18,
30:6, 30:11, 30:18,
36:14, 37:2, 37:3,
37:12, 50:5, 89:19
enrich [1] - 112:17
entered [10] - 17:21,
54:7, 89:25, 97:25,
118:3, 144:5,
149:12, 149:22,
156:24, 157:25
enters [1] - 108:15
entertain [7] - 20:23,
30:19, 53:23, 98:19,
129:1, 129:2, 160:11
Entin [2] - 169:11,
169:14
ENTIN [1] - 169:15
entities [1] - 28:7
entitled [2] - 135:20,
169:11
entity [1] - 81:17
Entry [14] - 114:23,
160:19, 161:1,
161:9, 161:17,
162:5, 162:11,
162:17, 162:23,
163:4, 163:10,
163:24, 164:5,
164:16
equally [1] - 127:16
equipment [1] - 153:5
177
Ermer [8] - 51:12,
51:17, 51:18, 81:4,
84:12, 92:3, 101:6
especially [1] - 48:24
Espinosa [2] - 44:12,
103:4
Esquia [1] - 102:10
Esquire [4] - 1:13,
1:14, 1:18, 1:20
establish [3] - 137:24,
138:3, 140:8
established [1] - 8:7
et [6] - 10:14, 50:10,
50:23, 121:22,
126:14, 126:24
ethical [5] - 63:7, 65:8,
75:24, 76:21, 95:9
ethically [6] - 63:8,
63:13, 65:1, 65:5,
65:6
evaluate [1] - 140:25
evaluating [1] - 38:11
evening [2] - 126:2,
159:18
events [3] - 6:13,
18:22, 20:5
eventualities [1] -
16:5
everyday [1] - 79:17
evidence [108] - 20:22,
29:9, 33:4, 35:9,
38:6, 40:24, 40:25,
41:3, 45:16, 47:4,
47:13, 49:5, 63:1,
63:4, 63:8, 63:22,
64:24, 64:25, 65:4,
65:24, 70:8, 79:17,
110:15, 111:5,
111:24, 113:23,
114:8, 116:21,
118:10, 118:17,
119:3, 119:6,
119:13, 119:17,
119:19, 119:25,
120:2, 120:5, 120:9,
121:9, 121:11,
121:12, 121:14,
122:6, 122:17,
122:19, 122:20,
122:21, 122:22,
122:24, 123:4,
124:24, 127:9,
127:13, 128:2,
128:3, 128:8,
128:23, 131:14,
134:16, 135:7,
136:2, 136:8,
136:24, 138:5,
141:18, 141:22,
148:4, 148:5, 148:7,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 177 of
195
148:24, 149:3,
149:17, 149:22,
150:18, 150:21,
152:3, 152:13,
152:20, 154:6,
154:10, 154:11,
154:17, 155:11,
156:3, 156:18,
157:3, 157:6,
157:11, 158:16,
160:14, 162:1,
162:9, 162:15,
162:21, 163:2,
163:8, 163:17,
163:22, 164:3,
164:9, 164:11, 165:3
exact [1] - 97:4
exactly [3] - 18:12,
88:10, 141:20
examination [4] -
128:12, 128:13,
128:14, 128:15
example [11] - 28:7,
37:23, 39:4, 121:19,
123:1, 123:4, 129:9,
132:13, 140:1,
143:14
examples [1] - 47:15
exams [1] - 57:17
except [1] - 110:22
exception [2] - 111:4,
160:15
exceptions [1] -
111:25
excluded [1] - 158:18
exclusion [2] - 76:12,
152:1
excuse [30] - 28:3,
62:10, 85:8, 85:17,
87:14, 87:21, 88:21,
89:7, 89:17, 90:17,
93:2, 93:18, 93:20,
93:24, 94:12, 94:17,
95:4, 95:9, 95:11,
95:14, 101:9, 102:7,
104:15, 108:9,
108:11, 108:20,
109:15, 109:19,
111:21, 129:1
excused [9] - 87:6,
88:1, 94:5, 94:7,
100:21, 109:22,
109:24, 128:20,
169:4
excusing [4] - 92:14,
92:18, 104:10,
108:21
executed [1] - 146:7
exercise [3] - 86:12,
99:18, 105:18
exercised [3] - 86:20,
103:17, 103:23
exercises [1] - 102:25
exercising [2] - 86:17,
104:4
exhibit [17] - 6:24,
111:6, 121:18,
121:19, 122:5,
122:6, 122:7,
122:11, 122:16,
161:2, 162:11,
162:17, 163:3,
163:9, 163:23,
164:5, 164:16
Exhibit [9] - 122:5,
122:10, 122:11,
122:12, 161:16,
162:4, 162:6,
162:23, 163:24
exhibits [21] - 110:15,
110:20, 110:22,
110:24, 111:4,
111:20, 111:21,
111:24, 112:1,
117:6, 119:12,
119:20, 121:16,
121:24, 122:1,
122:14, 160:14,
160:19, 160:21,
161:20, 164:13
Exhibits [24] - 112:3,
161:17, 161:25,
162:8, 162:12,
162:14, 162:20,
162:24, 163:1,
163:5, 163:7,
163:13, 163:16,
163:19, 163:21,
164:2, 164:5, 164:8,
164:11, 164:17,
165:2, 165:9,
166:11, 166:22
exist [5] - 122:25,
123:5, 131:18,
134:13, 134:24
existed [1] - 74:16
exited [4] - 54:5,
90:15, 110:11,
159:20
exits [1] - 98:15
expect [9] - 13:24,
119:19, 125:18,
128:2, 138:12,
150:1, 157:17,
157:23, 158:6
expected [3] - 58:25,
139:18, 144:3
expecting [1] - 61:14
expenses [1] - 147:13
experience [15] -
63:19, 64:12, 66:14,
66:16, 67:11, 67:21,
70:4, 70:23, 71:19,
75:11, 75:12, 75:19,
78:22, 81:22, 83:20
experiences [6] -
47:5, 63:16, 66:20,
80:25, 121:11,
124:19
expert [1] - 32:12
explain [9] - 13:3,
27:8, 37:18, 40:18,
50:1, 85:23, 138:12,
138:14, 138:16
explained [3] - 8:17,
9:25, 50:9
explaining [1] -
139:17
exposed [1] - 35:24
express [1] - 89:23
expressed [1] - 65:16
extended [3] - 9:8,
9:9, 56:24
extends [2] - 54:20,
57:16
extensions [1] - 56:14
extensively [2] -
15:17, 48:15
extent [5] - 7:4, 8:6,
11:19, 11:23, 120:11
extraordinary [1] -
5:11
eyewitness [1] -
122:23
F
face [1] - 144:21
faces [1] - 106:9
facilities [1] - 53:25
facing [1] - 60:12
fact [12] - 8:22, 31:18,
47:19, 52:7, 57:17,
58:12, 79:24, 85:2,
91:1, 122:23, 124:3,
158:17
factors [1] - 124:7
facts [18] - 6:4, 48:5,
79:15, 79:16,
118:18, 118:19,
118:23, 119:3,
119:4, 119:7, 119:8,
122:24, 122:25,
123:5, 127:15,
140:25, 158:13
factual [2] - 7:22,
20:12
fail [1] - 10:24
fair [33] - 11:7, 18:17,
18:20, 27:20, 29:5,
29:10, 31:24, 32:20,
33:14, 34:13, 37:22,
39:2, 39:9, 39:12,
39:14, 39:15, 48:17,
49:8, 50:5, 62:16,
62:23, 65:7, 71:20,
75:13, 75:20, 76:20,
81:1, 82:13, 87:4,
92:22, 93:20, 98:24
fairly [1] - 63:12
fairness [1] - 98:10
faith [2] - 7:21, 8:5
fake [21] - 115:17,
115:18, 134:25,
135:12, 135:13,
137:25, 138:3,
138:13, 138:17,
139:22, 140:12,
140:16, 141:3,
142:9, 145:21,
156:2, 156:4,
156:17, 157:13,
157:14
false [43] - 8:8, 21:12,
22:1, 22:3, 22:6,
22:8, 22:10, 22:12,
22:13, 27:11, 48:25,
112:18, 112:21,
113:2, 113:9,
114:10, 115:7,
115:19, 131:16,
134:7, 134:16,
134:17, 134:20,
134:21, 135:7,
135:8, 135:18,
135:25, 136:1,
136:7, 136:9,
136:10, 136:18,
136:19, 140:15,
141:5, 141:6, 145:5,
145:20, 146:8,
146:15, 146:19
falsely [1] - 115:13
familiar [13] - 7:23,
24:11, 25:22, 26:7,
26:20, 26:24, 28:5,
29:4, 35:5, 35:20,
45:7, 61:2, 74:16
familiarity [1] - 36:9
family [24] - 52:3,
52:6, 66:2, 68:20,
69:18, 77:6, 77:23,
80:4, 80:5, 80:11,
80:13, 82:24, 95:24,
96:5, 96:14, 97:5,
97:7, 104:8, 106:18,
106:23, 124:10,
139:21, 152:11
family's [1] - 28:21
fantastic [1] - 3:24
178
far [8] - 19:6, 19:7,
29:24, 30:11, 31:6,
60:4, 86:17, 86:21
fashion [2] - 157:22,
168:10
fast [1] - 16:4
father [3] - 71:7,
73:24, 74:12
fathers [1] - 74:10
FBI [11] - 24:5, 25:16,
68:18, 69:4, 77:16,
77:18, 151:14,
151:16, 157:15,
167:22
fear [2] - 57:16, 58:11
Federal [5] - 2:4,
26:13, 44:7, 66:23,
169:17
federal [14] - 10:18,
19:6, 20:4, 26:15,
40:8, 42:9, 43:16,
44:9, 44:18, 66:25,
67:11, 128:18, 132:1
feelings [2] - 63:21,
76:13
feet [1] - 3:18
felt [2] - 76:18
Fernandez [3] - 61:23,
97:14, 105:1
Ferris [3] - 107:17,
109:9, 130:5
few [18] - 3:25, 11:12,
37:25, 39:25, 50:25,
53:16, 73:7, 73:13,
86:10, 90:1, 106:23,
119:15, 124:8,
127:24, 138:9,
139:14, 143:25
fictitious [3] - 115:17,
156:20, 156:21
field [1] - 24:6
figure [3] - 67:14,
71:6, 168:1
figured [1] - 155:11
file [11] - 71:4, 72:25,
80:22, 152:14,
153:3, 153:4, 153:9,
153:10, 156:16,
156:17
filed [11] - 72:24, 73:2,
116:20, 146:24,
147:12, 151:23,
152:21, 152:23,
153:8, 162:17, 163:4
files [2] - 70:1, 153:19
filing [4] - 41:2, 70:24,
82:11, 83:10
fill [1] - 102:7
filled [2] - 73:14,
151:17
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 178 of
195
filling [2] - 5:7, 78:6
final [1] - 165:5
finally [2] - 136:17,
147:15
Finance [1] - 24:22
financial [3] - 58:11,
82:25, 89:4
findings [3] - 20:12,
21:23, 47:13
fine [11] - 3:9, 6:6,
6:11, 6:19, 9:19,
47:24, 55:2, 91:7,
91:15, 94:20, 94:21
finish [12] - 11:24,
13:11, 13:14, 14:2,
49:11, 51:7, 61:14,
62:9, 91:10, 91:20,
167:12
finished [1] - 87:17
firm [3] - 35:1, 56:13,
69:8
first [49] - 8:19, 9:5,
23:4, 24:13, 31:12,
31:19, 39:22, 42:17,
43:3, 43:7, 43:9,
45:9, 59:24, 62:21,
70:24, 71:3, 72:22,
75:10, 78:2, 78:6,
80:12, 80:14, 86:14,
86:15, 86:21, 99:25,
100:12, 102:14,
104:19, 104:25,
110:14, 115:18,
123:21, 124:8,
125:9, 126:5, 127:6,
127:25, 128:11,
129:4, 134:8,
135:20, 141:23,
156:5, 161:3,
161:15, 161:16,
161:19
Fisch [5] - 35:15, 36:9,
55:4, 87:13, 92:1
fitness [1] - 57:17
five [3] - 28:1, 39:17,
78:3
Flagler [3] - 40:6,
42:21, 44:2
flame [1] - 150:10
flight [4] - 60:12,
61:11, 61:18
flights [3] - 60:23,
95:13
float [1] - 96:23
flooding [3] - 10:7,
12:8, 19:16
Floor [1] - 1:16
floor [4] - 10:25,
109:17
FLORIDA [1] - 1:1
Florida [15] - 1:4,
1:15, 1:17, 1:19,
1:21, 2:5, 11:6, 19:5,
23:21, 24:2, 69:5,
69:7, 169:16, 169:18
fluent [1] - 150:7
flux [1] - 76:20
fly [2] - 11:21, 167:1
flying [1] - 11:11
focus [1] - 102:5
follow [29] - 6:4, 7:1,
17:11, 22:18, 22:23,
40:23, 45:19, 45:20,
46:9, 47:1, 47:18,
47:20, 48:3, 48:9,
48:11, 49:1, 63:3,
64:23, 68:12, 78:9,
79:11, 85:3, 85:6,
96:7, 98:13, 118:20,
121:5, 127:23,
129:15
follow-up [2] - 96:7,
98:13
followed [2] - 96:19,
128:13
following [10] - 9:5,
66:22, 90:25, 99:17,
111:25, 115:2,
115:11, 126:6,
160:5, 167:8
follows [1] - 65:25
FOR [2] - 1:13, 1:18
forbids [2] - 21:4,
136:5
forecast [1] - 11:4
foregoing [1] - 169:10
foreman [2] - 42:25,
43:21
foreperson [5] -
40:11, 40:13, 42:13,
42:14, 44:3
forgave [1] - 133:17
forgivable [1] - 133:12
forgiven [4] - 133:14,
133:16, 135:17,
148:21
forgiveness [7] -
71:25, 112:19,
134:8, 135:17,
136:19, 146:17,
146:18
Form [2] - 134:22
form [6] - 21:22, 72:4,
82:22, 127:9,
136:20, 150:25
formal [2] - 9:7, 48:2
former [6] - 40:13,
61:3, 68:23, 69:2,
69:5, 69:19
formerly [2] - 25:13,
149:21
forms [1] - 136:21
formula [1] - 132:23
formulating [1] -
45:18
Fort [3] - 1:17, 19:11
forth [3] - 140:22,
160:23, 164:12
forthcoming [1] -
120:21
forthright [1] - 18:16
fortunately [1] - 50:18
forward [5] - 14:11,
34:2, 52:14, 159:17,
167:20
forwarded [1] - 167:21
foul [1] - 38:22
foundation [4] - 8:6,
8:12, 121:17, 122:2
four [2] - 58:10,
135:23
fourth [1] - 101:16
Francia [1] - 44:12
frankly [2] - 6:17,
30:18
fraud [23] - 4:4, 4:11,
20:25, 21:5, 27:11,
64:10, 67:10, 67:24,
67:25, 68:16, 80:6,
80:7, 80:13, 81:5,
81:14, 82:3, 82:16,
82:21, 82:22,
135:24, 136:16,
140:15
frauds [1] - 67:15
fraudulent [18] -
21:12, 48:25, 64:6,
80:22, 112:21,
113:3, 113:9,
113:18, 115:8,
137:3, 137:19,
149:22, 149:25,
150:22, 151:1,
153:3, 157:9, 157:12
fraudulently [3] -
21:19, 21:20, 140:7
free [2] - 127:20,
127:23
French [1] - 18:11
Friday [14] - 10:18,
10:19, 15:18, 16:9,
19:23, 19:24, 20:2,
20:4, 49:10, 51:14,
58:25, 59:22, 60:3,
91:20
Friedman [1] - 24:23
friend [3] - 39:13,
95:24, 97:7
friendly [1] - 137:10
friends [5] - 47:21,
77:5, 77:23, 124:11,
139:21
frolic [1] - 152:16
front [2] - 97:6, 144:20
FRP [1] - 169:15
frustrating [1] - 82:1
full [3] - 20:2, 131:9,
154:20
full-time [1] - 131:9
fully [1] - 46:6
fun [1] - 80:24
function [1] - 9:24
funded [1] - 71:17
funds [3] - 21:11,
21:18, 21:20
Funeral [23] - 112:8,
112:10, 113:1,
115:6, 115:10,
115:12, 115:14,
115:16, 115:20,
115:22, 137:8,
137:9, 137:16,
143:7, 143:16,
147:10, 148:15,
148:16, 153:17,
153:20, 165:12,
166:23
funeral [4] - 137:7,
137:8, 137:9, 137:17
furtherance [1] -
115:1
G
Gabriel [1] - 109:5
game [1] - 38:18
games [1] - 82:5
Garcia [1] - 100:16
gathering [1] - 137:11
general [5] - 5:20,
9:21, 9:23, 20:17,
64:10
generally [7] - 6:20,
20:19, 38:25, 40:7,
48:21, 70:3, 80:12
generated [1] - 138:22
gentleman [4] - 28:16,
34:7, 42:13, 74:22
gentlemen [32] -
17:25, 18:7, 23:3,
25:18, 37:20, 39:21,
45:23, 62:14, 85:11,
86:8, 101:15,
109:14, 109:21,
109:25, 118:7,
149:20, 150:6,
151:19, 153:16,
153:21, 154:3,
154:21, 154:22,
156:7, 156:12,
179
156:24, 157:15,
158:6, 158:11,
158:15, 158:21,
159:1
Geraldine [1] - 83:10
Giraldo [2] - 31:4,
105:21
gist [1] - 66:17
given [7] - 3:4, 7:25,
51:12, 74:25, 89:24,
95:13, 150:10
glad [1] - 4:9
Glenda [2] - 169:11,
169:11
GLENDA [1] - 2:2
goal [5] - 18:17, 39:11,
39:14, 49:8, 62:8
Gomez [6] - 59:5,
82:8, 82:9, 93:10,
109:7, 130:3
gong [1] - 147:20
Gonzalez [4] - 44:6,
80:1, 103:12, 103:14
Googling [1] - 126:24
GOVERNMENT [1] -
1:13
government [1] -
81:17
Government [89] -
3:6, 7:6, 8:25, 9:9,
12:15, 13:10, 18:18,
23:5, 23:14, 24:9,
25:15, 27:11, 29:6,
33:11, 38:2, 38:15,
39:10, 48:18, 62:18,
64:20, 65:11, 65:12,
68:6, 72:5, 73:4,
86:14, 86:16, 86:17,
88:6, 99:12, 100:14,
102:8, 102:16,
102:21, 103:2,
103:7, 103:12,
103:19, 104:23,
105:1, 105:9,
105:17, 110:15,
111:4, 111:23,
112:3, 113:2, 113:4,
114:5, 114:7,
122:10, 123:25,
124:5, 128:4,
128:11, 129:4,
129:5, 129:7, 129:9,
130:19, 137:23,
140:21, 148:25,
149:16, 150:4,
152:1, 153:7,
153:23, 154:6,
154:18, 157:22,
157:24, 158:1,
158:18, 162:5,
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162:11, 162:17,
162:23, 164:5,
164:10, 164:12,
164:17, 165:9,
165:25, 166:2,
166:11, 167:1
Government's [42] -
3:15, 5:18, 6:23, 7:7,
7:10, 8:5, 11:11,
11:21, 13:14, 128:5,
129:10, 149:19,
160:14, 161:2,
161:16, 161:25,
162:4, 162:5, 162:8,
162:10, 162:14,
162:16, 162:20,
162:22, 163:1,
163:3, 163:4, 163:7,
163:9, 163:13,
163:16, 163:18,
163:21, 163:23,
163:24, 164:2,
164:4, 164:8,
164:15, 165:2,
166:22, 167:10
GOVERNMENT'S [1] -
130:21
GRAHAM [1] - 1:10
Graham [6] - 2:3,
17:23, 18:8, 24:9,
69:24, 79:21
Granada [3] - 154:3,
156:10, 157:25
Granados [9] - 25:14,
137:5, 149:21,
149:22, 151:18,
152:6, 152:16,
153:12, 155:14
Grand [1] - 41:20
grand [9] - 9:2, 9:6,
40:16, 41:19, 41:21,
167:22, 168:4,
168:17, 168:18
granddaughter [1] -
94:15
granddaughter's [1] -
59:24
grandmother [1] -
82:17
grappling [1] - 131:7
grass [1] - 123:2
great [3] - 58:12,
109:22, 159:18
greater [4] - 41:6,
41:7, 77:18, 77:19
greet [1] - 125:6
Grenada [1] - 153:18
gross [1] - 115:14
guess [12] - 13:2,
13:18, 33:10, 68:11,
69:13, 70:16, 75:15,
77:14, 99:13,
155:11, 166:5,
166:25
Guia [4] - 31:3, 75:23,
95:8, 95:11
guidance [3] - 16:20,
119:21, 127:6
guide [1] - 118:15
guideline [1] - 19:13
guidelines [3] - 9:21,
9:22, 9:24
guilt [4] - 45:18, 46:2,
46:3, 46:8
guilty [14] - 46:2, 46:3,
46:7, 47:4, 68:8,
76:12, 123:22,
140:14, 140:15,
140:18, 149:4,
149:5, 149:12
Gutierrez [3] - 81:11,
81:12, 101:24
guy [1] - 155:4
Guya [1] - 75:22
H
Haitian [2] - 100:1,
107:12
half [1] - 59:10
hand [29] - 4:14,
17:24, 25:23, 28:14,
28:15, 30:3, 31:11,
32:2, 34:23, 39:3,
39:25, 40:12, 40:15,
40:17, 42:13, 45:21,
46:9, 49:20, 50:6,
50:12, 51:10, 51:24,
53:18, 53:24, 70:13,
73:16, 75:8, 116:6,
154:12
handle [7] - 4:11,
10:8, 40:9, 59:20,
60:11, 60:25, 167:16
handling [3] - 3:10,
3:21, 117:19
hands [15] - 31:11,
31:12, 46:10, 48:14,
50:13, 51:25, 54:17,
66:1, 70:9, 70:10,
72:20, 73:18, 75:8,
118:6, 132:4
happy [1] - 12:6
hard [2] - 68:14, 90:11
Harris [2] - 7:14, 24:13
Harvest [2] - 24:22,
28:8
hate [1] - 80:16
Haydee [31] - 25:12,
25:13, 25:14, 137:4,
137:5, 137:13,
137:19, 139:13,
147:21, 147:23,
149:20, 149:21,
149:22, 150:7,
151:5, 151:18,
152:6, 152:15,
153:12, 154:3,
154:19, 154:22,
155:10, 156:10,
156:16, 157:14,
157:18, 157:21,
157:25
HAYDEE [1] - 25:13
Haydee's [1] - 150:17
header [1] - 161:8
heading [1] - 125:24
health [2] - 106:19,
106:24
hear [53] - 19:1, 21:10,
33:11, 38:20, 46:15,
52:20, 63:1, 99:1,
102:4, 113:25,
116:12, 121:10,
122:18, 125:13,
128:22, 132:21,
133:10, 137:14,
138:24, 139:16,
139:22, 141:6,
142:20, 144:1,
145:9, 149:21,
149:24, 150:1,
150:4, 150:6,
150:12, 151:4,
151:12, 151:19,
152:8, 152:11,
153:4, 153:12,
153:14, 153:15,
154:17, 154:22,
154:23, 154:25,
155:5, 155:16,
155:22, 156:3,
156:4, 156:7,
157:17, 157:21
heard [12] - 18:8, 21:7,
37:20, 39:4, 45:15,
50:1, 79:2, 117:10,
124:22, 127:13,
156:6, 165:8
hearing [5] - 49:16,
63:7, 75:15, 93:22
held [1] - 144:20
hello [2] - 34:25, 44:21
help [11] - 18:19,
55:18, 74:9, 81:18,
81:20, 88:19,
123:18, 127:14,
152:10, 152:11,
153:25
helped [1] - 74:11
helpful [1] - 11:25
Hely [1] - 25:6
Henry [1] - 73:12
hereby [1] - 169:10
hereinafter [1] - 115:6
Hernan [2] - 43:20,
109:6
herself [5] - 132:14,
137:20, 141:5,
148:11, 152:10
hesitate [1] - 51:4
Hi [2] - 30:5, 56:3
hi [5] - 36:13, 44:5,
56:23, 59:21, 82:15
higher [4] - 41:10,
41:14, 71:12, 77:17
highest [1] - 41:12
highlight [1] - 97:17
highly [2] - 50:9,
125:19
himself [1] - 132:14
hit [2] - 11:6, 11:7
hold [2] - 46:16, 65:12
holiday [10] - 10:18,
12:20, 20:4, 55:5,
58:25, 87:13, 90:19,
90:24, 91:5, 91:9
home [11] - 38:20,
38:21, 124:11,
137:7, 137:8, 137:9,
137:12, 137:17,
143:5, 146:13,
155:18
Home [23] - 112:8,
112:10, 113:2,
115:6, 115:10,
115:12, 115:13,
115:14, 115:16,
115:20, 115:22,
137:8, 137:9,
137:16, 143:7,
143:17, 147:11,
148:15, 148:16,
153:17, 153:20,
165:12, 166:23
honest [3] - 18:16,
39:19, 64:12
honestly [1] - 33:18
Honor [32] - 3:22, 8:3,
10:22, 12:16, 12:25,
14:9, 23:17, 24:8,
30:20, 36:8, 54:19,
58:22, 59:4, 60:8,
62:19, 65:19,
100:23, 101:16,
102:2, 105:22,
110:14, 111:23,
112:15, 116:7,
116:11, 116:13,
130:15, 130:20,
180
160:12, 165:7,
167:19, 168:15
HONORABLE [1] -
1:10
Honorable [2] - 2:3,
17:23
hope [3] - 13:13, 31:8
hopeful [1] - 10:20
hopefully [11] - 10:15,
11:1, 11:21, 13:19,
19:25, 49:13, 60:5,
61:21, 159:4, 167:9,
168:13
host [1] - 133:5
hour [3] - 59:10,
108:13
hours [1] - 58:10
house [2] - 142:21,
142:22
huge [4] - 32:22,
33:21, 34:8, 77:13
hundred [2] - 33:23,
113:19
Hunter [6] - 149:23,
150:11, 153:15,
155:2, 155:4, 155:9
husband [12] - 31:15,
31:18, 31:22, 35:23,
55:19, 83:18, 108:7,
137:6, 148:11,
154:24, 155:14
husband's [3] - 56:4,
80:23, 83:11
hypothetically [2] -
14:2, 16:10
I
I.R.S [13] - 25:1, 39:8,
39:10, 115:17,
134:21, 134:22,
146:22, 146:25,
147:12, 152:24,
153:4, 153:6
ID [2] - 81:15, 142:23
idea [2] - 93:4, 106:4
ideas [1] - 13:16
identifiable [1] -
168:19
identification [2] -
122:8, 122:12
identifies [2] - 142:22,
142:23
identify [3] - 45:25,
63:5, 144:17
Identities [2] - 24:20,
28:8
identity [4] - 81:6,
82:1, 144:11, 144:24
II [12] - 4:4, 4:7, 4:9,
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4:11, 4:12, 4:15,
4:19, 21:14, 21:18,
50:22
III [8] - 4:4, 4:9, 4:11,
4:13, 4:15, 4:19,
21:14, 21:19
illegal [1] - 136:4
immigration [2] -
32:13, 32:16
impact [2] - 14:2,
32:20
impartial [37] - 18:18,
18:20, 27:20, 31:24,
32:20, 33:7, 33:23,
35:8, 35:17, 39:2,
39:9, 39:12, 39:13,
39:15, 48:15, 48:17,
62:17, 62:24, 63:21,
66:11, 66:17, 66:19,
67:22, 69:2, 69:12,
70:6, 70:19, 71:20,
72:3, 72:18, 75:13,
75:21, 81:7, 82:12,
82:13, 98:24, 106:16
impartiality [6] - 6:21,
27:23, 66:11, 67:5,
71:22, 98:11
implement [1] - 48:1
important [17] - 29:8,
36:15, 37:4, 37:19,
38:24, 48:9, 50:15,
55:22, 61:12, 95:13,
124:6, 125:16,
126:25, 127:16,
127:20, 128:25,
158:11
importantly [1] - 19:19
impressed [1] - 3:4
Inc [1] - 24:20
incident [1] - 83:10
inclined [9] - 48:11,
87:14, 89:17, 93:2,
93:24, 94:14, 95:3,
95:9, 95:14
include [4] - 66:4,
115:2, 115:10,
161:18
included [4] - 119:12,
134:20, 135:12,
137:25
includes [3] - 99:11,
140:20, 144:12
including [8] - 23:11,
25:20, 115:17,
135:19, 137:11,
137:20, 142:2,
146:15
income [11] - 58:7,
89:6, 131:19,
132:18, 132:20,
132:23, 134:15,
134:24, 145:21,
147:2, 147:18
inconsistent [1] -
96:15
inconvenience [1] -
16:11
inconvenienced [2] -
16:21, 17:12
incredibly [1] - 58:7
independent [2] -
33:4, 35:16
indicate [3] - 21:23,
114:2, 118:23
indicated [9] - 13:10,
74:22, 75:1, 76:11,
77:7, 80:5, 80:11,
90:2, 104:7
indicted [1] - 149:10
indictment [21] - 4:2,
4:18, 4:23, 9:3, 9:7,
45:14, 112:14,
112:15, 113:12,
115:2, 116:19,
117:13, 117:18,
123:22, 123:24,
135:22, 136:13,
137:1, 165:17,
165:20
individual [5] - 19:14,
76:2, 147:6, 150:10,
154:15
individually [1] -
20:15
individuals [12] -
18:19, 24:12, 27:15,
46:18, 48:3, 49:16,
76:9, 139:20,
140:11, 154:4,
154:16
indulgence [1] - 85:8
industrial [1] - 131:7
Infante [3] - 101:4,
109:2, 129:23
infer [3] - 122:25,
123:3, 123:5
inference [1] - 123:6
inferences [1] - 46:14
influenced [1] - 121:1
inform [1] - 35:3
information [48] -
10:13, 18:23, 19:22,
20:17, 30:8, 30:13,
40:21, 41:17, 64:7,
64:12, 67:2, 67:14,
82:18, 83:19, 87:1,
104:14, 112:21,
114:10, 121:15,
125:21, 126:11,
127:8, 131:16,
133:7, 133:21,
134:1, 134:4, 136:7,
136:10, 136:20,
138:15, 139:6,
141:5, 144:4, 145:2,
145:5, 145:21,
146:8, 146:15,
146:19, 151:20,
151:21, 151:23,
152:6, 152:7,
153:16, 156:1,
168:19
initial [2] - 128:15,
129:10
initialing [1] - 145:1
Injury [1] - 72:12
innocence [7] - 45:10,
45:15, 45:18, 76:7,
76:25, 77:2, 149:15
innocent [10] - 45:10,
45:13, 64:19, 68:3,
68:5, 76:4, 76:10,
76:11, 123:21
inordinate [2] - 122:3,
125:13
inquiries [1] - 34:12
inquiry [1] - 128:19
insisted [2] - 12:20,
12:23
installing [1] - 58:20
instance [2] - 126:19,
167:15
instances [1] - 126:17
instinct [1] - 76:17
instruct [1] - 124:9
instructed [2] - 125:2,
148:24
instruction [27] - 5:22,
6:3, 6:5, 7:1, 7:22,
7:25, 8:1, 8:5, 8:14,
41:16, 45:20, 45:21,
46:5, 46:9, 47:2,
47:18, 63:3, 64:23,
79:3, 79:5, 79:8,
85:1, 85:6, 121:9,
123:11, 158:7,
158:20
instructions [20] -
7:20, 17:8, 17:11,
22:17, 45:16, 65:25,
68:13, 79:2, 108:14,
109:18, 110:4,
118:15, 121:6,
123:12, 127:10,
129:14, 129:15,
130:14, 130:17,
159:6
intended [1] - 118:23
intention [1] - 13:13
interaction [1] - 70:3
interchange [1] - 37:7
interest [3] - 38:23,
85:5, 123:16
interesting [2] -
152:20, 153:21
interfere [1] - 57:19
internal [2] - 76:17,
76:21
Internal [7] - 25:1,
28:9, 39:5, 69:24,
70:3, 70:4, 146:21
International [1] -
67:9
internet [2] - 126:9,
142:24
Internet [1] - 142:23
interpret [1] - 117:20
interpreter [1] -
137:18
interruptions [1] -
10:16
interrupts [1] - 49:14
interstate [1] - 136:14
introduce [6] - 23:4,
23:15, 23:24, 73:8,
116:22, 152:13
introduced [4] - 20:8,
23:11, 49:6, 73:8
introduction [1] - 3:12
introductions [3] -
23:5, 23:13, 23:14
invade [2] - 79:23,
79:24
invested [1] - 58:9
investigating [1] -
67:16
investigation [3] -
126:12, 126:16,
126:24
Investigation [1] -
66:23
involve [3] - 20:24,
48:22, 48:23
involved [11] - 20:19,
32:14, 47:6, 66:3,
66:7, 137:19,
139:19, 139:20,
139:25, 141:14,
141:15
involvement [2] -
141:8, 155:20
involves [4] - 20:7,
20:9, 20:18, 48:21
involving [2] - 22:9,
114:2
IP [15] - 142:13,
142:17, 142:20,
142:23, 143:1,
143:3, 143:5, 143:6,
143:8, 143:11,
181
143:16, 145:16,
146:1, 146:3, 151:4
iPads [1] - 126:10
iPhones [1] - 126:10
Israel [1] - 52:25
issue [35] - 6:25, 9:20,
14:8, 39:16, 49:21,
50:1, 50:5, 50:11,
51:12, 51:15, 52:2,
55:6, 55:10, 55:15,
57:2, 57:25, 58:24,
62:7, 83:25, 87:10,
87:11, 88:4, 89:4,
89:18, 92:11, 94:12,
96:17, 98:8, 99:22,
120:13, 140:2,
150:21, 159:24,
160:1, 166:8
issues [22] - 7:2, 10:3,
10:7, 27:21, 32:14,
49:13, 49:16, 52:23,
60:20, 87:4, 87:25,
88:24, 89:23, 90:10,
95:9, 118:9, 129:1,
129:2, 129:3, 160:8,
166:14
IT [1] - 61:3
items [5] - 5:2, 49:1,
119:6, 121:7, 121:16
itself [3] - 63:9,
123:24, 125:21
IV [2] - 21:25, 22:1
IX [1] - 22:12
J
Jack [2] - 60:9, 68:22
jails [1] - 131:12
Jamel [6] - 149:23,
153:15, 155:1,
155:4, 155:9, 155:12
James [3] - 2:4, 61:1,
169:17
Jencks [4] - 168:7,
168:12, 168:13,
168:25
Jenkins [1] - 61:5
Jesuit [1] - 60:16
Jewish [3] - 55:5,
87:13, 90:19
Jimmy [2] - 34:25,
56:9
Joanna [1] - 25:6
job [2] - 49:4, 95:2
jobs [1] - 127:15
John [1] - 34:4
Johnny [2] - 1:18,
73:9
joining [1] - 57:14
joint [1] - 148:15
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Jose [2] - 42:20,
108:24
Joseph [1] - 109:3
journey [1] - 59:14
Jr [1] - 1:18
judge [25] - 15:17,
34:1, 34:5, 34:18,
48:5, 48:7, 79:21,
89:2, 90:16, 91:23,
92:21, 97:11, 97:23,
98:16, 99:13,
101:20, 101:25,
103:10, 103:16,
105:2, 106:5, 121:3,
127:16, 140:24,
151:12
Judge [47] - 3:8, 3:14,
4:22, 5:4, 9:13, 9:17,
10:1, 10:12, 13:19,
14:5, 17:14, 18:9,
24:8, 34:20, 69:24,
73:21, 74:25, 75:24,
76:15, 79:21, 85:8,
85:9, 88:3, 89:16,
90:18, 92:12, 94:20,
95:22, 96:16, 97:15,
98:23, 99:19,
100:18, 101:8,
102:9, 102:17,
103:5, 105:16,
107:17, 107:22,
108:6, 130:18,
157:1, 165:10,
167:5, 168:3
JUDGE [1] - 1:11
judges [9] - 19:15,
48:4, 79:14, 79:15,
118:18, 127:15,
158:13
judging [1] - 46:24
judgment [1] - 39:13
judicial [2] - 40:19,
41:13
jump [1] - 89:10
June [2] - 115:24,
135:16
Junior [1] - 73:9
juries [2] - 28:1, 39:17
Juries [1] - 41:20
jurisdiction [1] - 19:6
jurisdictions [1] -
128:16
Juror [23] - 32:5, 36:9,
45:1, 52:1, 59:5,
61:9, 61:23, 63:6,
65:19, 67:7, 75:22,
82:15, 83:9, 89:25,
90:15, 97:25,
101:20, 103:16,
104:15, 107:11,
107:22, 108:15
juror [29] - 18:4,
27:20, 31:24, 32:20,
36:12, 37:14, 37:21,
39:23, 39:24, 43:21,
50:17, 51:11, 52:25,
60:8, 62:24, 68:22,
71:3, 91:13, 91:14,
91:18, 95:23, 96:18,
101:12, 104:5,
104:16, 107:16,
108:10, 124:13,
126:19
JUROR [225] - 26:1,
26:4, 26:8, 26:11,
26:13, 26:15, 26:17,
26:24, 27:4, 27:7,
27:10, 27:17, 27:22,
28:17, 28:19, 28:25,
29:7, 29:11, 29:14,
29:17, 29:25, 30:5,
30:14, 30:24, 31:2,
31:13, 31:15, 31:21,
31:25, 32:4, 32:7,
32:12, 32:17, 32:21,
33:1, 33:6, 33:18,
34:25, 35:6, 35:10,
35:12, 35:15, 35:22,
36:4, 36:13, 36:19,
36:21, 36:23, 36:25,
37:3, 37:8, 37:10,
37:12, 37:15, 42:18,
42:20, 42:23, 42:25,
43:10, 43:12, 43:15,
43:18, 43:20, 43:24,
44:1, 44:5, 44:8,
44:10, 44:12, 44:16,
44:19, 44:21, 45:1,
51:11, 51:17, 51:19,
52:1, 52:11, 52:13,
52:16, 52:25, 53:5,
53:9, 53:13, 54:19,
54:23, 54:25, 55:4,
55:9, 55:15, 55:19,
55:25, 56:3, 56:7,
56:9, 56:12, 56:18,
56:23, 57:3, 57:5,
57:8, 57:12, 57:14,
57:21, 57:24, 58:2,
58:6, 58:16, 58:19,
58:22, 58:23, 59:4,
59:10, 59:13, 59:17,
59:21, 59:24, 60:2,
60:5, 60:8, 60:22,
61:2, 61:5, 61:8,
61:9, 61:17, 61:21,
61:23, 62:2, 63:6,
63:18, 63:23, 64:3,
64:6, 64:9, 64:17,
64:22, 65:1, 65:8,
65:15, 65:20, 66:6,
66:12, 67:7, 67:13,
67:18, 67:23, 68:4,
68:7, 68:11, 68:14,
68:22, 69:3, 69:7,
69:10, 69:13, 69:15,
69:17, 69:23, 70:15,
70:24, 71:1, 71:3,
71:15, 71:18, 71:21,
72:6, 72:8, 72:10,
72:13, 72:15, 72:19,
73:25, 74:2, 74:7,
74:11, 74:14, 74:18,
74:20, 75:3, 75:5,
76:1, 76:5, 76:8,
76:14, 77:25, 78:2,
78:10, 78:19, 78:24,
80:2, 80:8, 80:15,
80:19, 80:21, 81:2,
81:5, 81:9, 81:12,
81:14, 81:25, 82:6,
82:8, 82:10, 82:15,
82:24, 83:3, 83:6,
83:9, 83:13, 83:16,
83:18, 83:22, 84:5,
84:8, 84:15, 84:17,
84:19, 90:4, 90:8,
90:11, 98:4, 98:6,
98:12, 130:7
jurors [32] - 5:13,
5:22, 10:24, 17:19,
17:21, 18:17, 22:24,
23:18, 34:6, 34:7,
34:8, 34:16, 38:3,
39:15, 49:20, 54:5,
62:20, 75:17, 79:12,
79:15, 85:16, 85:17,
86:3, 86:19, 102:13,
104:20, 109:24,
110:11, 124:8,
126:18, 126:20
JURY [3] - 1:10, 18:5,
118:12
jury [61] - 4:16, 4:24,
5:1, 5:6, 9:2, 9:6,
27:9, 34:10, 40:12,
40:16, 40:21, 41:20,
41:22, 42:2, 42:4,
42:6, 42:10, 43:5,
50:15, 51:12, 54:7,
55:21, 74:22, 74:24,
75:9, 75:12, 75:18,
75:20, 83:21, 85:13,
86:5, 87:23, 91:5,
91:11, 107:9,
107:18, 110:1,
110:7, 117:16,
117:22, 118:2,
118:3, 118:14,
124:19, 124:21,
126:18, 127:21,
130:24, 140:24,
148:23, 158:7,
158:11, 158:14,
159:19, 159:20,
160:2, 165:9, 168:5,
168:17, 168:18
Jury [2] - 3:2, 111:14
jury's [1] - 167:22
justice [3] - 46:11,
47:3, 48:18
Justice [4] - 2:4,
66:24, 151:14,
169:17
K
keen [1] - 62:16
keep [30] - 7:25,
10:14, 11:23, 18:23,
19:18, 20:5, 20:16,
23:1, 39:19, 41:25,
46:20, 46:25, 48:16,
49:14, 53:7, 59:19,
92:16, 94:13,
118:20, 119:11,
119:25, 122:18,
123:20, 124:7,
124:19, 125:1,
126:2, 132:6,
132:11, 142:18
Kelly [2] - 24:5, 25:16
Kendall [3] - 59:13,
59:14
kept [6] - 121:21,
141:25, 142:16,
142:17, 142:18,
145:12
Key [2] - 19:7, 19:9
kids [1] - 88:11
kind [4] - 50:23, 61:12,
77:1, 82:1
kinds [2] - 122:20,
153:4
King [2] - 2:4, 169:17
King's [1] - 30:10
knowing [5] - 63:11,
65:2, 70:20, 74:18,
149:25
knowingly [1] -
149:24
knowledge [3] - 6:14,
7:11, 154:8
known [6] - 18:11,
25:14, 131:10,
132:1, 137:4, 149:21
knows [2] - 77:14,
168:12
Korean [1] - 50:22
182
L
lack [1] - 96:13
Ladies [1] - 109:25
ladies [31] - 17:24,
18:7, 23:3, 25:18,
37:20, 39:21, 45:23,
62:14, 85:10, 86:8,
109:14, 109:21,
118:6, 149:19,
150:6, 151:19,
152:11, 153:16,
153:21, 154:3,
154:21, 154:22,
156:7, 156:12,
156:24, 157:14,
158:6, 158:11,
158:15, 158:21,
159:1
lady [6] - 58:24,
149:20, 152:2,
152:9, 153:10, 154:9
laid [1] - 121:17
Lakeland [2] - 69:5,
69:7
landline [2] - 142:21,
142:22
language [4] - 50:1,
50:4, 50:5, 50:11
large [1] - 126:23
last [12] - 3:23, 25:15,
86:16, 90:12, 94:16,
94:18, 103:15,
116:14, 117:1,
140:18, 144:24,
164:23
late [3] - 49:22, 53:13,
93:15
latest [1] - 51:15
Lauderdale [2] - 1:17,
19:11
Laura [2] - 61:23,
105:1
law [63] - 20:10, 21:4,
22:17, 22:18, 22:21,
22:22, 22:23, 22:25,
23:1, 33:4, 38:1,
45:20, 46:7, 47:2,
47:18, 47:19, 47:20,
47:21, 47:23, 47:25,
48:1, 48:3, 48:7,
48:8, 48:9, 48:11,
48:12, 49:1, 56:5,
66:25, 67:10, 77:8,
77:10, 77:16, 79:9,
79:11, 79:21, 79:22,
95:25, 97:8, 104:6,
106:23, 107:19,
107:23, 118:19,
118:21, 121:3,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 182 of
195
124:3, 124:25,
127:11, 127:12,
127:13, 127:16,
129:14, 130:25,
131:3, 136:5,
148:25, 156:22
lawful [1] - 152:7
laws [2] - 48:24, 49:3
lawsuit [2] - 41:2, 66:3
lawsuits [1] - 66:8
lawyer [10] - 26:17,
27:13, 32:25, 38:10,
84:3, 120:7, 120:24,
121:3, 121:4, 128:10
lawyers [19] - 14:19,
14:23, 20:20, 62:12,
110:5, 118:25,
119:7, 119:8,
119:16, 119:23,
120:4, 120:16,
121:15, 122:4,
123:1, 126:14,
127:25, 129:1, 129:4
lay [1] - 122:2
lead [3] - 14:24, 23:6,
114:19
leading [1] - 83:18
leaning [1] - 82:2
learn [6] - 133:22,
140:13, 140:18,
143:19, 143:20,
150:24
learned [4] - 150:8,
150:9, 153:15, 167:6
lease [2] - 73:20
least [12] - 11:24,
16:8, 27:23, 72:24,
73:17, 132:24,
150:14, 154:4,
155:4, 161:5, 167:23
leave [8] - 51:9, 51:15,
53:8, 86:18, 86:24,
87:24, 92:10, 168:20
leaves [1] - 101:4
leaving [4] - 56:25,
57:5, 60:1, 60:2
Lee [1] - 28:17
left [3] - 42:3, 121:13,
144:13
legal [11] - 32:14,
37:18, 39:22, 50:2,
73:11, 73:15, 129:1,
129:2, 129:3, 152:7,
152:25
legitimate [2] - 153:8,
153:10
legitimately [1] -
155:24
lender [2] - 142:7,
145:24
lenders [6] - 112:20,
133:2, 133:3, 133:9,
145:24, 146:11
lengthy [1] - 124:18
less [1] - 70:11
letting [1] - 69:17
level [2] - 77:17,
113:16
Lewis [1] - 61:3
liberty [1] - 41:13
license [1] - 144:16
lied [2] - 131:1, 154:13
lies [1] - 131:21
life [1] - 72:25
light [1] - 159:13
likely [7] - 10:10, 16:6,
16:7, 41:1, 41:4,
49:12, 89:7
limited [2] - 115:10,
121:8
Linda [2] - 25:2
Lindsey [1] - 24:19
line [2] - 42:15, 62:6
lined [1] - 14:4
linked [1] - 142:7
liquid [1] - 159:16
Lisandra [2] - 30:5,
30:24
list [23] - 6:23, 6:24,
7:10, 11:11, 23:8,
24:11, 68:16, 85:16,
85:23, 122:16,
160:14, 160:19,
161:2, 161:16,
162:4, 162:11,
162:17, 162:23,
163:4, 163:10,
163:24, 164:5,
164:16
listen [26] - 15:24,
18:15, 19:1, 19:12,
23:10, 23:13, 29:9,
30:16, 33:3, 33:14,
35:11, 37:17, 38:6,
49:4, 49:6, 52:24,
62:14, 63:3, 64:24,
65:24, 79:16,
117:10, 125:17,
126:3, 126:8, 158:16
Listen [1] - 155:3
listened [2] - 45:17,
50:8
lists [2] - 115:2,
150:25
live [3] - 5:10, 5:14,
36:25
lives [1] - 79:4
Livette [11] - 95:23,
97:2, 97:24, 97:25,
98:1, 98:15, 98:20,
99:11, 99:16, 99:22,
107:11
LLC [1] - 24:22
loan [99] - 21:9, 31:16,
31:19, 31:23, 35:4,
35:16, 64:11, 70:14,
70:18, 70:22, 71:4,
71:12, 72:10, 72:12,
72:14, 72:21, 73:14,
81:15, 112:9,
112:20, 112:24,
112:25, 113:4,
113:6, 113:8,
113:11, 113:13,
113:14, 113:20,
114:9, 114:18,
114:24, 115:3,
115:4, 115:21,
116:16, 116:18,
117:5, 131:17,
132:8, 132:11,
132:16, 132:25,
133:6, 133:13,
133:14, 133:17,
134:3, 134:10,
134:20, 135:2,
135:11, 136:18,
138:1, 138:4, 138:9,
138:17, 138:21,
139:19, 141:14,
141:16, 142:2,
143:2, 143:10,
143:14, 143:15,
144:7, 144:10,
144:25, 145:5,
145:12, 145:13,
145:17, 145:19,
145:20, 146:7,
146:10, 147:4,
147:22, 150:19,
152:15, 154:8,
155:10, 157:10,
165:11, 165:12,
165:14
loans [53] - 7:7, 7:11,
21:6, 21:8, 21:9,
22:1, 29:1, 29:4,
47:6, 47:8, 48:25,
71:1, 71:17, 72:1,
72:21, 73:24, 77:22,
112:19, 113:7,
113:19, 113:20,
114:2, 116:23,
131:1, 132:8,
132:15, 132:18,
133:12, 134:7,
134:9, 135:15,
135:16, 135:20,
136:7, 136:9, 137:3,
137:20, 141:5,
141:21, 141:24,
148:20, 148:21,
149:25, 150:11,
153:13, 155:1,
155:2, 155:4, 155:9,
156:16, 165:16
Loans [4] - 24:24,
28:9, 28:22, 131:16
local [2] - 66:25, 77:17
location [2] - 59:12,
142:22
location-wise [1] -
59:12
log [3] - 139:1, 139:3,
144:4
log-in [1] - 144:4
logged [5] - 142:5,
144:6, 144:7, 144:9,
144:22
logging [3] - 142:12,
142:16, 143:12
login [1] - 151:21
look [17] - 5:18, 8:1,
26:24, 52:14, 53:24,
54:1, 62:4, 86:13,
99:10, 103:1,
104:17, 106:21,
107:15, 142:11,
157:23, 159:17,
161:19
looked [2] - 74:5,
89:12
looking [5] - 26:2,
26:23, 126:13,
160:18, 161:8
looks [1] - 112:8
losses [1] - 150:25
lost [2] - 16:14, 167:7
Louis [1] - 61:1
Lourdes [3] - 51:11,
51:17, 101:6
love [1] - 116:6
LOVE [14] - 23:25,
36:8, 89:20, 92:9,
97:11, 97:15, 97:17,
97:23, 105:4, 105:6,
107:1, 107:25,
108:2, 116:7
Love [6] - 1:14, 23:25,
35:18, 35:21, 36:3,
36:6
lower [2] - 41:24,
41:25
lowest [1] - 41:20
Loynaz [4] - 56:23,
87:10, 109:1, 129:22
luckily [1] - 71:11
lunch [7] - 13:24,
14:5, 108:12,
108:20, 110:13,
124:20, 126:7
183
luncheon [1] - 111:13
M
ma'am [6] - 63:5, 65:9,
67:6, 72:5, 72:9,
81:10
mail [1] - 51:3
mailed [1] - 145:10
major [2] - 60:25, 69:8
mal [1] - 69:8
malpractice [1] - 40:3
man [2] - 149:23,
155:4
manager [2] - 71:5,
74:3
Mandri [4] - 82:15,
109:8, 130:4
manner [1] - 112:22
Marceau [2] - 97:2,
107:11
Mario [1] - 108:25
marked [2] - 122:7,
122:12
married [3] - 25:14,
131:5, 137:4
martial [1] - 40:14
MasterCard [1] - 67:8
materially [1] - 115:7
math [1] - 137:15
matter [4] - 32:12,
52:7, 143:24, 169:11
matters [9] - 3:25,
8:16, 50:2, 110:13,
128:14, 143:25,
160:4, 160:10
Maurice [1] - 61:5
maximum [8] - 129:8,
129:9, 132:20,
132:21, 132:22,
132:23, 134:10,
135:3
McClain [1] - 24:25
McCray [106] - 1:18,
4:22, 9:13, 9:17,
10:1, 12:16, 13:2,
14:4, 15:10, 15:17,
16:19, 31:4, 34:1,
34:4, 34:18, 34:20,
73:7, 73:9, 74:1,
74:5, 74:10, 74:17,
74:19, 74:21, 75:4,
76:2, 76:6, 76:9,
76:23, 78:1, 78:8,
78:18, 78:22, 78:25,
80:9, 80:16, 80:20,
80:25, 81:3, 81:8,
81:10, 81:13, 81:22,
82:4, 82:7, 82:9,
82:13, 82:22, 83:1,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 183 of
195
83:4, 83:8, 83:12,
83:14, 83:17, 83:20,
83:23, 84:6, 84:9,
84:16, 84:18, 84:24,
87:9, 87:12, 87:18,
88:3, 89:2, 89:16,
89:18, 91:23, 92:5,
92:8, 92:12, 92:16,
92:21, 94:9, 94:10,
95:2, 95:7, 95:10,
95:16, 96:16, 97:4,
97:21, 101:8,
101:25, 102:2,
102:24, 103:5,
103:10, 103:16,
104:22, 105:5,
105:14, 105:16,
106:3, 106:5, 106:8,
106:22, 107:4,
107:22, 108:6,
109:13, 130:10,
130:18, 149:9
MCCRAY [6] - 80:3,
88:17, 100:1,
100:12, 107:16,
108:3
mean [14] - 3:16,
15:13, 19:10, 21:1,
26:9, 39:9, 64:1,
65:10, 81:25, 83:25,
84:2, 94:5, 114:5,
117:3
means [27] - 18:11,
21:2, 21:15, 21:16,
40:25, 53:8, 58:7,
65:7, 79:3, 84:4,
84:7, 85:15, 86:24,
91:10, 93:15, 96:1,
106:25, 112:22,
120:19, 120:22,
122:6, 126:22,
127:4, 128:23,
159:3, 160:2, 168:2
meant [1] - 3:16
med [1] - 69:7
medical [1] - 40:3
meeting [2] - 21:2,
141:8
meets [1] - 68:6
Megan [1] - 24:21
Melbourne [2] - 60:5,
94:15
member [9] - 66:2,
68:19, 77:18, 80:11,
82:24, 96:5, 96:14,
97:6, 104:8
members [15] - 23:23,
27:8, 69:18, 77:6,
80:4, 80:13, 106:23,
118:14, 124:10,
130:24, 139:21,
140:24, 148:23,
168:21
memo [3] - 148:12,
148:13, 148:17
memorize [1] - 106:9
mental [1] - 58:12
mention [1] - 102:3
mentioned [7] - 24:9,
25:19, 28:5, 46:4,
76:15, 140:17,
143:18
mentioning [1] - 117:4
messages [3] - 151:9,
151:11, 151:16
met [2] - 141:7, 141:10
Mexico [3] - 61:11,
95:2
MIAMI [1] - 1:2
Miami [19] - 1:4, 2:5,
5:8, 19:2, 19:12,
19:13, 19:20, 24:6,
36:10, 44:13, 53:5,
55:25, 56:1, 60:9,
60:17, 107:23,
108:8, 124:12,
169:18
Miami-Dade [9] - 5:8,
19:2, 19:12, 19:13,
19:20, 36:10, 44:13,
60:9, 107:23
Michael [2] - 24:23,
32:4
microphone [7] -
14:11, 25:24, 28:15,
42:3, 42:7, 42:15,
51:10
midday [1] - 13:24
middle [3] - 11:9,
38:17, 61:13
Middle [1] - 60:17
might [8] - 39:18,
48:11, 50:1, 51:12,
52:2, 53:2, 53:13,
67:4
Mike [1] - 58:23
military [3] - 40:14,
50:19, 102:4
Miller [7] - 31:1, 31:3,
44:22, 45:1, 61:9,
94:24, 95:4
million [1] - 115:15
mind [23] - 7:25,
10:14, 20:5, 20:16,
23:2, 39:20, 42:1,
46:20, 46:25, 47:11,
48:16, 49:14, 53:7,
62:16, 118:20,
119:11, 119:25,
122:18, 123:20,
124:7, 124:20,
125:1, 126:2
minds [1] - 21:3
mine [3] - 56:24, 71:8,
161:6
ministerial [1] - 4:18
minute [3] - 13:1,
90:12, 131:22
minutes [13] - 12:15,
53:6, 53:16, 59:15,
85:12, 86:2, 129:8,
129:10, 129:11,
138:23, 159:12,
160:7
misinformed [1] -
64:7
misnumbered [1] -
4:8
misrepresent [1] -
17:6
miss [3] - 10:24,
16:21, 90:21
missed [1] - 30:21
missing [3] - 10:23,
130:6, 130:11
mistrial [3] - 9:6, 34:5,
126:21
misunderstanding [1]
- 165:23
model [4] - 142:14,
142:15, 144:20
models [1] - 143:22
moment [15] - 36:15,
37:1, 37:4, 56:10,
65:9, 70:25, 71:2,
72:7, 108:22, 112:6,
114:13, 135:1,
135:21, 141:22
momentarily [1] - 20:8
moments [3] - 71:12,
119:15, 127:24
Monday [16] - 10:18,
10:19, 19:24, 19:25,
20:3, 20:4, 49:9,
58:20, 61:15, 61:16,
61:17, 61:24, 97:12,
97:20, 97:22
Monday's [1] - 12:20
money [22] - 71:24,
82:20, 82:25, 132:4,
132:11, 133:14,
133:16, 133:24,
135:19, 138:9,
138:10, 142:8,
148:1, 150:2,
150:16, 152:10,
154:2, 154:23,
155:12, 155:23,
157:19
monitor [1] - 19:15
month [3] - 56:17,
140:19, 154:12
months [1] - 149:10
mope [1] - 155:12
moral [2] - 62:22,
65:23
morning [38] - 3:3,
5:6, 12:12, 13:5,
13:17, 14:12, 14:13,
15:12, 15:13, 15:14,
18:6, 18:13, 20:20,
23:18, 23:25, 24:4,
29:24, 44:1, 44:5,
44:21, 51:11, 52:1,
59:4, 60:8, 60:16,
61:9, 62:19, 66:7,
83:9, 93:11, 124:21,
125:4, 126:2, 126:6,
159:10, 159:17,
160:6, 169:3
Morrow [1] - 25:4
most [10] - 11:15,
11:16, 18:21, 40:4,
49:18, 60:22, 64:12,
70:2, 72:24, 90:12
mother [9] - 44:17,
56:5, 60:18, 88:15,
88:18, 88:19,
106:20, 107:1, 107:3
mother's [2] - 88:17,
107:4
mother-in-law [1] -
56:5
motion [1] - 4:17
motive [6] - 84:7,
84:13, 84:16, 84:19,
84:23
Motive [1] - 84:15
move [10] - 31:7,
91:12, 91:25, 94:14,
94:17, 94:22, 99:3,
105:4, 130:8, 130:9
moved [4] - 105:6,
105:7, 110:15,
110:16
movie [1] - 47:9
moving [3] - 91:23,
97:23, 111:23
MR [386] - 3:8, 3:13,
3:22, 4:5, 4:8, 4:20,
4:22, 5:4, 6:9, 6:18,
7:5, 7:14, 8:3, 8:11,
8:15, 9:1, 9:5, 9:13,
9:17, 10:1, 10:12,
10:22, 11:3, 12:4,
12:7, 12:10, 12:15,
12:16, 12:25, 13:2,
13:13, 13:18, 14:4,
14:9, 14:13, 14:16,
14:18, 14:21, 15:1,
184
15:3, 15:5, 15:9,
15:12, 15:14, 15:17,
15:21, 15:23, 16:14,
16:17, 16:23, 16:25,
17:5, 17:14, 17:16,
23:17, 23:25, 24:8,
26:12, 30:20, 34:1,
34:4, 34:18, 34:20,
36:8, 62:19, 63:15,
63:19, 63:25, 64:5,
64:8, 64:15, 64:18,
65:19, 65:22, 66:10,
66:13, 67:11, 67:17,
67:20, 68:2, 68:5,
68:9, 68:12, 68:17,
69:1, 69:6, 69:9,
69:11, 69:14, 69:16,
69:21, 69:24, 70:17,
71:14, 71:16, 71:19,
71:23, 72:9, 72:12,
72:14, 72:16, 72:20,
73:7, 74:1, 74:5,
74:10, 74:17, 74:19,
74:21, 75:4, 75:6,
76:2, 76:6, 76:9,
76:23, 78:1, 78:8,
78:18, 78:22, 78:25,
80:3, 80:9, 80:16,
80:20, 80:25, 81:3,
81:8, 81:10, 81:13,
81:22, 82:4, 82:7,
82:9, 82:13, 82:22,
83:1, 83:4, 83:8,
83:12, 83:14, 83:17,
83:20, 83:23, 84:6,
84:9, 84:16, 84:18,
84:24, 87:8, 87:9,
87:11, 87:12, 87:15,
87:16, 87:18, 87:19,
87:23, 88:3, 88:6,
88:7, 88:10, 88:14,
88:17, 88:18, 88:22,
89:1, 89:2, 89:15,
89:16, 89:18, 89:20,
90:16, 90:18, 91:1,
91:7, 91:15, 91:23,
92:5, 92:8, 92:9,
92:10, 92:12, 92:16,
92:21, 92:25, 93:3,
93:6, 93:8, 93:14,
93:17, 93:25, 94:1,
94:3, 94:7, 94:10,
94:20, 94:21, 94:25,
95:2, 95:5, 95:7,
95:10, 95:16, 95:17,
95:20, 95:22, 96:3,
96:10, 96:13, 96:16,
96:21, 97:1, 97:4,
97:5, 97:11, 97:15,
97:17, 97:20, 97:21,
97:22, 97:23, 98:14,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 184 of
195
98:16, 98:20, 98:23,
99:1, 99:4, 99:7,
99:13, 99:16, 99:19,
99:21, 99:24, 100:1,
100:3, 100:5,
100:12, 100:15,
100:18, 100:20,
100:23, 100:25,
101:2, 101:5, 101:6,
101:8, 101:12,
101:16, 101:23,
101:25, 102:2,
102:9, 102:12,
102:17, 102:19,
102:22, 102:24,
103:3, 103:5, 103:8,
103:10, 103:13,
103:16, 103:20,
103:22, 103:25,
104:2, 104:4,
104:12, 104:22,
104:24, 105:2,
105:4, 105:5, 105:6,
105:10, 105:12,
105:16, 105:18,
105:22, 106:1,
106:3, 106:4, 106:5,
106:6, 106:8, 106:9,
106:10, 106:11,
106:15, 106:18,
106:22, 107:1,
107:4, 107:5,
107:10, 107:13,
107:14, 107:16,
107:21, 107:22,
107:25, 108:2,
108:3, 108:5, 108:6,
110:14, 110:19,
110:25, 111:3,
111:10, 111:20,
111:23, 112:5,
112:9, 112:13,
112:15, 112:25,
113:6, 113:13,
113:16, 113:22,
114:4, 114:12,
114:14, 114:17,
114:21, 114:23,
116:4, 116:6, 116:7,
116:11, 116:13,
117:8, 117:9,
117:21, 117:24,
130:15, 130:18,
130:20, 130:22,
130:24, 149:9,
159:23, 160:12,
160:17, 160:20,
160:24, 161:1,
161:4, 161:8,
161:13, 161:15,
161:21, 161:23,
162:2, 162:4,
162:10, 162:16,
162:22, 163:3,
163:9, 163:12,
163:18, 163:23,
164:4, 164:10,
164:15, 164:20,
164:22, 165:1,
165:7, 165:18,
165:21, 165:25,
166:5, 166:7,
166:10, 166:16,
166:18, 167:5,
167:10, 167:19,
168:4, 168:8, 168:15
multiple [2] - 134:7,
143:8
murder [1] - 84:20
Musil [1] - 24:21
must [12] - 45:10,
45:13, 47:13, 48:3,
49:1, 51:20, 118:20,
119:13, 121:5,
122:19, 123:20,
158:9
N
name [54] - 5:14,
14:10, 18:8, 23:18,
23:25, 24:4, 24:13,
25:12, 25:25, 26:1,
26:10, 26:20, 28:16,
28:17, 30:20, 30:23,
31:12, 32:3, 32:4,
34:25, 35:15, 35:19,
35:23, 36:13, 42:20,
43:9, 43:20, 44:5,
44:21, 44:24, 51:16,
53:19, 55:3, 56:23,
57:11, 59:4, 59:21,
61:23, 63:5, 67:7,
73:9, 74:21, 81:20,
82:11, 83:11,
107:16, 132:3,
134:14, 135:4,
149:20, 149:23,
153:19
named [12] - 134:13,
134:17, 134:18,
134:24, 135:8,
135:9, 135:13,
137:4, 145:22,
147:1, 147:2, 147:8
names [9] - 23:7,
25:19, 25:21, 35:24,
108:17, 126:13,
153:13, 156:20,
156:21
nature [1] - 88:10
navigate [1] - 74:9
navigated [1] - 71:6
NE [2] - 2:4, 169:17
near [1] - 7:2
nearby [1] - 55:24
necessarily [2] - 39:9,
120:13
necessary [1] - 85:21
necessity [1] - 122:2
need [12] - 20:1,
22:25, 49:18, 49:19,
52:20, 86:24, 91:18,
101:15, 126:15,
159:25, 160:1, 168:4
needed [3] - 12:23,
33:8, 133:8
needs [2] - 58:13,
159:24
negative [1] - 70:5
neglected [1] - 102:3
nephew [3] - 96:1,
96:12, 98:2
nervous [1] - 130:11
network [1] - 146:13
neutral [2] - 100:8,
104:12
never [8] - 16:3,
138:14, 151:20,
152:19, 152:24,
155:8, 156:18, 158:5
new [2] - 71:5, 126:9
news [3] - 19:1,
125:20, 126:2
newspaper [2] - 47:8,
125:23
Next [1] - 109:11
next [43] - 12:19,
12:23, 13:4, 20:3,
24:21, 24:23, 24:25,
25:2, 25:4, 25:6,
25:10, 25:12, 42:7,
43:2, 45:23, 49:10,
50:25, 51:14, 52:23,
53:3, 55:4, 56:4,
58:8, 58:11, 58:17,
58:19, 58:24, 59:3,
59:6, 59:8, 59:22,
86:15, 87:16, 87:19,
91:3, 91:8, 93:10,
93:14, 105:8, 115:7,
120:25, 159:4,
168:12
nicely [1] - 110:17
Nicholas [2] - 82:15,
109:8
night [2] - 55:8, 60:2
nine [3] - 123:17,
131:5, 149:11
NO [1] - 1:2
nobody's [1] - 73:22
none [5] - 9:22, 11:4,
93:22, 126:14,
167:13
nonprofit [2] - 71:4,
74:2
noon [1] - 14:2
normally [1] - 56:4
north [2] - 19:6, 60:24
North [1] - 108:8
note [2] - 127:20,
164:10
noted [1] - 69:25
notes [4] - 127:17,
127:21, 127:23,
169:12
nothing [10] - 49:2,
68:10, 75:15,
116:23, 117:4,
118:22, 123:23,
123:24, 157:9
notice [15] - 7:12,
16:9, 114:1, 114:5,
114:6, 114:11,
114:15, 114:18,
115:25, 116:20,
117:11, 117:18,
164:12, 165:22,
166:13
noticed [4] - 7:11,
7:18, 111:4, 166:2
noting [1] - 4:15
notions [3] - 47:20,
48:10, 48:13
notwithstanding [1] -
69:11
nowadays [2] - 30:10,
59:15
Number [54] - 7:12,
7:14, 30:24, 36:9,
52:1, 52:25, 56:24,
57:12, 60:9, 61:10,
61:24, 65:19, 65:20,
67:8, 68:22, 75:22,
82:15, 83:9, 87:3,
87:8, 90:18, 91:17,
91:25, 92:1, 92:4,
92:19, 93:22, 94:17,
94:24, 95:23, 99:13,
100:25, 101:8,
101:17, 101:20,
101:21, 102:15,
103:16, 104:7,
104:15, 104:20,
105:22, 107:11,
107:16, 107:22,
108:24, 108:25,
109:1, 109:2, 115:4,
122:7, 129:19
number [47] - 13:8,
17:3, 19:18, 24:9,
185
80:23, 87:13, 87:25,
91:25, 93:12, 95:22,
100:16, 100:20,
100:21, 101:1,
101:3, 101:7,
101:18, 102:2,
103:17, 108:5,
109:3, 109:4, 109:5,
109:6, 109:7, 109:8,
109:9, 109:10,
113:13, 113:20,
114:9, 115:2, 115:3,
115:5, 129:8,
138:25, 139:3,
139:15, 142:21,
142:22, 147:17,
147:20, 154:15,
161:6, 165:13
number.. [1] - 102:19
numbers [5] - 111:6,
135:13, 137:15,
140:10, 150:14
O
object [1] - 3:17
objecting [2] - 100:9,
117:5
objection [45] - 4:21,
34:11, 34:12, 87:7,
87:15, 88:2, 88:22,
89:1, 90:20, 93:21,
94:5, 94:6, 94:7,
94:21, 95:5, 95:7,
95:15, 95:16, 95:17,
100:6, 100:10,
103:8, 103:13,
105:10, 105:12,
110:16, 110:20,
111:24, 112:1,
112:3, 117:25,
120:19, 120:22,
121:2, 161:24,
162:7, 162:13,
162:19, 162:25,
163:6, 163:15,
163:20, 164:1,
164:7, 164:25
objections [6] - 88:5,
111:9, 117:14,
120:16, 121:4
objective [1] - 132:3
obligation [1] - 52:22
obligations [3] -
50:16, 55:13, 58:11
observe [1] - 123:15
obtain [6] - 21:11,
64:13, 112:19,
113:17, 137:3
obtained [2] - 21:18,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 185 of
195
21:20
obviously [3] - 13:19,
20:9, 167:10
occasion [3] - 39:23,
39:24, 126:7
occasionally [1] -
121:7
occasions [1] - 47:6
occurring [1] - 20:15
occurs [3] - 121:8,
127:20, 160:6
October [4] - 1:5,
14:22, 14:24, 87:10
odd [1] - 106:9
OF [3] - 1:1, 1:4, 1:10
offense [3] - 46:1,
65:10, 65:11
offenses [2] - 115:1,
136:12
offer [6] - 9:1, 9:8, 9:9,
9:14, 164:17, 166:3
offered [2] - 161:22,
161:23
offering [12] - 114:6,
114:7, 162:5,
162:11, 162:18,
162:23, 163:4,
163:13, 163:18,
163:24, 164:5, 166:1
offers [7] - 8:20, 8:21,
8:22, 8:25, 9:12,
9:15
Office [22] - 1:15,
23:20, 24:1, 25:7,
25:8, 26:19, 27:3,
27:19, 28:10, 32:19,
32:22, 33:5, 33:15,
37:23, 38:13, 66:24,
68:18, 68:19, 97:9,
98:3, 98:8, 131:10
office [8] - 24:6, 35:2,
36:25, 53:10, 53:19,
54:13, 61:6, 78:12
officer [8] - 38:9,
77:10, 98:4, 98:6,
106:20, 107:1,
107:4, 153:2
Officer [1] - 57:15
officers [7] - 38:1,
77:8, 77:16, 130:25,
131:3, 131:11,
156:22
Official [2] - 2:2,
169:15
oft [1] - 38:1
oftentimes [1] - 35:24
Ohanian [1] - 101:21
Olga [3] - 31:13,
43:10, 109:4
once [15] - 8:12,
21:21, 21:23, 37:17,
43:15, 43:16, 71:6,
71:7, 72:24, 80:22,
82:17, 86:18,
108:23, 141:7
One [2] - 147:2,
153:11
one [96] - 7:16, 8:3,
11:15, 20:10, 25:23,
27:23, 28:2, 28:15,
30:10, 31:11, 32:1,
34:23, 35:14, 36:11,
37:20, 38:12, 40:13,
42:13, 46:15, 50:25,
51:10, 51:24, 53:18,
55:18, 56:10, 60:16,
61:7, 64:1, 65:9,
70:25, 71:2, 72:7,
72:11, 72:13, 75:7,
75:10, 76:22, 77:4,
80:3, 80:8, 80:23,
83:18, 84:24, 85:4,
85:12, 91:12, 96:23,
96:24, 97:6, 97:9,
98:9, 98:16, 98:20,
102:14, 105:2,
112:6, 112:24,
113:22, 114:13,
115:1, 115:3,
117:19, 120:20,
125:12, 127:14,
127:22, 130:8,
130:9, 132:3,
138:22, 139:1,
139:4, 140:10,
142:13, 143:25,
145:19, 145:20,
146:12, 146:13,
147:17, 147:19,
150:22, 153:4,
153:9, 153:10,
154:7, 154:14,
154:17, 155:18,
158:4, 161:5, 161:6,
166:19, 167:19
one's [1] - 84:16
one-time [3] - 138:22,
139:1, 139:4
ones [4] - 71:13,
71:14, 139:25, 140:3
online [2] - 138:18,
141:18
open [7] - 13:20,
19:12, 47:4, 47:14,
53:11, 53:13, 126:16
opened [1] - 81:15
opening [12] - 3:15,
7:8, 12:13, 20:21,
108:14, 110:5,
119:16, 119:21,
120:2, 128:1,
158:24, 159:8
OPENING [2] -
130:21, 149:8
opens [1] - 58:19
operates [1] - 131:12
operations [2] - 71:5,
74:3
opinion [2] - 76:19,
127:9
opinions [3] - 22:20,
22:22, 48:23
opportunity [12] -
5:19, 34:14, 40:20,
45:5, 85:20, 89:24,
96:4, 96:9, 126:6,
127:6, 128:6, 158:12
opposed [1] - 4:15
opposing [5] - 4:25,
128:13, 159:25,
160:7, 165:5
option [2] - 3:10, 3:21
Order [1] - 3:1
order [3] - 41:3, 65:25,
133:16
ordinary [2] - 121:21,
158:12
originally [2] - 10:4,
69:3
Osorio [2] - 36:14,
101:2
otherwise [6] - 62:23,
114:20, 118:25,
127:1, 159:8, 165:19
Oto [2] - 24:17, 28:8
ought [4] - 22:21,
47:21, 47:25, 48:11
ourselves [1] - 19:14
out-of-town [2] -
11:20, 11:24
outcome [2] - 47:7,
123:16
outside [5] - 85:20,
85:25, 121:10,
122:18, 123:2
overnight [2] - 127:21,
160:6
overrule [1] - 120:19
overruled [2] - 34:12,
100:10
overt [1] - 117:4
own [16] - 22:20,
22:21, 46:12, 48:23,
63:16, 64:11, 65:8,
71:9, 76:17, 126:13,
126:16, 133:1,
137:7, 139:21,
141:14, 152:16
owned [1] - 137:16
owner [6] - 56:13,
63:11, 63:17, 63:20,
64:10, 133:6
owners [6] - 67:14,
70:13, 132:5, 132:6,
132:13, 133:25
owning [1] - 70:17
owns [2] - 70:9, 137:8
P
p.m [16] - 10:5, 10:6,
51:20, 86:3, 86:7,
92:3, 109:24, 110:3,
110:6, 110:9,
110:11, 111:13,
111:16, 118:3,
159:20, 169:6
package [1] - 133:8
packet [1] - 74:25
pads [1] - 127:18
page [31] - 4:2, 4:3,
4:6, 4:18, 114:23,
160:22, 161:1,
161:3, 161:4, 161:5,
161:8, 161:11,
161:15, 161:16,
161:19, 162:3,
162:4, 162:10,
162:16, 162:22,
163:3, 163:9,
163:14, 163:18,
163:23, 164:4,
164:15
Pages [1] - 1:8
paid [11] - 113:5,
113:7, 115:14,
132:10, 132:17,
138:7, 138:8, 140:4,
140:5
Palm [2] - 15:5, 19:11
pandemic [6] - 72:5,
131:2, 131:8, 132:2,
132:7, 153:9
Panel [1] - 108:15
PANEL [2] - 18:5,
118:12
panic [1] - 82:19
paper [2] - 15:3, 78:6
papers [1] - 73:14
paperwork [1] - 61:14
paragraph [3] -
112:23, 115:7,
115:11
parents [1] - 50:22
part [6] - 59:1, 60:23,
117:1, 117:3,
140:21, 145:1
partial [2] - 30:8,
104:5
participated [1] -
186
136:9
participating [1] -
109:22
participation [1] -
118:16
particular [10] - 19:16,
36:2, 47:23, 58:18,
63:2, 63:25, 113:11,
126:18, 142:24,
156:12
particulars [1] - 54:14
parties [5] - 23:4,
28:5, 50:6, 98:11,
125:2
partisan [1] - 38:23
partisans [1] - 38:21
partner [6] - 35:1,
35:2, 56:13, 69:8,
78:11, 90:5
partnered [2] - 133:2,
133:4
parts [1] - 11:12
party [2] - 133:4,
155:18
pass [6] - 25:24,
28:15, 42:3, 42:6,
42:15, 51:10
passcode [1] - 155:25
password [2] -
155:25, 157:8
passwords [1] -
151:22
past [1] - 121:11
patients [1] - 55:19
Patricia [1] - 169:11
PATRICIA [1] - 169:15
pay [3] - 132:18,
133:18, 157:19
Paycheck [9] - 7:15,
21:8, 28:22, 70:21,
131:1, 131:16,
131:22, 131:25,
148:3
paychecks [5] - 132:4,
132:12, 148:4,
148:6, 148:8
paying [1] - 78:2
payment [2] - 147:21,
150:17
payroll [7] - 115:15,
115:19, 132:9,
132:11, 133:15,
133:16, 148:17
pays [1] - 70:1
peers [1] - 158:14
pencils [1] - 127:18
people [30] - 5:10,
16:25, 35:25, 38:14,
46:1, 48:15, 50:21,
63:12, 74:3, 82:4,
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91:4, 99:25, 114:1,
124:15, 137:1,
137:20, 139:19,
151:17, 153:5,
153:24, 154:8,
154:19, 154:20,
155:13, 155:20,
155:21, 156:21
people's [1] - 106:7
per [1] - 146:18
percent [5] - 33:23,
41:6, 41:7, 67:24,
133:15
peremptories [1] -
103:18
peremptory [17] -
99:14, 99:18,
100:11, 100:19,
101:3, 101:9,
101:14, 101:17,
101:22, 102:9,
102:16, 102:25,
103:15, 103:20,
104:2, 104:4, 105:18
PEREZ [21] - 12:25,
14:9, 14:13, 14:16,
14:18, 14:21, 15:1,
15:3, 15:5, 15:9,
15:12, 15:14, 15:21,
15:23, 16:14, 16:17,
16:23, 16:25, 17:5,
17:14, 17:16
Perez [1] - 15:17
perfect [2] - 30:6, 43:2
perfectly [1] - 47:24
perhaps [5] - 13:24,
53:14, 96:10,
149:18, 158:3
period [5] - 10:21,
21:9, 113:1, 139:11,
167:15
permanent [2] - 86:19,
102:13
person [31] - 24:13,
26:25, 35:8, 36:7,
38:4, 38:8, 39:13,
41:2, 42:7, 43:2,
45:9, 46:2, 46:16,
46:19, 46:25, 65:14,
80:8, 82:3, 93:10,
100:1, 106:1, 106:4,
106:16, 107:10,
125:6, 137:25,
144:5, 144:17,
150:4, 158:8
person's [2] - 77:19,
132:20
persona [1] - 144:16
Persona [2] - 24:20,
28:8
personal [12] - 6:14,
22:22, 35:19, 48:23,
56:16, 62:5, 63:20,
65:3, 97:16, 123:16,
148:15, 168:19
personally [2] - 49:2,
93:5
persons [11] - 21:3,
23:11, 25:19, 34:13,
39:12, 48:17, 77:23,
78:15, 107:9,
107:18, 136:4
peruse [1] - 104:14
pharmacy [1] - 106:22
phase [4] - 8:2, 41:16,
46:5, 123:12
phases [1] - 128:15
Philadelphia [1] -
11:14
philosophical [2] -
62:22, 65:23
phone [23] - 17:3,
19:18, 27:1, 78:3,
78:8, 78:10, 138:25,
139:3, 139:5, 139:8,
139:9, 139:10,
139:13, 139:14,
139:15, 142:15,
142:19, 143:9,
143:18, 146:3,
151:10, 154:18
phony [1] - 148:8
photo [1] - 144:16
physical [1] - 57:17
pick [7] - 18:19, 38:24,
39:11, 55:16, 62:12,
88:11, 104:18
picked [1] - 50:21
pictures [2] - 144:14,
144:15
Pierce [1] - 19:11
Pivnik [4] - 28:17,
29:13, 73:23, 93:22
pivotal [2] - 149:19,
150:21
place [4] - 3:4, 58:12,
134:8, 135:20
plaintiff [2] - 41:1,
66:15
plaintiff's [1] - 26:17
plan [9] - 13:23, 13:25,
116:21, 136:6,
136:13, 136:15,
159:5, 159:12
plane [1] - 61:20
planned [8] - 10:4,
51:13, 54:20, 59:25,
60:3, 61:25, 97:12,
105:3
plans [5] - 52:4, 52:6,
59:22, 94:25, 97:20
Plantation [1] - 1:21
play [1] - 82:4
plea [9] - 9:1, 9:8, 9:9,
140:19, 140:20,
140:22, 156:24,
157:23, 158:8
pleaded [3] - 140:13,
140:14, 140:18
pleading [1] - 116:3
pleas [1] - 149:12
pleased [2] - 3:3,
50:13
pleases [1] - 157:22
pleasure [1] - 94:19
pled [1] - 140:15
plenty [2] - 28:1,
124:18
PM [1] - 1:6
point [16] - 8:3, 13:14,
13:16, 34:6, 38:24,
39:11, 57:25, 71:11,
85:1, 85:17, 85:21,
91:18, 121:5,
139:16, 145:4,
165:10
pointers [2] - 37:25,
39:20
points [1] - 79:9
police [7] - 6:14, 38:9,
77:17, 98:4, 98:6,
153:2
Police [2] - 107:23,
108:8
Pompano [1] - 1:19
pose [1] - 120:16
position [9] - 8:5,
41:7, 91:22, 93:13,
93:16, 95:13,
104:21, 110:22
positions [2] - 20:22,
88:25
possible [6] - 12:5,
16:12, 24:21, 25:12,
64:13, 133:24
possibly [3] - 36:6,
58:1, 62:15
post [1] - 125:18
post-trial [1] - 125:18
postponement [1] -
58:14
potential [4] - 24:19,
25:15, 36:4, 39:5
potentially [1] - 91:14
Power's [1] - 169:11
POWERS [1] - 2:2
Powers [1] - 169:11
PPP [106] - 21:6, 21:8,
21:12, 29:1, 29:4,
31:19, 35:2, 35:4,
35:17, 47:6, 47:8,
48:24, 70:14, 70:18,
71:24, 72:21, 73:24,
77:22, 78:3, 78:12,
112:9, 112:19,
112:20, 112:25,
113:8, 114:24,
115:4, 115:6, 115:8,
115:9, 115:10,
115:12, 115:13,
115:16, 115:20,
115:21, 115:22,
116:16, 116:18,
131:17, 131:25,
132:8, 132:15,
132:16, 133:12,
133:13, 133:15,
133:19, 133:21,
134:3, 134:10,
134:20, 135:2,
135:11, 135:15,
136:7, 136:9,
136:18, 137:3,
137:20, 138:1,
138:4, 138:9,
138:10, 138:17,
138:21, 139:19,
141:5, 141:14,
141:16, 141:20,
141:24, 142:2,
143:2, 143:10,
143:14, 143:22,
144:2, 144:4, 144:7,
144:10, 144:25,
145:5, 145:12,
145:13, 145:17,
145:19, 145:20,
146:7, 146:10,
147:4, 147:22,
148:1, 148:20,
149:25, 152:15,
153:13, 155:2,
155:9, 156:16,
157:10, 165:11,
166:23
PPPs [1] - 78:3
pre [1] - 125:18
pre-trial [1] - 125:18
precise [2] - 13:3,
160:16
precisely [2] - 14:25,
116:21
predetermined [2] -
63:9, 65:13
predict [1] - 10:8
predicted [1] - 11:6
preemptory [1] -
99:12
preface [1] - 66:13
preference [1] - 11:22
187
preliminary [5] - 3:25,
97:12, 108:13,
118:15, 130:16
preparation [1] -
88:24
prepare [1] - 78:16
prepared [9] - 73:1,
73:24, 74:6, 77:22,
140:16, 151:3,
151:6, 156:2, 164:23
preparer [1] - 73:1
preparing [1] - 78:4
preplanned [2] - 57:6,
61:24
preponderance [4] -
40:24, 40:25, 41:3,
41:24
presence [2] - 34:8,
47:14
present [14] - 3:2,
33:13, 48:3, 89:7,
110:5, 111:14,
119:16, 119:24,
128:1, 128:4, 128:6,
128:7, 128:8, 129:4
presented [17] - 5:24,
6:7, 6:13, 6:16, 6:21,
33:11, 33:12, 46:21,
47:4, 47:13, 47:20,
48:9, 124:24,
124:25, 128:21,
129:3, 129:16
presenting [1] -
128:10
preserve [1] - 127:21
presiding [2] - 17:23,
18:9
presume [2] - 45:10,
45:13
presumed [5] - 64:18,
68:3, 76:4, 76:10,
123:21
presumption [5] -
45:15, 76:6, 76:25,
77:2, 149:15
pretty [6] - 10:8,
30:18, 36:15, 37:11,
53:24, 80:9
prevail [2] - 41:3, 68:5
prevent [1] - 62:23
preview [1] - 119:18
previously [10] - 8:17,
10:17, 24:17, 32:8,
37:14, 46:4, 58:24,
75:1, 144:5, 166:20
price [1] - 71:11
primarily [1] - 139:16
primary [1] - 89:4
principle [3] - 45:9,
45:23, 46:6
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 187 of
195
principles [6] - 37:18,
39:22, 45:6, 45:8,
50:2, 50:10
print [2] - 168:23,
168:25
prison [3] - 104:7,
157:18, 158:4
private [8] - 52:17,
52:18, 89:6, 90:3,
90:4, 133:2, 133:3
problem [24] - 22:24,
29:5, 29:8, 29:17,
30:6, 49:24, 50:4,
51:21, 51:22, 55:11,
55:12, 57:4, 60:25,
76:25, 88:9, 89:11,
89:19, 92:3, 92:14,
96:8, 98:10, 124:14,
126:17
problems [5] - 12:9,
49:3, 49:18, 91:2,
100:25
proceed [2] - 110:8,
127:7
proceeding [2] - 3:7,
66:3
proceedings [2] -
169:6, 169:10
process [22] - 18:11,
23:2, 29:22, 35:17,
62:9, 63:11, 71:25,
72:2, 72:16, 74:9,
85:14, 86:9, 129:12,
131:24, 133:13,
138:16, 144:11,
144:12, 144:23,
144:25, 145:1, 145:3
produced [3] - 119:11,
168:9, 168:16
producing [1] -
150:17
profession [1] - 38:10
professionals [1] -
32:23
profits [1] - 150:25
Program [8] - 7:16,
21:8, 57:15, 70:22,
131:1, 131:23,
131:25, 148:3
program [8] - 21:9,
21:12, 71:7, 72:14,
132:1, 132:2, 133:3,
153:25
programs [2] - 7:16,
74:15
progress [1] - 14:20
prohibits [1] - 124:3
project [3] - 61:10,
94:24, 95:3
prolonged [1] - 3:16
prolongs [1] - 54:20
promise [1] - 51:7
promptly [1] - 160:9
proof [18] - 40:19,
40:23, 40:24, 41:10,
41:11, 41:14, 41:15,
41:17, 41:20, 41:21,
41:25, 122:22,
122:24, 123:25,
128:7, 151:13,
154:21
proper [7] - 5:23, 31:9,
120:18, 120:20,
120:23, 120:25,
127:5
properly [1] - 166:2
proponent [1] - 41:1
propose [1] - 97:23
proposed [3] - 5:18,
6:7, 7:21
proposing [2] - 88:21,
110:19
propounded [1] - 18:3
proprietor [6] -
132:14, 132:16,
132:17, 134:11,
134:13, 135:3
proprietors [2] -
132:18, 132:19
prosecution [1] -
23:23
prosecutor [5] -
68:23, 69:2, 69:5,
69:9, 69:20
Prospective [5] -
89:25, 90:15, 97:25,
108:15, 110:11
PROSPECTIVE [225] -
18:5, 26:1, 26:4,
26:8, 26:11, 26:13,
26:15, 26:17, 26:24,
27:4, 27:7, 27:10,
27:17, 27:22, 28:17,
28:19, 28:25, 29:7,
29:11, 29:14, 29:17,
29:25, 30:5, 30:14,
30:24, 31:2, 31:13,
31:15, 31:21, 31:25,
32:4, 32:7, 32:12,
32:17, 32:21, 33:1,
33:6, 33:18, 34:25,
35:6, 35:10, 35:12,
35:15, 35:22, 36:4,
36:13, 36:19, 36:21,
36:23, 36:25, 37:3,
37:8, 37:10, 37:12,
37:15, 42:18, 42:20,
42:23, 42:25, 43:10,
43:12, 43:15, 43:18,
43:20, 43:24, 44:1,
44:5, 44:8, 44:10,
44:12, 44:16, 44:19,
44:21, 45:1, 51:11,
51:17, 51:19, 52:1,
52:11, 52:13, 52:16,
52:25, 53:5, 53:9,
53:13, 54:19, 54:23,
54:25, 55:4, 55:9,
55:15, 55:19, 55:25,
56:3, 56:7, 56:9,
56:12, 56:18, 56:23,
57:3, 57:5, 57:8,
57:12, 57:14, 57:21,
57:24, 58:2, 58:6,
58:16, 58:19, 58:22,
58:23, 59:4, 59:10,
59:13, 59:17, 59:21,
59:24, 60:2, 60:5,
60:8, 60:22, 61:2,
61:5, 61:8, 61:9,
61:17, 61:21, 61:23,
62:2, 63:6, 63:18,
63:23, 64:3, 64:6,
64:9, 64:17, 64:22,
65:1, 65:8, 65:15,
65:20, 66:6, 66:12,
67:7, 67:13, 67:18,
67:23, 68:4, 68:7,
68:11, 68:14, 68:22,
69:3, 69:7, 69:10,
69:13, 69:15, 69:17,
69:23, 70:15, 70:24,
71:1, 71:3, 71:15,
71:18, 71:21, 72:6,
72:8, 72:10, 72:13,
72:15, 72:19, 73:25,
74:2, 74:7, 74:11,
74:14, 74:18, 74:20,
75:3, 75:5, 76:1,
76:5, 76:8, 76:14,
77:25, 78:2, 78:10,
78:19, 78:24, 80:2,
80:8, 80:15, 80:19,
80:21, 81:2, 81:5,
81:9, 81:12, 81:14,
81:25, 82:6, 82:8,
82:10, 82:15, 82:24,
83:3, 83:6, 83:9,
83:13, 83:16, 83:18,
83:22, 84:5, 84:8,
84:15, 84:17, 84:19,
90:4, 90:8, 90:11,
98:4, 98:6, 98:12
prospective [12] -
17:21, 22:24, 23:18,
30:20, 37:21, 54:5,
54:7, 62:20, 86:3,
96:17, 104:5, 109:24
protect [5] - 132:4,
132:12, 148:3,
148:6, 148:8
Protection [9] - 7:15,
21:8, 28:22, 70:22,
131:1, 131:16,
131:23, 131:25,
148:3
prove [6] - 65:11,
76:11, 114:8,
123:25, 149:1, 152:1
proved [2] - 46:3, 46:8
proven [1] - 123:22
proves [2] - 64:20,
123:24
provide [2] - 30:8,
49:17
provided [4] - 67:1,
122:14, 127:18,
138:14
provider [4] - 133:7,
133:10, 141:24,
146:3
providers [2] - 133:4,
133:5
provides [1] - 131:12
providing [1] - 64:12
province [3] - 79:19,
79:23, 79:24
proving [2] - 124:5,
149:16
Public [1] - 159:2
public [2] - 10:13,
61:13
publicity [1] - 125:19
publicized [1] -
125:20
punishment [2] - 5:21,
6:3
purportedly [1] -
115:18
purpose [4] - 112:16,
112:22, 121:8, 138:6
pursuant [3] - 116:22,
116:25, 140:19
push [2] - 13:21,
13:22
put [13] - 12:17, 33:3,
63:20, 65:24, 77:9,
113:25, 117:17,
117:18, 125:14,
132:4, 141:3,
150:14, 152:17
Put [1] - 168:10
putting [1] - 156:20
Q
qualifications [1] -
18:3
qualify [1] - 29:1
quantify [1] - 41:5
quarter [1] - 115:18
188
questionnaire [7] -
5:3, 5:6, 95:23,
96:19, 98:1, 100:7,
104:13
questionnaires [1] -
5:16
questions [23] - 5:15,
5:19, 12:2, 18:2,
18:14, 34:14, 40:18,
42:4, 42:16, 47:22,
53:23, 62:13, 62:15,
73:7, 73:13, 80:3,
90:1, 97:6, 98:13,
98:22, 120:4,
120:16, 128:12
qui [8] - 26:13, 26:15,
26:18, 27:4, 27:9,
92:25, 93:1, 93:7
quick [1] - 5:17
quickly [8] - 7:20,
34:2, 53:25, 54:3,
108:16, 108:17,
132:5, 133:24
quite [3] - 78:9, 86:10,
88:18
R
rabbi [1] - 35:24
race [6] - 99:23, 100:8,
104:12, 106:1,
106:4, 106:14
race-neutral [2] -
100:8, 104:12
races [1] - 106:7
Rachel [2] - 7:12,
25:10
radio [5] - 10:14,
125:20, 125:24,
125:25, 126:1
rained [1] - 123:3
raise [18] - 17:24,
28:14, 39:3, 39:24,
40:12, 40:15, 40:17,
45:21, 46:9, 49:20,
50:6, 50:11, 53:24,
70:13, 73:16,
103:22, 118:6, 160:4
raised [4] - 42:13,
116:15, 128:14,
154:12
raising [1] - 168:24
Ramos [6] - 42:20,
86:22, 87:2, 87:3,
108:24, 129:18
ran [1] - 140:1
Raphael [4] - 31:3,
105:8, 109:12,
130:10
rather [4] - 19:25,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 188 of
195
48:12, 111:1, 121:23
re [1] - 128:17
re-recross [1] - 128:17
reach [8] - 26:18,
42:12, 44:2, 44:23,
45:2, 65:25, 122:4
reached [6] - 42:10,
42:11, 42:23, 43:24,
44:6, 124:19
reaching [1] - 124:4
read [18] - 6:13, 47:8,
64:16, 67:4, 71:10,
73:14, 73:15, 73:20,
107:2, 114:21,
117:12, 125:17,
125:24, 126:3,
126:8, 127:22,
129:15, 158:19
reading [5] - 72:22,
73:3, 74:8, 78:5,
116:3
ready [5] - 30:22,
53:17, 110:8, 112:2,
160:8
real [1] - 138:15
really [19] - 11:22,
20:11, 26:24, 38:22,
50:14, 66:17, 68:14,
76:24, 78:7, 90:13,
96:22, 127:12,
154:24, 155:17,
155:20
rear [1] - 30:4
reason [8] - 84:8,
84:9, 106:12,
106:13, 133:22,
138:23, 144:9,
145:22
reasonable [17] -
41:12, 41:17, 41:25,
46:4, 46:8, 64:20,
65:12, 76:12, 92:21,
123:22, 124:1,
124:6, 141:19,
149:1, 152:2,
158:18, 158:20
reasons [6] - 46:19,
65:3, 104:10,
104:12, 117:14,
143:25
rebuttal [2] - 129:6,
129:11
receive [8] - 71:23,
90:6, 111:1, 111:9,
122:13, 150:16,
158:7, 165:24
received [54] - 35:17,
45:16, 51:3, 71:23,
78:3, 78:10, 119:5,
119:20, 121:7,
121:13, 121:16,
121:24, 122:1,
122:8, 122:9,
122:11, 122:12,
122:17, 127:10,
131:16, 131:17,
133:13, 135:15,
140:5, 146:7,
147:22, 148:1,
148:19, 160:13,
160:22, 160:23,
161:22, 161:24,
162:1, 162:7, 162:9,
162:13, 162:15,
162:19, 162:21,
162:25, 163:2,
163:6, 163:8,
163:15, 163:17,
163:20, 163:22,
164:1, 164:3, 164:7,
164:9, 164:24, 165:3
receives [1] - 119:6
receiving [2] - 121:16,
122:1
recent [1] - 18:21
recess [9] - 54:4, 54:6,
86:2, 86:3, 86:6,
86:7, 111:12,
111:13, 159:10
recipients [1] - 150:15
recognize [5] - 25:19,
25:21, 26:23, 36:9,
125:6
record [8] - 93:4,
111:16, 121:19,
141:17, 141:25,
160:13, 164:10,
168:16
records [22] - 112:7,
139:9, 139:12,
141:13, 141:23,
142:4, 142:11,
144:11, 146:1,
146:4, 146:6,
146:21, 147:8,
147:15, 147:16,
147:25, 148:7,
148:18, 154:18,
154:19, 166:19,
166:22
recoup [1] - 154:2
recovery [1] - 83:7
recross [1] - 128:17
red [1] - 120:8
redirect [3] - 128:14,
128:17, 128:19
redirected [1] - 60:23
refer [1] - 113:20
referee [3] - 39:2,
49:4, 49:8
referees [3] - 38:16,
38:19, 38:24
reference [6] - 4:3,
67:15, 116:16,
116:18, 117:11,
129:6
referenced [9] - 23:13,
28:7, 28:13, 69:24,
113:11, 116:22,
117:13, 124:23,
165:16
references [1] - 4:6
referred [3] - 24:15,
122:5, 129:6
refers [2] - 122:10,
165:22
refresh [1] - 85:21
refreshments [1] -
159:14
regard [12] - 5:20,
7:24, 8:16, 33:17,
34:14, 34:17, 38:8,
39:19, 86:21,
110:23, 111:18,
111:21
regarding [10] - 5:2,
5:17, 7:7, 7:20, 9:14,
67:10, 125:17,
126:3, 153:17,
154:16
regular [1] - 77:17
regulated [1] - 60:20
reject [1] - 123:10
related [4] - 45:8,
110:24, 112:14,
114:24
relates [4] - 9:13,
126:8, 126:14,
165:23
relating [4] - 115:11,
165:11, 165:12,
166:19
relationship [15] -
23:12, 27:19, 28:6,
28:11, 28:20, 29:2,
32:10, 33:5, 33:8,
35:19, 67:19, 67:21,
69:4, 77:9, 149:23
relationships [1] -
69:18
relative [2] - 39:13,
66:22
relatives [2] - 77:5,
77:6
relax [1] - 86:1
relevant [1] - 166:9
relied [3] - 74:17,
133:20, 133:25
relief [1] - 72:4
religious [6] - 51:13,
59:1, 62:22, 65:23,
92:5, 92:8
remain [11] - 3:6,
64:19, 76:10, 76:19,
86:14, 91:18, 99:10,
100:17, 104:17,
118:5, 124:2
remaining [1] - 5:15
remains [2] - 45:15,
91:5
remember [7] - 42:16,
52:22, 59:15, 71:17,
124:16, 138:18,
159:6
remind [1] - 159:7
reminder [1] - 40:10
removed [1] - 34:6
render [7] - 62:25,
63:4, 63:21, 69:2,
70:7, 70:20, 118:10
Renee [1] - 24:25
repeat [4] - 29:25,
42:16, 42:18, 67:3
report [2] - 61:6,
125:25
REPORTED [1] - 2:1
reported [3] - 125:11,
147:3, 169:11
Reporter [2] - 2:2,
169:15
reports [2] - 125:20
represent [4] - 23:21,
27:15, 73:9, 147:1
representations [3] -
92:23, 115:8, 115:20
represented [1] -
115:13
represents [1] - 92:23
request [5] - 34:16,
34:18, 58:14, 99:5,
99:6
requested [1] - 115:21
requesting [2] - 12:13,
130:13
requires [2] - 7:24,
140:22
rescheduled [2] -
59:6, 86:24
research [1] - 126:16
reserved [1] - 111:5
reside [1] - 5:7
resided [1] - 143:6
resolve [4] - 49:18,
51:21, 90:10, 117:17
resolved [1] - 83:14
resources [1] - 81:18
respect [14] - 11:3,
20:12, 20:22, 32:23,
33:21, 34:8, 77:14,
77:15, 91:4, 91:8,
189
140:9, 145:18,
146:9, 146:23
respective [1] -
143:22
respond [9] - 18:15,
29:21, 62:15, 89:13,
89:24, 117:8,
117:21, 117:22,
168:6
responded [2] - 96:20,
98:2
response [3] - 67:2,
80:3, 104:6
responses [2] - 18:16,
100:7
responsibility [2] -
119:2, 121:2
responsible [1] -
118:24
rest [1] - 78:13
resting [1] - 128:22
restroom [1] - 53:17
result [2] - 149:13,
156:1
resulted [1] - 9:6
resume [2] - 54:2,
110:3
retire [1] - 20:13
retreat [3] - 51:14,
92:5, 92:8
retrieve [1] - 167:24
return [7] - 80:23,
110:4, 110:8, 111:8,
146:24, 147:6, 149:2
returned [2] - 9:7,
127:22
returning [1] - 9:2
returns [7] - 72:25,
73:2, 73:3, 83:11,
146:23, 147:10,
147:13
reveal [1] - 33:8
revealed [1] - 168:14
Revenue [7] - 25:1,
28:9, 39:6, 69:25,
70:3, 70:4, 146:22
review [1] - 49:6
reword [1] - 76:8
rise [4] - 111:15,
118:2, 159:19, 169:5
Rivera [11] - 34:25,
56:9, 77:24, 78:25,
88:23, 89:9, 89:25,
90:2, 90:15, 90:17,
130:2
Rivero [49] - 25:12,
25:13, 137:4, 137:6,
137:13, 137:16,
137:19, 137:22,
138:3, 138:6, 138:7,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 189 of
195
138:8, 138:11,
138:12, 138:20,
139:7, 139:8,
139:10, 139:13,
139:17, 139:18,
139:22, 140:2,
140:5, 140:13,
140:18, 140:20,
141:2, 141:5, 141:6,
142:10, 144:8,
147:21, 147:24,
149:20, 151:18,
154:23, 155:14,
156:16, 157:5,
157:14, 157:18,
157:19, 157:21
Rivero's [6] - 137:23,
138:2, 139:15,
140:8, 141:1, 141:12
Riveros [2] - 137:7,
137:10
Riveros' [1] - 137:11
robbery [1] - 104:8
Rodriguez [1] - 25:9
role [2] - 60:10, 71:6
room [7] - 85:13, 86:5,
110:1, 110:7,
124:21, 126:18,
127:21
row [6] - 42:3, 43:3,
43:7, 43:25, 86:18
rows [5] - 86:14,
86:15, 86:16, 86:21,
100:12
RPR [1] - 169:15
rude [1] - 125:7
rule [2] - 166:8,
166:14
ruled [1] - 166:6
rules [4] - 19:8, 46:24,
123:20, 127:2
ruling [7] - 7:5, 111:5,
117:25, 121:1,
164:13, 165:8, 167:2
run [1] - 91:2
S
S1 [1] - 115:1
Saba [6] - 26:1, 26:2,
26:7, 72:8, 82:7,
92:19
sad [1] - 82:4
safe [3] - 18:23, 82:19,
109:23
salaries [1] - 147:13
salary [5] - 90:6,
148:9, 148:11,
148:12
Salon [1] - 153:11
Samantha [2] - 56:23,
109:1
Sanchez [3] - 109:5,
130:1
Sandra [3] - 44:22,
45:1, 61:9
Sara [2] - 26:1, 72:8
satisfy [1] - 41:6
Saturday [2] - 61:12,
61:18
save [1] - 119:9
saves [1] - 122:3
savvy [1] - 168:3
saw [7] - 73:17, 75:18,
80:9, 81:16, 124:22,
125:23, 145:4
SBA [27] - 7:15, 8:9,
22:6, 22:8, 22:10,
24:15, 25:11, 28:20,
29:2, 31:16, 31:18,
35:3, 35:16, 72:10,
112:19, 115:23,
133:2, 133:9,
133:17, 133:23,
135:25, 136:1,
136:11, 136:20,
140:15, 153:24
scared [2] - 30:7, 78:5
scenario [2] - 3:4, 5:9
Schaffer [4] - 107:22,
107:24, 109:3,
129:24
Schedule [33] -
134:22, 134:23,
134:25, 135:12,
137:25, 138:4,
138:13, 139:22,
140:2, 140:4, 140:6,
140:9, 140:11,
140:16, 141:3,
142:10, 144:8,
146:25, 147:3,
147:4, 147:7,
150:13, 150:23,
150:24, 151:1,
152:22, 153:3,
156:2, 156:4,
156:17, 157:13,
157:14
schedule [4] - 20:5,
49:14, 167:7, 167:10
scheduled [1] - 57:18
scheduling [1] - 11:3
scheme [1] - 136:14
school [6] - 19:13,
37:1, 37:2, 55:7,
55:16, 55:24
Schools [1] - 159:2
schools [10] - 10:11,
13:21, 18:24, 19:2,
19:9, 19:10, 19:12,
19:20, 60:16
scientific [1] - 50:10
score [1] - 81:21
screen [2] - 145:7,
146:15
screens [1] - 146:20
scrutinize [1] - 158:9
searching [1] - 10:25
seat [10] - 30:25, 31:6,
31:9, 54:1, 54:2,
74:19, 129:19,
129:21, 130:11
Seat [1] - 108:24
seated [15] - 3:5, 3:7,
17:19, 17:22, 18:6,
45:13, 54:8, 54:9,
54:10, 85:23,
108:19, 111:17,
118:13, 157:4,
159:21
seating [1] - 129:17
seats [1] - 129:18
Sebastian [1] - 101:21
second [13] - 9:20,
24:16, 43:3, 75:23,
86:15, 86:16, 89:11,
89:14, 89:23,
112:24, 123:25,
128:11, 129:5
Secret [3] - 67:9,
67:12, 67:21
section [1] - 158:15
secured [1] - 127:22
security [2] - 80:23,
131:13
see [79] - 8:13, 24:11,
25:23, 26:25, 28:15,
30:3, 31:11, 36:3,
37:17, 50:3, 51:10,
51:23, 51:24, 53:19,
57:9, 61:19, 62:6,
62:11, 66:1, 73:17,
75:8, 87:11, 104:13,
106:3, 110:7,
113:25, 116:1,
116:5, 121:10,
122:18, 123:2,
125:12, 130:11,
134:6, 134:23,
137:24, 139:9,
139:11, 141:17,
141:23, 142:9,
143:1, 143:5, 143:6,
143:8, 143:10,
143:12, 143:19,
143:21, 144:6,
144:11, 144:19,
144:21, 146:12,
146:24, 147:6,
147:10, 147:15,
147:22, 147:23,
148:10, 148:14,
148:18, 148:20,
150:18, 151:8,
151:15, 151:23,
152:5, 154:19,
156:8, 157:5,
157:24, 163:12,
166:10, 167:9, 169:3
seeing [6] - 46:10,
48:14, 50:13, 52:14,
54:17, 159:17
seeking [3] - 64:11,
113:8, 157:10
seem [2] - 11:5, 11:6
sees [1] - 125:8
segment [1] - 86:18
select [4] - 18:17,
48:16, 49:20, 62:16
selected [11] - 19:23,
48:5, 49:23, 51:9,
59:18, 62:10, 81:24,
85:18, 108:12,
108:18, 108:21
selection [1] - 62:9
self [3] - 132:13,
132:20, 132:25
self-employed [3] -
132:13, 132:20,
132:25
selfies [2] - 144:12,
144:21
send [3] - 68:15,
142:8, 145:23
sense [3] - 38:7,
47:12, 165:23
sent [12] - 9:17, 82:18,
116:20, 138:10,
138:22, 138:24,
139:4, 145:15,
152:5, 167:25
sentencing [1] - 9:20
separate [2] - 133:12,
145:19
September [1] -
168:17
serious [3] - 10:7,
53:24, 87:18
serve [20] - 16:5, 18:3,
40:1, 48:6, 50:14,
50:17, 50:24, 51:1,
51:2, 51:9, 52:10,
52:23, 81:23, 84:21,
85:24, 87:5, 90:19,
127:16, 158:13
served [25] - 15:23,
15:24, 37:14, 39:23,
39:24, 40:2, 40:11,
40:14, 40:16, 40:21,
190
41:19, 42:8, 42:12,
42:14, 42:21, 43:12,
43:20, 44:12, 44:14,
44:22, 74:22, 75:8,
75:11, 75:17, 75:20
server [1] - 168:20
service [18] - 40:22,
41:22, 42:2, 42:4,
42:6, 43:5, 45:4,
50:15, 55:21, 58:14,
59:1, 106:25,
109:16, 133:4,
133:5, 133:7,
133:10, 141:24
Service [10] - 25:1,
28:9, 39:6, 67:9,
67:12, 67:21, 69:25,
70:3, 70:5, 146:22
serviced [1] - 40:22
services [3] - 50:20,
106:19, 144:17
serving [2] - 104:7,
124:13
session [20] - 10:4,
10:6, 10:17, 10:19,
17:23, 19:17, 19:24,
20:5, 54:9, 91:6,
91:9, 91:10, 102:6,
111:15, 124:21,
159:3, 159:4, 165:9
set [5] - 54:14, 140:21,
164:12, 165:13,
166:19
setting [1] - 48:2
seven [5] - 11:11,
85:11, 123:17,
126:22, 152:23
several [9] - 12:18,
18:14, 19:4, 75:6,
75:18, 77:5, 91:3,
115:17, 123:17
shall [1] - 167:9
sharp [1] - 159:17
sheet [2] - 74:25,
161:4
Sheila [1] - 59:21
Shelby [1] - 91:17
Sheriff's [10] - 25:7,
25:8, 28:10, 66:24,
68:18, 68:19, 97:8,
98:3, 98:8, 131:10
sheriffs [1] - 131:9
short [2] - 53:25,
157:3
shorten [1] - 167:15
show [46] - 4:24, 47:9,
58:8, 58:11, 58:15,
70:9, 70:10, 72:20,
93:23, 108:19,
110:8, 131:14,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 190 of
195
134:16, 135:7,
136:2, 136:8,
136:24, 138:5,
141:13, 141:18,
142:4, 146:1, 146:4,
146:6, 147:11,
147:16, 147:17,
147:20, 147:25,
148:4, 148:5, 148:7,
149:18, 150:22,
152:4, 152:21,
154:6, 154:11,
155:11, 156:19,
157:3, 157:7,
157:11, 165:5
shows [2] - 143:14,
145:15
shred [1] - 154:17
side [7] - 33:22, 99:9,
128:13, 128:21,
129:9, 152:8, 152:9
sidebar [2] - 34:1,
52:21
Sidebar [2] - 34:3,
34:21
sides [7] - 29:6, 29:10,
33:14, 35:11, 37:22,
65:7
sidewalk [1] - 123:2
sigh [1] - 51:4
sign [9] - 72:21, 74:8,
145:6, 145:10,
145:17, 145:22,
145:25, 146:2,
146:19
signal [1] - 62:11
signature [1] - 136:22
signed [13] - 73:3,
73:15, 73:19,
136:21, 145:16,
145:18, 146:5,
146:9, 146:12,
146:13, 146:14,
146:18
significant [2] - 49:21,
127:19
signing [6] - 57:24,
74:8, 144:25, 145:1,
145:7, 146:14
silent [1] - 124:2
similar [5] - 6:17,
47:5, 56:3, 58:23,
77:15
simple [2] - 8:21, 78:7
simply [6] - 42:6,
64:16, 121:2,
124:13, 125:14,
155:3
simultaneously [1] -
20:16
single [1] - 140:10
singled [1] - 99:23
sinister [1] - 45:25
sister [1] - 81:14
sit [8] - 39:13, 49:4,
51:5, 51:6, 54:2,
78:23, 83:21, 108:24
situation [4] - 54:12,
60:19, 65:16, 84:22
six [8] - 28:1, 73:17,
78:3, 121:4, 126:21,
144:14, 152:23
sky [2] - 120:7, 120:8
slate [1] - 123:24
slept [1] - 58:10
slot [2] - 94:18, 102:7
Small [5] - 22:3,
24:14, 24:22, 25:11,
28:7
small [11] - 70:9,
70:11, 70:13, 70:17,
71:8, 72:10, 132:5,
133:6, 133:24
smaller [3] - 71:11,
71:13, 71:14
SmartBiz [4] - 24:24,
28:9, 112:7, 115:5
Smith [2] - 15:18,
73:12
sneak [1] - 53:2
Snider [6] - 1:13,
23:19, 26:12, 99:2,
116:15, 167:20
SNIDER [200] - 3:8,
3:13, 3:22, 4:5, 4:8,
4:20, 5:4, 6:9, 6:18,
7:5, 7:14, 8:3, 8:11,
8:15, 9:1, 10:22,
11:3, 12:4, 12:7,
12:10, 12:15, 13:13,
13:18, 23:17, 24:8,
26:12, 62:19, 63:15,
63:19, 63:25, 64:5,
64:8, 64:15, 64:18,
65:22, 66:10, 66:13,
67:11, 67:17, 67:20,
68:2, 68:5, 68:9,
68:12, 68:17, 69:1,
69:6, 69:9, 69:11,
69:14, 69:16, 69:21,
69:24, 70:17, 71:14,
71:16, 71:19, 71:23,
72:9, 72:12, 72:14,
72:16, 72:20, 75:6,
87:8, 87:11, 87:16,
87:19, 87:23, 88:6,
88:14, 88:18, 88:22,
89:1, 89:15, 90:16,
90:18, 91:1, 91:7,
91:15, 92:10, 92:25,
93:3, 93:6, 93:8,
93:25, 94:21, 95:5,
95:17, 95:20, 95:22,
96:3, 96:10, 96:13,
96:21, 97:1, 97:5,
98:14, 99:13, 99:19,
100:5, 100:15,
100:18, 101:5,
101:12, 102:9,
102:12, 102:17,
102:22, 103:3,
103:8, 103:13,
103:20, 104:2,
104:4, 104:12,
104:24, 105:2,
105:10, 105:18,
106:1, 106:4, 106:6,
106:9, 106:11,
106:15, 106:18,
107:5, 107:13,
107:21, 110:14,
110:19, 110:25,
111:3, 111:10,
111:20, 111:23,
112:5, 112:9,
112:13, 112:15,
112:25, 113:6,
113:13, 113:16,
113:22, 114:4,
114:12, 114:14,
114:17, 114:21,
114:23, 116:4,
116:6, 117:8,
117:21, 117:24,
130:15, 130:20,
130:22, 130:24,
160:12, 160:17,
160:20, 160:24,
161:1, 161:4, 161:8,
161:13, 161:15,
161:21, 161:23,
162:2, 162:4,
162:10, 162:16,
162:22, 163:3,
163:9, 163:12,
163:18, 163:23,
164:4, 164:10,
164:15, 164:20,
164:22, 165:1,
165:7, 165:18,
165:21, 165:25,
166:5, 166:7,
166:10, 166:16,
166:18, 167:5,
167:10, 168:15
so.. [2] - 57:1, 74:9
social [2] - 49:3, 80:23
socialized [1] - 137:11
society [1] - 47:24
sole [11] - 132:14,
132:15, 132:17,
132:19, 134:11,
134:13, 135:3,
157:12, 158:1
solely [2] - 62:25,
79:19
solemnly [2] - 18:1,
118:8
solved [1] - 81:17
someone [15] - 25:21,
47:15, 48:25, 65:9,
66:2, 80:5, 80:11,
80:22, 82:10, 84:3,
106:15, 106:17,
106:19, 108:3, 125:8
sometime [3] - 11:7,
57:15, 153:3
sometimes [9] - 16:3,
16:4, 26:18, 38:2,
49:16, 82:4, 119:8,
119:12, 121:7
soon [3] - 11:1, 52:15,
58:1
sorry [20] - 5:4, 26:14,
63:24, 66:6, 79:13,
80:10, 82:9, 88:13,
92:7, 94:2, 98:5,
99:17, 103:21,
105:20, 107:14,
107:15, 108:1,
111:20, 114:14,
116:11
sort [6] - 30:12, 40:3,
62:11, 82:18,
142:23, 159:14
sorts [2] - 16:4,
126:10
sound [1] - 61:2
sounds [2] - 35:19,
37:11
South [2] - 55:25, 56:1
south [1] - 19:7
SOUTHERN [1] - 1:1
Southern [6] - 1:15,
19:4, 19:5, 23:20,
24:1, 169:16
Southwest [1] - 1:20
Spanish [2] - 89:11,
137:18
speaking [5] - 29:18,
37:7, 38:25, 69:25,
125:14
speaks [1] - 30:10
special [8] - 24:5,
49:15, 49:17, 49:24,
52:22, 52:23, 54:11,
54:17
specific [3] - 41:16,
116:18, 121:8
specifically [7] - 17:9,
191
96:3, 113:20, 114:9,
131:17, 138:6, 142:1
specificity [1] - 113:17
specifics [1] - 33:7
spectator [5] - 31:12,
34:22, 38:20, 43:7,
51:25
speculate [1] - 46:19
speed [1] - 84:12
spelled [1] - 25:13
spend [1] - 133:15
spent [3] - 133:14,
135:19, 148:2
spoken [4] - 12:18,
153:18, 154:3, 158:7
spot [1] - 94:14
Spouse [1] - 70:15
spouse [3] - 66:21,
70:16, 71:24
sprinkler [1] - 123:4
St [2] - 61:1, 61:3
staff [1] - 16:20
stages [1] - 128:18
stake [1] - 41:13
stand [12] - 3:14, 5:13,
31:1, 46:22, 46:23,
57:11, 65:2, 108:16,
121:13, 155:8,
157:17
standard [1] - 65:13
standing [4] - 3:17,
109:15, 118:4, 118:5
stands [1] - 21:8
start [20] - 13:6, 18:10,
45:11, 51:6, 66:4,
80:14, 80:17, 83:25,
85:14, 86:9, 93:12,
93:15, 104:20,
110:14, 123:23,
124:14, 126:22,
132:2, 160:2, 160:8
started [7] - 14:7,
17:20, 78:2, 78:5,
78:6, 126:20, 143:15
starting [2] - 16:2,
159:22
starts [2] - 14:22,
161:6
state [6] - 40:5, 42:9,
43:15, 43:21, 66:25,
77:17
State [9] - 40:6, 44:7,
44:9, 44:10, 44:17,
44:18, 44:19, 44:22,
45:2
statement [4] - 3:15,
7:8, 8:8, 49:1
STATEMENT [2] -
130:21, 149:8
statements [32] -
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195
12:14, 20:21, 21:12,
22:1, 22:3, 22:6,
22:8, 22:10, 22:12,
22:13, 104:14,
108:14, 110:6,
112:18, 113:3,
113:10, 119:16,
119:21, 120:2,
127:10, 128:1,
135:18, 135:19,
135:25, 136:1,
136:10, 136:18,
136:20, 140:15,
142:7, 158:24, 159:8
states [4] - 46:11,
104:6, 115:7, 115:12
STATES [3] - 1:1, 1:4,
1:11
States [13] - 2:3, 9:1,
18:9, 23:19, 23:21,
24:1, 24:2, 27:13,
27:25, 36:18,
140:19, 168:16,
169:16
station [1] - 126:1
status [4] - 9:12, 38:3,
116:14, 117:1
stay [2] - 16:19, 89:5
staying [1] - 13:8
stays [1] - 13:20
steal [1] - 82:25
stenographic [1] -
169:12
STENOGRAPHICAL
LY [1] - 2:1
Step [3] - 8:13, 147:2,
153:11
step [2] - 85:25,
144:25
Stephen [2] - 107:24,
109:3
stick [1] - 60:13
still [6] - 8:13, 13:11,
50:3, 69:12, 101:12,
156:9
stipulate [3] - 4:14,
119:7, 119:8
stipulations [2] -
119:9, 119:11
stolen [3] - 81:6,
81:15, 157:20
stood [1] - 14:7
storm [4] - 11:5,
11:21, 60:12, 90:21
Street [5] - 1:20, 2:4,
40:6, 42:21, 169:17
strike [6] - 101:6,
101:20, 103:5,
103:10, 103:16,
107:14
striking [1] - 86:19
strong [4] - 48:10,
48:13, 65:22, 154:24
stronger [2] - 89:20,
89:21
struck [2] - 99:14,
107:13
struggling [1] - 154:1
stuck [1] - 56:7
stuff [1] - 82:1
subject [6] - 32:12,
34:23, 86:10, 91:13,
112:11, 116:12
submission [1] -
112:20
submitted [6] - 4:25,
5:6, 112:25, 114:25,
145:13
submitting [3] -
112:20, 144:18,
155:1
subpoena [4] - 12:22,
14:23, 15:19
subpoenaed [5] -
12:17, 14:13, 17:5,
151:16, 154:18
subpoenas [2] -
14:17, 16:2
substance [2] - 7:17,
8:21
substantially [1] -
41:24
substantive [8] -
21:15, 21:17, 22:14,
22:15, 113:22,
113:23, 165:18,
165:19
successfully [1] - 71:7
sued [2] - 66:8
suffering [1] - 81:16
suggest [3] - 17:11,
119:1, 167:20
suggesting [1] - 87:20
suggestion [1] - 6:9
suggestions [1] -
85:15
suggests [1] - 132:3
Suite [1] - 1:16
suited [1] - 28:2
Sukkot [2] - 55:5,
58:25
summarized [1] -
157:5
summary [2] - 164:17,
164:22
summary's [1] -
164:23
summons [1] - 51:3
sundown [1] - 55:5
superseding [3] - 9:3,
9:7, 115:2
supply [1] - 133:21
supported [1] -
115:16
supporting [2] -
133:22, 134:4
suppose [1] - 5:25
supposed [5] - 16:14,
31:16, 58:19,
125:10, 152:14
suspect [1] - 109:18
sustain [1] - 120:22
sustained [3] - 118:1,
121:4, 121:5
sustaining [1] -
117:14
Susy [2] - 59:5, 109:7
sway [1] - 65:3
swayed [1] - 65:5
swaying [1] - 76:22
swear [2] - 18:2, 118:9
sweetheart [1] -
154:10
switch [1] - 129:20
sworn [5] - 17:25,
110:5, 118:4,
118:14, 131:11
synagogues [1] - 36:4
system [10] - 33:2,
35:5, 40:19, 41:13,
46:11, 47:3, 48:18,
50:19, 66:20, 133:19
T
table [1] - 4:8
tainted [1] - 34:10
talks [2] - 158:7,
158:14
tam [8] - 26:13, 26:15,
26:18, 27:4, 27:9,
92:25, 93:1, 93:7
Tammie [2] - 44:1,
109:10
tasks [1] - 137:17
taught [1] - 150:12
tax [21] - 72:23, 72:25,
73:2, 80:22, 83:11,
88:24, 90:2, 134:21,
135:12, 138:15,
141:3, 146:22,
146:24, 147:6,
147:10, 147:13,
150:24, 151:20
taxes [9] - 56:14,
56:16, 70:1, 70:2,
72:24, 78:16, 82:11,
147:12, 152:21
tea [1] - 159:14
team [5] - 23:23,
38:20, 38:21, 74:3,
168:21
tech [1] - 106:22
technical [2] - 50:9,
140:2
technically [2] -
121:17, 168:3
technological [1] -
126:9
television [2] - 47:9,
126:1
temple [1] - 36:2
temples [1] - 36:10
ten [7] - 129:11,
138:23, 148:10,
148:11, 154:9,
164:15
tend [1] - 77:18
tender [1] - 61:13
tendered [3] - 9:14,
9:16, 116:9
term [7] - 18:11, 21:7,
40:25, 41:5, 45:25,
49:13, 124:23
terms [1] - 89:18
testified [1] - 123:15
testifies [1] - 158:3
testify [16] - 7:11,
46:12, 46:15, 46:18,
46:20, 47:1, 121:21,
124:2, 124:4, 128:9,
137:22, 139:18,
140:22, 157:22,
166:19, 166:22
testifying [3] - 16:6,
16:7, 158:8
testimony [29] - 7:6,
7:15, 7:24, 11:17,
11:25, 16:10, 33:11,
33:12, 33:13, 38:6,
38:11, 49:5, 77:19,
119:5, 119:9,
119:20, 122:23,
123:9, 123:14,
137:23, 138:2,
140:8, 155:22,
158:10, 167:22,
168:5, 168:17,
168:19
testimony's [1] - 16:9
tests [1] - 123:17
Texas [4] - 11:13,
56:5, 88:18, 166:24
text [3] - 151:8,
151:11, 151:16
Thakral [1] - 24:16
THE [414] - 1:10, 1:13,
1:18, 3:3, 3:9, 3:20,
3:24, 4:6, 4:17, 4:21,
4:23, 5:5, 6:11, 6:19,
192
7:13, 7:19, 8:10,
8:12, 8:16, 9:4, 9:11,
9:15, 9:19, 10:2,
10:13, 10:23, 12:1,
12:5, 12:8, 12:11,
13:1, 13:10, 13:16,
14:1, 14:6, 14:15,
14:17, 14:19, 14:22,
15:2, 15:4, 15:7,
15:10, 15:13, 15:15,
15:22, 15:24, 16:15,
16:18, 16:24, 17:2,
17:6, 17:15, 17:17,
17:24, 18:6, 24:7,
25:17, 25:25, 26:2,
26:5, 26:10, 26:14,
26:16, 26:23, 27:2,
27:6, 27:8, 27:15,
27:18, 27:24, 28:18,
28:23, 29:3, 29:9,
29:12, 29:15, 29:20,
30:1, 30:10, 30:15,
30:22, 30:25, 31:3,
31:14, 31:18, 31:22,
32:1, 32:6, 32:10,
32:16, 32:18, 32:25,
33:2, 33:9, 33:25,
34:2, 34:11, 34:19,
34:22, 35:4, 35:7,
35:11, 35:13, 35:21,
36:2, 36:6, 36:11,
36:17, 36:20, 36:22,
36:24, 37:2, 37:6,
37:9, 37:11, 37:14,
37:16, 42:19, 42:22,
42:24, 43:2, 43:11,
43:14, 43:17, 43:19,
43:23, 43:25, 44:4,
44:7, 44:9, 44:11,
44:14, 44:18, 44:20,
44:24, 45:3, 51:16,
51:18, 51:20, 52:9,
52:12, 52:14, 52:18,
52:20, 53:4, 53:7,
53:10, 53:15, 54:10,
54:22, 54:24, 55:2,
55:8, 55:11, 55:18,
55:21, 56:1, 56:6,
56:8, 56:10, 56:17,
56:20, 57:2, 57:4,
57:7, 57:9, 57:13,
57:19, 57:23, 57:25,
58:3, 58:15, 58:17,
58:21, 59:2, 59:8,
59:12, 59:14, 59:18,
59:23, 60:1, 60:4,
60:7, 60:20, 61:1,
61:3, 61:7, 61:16,
61:19, 61:22, 62:1,
62:4, 63:24, 64:23,
65:6, 65:9, 65:18,
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 192 of
195
65:21, 69:22, 70:16,
70:25, 71:2, 72:7,
73:6, 74:12, 85:10,
86:4, 86:8, 87:13,
87:20, 87:24, 88:4,
88:8, 88:11, 88:16,
88:21, 88:23, 89:3,
89:17, 89:22, 90:1,
90:6, 90:9, 90:14,
90:17, 90:23, 91:4,
91:8, 91:16, 91:25,
92:7, 92:14, 92:17,
93:1, 93:5, 93:7,
93:9, 93:15, 93:18,
94:2, 94:4, 94:11,
94:22, 95:3, 95:6,
95:8, 95:11, 95:18,
95:21, 96:2, 96:7,
96:12, 96:17, 96:22,
97:2, 97:10, 97:14,
97:16, 97:19, 97:24,
98:1, 98:5, 98:7,
98:13, 98:18, 98:22,
98:24, 99:3, 99:5,
99:8, 99:17, 99:20,
99:22, 100:2, 100:4,
100:10, 100:13,
100:16, 100:19,
100:21, 100:24,
101:1, 101:3, 101:7,
101:9, 101:13,
101:18, 101:21,
101:24, 102:1,
102:6, 102:10,
102:13, 102:18,
102:20, 102:23,
102:25, 103:4,
103:6, 103:9,
103:11, 103:14,
103:17, 103:21,
103:23, 104:1,
104:3, 104:10,
104:13, 104:23,
104:25, 105:7,
105:11, 105:13,
105:17, 105:20,
105:25, 106:13,
106:17, 106:21,
106:23, 107:3,
107:8, 107:18,
108:1, 108:9,
108:16, 109:25,
110:12, 110:18,
110:21, 111:1,
111:7, 111:11,
111:17, 111:21,
112:4, 112:6,
112:11, 112:14,
112:24, 113:4,
113:11, 113:14,
113:19, 113:25,
114:11, 114:13,
114:15, 114:18,
114:22, 116:1,
116:5, 116:8,
116:10, 116:12,
117:7, 117:10,
117:22, 117:25,
118:4, 118:6,
118:13, 130:8,
130:16, 130:19,
130:23, 149:7,
158:24, 159:21,
159:24, 160:16,
160:18, 160:21,
160:25, 161:3,
161:5, 161:10,
161:14, 161:19,
161:22, 161:24,
162:3, 162:7,
162:13, 162:19,
162:25, 163:6,
163:11, 163:15,
163:20, 164:1,
164:7, 164:14,
164:19, 164:21,
164:24, 165:4,
165:16, 165:19,
165:22, 166:4,
166:6, 166:8,
166:13, 166:17,
167:3, 167:6,
167:13, 168:2,
168:6, 168:9, 169:2
themselves [9] - 23:4,
23:15, 23:24, 66:2,
112:18, 132:17,
132:18, 144:13,
161:20
then.. [1] - 14:3
thereafter [2] - 128:3,
128:14
therefore [1] - 120:23
they've [3] - 120:17,
121:25, 137:16
thief [2] - 154:4,
156:11
thieves [1] - 154:1
thin [2] - 131:19,
140:10
thinking [2] - 33:15,
90:24
thinks [3] - 38:12,
39:1, 47:17
third [3] - 24:19,
108:10, 133:4
third-party [1] - 133:4
Thomas [2] - 25:2,
25:3
thoughts [3] - 33:17,
87:2, 92:19
thousand [1] - 152:23
three [17] - 43:18,
59:7, 62:2, 104:18,
104:19, 114:23,
115:18, 121:3,
124:6, 128:15,
128:18, 145:19,
145:22, 145:23,
146:2, 147:16,
149:10
threw [1] - 66:6
throughout [1] - 3:7
Thursday [30] - 13:11,
13:15, 13:16, 13:17,
13:24, 14:2, 14:5,
19:25, 49:10, 55:6,
55:9, 55:12, 58:19,
58:24, 59:6, 59:8,
59:19, 60:2, 87:16,
87:19, 90:20, 90:24,
90:25, 91:6, 91:8,
91:19, 93:11, 93:14,
159:4
tie [1] - 33:16
timely [2] - 168:10,
168:14
ting [2] - 39:13, 82:3
today [21] - 10:5,
11:16, 11:17, 12:20,
14:14, 14:23, 15:8,
15:12, 16:6, 16:14,
28:1, 39:17, 45:13,
49:9, 52:3, 52:6,
53:2, 73:12, 74:24,
149:13, 168:22
together [5] - 74:14,
133:9, 136:3,
137:11, 143:6
tomorrow [11] - 10:6,
11:4, 11:18, 11:20,
11:22, 12:6, 13:22,
125:4, 159:10,
159:17, 169:3
took [3] - 46:22, 61:4,
81:15
top [2] - 161:9, 161:11
tops [1] - 59:11
total [1] - 131:20
touch [4] - 7:7, 13:8,
16:19, 17:3
touching [1] - 18:3
tough [1] - 60:13
towards [3] - 58:9,
82:2
town [5] - 11:20,
11:24, 59:22, 60:16,
69:8
track [4] - 142:16,
142:17, 142:18
TRACY [1] - 1:7
Tracy [61] - 4:12, 4:13,
9:10, 20:8, 22:7,
22:9, 22:13, 73:10,
114:24, 115:3,
115:8, 131:4, 131:5,
131:9, 131:15,
131:17, 134:2,
134:10, 134:13,
134:14, 134:16,
134:18, 134:20,
134:24, 135:10,
136:2, 136:8,
136:25, 137:2,
137:21, 138:8,
138:25, 139:2,
139:13, 140:5,
140:17, 141:7,
141:10, 141:14,
141:15, 141:19,
142:5, 143:2,
143:11, 143:15,
143:20, 144:15,
145:11, 145:18,
145:22, 147:6,
147:9, 147:18,
148:14, 149:4,
153:18, 153:20,
157:6, 157:9
trade [2] - 150:8,
150:9
traffic [1] - 159:12
transcribed [1] -
169:11
TRANSCRIPT [1] -
1:10
transcript [2] - 168:4,
168:16
transcription [1] -
169:10
transmitted [1] - 139:7
transparent [1] -
35:18
travel [4] - 94:25,
97:11, 97:20, 159:11
traveling [2] - 56:4,
60:4
treating [2] - 166:1,
166:11
trial [31] - 9:5, 10:15,
14:20, 14:22, 16:2,
16:4, 24:10, 27:25,
48:3, 51:13, 54:19,
75:1, 75:2, 91:3,
110:15, 117:6,
118:16, 118:22,
124:9, 125:15,
125:18, 125:21,
126:6, 126:22,
127:24, 141:11,
150:24, 164:23,
193
168:10
TRIAL [1] - 1:10
trials [5] - 20:11,
20:15, 30:12, 37:25,
140:22
tricked [1] - 82:17
tricks [2] - 150:8,
150:9
tried [6] - 18:4, 20:10,
49:9, 82:20, 152:10,
154:5
trier [3] - 79:24, 85:1,
158:17
Trinidad [5] - 56:3,
56:8, 80:18, 88:4,
88:21
trip [7] - 51:13, 54:20,
57:5, 57:6, 61:24,
97:12, 105:2
trouble [2] - 54:24,
73:22
true [12] - 118:10,
126:12, 134:1,
134:3, 134:4, 134:5,
135:19, 136:21,
141:2, 141:4, 145:2,
146:17
truly [2] - 18:2, 118:9
trust [3] - 133:19,
133:23, 134:2
trust-based [2] -
133:19, 133:23
trusted [3] - 74:12,
155:13, 155:23
truth [4] - 18:12,
73:21, 154:20, 158:2
truthful [7] - 73:16,
73:20, 133:21,
141:2, 141:4, 141:9,
152:7
truthfulness [2] -
100:7, 133:20
try [17] - 3:19, 12:5,
16:8, 16:11, 31:11,
49:18, 62:9, 62:15,
65:1, 65:4, 65:15,
65:16, 67:14, 76:19,
118:9, 126:12,
127:18
trying [11] - 38:16,
38:23, 39:11, 48:16,
62:16, 74:21, 81:17,
98:7, 119:1, 133:23,
154:2
Tuesday [7] - 12:19,
12:23, 13:4, 16:10,
49:10, 159:4, 159:5
turn [2] - 4:2, 126:1
turns [1] - 153:19
TV [1] - 10:14
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 193 of
195
twice [2] - 34:7, 82:11
two [50] - 10:20,
10:23, 20:7, 20:9,
20:11, 20:15, 21:3,
23:23, 30:12, 31:11,
31:12, 32:9, 36:4,
48:4, 49:13, 51:25,
52:23, 53:3, 54:20,
57:16, 57:17, 60:15,
60:16, 68:2, 74:3,
78:12, 86:14, 86:15,
86:16, 86:18, 86:21,
100:12, 104:18,
112:16, 113:7,
116:22, 122:20,
130:25, 131:3,
134:9, 136:4,
142:11, 146:9,
146:11, 147:20,
149:24, 153:5,
155:3, 156:13,
166:18
two-row [1] - 86:18
two-ways [1] - 142:11
two-week [1] - 10:20
type [5] - 31:20, 84:22,
142:19
types [1] - 121:23
U
U.S [21] - 1:15, 23:20,
24:14, 25:11, 26:9,
26:10, 26:19, 27:2,
27:12, 27:19, 32:11,
32:18, 32:22, 33:5,
33:15, 37:23, 38:13,
57:14, 66:24, 67:12,
77:14
ultimately [1] - 115:23
unable [1] - 90:19
unbeknownst [3] -
152:15, 152:17,
153:17
unclear [1] - 161:10
under [6] - 60:10,
76:9, 83:11, 153:10,
153:13, 158:8
underlying [1] - 84:9
understood [6] -
29:23, 30:11, 37:6,
89:13, 89:22, 96:21
undisputed [1] - 151:2
unfair [1] - 35:8
unfortunate [2] -
81:22, 83:20
unfortunately [1] -
52:5
unique [4] - 49:15,
49:24, 52:23, 54:11
United [13] - 2:3, 9:1,
18:9, 23:19, 23:21,
24:1, 24:2, 27:13,
27:25, 36:18,
140:19, 168:16,
169:16
UNITED [3] - 1:1, 1:4,
1:11
unlawful [3] - 136:6,
156:14, 156:15
unlawfully [1] -
112:17
unless [8] - 46:3, 46:7,
46:13, 64:19, 68:5,
76:11, 93:21, 111:2
unpaid [1] - 113:6
unpredictable [1] -
58:8
unsure [1] - 127:3
up [40] - 3:16, 4:10,
10:25, 11:10, 14:4,
14:7, 17:10, 47:22,
54:18, 55:16, 60:24,
62:12, 81:6, 81:15,
84:12, 88:11, 91:19,
96:7, 96:19, 98:13,
101:25, 112:2,
116:6, 120:11,
125:4, 126:13,
131:19, 131:23,
135:13, 140:10,
140:24, 141:3,
148:9, 151:21,
153:1, 154:12,
155:25, 159:10,
161:13, 167:8
up-and-down [1] -
3:16
upload [1] - 144:15
uploaded [6] - 138:4,
138:17, 142:6,
144:8, 151:3, 157:13
uploading [3] - 142:9,
143:13, 157:13
upset [1] - 39:18
USAO [1] - 1:14
USAs [5] - 32:8, 32:9,
32:13, 33:20, 34:9
USDIS [1] - 32:8
username [1] - 157:8
utilize [1] - 41:20
utilizing [1] - 41:15
V
vacation [5] - 52:5,
57:7, 59:23, 62:1,
97:16
vacations [1] - 62:5
vacillates [1] - 77:1
Varela [7] - 31:4, 60:9,
61:19, 68:22, 69:22,
95:12, 95:14
variables [1] - 13:19
various [1] - 20:22
Veda [2] - 107:16,
109:9
Velarde [1] - 83:10
Vera [2] - 43:20, 109:6
veracity [2] - 38:8,
96:6
verdict [26] - 21:22,
42:10, 42:11, 42:12,
42:23, 43:18, 43:23,
43:24, 44:2, 44:6,
44:23, 45:2, 62:25,
63:4, 63:21, 65:25,
70:7, 70:20, 118:10,
119:1, 124:19,
149:3, 149:4
verified [1] - 144:24
verify [2] - 144:10,
144:17
Verizon [5] - 25:5,
28:10, 143:8, 146:2,
146:13
Vero [1] - 19:6
VI [1] - 22:6
via [3] - 138:8, 145:6,
146:10
victim [4] - 80:6,
80:13, 82:10, 104:8
Vietnam [1] - 50:22
view [3] - 27:23,
32:24, 145:16
viewed [3] - 145:15,
145:18, 146:4
views [1] - 6:14
VII [1] - 22:8
VIII [1] - 22:10
violated [1] - 134:2
visible [3] - 144:5,
145:7, 146:15
Viviane [1] - 109:2
voice [1] - 76:19
void [1] - 152:13
voir [11] - 5:2, 5:17,
5:18, 6:7, 18:11,
29:21, 96:4, 96:9,
97:6, 99:5, 131:23
Volume [1] - 1:7
vote [2] - 33:16, 50:17
vs [1] - 1:5
W
W2 [1] - 78:12
Wade [154] - 4:12,
4:13, 8:16, 8:17, 9:2,
9:10, 9:14, 9:15,
20:8, 20:9, 21:18,
21:19, 22:5, 22:7,
22:9, 22:11, 22:12,
22:13, 34:5, 45:12,
73:10, 112:8, 112:9,
113:1, 114:24,
115:3, 115:4, 115:6,
115:8, 115:9,
115:12, 115:14,
115:16, 115:20,
115:22, 116:17,
131:4, 131:5, 131:9,
131:15, 131:17,
134:2, 134:13,
134:14, 134:15,
134:16, 134:18,
134:24, 135:5,
135:7, 135:9,
135:10, 135:13,
136:2, 136:8,
136:25, 137:2,
137:3, 137:8, 137:9,
137:21, 138:8,
138:10, 139:10,
139:13, 139:16,
140:5, 140:17,
141:7, 141:10,
141:13, 141:14,
141:15, 141:19,
142:5, 143:2, 143:7,
143:11, 143:16,
143:19, 143:20,
144:14, 144:15,
145:11, 145:18,
145:22, 146:2,
146:4, 146:6, 146:9,
146:12, 146:23,
147:1, 147:4, 147:9,
147:10, 147:18,
147:24, 148:10,
148:14, 148:15,
148:16, 149:4,
149:5, 149:10,
149:12, 151:10,
151:20, 152:2,
152:6, 152:15,
152:18, 152:21,
153:16, 153:17,
153:18, 153:20,
155:7, 155:8,
155:13, 155:22,
156:4, 156:6,
156:10, 157:6,
157:10, 165:12,
166:23
WADE [2] - 1:7, 1:7
Wade's [14] - 134:10,
134:20, 135:2,
135:11, 139:1,
139:2, 139:3, 139:4,
139:14, 143:7,
194
143:15, 147:6
Wades [6] - 12:16,
77:9, 137:10, 155:2,
156:19, 156:24
wait [8] - 31:10, 49:19,
81:19, 90:12, 101:5,
164:18, 164:22,
166:8
waiting [1] - 97:10
waivers [1] - 77:1
walk [1] - 14:7
walking [3] - 80:16,
123:1, 160:3
wants [6] - 4:10,
52:18, 58:3, 92:11,
94:15, 150:4
War [2] - 50:22
waste [2] - 6:1, 126:23
watched [1] - 38:18
ways [3] - 137:7,
142:11, 142:13
weather [12] - 3:4, 5:9,
5:11, 10:3, 11:5,
11:8, 13:22, 18:21,
49:13, 51:23, 52:5,
95:13
website [13] - 133:8,
138:21, 141:24,
142:1, 142:13,
142:17, 142:25,
144:3, 144:10,
144:22, 144:24,
145:8, 150:13
websites [1] - 133:5
Wednesday [13] -
11:7, 49:21, 55:6,
55:8, 55:11, 62:3,
88:24, 97:13, 159:2,
159:3, 166:25,
167:7, 167:16
week [22] - 3:23,
10:20, 11:9, 13:20,
49:10, 49:13, 52:2,
52:4, 52:10, 55:4,
56:4, 57:18, 58:8,
58:12, 58:17, 59:22,
60:21, 60:22, 87:5,
91:3, 117:1, 167:8
weekend [1] - 58:10
weeks [6] - 50:25,
52:23, 53:3, 54:20,
57:16, 126:22
weight [2] - 77:19
welcome [3] - 17:16,
43:17, 45:3
West [4] - 11:6, 19:7,
19:9, 19:11
wet [2] - 123:2
whatsoever [2] -
125:3, 125:8
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 194 of
195
whistleblower [1] -
27:5
whistleblowers [1] -
92:24
wife [6] - 68:23, 69:1,
69:4, 69:9, 69:19,
155:10
wife's [3] - 141:16,
156:5
Wilcox [2] - 1:20,
73:11
WILCOX [49] - 9:5,
10:12, 30:20, 65:19,
87:15, 88:7, 88:10,
93:14, 93:17, 94:1,
94:3, 94:7, 94:20,
94:25, 97:20, 97:22,
98:16, 98:20, 98:23,
99:1, 99:4, 99:7,
99:16, 99:21, 99:24,
100:3, 100:20,
100:23, 100:25,
101:2, 101:6,
101:16, 101:23,
102:19, 103:22,
103:25, 105:12,
105:22, 106:10,
107:10, 107:14,
108:5, 116:11,
116:13, 117:9,
159:23, 167:19,
168:4, 168:8
Williams [4] - 44:1,
109:10, 130:6, 130:7
willing [1] - 52:24
willingly [2] - 50:25,
51:2
win [1] - 38:21
wind [1] - 10:7
wire [8] - 4:4, 4:11,
20:25, 21:5, 135:24,
136:16, 140:14
wireless [3] - 143:8,
146:3, 146:13
wires [1] - 136:14
wise [1] - 59:12
witness [52] - 6:23,
7:9, 7:10, 11:11,
11:13, 11:14, 11:15,
12:17, 13:5, 14:7,
15:15, 24:16, 24:19,
24:21, 24:23, 24:25,
25:2, 25:4, 25:10,
25:12, 25:15, 25:16,
30:21, 39:5, 39:10,
77:11, 84:22, 96:20,
110:24, 120:7,
120:12, 121:13,
122:10, 123:15,
125:5, 125:9,
128:16, 128:19,
128:20, 137:23,
144:1, 144:3,
149:19, 154:10,
157:17, 162:16,
166:21, 166:24,
168:11
Witness [1] - 7:14
witness's [4] - 85:4,
120:9, 123:9, 123:13
witnesses [32] - 6:23,
11:10, 11:12, 11:17,
11:20, 11:24, 14:4,
14:19, 14:23, 14:24,
16:12, 23:7, 23:9,
23:11, 24:9, 28:13,
38:7, 49:5, 49:6,
111:18, 119:5,
120:5, 120:11,
120:15, 121:20,
121:23, 123:8,
123:18, 126:13,
128:12, 166:18
witnesses' [1] - 123:9
woman [2] - 137:3,
153:2
Wombly [1] - 24:18
Womply [15] - 133:11,
138:21, 138:24,
141:23, 141:25,
142:5, 142:16,
144:1, 144:2,
144:10, 144:16,
145:12, 145:23,
153:25, 157:7
Womply's [4] -
144:22, 144:24,
145:8, 150:13
word [8] - 79:2, 79:3,
83:25, 84:1, 84:6,
141:12, 148:12,
148:17
words [6] - 46:14,
53:11, 64:24, 89:5,
91:17, 124:8
work-regulated [1] -
60:20
works [22] - 24:14,
24:20, 24:21, 24:23,
24:25, 25:3, 25:4,
25:6, 25:10, 33:2,
39:10, 51:23, 68:19,
89:5, 95:12, 96:1,
96:5, 96:12, 98:2,
106:15, 106:17,
129:12
World [1] - 50:22
world [2] - 126:9,
126:11
worse [1] - 11:8
195
write [5] - 39:7, 78:19,
106:6, 106:8, 127:19
writing [3] - 80:9,
119:12, 148:16
written [1] - 156:25
wrote [11] - 88:14,
90:23, 92:8, 92:24,
95:25, 144:2, 148:8,
148:10, 148:14,
148:19, 157:2
Y
year [6] - 57:15, 58:9,
80:23, 83:13, 83:14,
147:7
years [11] - 32:21,
33:19, 36:19, 36:20,
68:15, 131:6,
146:23, 147:14,
152:9, 153:2, 159:15
yesterday [2] - 11:16,
38:19
you-all [11] - 61:4,
73:12, 73:14, 73:15,
73:19, 77:7, 79:13,
79:15, 83:17, 85:6
young [2] - 58:24,
149:23
yourself [4] - 3:20,
39:14, 63:5, 85:21
yourselves [1] - 73:1
Yusdaliencys [1] -
36:13
Z
Zelle [4] - 138:8,
138:10, 147:20,
147:23
Case 0:23-cr-60173-KMW Document 280 Entered on FLSD Docket 05/27/2025 Page 195 of
195File and source
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