Court filing

Motion for New Trial — Hockridge, US v. Reis & Hockridge

Filed November 6, 2025 in Reis Hockridge; one of 9 filings from this case.

Record facts

Court	UNITED STATES DISTRICT COURT
Filed	2025-11-06

UNITED STATES DISTRICT COURT · No. 4:24-cr-00287-O · Doc. 342 · 2025-11-06 · Docket on CourtListener

Full text

lIN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

UNITED STATES OF AMERICA,
§

Plaintiff,

§
v.

§
Case No. 4:24 CR-00287-O

STEPHANIE HOCKRIDGE, a/k/a

§
(02)
STEPHANIE REIS,

Defendants.

DEFENDANT STEPHANIE HOCKRIDGE’S MEMORANDUM IN SUPPORT OF
HER MOTION FOR NEW TRIAL BASED ON NEWLY DISCLOSED EVIDENCE
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TABLE OF CONTENTS
Table of Authorities ........................................................................................................................ ii
Summary and Introduction ............................................................................................................. 1
Legal Standard ................................................................................................................................ 3
Discussion ....................................................................................................................................... 4
I. Regardless of Its Good or Bad Faith, the Government Violated Brady and Giglio by
Withholding Favorable Exculpatory and Impeachment Evidence ....................................... 4
A. The Government Was in Possession the Withheld Evidence Prior to Trial ................... 5
B. The Withheld Evidence Shows That Eric Karnezis Was Part of a Separate Criminal
Conspiracy to Commit PPP Fraud That Predated His Being Introduced to Ms. Hockridge .. 6
C. The Withheld Evidence Undermines the Credibility of the Government’s Star Witness,
Eric Karnezis ......................................................................................................................... 10
II. The Withheld Evidence Was Material ............................................................................... 11
A. The Withheld Evidence Materially Undermines the Government’s Case That Ms.
Hockridge Knowingly Engaged in the Conspiracy Alleged in the Indictment .................... 12
B. The Withheld Evidence Materially Undermines the Government’s Reliance on Eric
Karnezis’s Repeated Lies ...................................................................................................... 16
C. At the Very Least, the Cumulative Effect of the Withheld Evidence on the
Government’s Case Establishes Its Materiality .................................................................... 21
III. The Government’s Violation of Brady, in Combination with Other Trial Errors, Warrants
a New Trial in the Interest of Justice .................................................................................. 23
Conclusion .................................................................................................................................... 25

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TABLE OF AUTHORITIES

Page(s)
Cases
Brady v. Maryland,
373 U.S. 83 (1963) .................................................2, 3, 4, 5, 6, 7, 10, 11, 16, 19, 21, 22, 23, 25
Giglio v. United States,
404 U.S. 150 (1972) ...................................................................................................................4
Kyles v. Whitley,
514 U.S. 419 (1995) .......................................................................................................5, 11, 23
Smith v. Cain,
565 U.S. 73 (2012) ...................................................................................................................11
Strickler v. Green,
527 U.S. 263 (1999) .............................................................................................................4, 23
United States v. Auten,
632 F.2d 478 (5th Cir. 1980) .................................................................................................5, 6
United States v. Beacham,
774 F.3d 267 (5th Cir. 2014) ...................................................................................................15
United States v. Bowen,
969 F. Supp. 2d 546 (E.D. La. 2013) .........................................................................................3
United States v. Bowen,
799 F.3d 336 (5th Cir. 2015) ...............................................................................................3, 23
United States v. Cessa,
861 F.3d 121 (5th Cir. 2017) .........................................................................................4, 10, 11
United States v. Deutsch,
475 F.2d 55 (5th Cir. 1973) .......................................................................................................6
United States v. Dvorin,
817 F.3d 438 (5th Cir. 2016) ...................................................................................................11
United States v. Jindal,
621 F. Supp. 3d 727 (E.D. Tex. 2022) .................................................................................3, 23
United States v. McRae,
795 F.3d 471 (5th Cir. 2015) ...............................................................................................3, 24
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iii

United States v. Poole,
735 F.3d 269 (5th Cir. 2013) .....................................................................................................3
United States v. Runyan,
290 F.3d 223 (5th Cir. 2002) .....................................................................................................3
United States v. Shah,
95 F.4th 328 (5th Cir. 2024) ..............................................................................................15, 16
United States v. Sipe,
388 F.3d 471 (5th Cir. 2024) .............................................................................7, 11, 21, 22, 23
United States v. Weintraub,
871 F.2d 1257 (5th Cir. 1989) .................................................................................................14
United States v. White,
569 F.2d 263 (5th Cir. 1978) ...................................................................................................12

Other Authorities
Fed. R. Crim. P. 33(a) ........................................................................................................2, 3, 4, 23
Department of Justice, Justice Manual ............................................................................................6

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SUMMARY AND INTRODUCTION
Over three months after Ms. Hockridge’s trial, the Government belatedly produced
material, favorable evidence material to the defense as evidence the Government seeks to use at
sentencing. While the newly disclosed is “new” to Ms. Hockridge and her counsel, it has not “new”
to the Government: it has been in the Government’s possession for years. The evidence in question
includes recordings and transcripts of interviews conducted by the Government during its
investigation into its star witness, Eric Karnezis. At trial, Karnezis claimed that Ms. Hockridge
had taught him how to submit fraudulent PPP applications—despite a long, written chain of
communications where Karnezis assured Ms. Hockridge of the validity of the applications he
submitted and provided false explanations to Ms. Hockridge to dispel her suspicions. Given the
lack of corroboration (and the presence of written contradictions) for his testimony, Karnezis’s
credibility (or lack thereof) was a central issue in Ms. Hockridge’s trial. The newly disclosed
materials, which the Government had in its possession for more than two years before Ms.
Hockridge’s trial, plainly discredits Karnezis’s testimony. Yet the Government never disclosed the
evidence to the defense until the jury had already rendered a verdict.
The Government’s late-breaking production includes (1) an audio recording and MOI of a
2023 interview with Newly Disclosed Government Witness #1 (“GW-1”), see Ex. A,1 (2) a
transcript of an interview of Newly Disclosed Government Witness #2 (“GW-2”), see Ex. B, and
(3) the audio recording and transcript of an interview of Newly Disclosed Government Witness #3
(“GW-3”), see Ex. C, all of whom were involved in fraudulent activities with Karnezis related to
their PPP applications. The statements in those transcripts and recordings tell a very different story

1 At the Government’s request, the names of witnesses in the newly disclosed evidence have

been redacted and Ms. Hockridge has contemporaneously filed a motion seeking to file the refer-
enced exhibits under seal.

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from the one Karnezis testified to at trial, and they provide alternative explanations and
motivations that Ms. Hockridge’s counsel could have used to undercut his testimony and
credibility on cross-examination. Given that such evidence was not only favorable but critical to
Ms. Hockridge’s defense to Count One of the Superseding Indictment, it should have been
produced to the defense months ago and, at a minimum, before the jury returned its verdict based
on an incomplete record.
The newly disclosed evidence is also material to Ms. Hockridge’s defense because it raises
a reasonable probability that the jury would not have convicted her if the evidence had been
disclosed. It substantially bolsters Ms. Hockridge’s arguments that Count One of the Superseding
Indictment did not describe a single conspiracy but was unconstitutionally duplicative. It undercuts
the Government’s case that Ms. Hockridge knowingly joined any conspiracy. And it contradicts
Karnezis’s trial testimony in key aspects in which he appears to have twisted the facts to connect
Ms. Hockridge to his own PPP fraud. Each of these on its own provides a substantial probability
that the jury would not have convicted Ms. Hockridge of conspiracy. Considered together, the
record is unequivocal that Ms. Hockridge was fundamentally deprived of her right to a fair trial,
based on the Government’s inexcusable delay in producing material, exculpatory evidence. The
Court should therefore grant Ms. Hockridge’s motion for a new trial.2

2 Ms. Hockridge and her codefendant Nathan Reis have filed a joint motion to compel the
disclosure of additional evidence the Government has withheld. See Defs.’ Joint Mot. to Compel
(Doc. #332). The Court has yet to rule on that motion. While Ms. Hockridge is and has been
entitled to that evidence, she respectfully submits that the Government’s belated disclosures to
date are alone sufficient to warrant relief under Brady v. Maryland, 373 U.S. 83 (1963).
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LEGAL STANDARD
Under Federal Rule of Criminal Procedure 33(b)(1), a defendant may move for a new trial
on the basis of newly discovered evidence within three years of a guilty verdict. The Court may
grant such a motion “if the interest of justice so requires.” Fed. R. Crim. P. 33(a). The Court’s
inquiry on a Rule 33 motion “goes to the fairness of the trial rather than to the question of guilt or
innocence.” United States v. McRae, 795 F.3d 471, 481 (5th Cir. 2015) (citations omitted). Indeed,
“if a trial court concludes for any reason that the trial has resulted in a miscarriage of justice,” Rule
33 vests “the court [with] broad powers to grant a new trial.” United States v. Bowen, 969 F. Supp.
2d 546, 574 (E.D. La. 2013) (emphasis added), aff’d, 799 F.3d 336 (5th Cir. 2015).
Rule 33 therefore provides a critical mechanism for this Court “to avoid injustice generally
and to avoid a jury verdict for which one has compromised confidence specifically,” United States
v. Poole, 735 F.3d 269, 278 (5th Cir. 2013), including where “the defendant’s ‘substantial rights’
have been harmed” by errors at trial, United States v. Jindal, 621 F. Supp. 3d 727, 735 (E.D. Tex.
2022) (citing United States v. Bowen, 799 F.3d 336, 349 (5th Cir. 2015)). While a motion for new
trial on the basis of newly discovered evidence typically requires the movant to prove (among
other things) that the new evidence is not merely impeaching and “would probably produce a new
result,” a motion for new trial based the Government’s wrongful failure to produce favorable
evidence before trial is reviewed under the less demanding Brady standard detailed below. See
United States v. Runyan, 290 F.3d 223, 247 (5th Cir. 2002) (“[W]hen a motion for new trial based
on newly discovered evidence raises a Brady claim, this court instead applies the three-prong
Brady test to determine whether a new trial is appropriate.”).
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DISCUSSION
The Due Process Clause requires that the Government disclose evidence in its possession
that is (1) favorable to a defendant and (2) material to guilt or punishment. See Brady v. Maryland,
373 U.S. 83, 87 (1963). This affirmative obligation attaches “irrespective of the good or bad faith
of the prosecution.” Id. The Brady doctrine applies both to substantive and impeachment evidence.
See Giglio v. United States, 404 U.S. 150, 154 (1972). And it “encompasses evidence known only
to police and investigators and not to the prosecutor,” such that “the individual prosecutor has a
duty to learn of any favorable evidence known to the others acting on the government’s behalf in
[the] case, including the police.” Strickler v. Green, 527 U.S. 263, 280–81 (1999) (quotation
omitted). Here, the Government possessed favorable, material evidence that called into question
the veracity of its star witness’s trial testimony, yet it failed to disclose this information before trial.
Ms. Hockridge is therefore entitled to a new trial, and her Rule 33 motion should be granted.
I.
Regardless of Its Good or Bad Faith, the Government Violated Brady and Giglio by
Withholding Favorable Exculpatory and Impeachment Evidence
Under the first step of the Brady analysis, a defendant can show that undisclosed “evidence
is favorable . . . if it is either exculpatory or impeaching.” United States v. Cessa, 861 F.3d 121,
128 (5th Cir. 2017). Here, the withheld evidence satisfies both prongs of the test. It is exculpatory
because the information contained in the transcripts and recordings undermines the Government’s
claim that there was a single conspiracy and that Ms. Hockridge “joined the conspiracy and did so
with specific intent,” including its assertion that it was Ms. Hockridge who instructed Karnezis on
how to submit fraudulent PPP applications. Id. at 130 (holding 302 reports were exculpatory where
they supported defense theory that “although [the defendant] knew” his business partners “were
engaged in drug trafficking, he did not join the money laundering conspiracy” he was charged
with). And because key Government witness Eric Karnezis “testified inconsistently with”
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statements by his coconspirators that are reflected in the transcripts and recordings, those
statements (or the testimony of those witnesses) “could have impeached [his] testimony” and thus
constitute Brady material on that independent basis. Id. at 131. On either basis, a new trial is
warranted.
A. The Government Was in Possession the Withheld Evidence Prior to Trial
Brady’s disclosure obligations extend to “any favorable evidence known to the others
acting on the government’s behalf in the case,” including members of the police and other
investigators. Kyles v. Whitley, 514 U.S. 419, 437 (1995). If Brady material is not in the direct
possession of a prosecuting office but is possessed by another arm of the Government, the
prosecution “has a duty to learn” of that evidence and disclose it. Id.; see also United States v.
Auten, 632 F.2d 478, 481 (5th Cir. 1980) (holding prosecution violated Brady by failing to “run
an FBI or NCIC check on [a] witness,” since that information was “known” to the government “in
the context of the disclosure requirements”).3
Here, the Government obviously possessed the withheld evidence—after all, it eventually
produced the withheld evidence to the defense. The Government also possessed the withheld
evidence before Ms. Hockridge’s trial, as reflected by the dates of the recordings, transcripts, and
reports themselves, all of which were generated by the Government. It also appears likely that at
least the DOJ prosecutors entered in Ms. Hockridge’s case had actual possession of the withheld
evidence prior to trial, seeing as those prosecutors investigated Karnezis in a joint operation with

3 Indeed, the interview of GW-3 appears to have taken place the same day as Ms.
Hockridge’s proffer interview, and the interview of GW-2 the day prior. Despite that timing, FBI
Special Agent Colin Friedemann testified at trial that the Government had not recorded interviews
of any witnesses related to the case besides Anthony and Eric Karnezis. See 6/14 Tr. 175:4–7.
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the District of Oregon. See Resp. to Joint Mot. to Compel (Doc. #332) at 4 n.3 (detailing
coordination among the various offices following Karnezis’s arrest).4
But even if the trial team in Ms. Hockridge’s case did not have “present possession” of the
withheld evidence prior to trial of the trial, its coordination with the U.S. Attorney’s Office for the
District of Oregon demonstrates that the prosecution nonetheless “had access” to the evidence and
therefore “possessed” it for Brady purposes. Auten, 632 F.2d at 481 (citing United States v.
Deutsch, 475 F.2d 55 (5th Cir. 1973)). Given the multi-district nature of the DOJ’s investigation,
the DOJ’s supervision of a multi-district operation tied the various offices together as part of a
single prosecution team. See U.S. Dep’t of Justice, Justice Manual § 9-5.002(A) (noting that in
“multi-district investigations,” the “prosecution team” can include “both Assistant United States
Attorneys and prosecutors from a Department litigating component or other United States
Attorney’s Office,” thus reaching “parallel criminal and civil proceedings”).
B. The Withheld Evidence Shows That Eric Karnezis Was Part of a Separate Criminal
Conspiracy to Commit PPP Fraud That Predated His Being Introduced to Ms.
Hockridge
The withheld materials describe Eric Kanezis’s involvement in a separate PPP conspiracy
that existed before January 2021, which is when he first met Ms. Hockridge. 6/16 Tr. 136:21–
136:22, 171:12–172:2. First, in the recording of GW-1’s interview—which contains no mention
of Ms. Hockridge (or even Mr. Reis)—GW-1 stated that in December 2020 (the month before Ms.

4 The Government’s Response is somewhat equivocal on this point, indicating that the
Government “obtain[ed] and produc[ed] these witness interviews” in response to the defense’s
request of evidence supporting the Government’s loss calculations at sentencing, without
specifying precisely when it “obtained” the withheld evidence. Resp. (Doc. #332) at 5. But, as
explained herein, the exact moment the members of the prosecution team obtained actual
possession of the withheld evidence is irrelevant—it plainly had access to Karnezis-related files
and evidence maintained by the United States Attorney’s Office for the District of Oregon, where
the interviews were conducted.
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Hockridge was introduced Karnezis), GW-1 met GW-2 at a hookah lounge. See Ex. A at 2.
According to GW-1, GW-2 conveyed that he could help GW-1 obtain a loan. Id. The following
month, GW-1, GW-2, and two others met at the hookah lounge and discussed the loan opportunity,
which was part of the PPP. Id. GW-2 and the two others outlined the process for obtaining a PPP
loan on GW-1’s behalf, in exchange for 30% of the loan proceeds. Id. at 3. GW-1 agreed to proceed,
received a PPP loan, and paid the 30% fee. Id. at 4.
GW-1further stated that authorities arrested him in early 2023 for PPP fraud, and he shared
a jail cell with GW-2. Id. at 5. During their detention, GW-2 told GW-1 that “if anyone should
‘snitch’ they should be telling on ‘ERIC [Karnezis5]’ and ‘BAYLESS [Cobb],6” whom GW-2 said
were the people above him that were running ‘whatever was going on.’” Id. at 6 (emphasis added).
GW-2 “described either ERIC or BAYLESS . . . as the actual banker, and specifically stated that
‘if there was anybody that needed to be snitched on [it’s] ERIC and BAYLESS.” Id. (emphasis
added). GW-2 further explained that either Karnezis or Bayless Cobb was the “banker who [was]
pushing the loans through.” Id. Additionally, GW-2 stated that the “Banker” had run “up a lot of
money the first round of funding,” referencing PPP Round 1, which ended months before
Karnezis ever interacted with Ms. Hockridge. Id. (emphasis added). GW-2 also revealed that
members of the infamous “Bloods” gang were part of the PPP fraud scheme, under Karnezis and
Bayless Cobb. Id.7

5 GW-2’s plea agreement says “there was an agreement between defendant and co-
conspirators known and unknown, including [GW-2] and Eric Karnezis, to fraudulently obtain
funds under the Paycheck Protection Program.”
6 Bayless Cobb is a Karnezis associate whom Karnezis falsely identified to Ms. Hockridge
as “Rick Diamond” and “Victor Strand.” See 6/16 Tr. 93:20–94:3.
7 The newly disclosed evidence can constitute Brady material even though it is hearsay,
including because it would provide the defense additional lines of inquiry to investigate the
witnesses or cross-examine Karnezis. See United States v. Sipe, 388 F.3d 471, 485 (5th Cir. 2024)

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Next, in the transcript of his interview, GW-2—consistent with GW-1’s interview—
admitted that that GW-2 was in a scheme with Karnezis and Cobb and that he would “pay them
[not Ms. Hockridge] a third” of the proceeds. Ex. B at 21:6–14, 68:4–9 (emphasis added). GW-2
did not identify anyone “above” Karnezis and Cobb in the scheme. In addition, GW-2 stated that
the scheme involved money laundering. Id. at 145:22–25.
Finally, the Government interviewed GW-3—one of Karnezis’s clients who had submitted
a PPP loan application. In that interview, GW-3 stated that another Karnezis associate approached
him in early 2020, even prior to Round 1 of the PPP program, and helped GW-3 apply for a
fraudulent EIDL loan. Ex. C at 4:15–21. Then, during Round 1 of the PPP program (again, prior
to Ms. Hockridge’s ever meeting Karnezis), Karnezis’s associate approached GW-3 again to tell
him about “Eric” (i.e., Karnezis), who could get GW-3 $1 million in exchange for 35% of the loan
proceeds. Id. at 12:14–13:19. Karnezis told GW-3 that Karnezis had a “guy in the SBA” who was
“bulletproof.” Id. at 20:7–11. Then, in 2022, well after Ms. Hockridge left Blueacorn, Karnezis
told GW-3 that he would need to send an additional $150,000 to “Jack Whitehead” at Blueacorn
to get his loan forgiven.8 Id. at 41:8–9, 50:11–19, 52:15–19. In contrast, Karnezis testified at trial
that he and his cohorts charged borrowers fees of between 2.5% and 10%. 6/16 Tr. 145:19–145:23;
see also 147:8–147:10. Critically, GW-3 stated that the name “Stephanie” does not “ring a bell.”
Id. at 96:22–24.

(“Evidence may be material under Brady even though it is inadmissible. . . . Because of the
requirement that the outcome of the proceeding be affected, we often consider whether the
suppressed, inadmissible evidence would have led to admissible evidence.”).
8 Ms. Hockridge is not aware of any person affiliated with Blueacorn named “Jack
Whitehead,” who may very well be yet another fictious person created by Karnezis, likely as cover
for asking for more money. Neither Blueacorn nor VIPPP charged additional fees upon loan
forgiveness. See 6/17 Tr. 331:8–20.
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Together, the withheld pieces of evidence illustrate Karnezis’s involvement in a criminal
conspiracy that (1) existed before January 2021, when he first met Ms. Hockridge, (2) was separate
from the alleged VIPPP conspiracy, and (3) continued after Ms. Hockridge left Blueacorn. GW-1
described Karnezis’s involvement in a conspiracy to obtain PPP loans during the “first round of
funding” for PPP—i.e., in mid-2020—and that also involved a December 2020 meeting about
obtaining a PPP loan. GW-3 described being personally asked by Karnezis for an additional fee in
2022 (supposedly to be sent to “Jack Whitehead” at Blueacorn), even though Ms. Hockridge left
Blueacorn in mid-April 2021. Compare Ex. C at 41:3–9, with 6/17 Tr. 350:16–351:3. And as to
the distinct nature of the conspiracy described by Karnezis’s coconspirators and the one he testified
to a trial, the scheme GW-1 described involved gang members, money laundering, and paying the
conspirators 30% of the loan proceeds—totally unlike conspiracy under which the Government
charged Ms. Hockridge and to which Karnezis testified at trial.
On top of that, GW-3 described Karnezis’s scheme as charging an initial fee of 35% of the
loan proceeds, then explained that Karnezis increased the fee by another 5% because he claimed
Blueacorn allegedly had “received more applications than they could cover,” and that Karnezis
personally demanded more money to get GW-3’s applications approved. Ex. C at 73:15–25, 75:9–
23. The only people on the phone call where Karnezis demanded more money were GW-3,
Karnezis himself, and Karnezis’s associate (who did not work for Blueacorn or VIPPP). Id. at
78:6–8. The indictment does not allege anything about those transactions, which undermine the
claim that Karnezis was engaged in the same conspiracy as Government claims Ms. Hockridge
was involved in during “Round 1” of the PPP funding in early 2020.
Put together, the withheld evidence supports Ms. Hockridge’s defense in at least two ways.
By painting a fuller picture of Karnezis’s activities, which were distinct from and inconsistent with
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the fraudulent conspiracy alleged in Count One of the Superseding Indictment, the withheld
evidence bolsters Ms. Hockridge’s argument at trial that the Government’s indictment
impermissibly lumped together numerous distinct courses of conduct during the two distinct
rounds of the PPP. Similarly, by implicating Karnezis with a cast of characters who did not know
Ms. Hockridge, the withheld evidence makes it less likely that Ms. Hockridge knowingly agreed
to join any conspiracy in the first place. And, because the withheld evidence “len[ds] support to”
Ms. Hockridge’s “trial theory,” it is therefore “favorable” to the defense for Brady purposes. Cessa,
861 F.3d at 130.
C. The Withheld Evidence Undermines the Credibility of the Government’s Star
Witness, Eric Karnezis
In addition to undermining the Government’s theory as to Ms. Hockridge’s involvement in
the conspiracy charged in Count One, the Government’s late-breaking revelations undermine at
least three important aspects of Karnezis’s testimony—and thus, the Government’s case against
Ms. Hockridge.
First, Karnezis testified that he only started working with Ms. Hockridge to process PPP
loans in January 2021, 6/16 Tr. 136:21–136:22, 171:12–172:2, based on training he received from
Mr. Reis in December 2020 or January 2021, 6/16 Tr. 65:19–65:25; see also id. at 106:9–106:14.
Yet GW-1’s account indicates that Karnezis was involved in PPP loan fraud even earlier—
including during the first round of PPP in mid-2020. That claim is corroborated by GW-3’s
statements that he received PPP loans in 2020 through Karnezis’s associate. See Ex. C at 26:3–14,
27:6–11.
Second, Karnezis portrayed himself as merely following Ms. Hockridge’s training and
instructions to commit PPP fraud in 2021. See, e.g., 6/16 Tr. 71:9–71:21, 72:16–72:17, 74:2–74:11,
107:10–107:14. Yet GW-1’s account paints Karnezis as the leader of the conspiracy, along with
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Bayless Cobb. GW-3’s statements undermine the notion that Karnezis was simply following orders
from Ms. Hockridge, as he recounted Karnezis as conspiring with a corrupt SBA employee to get
loan applications approved and charging a 35% fee (with a 5% follow-up in 2022)—a far cry from
the 2.5% to 10% that Karnezis said his customers were charged. Compare Ex. C at 12:23–13:5,
41:3–9, with 6/26 Tr. 146:19–23.
Third, despite the fact that his loans account for more than 90% of its proposed loss
calculation, the Government contends that Karnezis’s fraud was merely an extension of the
conspiracy. Yet GW-1’s and GW-2’s accounts describe Karnezis as involved in a conspiracy that
differed fundamentally from the Government’s allegations, because, for example, the Karnezis
conspiracy involved gang members, money laundering, and a 30% fee.
II. The Withheld Evidence Was Material

Withheld evidence is material, and thus a violation of the Fifth Amendment, if, among
other things, “there is a reasonable probability that, had the evidence been disclosed to the defense,
the result of the proceeding would have been different.” Cessa, 861 F.3d at 128 (quoting United
States v. Dvorin, 817 F.3d 438, 450 (5th Cir. 2016)). A “reasonable probability” is less than a
preponderance of the evidence—it “does not mean that the defendant ‘would more likely than not
have received a different verdict with the evidence,’ only that the likelihood of a different result is
great enough to ‘undermine confidence in the outcome of the trial.’” Smith v. Cain, 565 U.S. 73,
75 (2012) (cleaned up, emphasis added) (quoting Kyles v. Whitley, 514 U.S. 419, 434 (1995)).
“When there are a number of Brady violations, a court must analyze whether the cumulative effect
of all such evidence suppressed by the government raises a reasonable probability that its
disclosure would have produced a different result.” United States v. Sipe, 388 F.3d 471, 478 (5th
Cir. 2004). Here, there is far more than a “reasonable probability” that the outcome of the trial
might have differed had the withheld evidence been disclosed. The evidence “would have allowed
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[Ms. Hockridge] to attack the government’s case from every angle,” id. at 488—both as to the
Government’s theory of the case and as to the credibility of its key witness. Thus, the withheld
evidence easily clears the low bar of materiality under Brady and warrants a new trial. Id.
A. The Withheld Evidence Materially Undermines the Government’s Case That Ms.
Hockridge Knowingly Engaged in the Conspiracy Alleged in the Indictment
At trial, Ms. Hockridge maintained that the Government’s case against her suffered from
at least two fatal defects: that the Government could not prove beyond a reasonable doubt that she
knowingly joined any conspiracy, and that the Government presented evidence not of a single
conspiracy but of multiple different conspiracies. The withheld evidence further exposes both of
those flaws, creating a reasonable probability that the jury would not have found Ms. Hockridge
guilty beyond a reasonable doubt, if only she had been able to use the withheld evidence to
challenge the testimony and credibility of the Government’s key cooperating witness, Eric
Karnezis. The interest of justice therefore requires that Ms. Hockridge be granted a new trial.
1. Had Ms. Hockridge Been Able to Investigate and Introduce Evidence Relating to
the Withheld Evidence, It Would Have Decreased the Likelihood That the Jury
Would Have Convicted Her of Conspiring with Karnezis

The withheld evidence creates a reasonable likelihood that the jury might not have found
that Ms. Hockridge knowingly joined a conspiracy with Karnezis.9 It was the Government’s
burden to prove “beyond a reasonable doubt that a conspiracy existed, that the accused knew it
and, with knowledge, voluntarily joined it.” United States v. White, 569 F.2d 263, 266–67 (5th Cir.
1978) (emphasis added, citation omitted). The Government’s trial evidence that Ms. Hockridge
ever engaged in a fraudulent conspiracy with Karnezis was thin. Importantly, the contemporaneous
written evidence completely contradicted the Government’s theory: it showed (1) that Karnezis

9 That probability is only increased by the fact that Ms. Hockridge was acquitted on the
remaining counts of the Superseding Indictment.
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lied to Ms. Hockridge to cover up fraud he was committing and (2) that Ms. Hockridge had
repeatedly instructed her employees not to accept fraudulent applications and shared guidance on
how to avoid fraud. See, e.g., DE-5221 (message from Ms. Hockridge to members of the VIPPP
team: “[P]lease take a moment to read this. . . . The Secret Service alert contains fraud indicators
for PPP Application fraud. . . . If you ever suspect fraud, please let me know!”); DE-1509 (message
chain from Ms. Hockridge providing “an update on the ‘Rick Diamond Situation’” in which she
describes attempts to rectify fraud by withdrawing fraudulent applications and in which she advises
VIPPP team members to seek applicant verification of loans that may appear fraudulent). To
circumvent the facts in hopes of a more favorable sentencing recommendation, Karnezis concocted
a just-so story that all these communications were in fact evidence that there was a conspiracy, but
that Ms. Hockridge wanted to cover it up by leaving a “clean” paper trail.
The withheld evidence, by contrast, provides a much more plausible explanation: Karnezis
was lying to Ms. Hockridge because he was involved in an independent fraudulent conspiracy that
allowed him to squeeze borrowers for a higher fee than Ms. Hockridge was charging within her
own channel and that Ms. Hockridge would have shut down had she known about Karnezis’s fraud.
Nor did the Government present any evidence, much less evidence beyond a reasonable doubt,
that Ms. Hockridge knowingly joined a scheme like the one described by GW-1 and GW-2. Neither
GW-1 nor GW-2 knew anything about Ms. Hockridge; they stated that Karnezis and Bayless Cobb
were the leaders of their conspiracy—the same Bayless Cobb whose identity Karnezis hid from
Ms. Hockridge and whose fraudulent loan applications Ms. Hockridge stopped from being
submitted to the SBA. See, e.g., DE-40.
GW-3’s interview transcript further reveals that Karnezis and his associates were charging
substantially more for submitting a PPP loan application—35%, followed by a later squeeze for
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an additional 5%—than the 2.5% to 10% processing fee Karnezis said he charged his VIPPP clients.
In other words, for Ms. Hockridge to be part of this conspiracy, she would have been cutting herself
out of any benefit from the huge cut that Karnezis took and that all of his other co-conspirators
shared in. The jury heard no evidence tying Ms. Hockridge to anything like this belatedly disclosed
scheme. But the more Karnezis could have been shown to have worked independently from and at
cross-purposes with Ms. Hockridge, the less likely it is that the jury would have found beyond a
reasonable doubt that Ms. Hockridge conspired with him.
The newly disclosed evidence further buttresses Ms. Hockridge’s steadfast assertion at trial
that she never conspired with Karnezis but acted consistently with the exculpatory
communications she was ultimately permitted to introduce. See United States v. Weintraub, 871
F.2d 1257, 1262 (5th Cir. 1989) (“[W]here the withheld evidence would seriously undermine the
testimony of a key witness on an essential issue or there is no strong corroboration, the withheld
evidence has been found to be material.”). What’s more, the newly disclosed evidence places
Karnezis in a conspiracy that both started before and continued after he worked with Ms.
Hockridge at VIPPP, involving people who had no connection to Blueacorn or Ms. Hockridge,
with Karnezis and Cobb the top of the pyramid. If the jurors had heard evidence about GW-1,
GW-2, and GW-3, there is at least a reasonable probability that they would have acquitted Ms.
Hockridge on Count One of the Superseding Indictment, as they did on the other charges against
her.
2. Had the Newly Disclosed Evidence Not Been Withheld, It Would Have Decreased
the Likelihood That the Jury Would Have Found That Ms. Hockridge Was Part
of the Conspiracy Charged in the Superseding Indictment
Given the night-and-day evidence regarding Karnezis’s involvement with GW-1, GW-2,
and GW-3 and the nature of Karnezis’s involvement with Ms. Hockridge, there is also a reasonable
probability that the withheld evidence would have convinced the jury that the conspiracy Karnezis
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was part of was not the conspiracy charged in the Superseding Indictment. As Ms. Hockridge has
previously explained, the Government had to prove that Count One of the Superseding Indictment
referred to a single conspiracy, while the evidence showed at least two distinct conspiracies that
took place at different times and with different manners and means. See, e.g., Mem. ISO Renewed
Mot. for Judgment of Acquittal (Doc. #267) at 24–32. To prove the existence of a single conspiracy,
the Government had to demonstrate “the existence of a common goal,” a similar “nature of the
scheme,” and “the overlapping of the participants in various dealings.” United States v. Shah, 95
F.4th 328, 361 (5th Cir. 2024) (quoting United States v. Beacham, 774 F.3d 267, 273 (5th Cir.
2014)). The withheld evidence, however, would have seriously compromised the Government’s
efforts to make those showings.
The withheld evidence drives home that any conspiracy involving Karnezis during
Round 2 of the PPP program in 2021 simply could not have been the same conspiracy as what the
Government alleges occurred during Round 1 in 2020. Most notably, the manner, means, and
members of the conspiracy described in the withheld evidence diverge substantially from the
activities alleged to have occurred during the first half of 2020. The activities in early 2020—
which largely involved loan applicants personally known to Mr. Reis, Flores, and others—look
nothing like the course of conduct described in the newly disclosed evidence: a scheme involving
members of the infamous “Bloods” gang, who were creating fake businesses and funneling
applications to Karnezis for processing by his contact at the SBA. According to GW-3, Karnezis’s
conspiracy involved a two-part fee structure: charge 35% of the loan amount as an upfront price
for submitting a loan application and calling up a corrupt SBA member to shepherd the loan
through the approval process, then reach out and charge an additional 5% on the grounds that there
was only a little bit of money “to distribute” and there would be “a lot of empty chairs.” Ex. C at
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74:9–24. Finally, several key players in Karnezis’s conspiracy, as described in the newly disclosed
evidence, were unknown and unrelated to Ms. Hockridge—and in several cases committed their
crimes during Round 1 of the PPP, before Ms. Hockridge had even met Karnezis.
The withheld evidence further thus suggests that Karnezis’s conspiracy started
independently from Ms. Hockridge. It shows a completely different manner and means, and
reveals entirely different participants, than the Government’s evidence of a conspiracy at VIPPP
during the first few months of 2021. Those courses of conduct lack any “common goal,” a similar
“nature,” or substantial “overlapping of the participants.” Shah, 95 F.4th at 361 (quotation omitted).
And the Government has produced no evidence tending to show that Karnezis’s conspiracy ever
merged with a conspiracy involving Ms. Hockridge, or that Karnezis’s original goals and conduct
ever morphed to cover the different goals and conduct which he claimed to have carried out with
Ms. Hockridge’s help. In other words, if Ms. Hockridge were conspiring with Karnezis in the
scheme revealed by the newly disclosed evidence, her conduct could not have formed part of the
same conspiracy as charged in the indictment. There is thus a reasonable probability that, if the
withheld evidence had been disclosed to Ms. Hockridge so she could call GW-1, GW-2, and GW-3
as witnesses (or develop further evidence based on their interviews), the jury would not have found
beyond a reasonable doubt that Ms. Hockridge was guilty of the conspiracy alleged in the
indictment. The evidence is therefore material under Brady and warrants a new trial.
B. The Withheld Evidence Materially Undermines the Government’s Reliance on Eric
Karnezis’s Repeated Lies
The jury acquitted Ms. Hockridge of substantive fraud counts that the Government alleged
involved prosecution witnesses Devin Hochberg and Jimmy Flores. Its case that Ms. Hockridge
was involved in a conspiracy in 2021 therefore relied heavily on the credibility of its star witness,
Eric Karnezis. Karnezis, who was testifying pursuant to a plea agreement and hoping for a lighter
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sentence, told an apparently damning story: that he met Ms. Hockridge and began committing
fraud at the start of PPP Round 2 in January 2021, 6/16 Tr. 65:19–65:25; see also id. at 106:9–
106:14; that Ms. Hockridge instructed him on how to commit fraud, id. at 71:9–71:21, 72:16–
72:17, 74:2–74:11, 107:10–107:14; and that Ms. Hockridge wanted to keep a “clean” paper trail,
so the evidence that she was trying to prevent fraud at Blueacorn was transmogrified into evidence
of the conspiracy itself, id. at 96:20–25. Yet the newly disclosed evidence undermines every part
of that story.
The first new hole in Karnezis’s testimony is the timing. At trial, Karnezis testified that he
met Bayless Cobb “at a Ford dealership” in February 2021, after Karnezis started submitting loan
applications to VIPPP. 6/16 Tr. at 190:15–22. But the report of the Government’s interview with
GW-1 indicates that both Karnezis and Bayless Cobb were involved in “the first round of
funding,”—i.e., the PPP Round 1 that ran from May until August of 2020. See Ex. A at 7. Evidence
that Karnezis was involved in fraud with Cobb before Karnezis worked with Ms. Hockridge would
have undermined his credibility and unraveled the story that it was Ms. Hockridge who coached
him on how to commit fraud. Likewise, the newly disclosed evidence reveals Karnezis as the
mastermind of a separate scheme to commit PPP fraud, alongside Cobb. GW-3 told Government
investigators that he was introduced to Karnezis as someone who “ha[d] a guy in Sacramento who
works with the SBA,” which is nothing like the means of the alleged conspiracy the Government
accused Ms. Hockridge of joining. See Ex. C at 12:23–13:2. As such, the new evidence seriously
challenges Karnezis’s claims that he learned to commit fraud from Ms. Hockridge and Mr. Reis
and that he merely followed their lead in doing so. And if Ms. Hockridge had been able to impeach
Karnezis with the newly disclosed evidence—or if she had enough information to have called
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GW-1 and GW-2 as witnesses—she would have been able to undercut the alleged ties between
herself and Karnezis’s criminal activities.
The Government’s interview of GW-3 further provides material to impeach Karnezis by
contextualizing one of the Government’s trial exhibits. GW-3’s interview indicates that GW-3
submitted a false PPP loan application with Karnezis’s assistance. Ex. 3 at 12:23–13:11. When an
SBA investigator called GW-3 and left a voicemail inquiring about his PPP loan application,
Karnezis messaged Ms. Hockridge for advice. Karnezis explained, “I never put [GW-3’s] phone
number on the application so I’m wondering if this is legit?” See GX35 at 79–80. Ms. Hockridge
replied that Karnezis should “Just have [GW-3] talk to the SBA guy and provide all necessary
paperwork. He should be just fine. . . . Capital plus was probably being safe rather than sorry.” Id.
While Ms. Hockridge had this exhibit before trial, she lacked the essential context of GW-3’s
interview to demonstrate to the jury that these messages showed Karnezis asking about a loan
application he knew was fraudulent but Ms. Hockridge did not know was fraudulent. GW-3’s
interview would have allowed the defense to undercut Karnezis’ credibility (by showing that he
lied to Ms. Hockridge) and to underscore the implausibility of the Government’s theory that Ms.
Hockridge had knowingly conspired with Karnezis to commit fraud.
Finally, when Ms. Hockridge’s counsel asked why Karnezis had kept full knowledge of
his Cobb-related coconspirators from Ms. Hockridge, he testified that he wanted to be able to
collect his commission from the borrowers. 6/16 Tr. at 205:8–14. But the evidence from GW-2
and GW-3 casts doubt on that testimony by painting Karnezis as collecting 35% (not the 10% that
he testified to) as a fee for the borrowers he conspired with. In other words, Karnezis was hiding
his own fraudulent activities from Ms. Hockridge because he, without her knowledge, was running
a personally lucrative fraudulent conspiracy and using Ms. Hockridge’s status as a loan processer
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to further his own interests. Plus, Karnezis continued to squeeze an additional 5% out of his
“clients,” such as GW-3, after Ms. Hockridge had already left Blueacorn and after the alleged
conspiracy in the Superseding Indictment had ended. See Ex. C at 41:3–9. Evidence that Karnezis
had an even more powerful financial incentive to hide his fraudulent activities from Ms. Hockridge
seriously undermines his uncorroborated claim that he and Ms. Hockridge discussed his fraud in
off-the-record conversations—the only evidence the Government had to connect Ms. Hockridge
to Karnezis’s admitted fraud.
In its response to Ms. Hockridge’s joint motion to compel additional exculpatory material,
the Government argues that the withheld evidence is not material under Brady because GW-1’s
and GW-2’s statements were not reliable. Resp. (Doc. #332) at 4–9. But the Government’s ipse
dixit is not enough—particularly when the Government believes some of the statements in the
newly disclosed evidence are sufficiently reliable to bolster its loss calculations at sentencing. Ms.
Hockridge at least had the right to investigate the claims made in the newly disclosed evidence to
determine how they could have been used at trial. Moreover, the Government’s response presumes
that Karnezis was truthful when he confessed in custody that he did not have contacts at the SBA
(contrary to what he had told GW-2). But Ms. Hockridge had the right to confront Karnezis with
his inconsistent statements to the jury—not the Government—could judge his credibility. And
although the Government claims to have evidence connecting Mr. Reis to Karnezis before 2021,
there is no evidence that Ms. Hockridge knew Karnezis at that time. Cf. Resp. (Doc. #332) at 9
n.8.
The Government attempts to shore up its argument by again misconstruing the
documentary record in the case. While it claims that exhibits GX-35A and GX-35C are evidence
of Ms. Hockridge “instructing Eric Karnezis” to “invent[] numbers” and make false documents
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“look legitimate,” see Resp. (Doc. #332) at 8–9, these documents show nothing of the sort. Exhibit
35A contains repeated instances of Ms. Hockridge preventing and rectifying fraud, such as
withdrawing and investigating “Rick Diamond” loans and mocking applicants who submitted
suspicious documents for applications the Government did not establish were ever submitted to
the SBA. See, e.g., Ex. 35A at 17 (Ms. Hockridge describing one group of applications that
“needed to be cross-checked to see if they were fraud” and another group of “109 applications that
were all submitted by the same guy [“Rick Diamond” / Bayless Cobb] with Schedule Cs not filled
out in good faith,” where Ms. Hockridge “had to Audit each one by asking [the applicants] to fill
out a new Schedule C and provide supporting documentation, including 1099s and other forms of
payment to prove their amount”). And Exhibit 35C shows only Ms. Hockridge coaching Karnezis
on how a properly completed loan application should look—but nowhere in Exhibit 35C does Ms.
Hockridge instruct Karnezis to invent numbers not provided to him by the borrowers. The only
reason the Government can say that the documents support its case is because Karnezis’s
testimony added extraneous information that altered and sometimes contradicted what the
documents themselves show. See 6/16 Tr. 121 (“Q: Did you understand Ms. Hockridge to be
telling you [in Exhibit 35C] to get real information from the borrowers. A: No.”). In other words,
it all comes back to whether Karnezis was credible, which is exactly Ms. Hockridge’s point. The
newly disclosed evidence undermines his credibility, and Ms. Hockridge should have been able to
have the benefit of the withheld evidence (and any admissible evidence discovered through further
investigation) in attacking his credibility at trial.
Because Karnezis was the Government’s key witness in attempting to prove Ms. Hockridge
knowingly joined a criminal conspiracy, his credibility was essential to the Government’s case.
And although Karnezis presented himself at trial as a reformed criminal trying to right his wrongs,
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the newly disclosed (and previously withheld) evidence only solidifies him as a fundamentally
untrustworthy person who will lie without hesitation to save his own skin. The jury should have
been able to consider whether his testimony was credible in light the full record, not the record as
artificially abridged by the Government’s decision to withhold favorable, material information
from Ms. Hockridge until after the jury returned its verdict. Had the Government honored its
obligations under Brady and its progeny and Ms. Hockridge had been able to introduce or
investigate that evidence, it is significantly less likely that the jury would have found Karnezis’s
testimony sufficiently credible to convict Ms. Hockridge beyond a reasonable doubt on the sole
count on which it returned a guilty verdict.
C. At the Very Least, the Cumulative Effect of the Withheld Evidence on the
Government’s Case Establishes Its Materiality
Even if any part of the withheld evidence were insufficient alone to be material, considered
together, the withheld evidence comfortably satisfies Brady’s materiality standard. As the Fifth
Circuit has explained, undisclosed evidence must be considered in light of its cumulative effect to
assess its “potential impact on the outcome of the trial.” United States v. Sipe, 388 F.3d 471, 491
(5th Cir. 2004). A defendant need not show that the Government failed to present “sufficient
evidence to support a finding of guilt,” id. (emphasis added), as evidence from which a guilty
verdict could be rendered might also leave room for reasonable doubt. Here, there is at least a
reasonable probability that the withheld evidence would have so weakened the Government’s case
under Count One that the jury would not have returned a guilty verdict on the sole count of
conviction, but instead acquitted Ms. Hockridge, as it did on the other counts of the Superseding
Indictment.
In Sipe, the defendant was a border patrol agent who was indicted for using excessive force
during an arrest. 388 F.3d at 478. But “the Presentence Report became a source of controversy
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when it became apparent that the government had disclosed information to the probation officer
that it did not disclose to the defense.” Id. at 475. While the Government’s key witness at trial—a
former colleague of the defendant—had testified to the grand jury that while he “d[idn’t] get along
with [the defendant] that well, he did “[n]ot . . . dislike” the defendant, a prosecution memorandum
had memorialized a pretrial conversation with the witness in which he had “admit[ted] to disliking
[the defendant] even before” the alleged use of excessive force. Id. at 480–81. Moreover, the
Government had “failed to produce information regarding” the witness’s several “brushes with the
law,” including an acquitted charge of falsifying a police report and a deferred adjudication for
misdemeanor theft. Id. at 484–85. The Government had also failed to provide the defense “with a
complete description of the benefits accorded” other testifying witnesses (all of whom had entered
the United States illegally), including living expenses and travel authorizations pending the
defendant’s trial. Id. at 488.10
Both the trial court and the Fifth Circuit agreed that this evidence, taken cumulatively, was
material under Brady and warranted a new trial. Id. at 491. Even though the individual pieces of
evidence were either relatively minor discrepancies or were cumulative of other impeachment
evidence (the Government had already disclosed, for example, that its immigrant witnesses had
been given work authorizations pending their testimony), the Fifth Circuit considered the
“potential impact on the outcome of the trial” to be “too strong” to discount. Id. Finally, the Fifth
Circuit alternatively noted that even if a new trial were not required under Brady, there was
sufficient doubt introduced by the undisclosed evidence to “convince[] the district court that [the
defendant] did not receive a fair trial” and was entitled to a new one. Id.

10 Several other “minor” pieces of evidence were not disclosed but not deemed to be Brady
violations because they were not clearly favorable to the defense and could have been discovered
by the defense. Sipe, 388 F.3d at 491. Neither such qualification of the Brady doctrine applies here.
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Here, the weight of the newly disclosed evidence is substantially greater than in Sipe. Much
of the evidence in Sipe was merely cumulative impeachment evidence that would have allowed
the defense to drive home points they could have made with evidence that had already been timely
disclosed by the Government. Other evidence was relatively minor: a slight discrepancy between
“didn’t get along with” and “disliked,” for example. Here, however, Ms. Hockridge now has access
to substantial evidence that undermines the multiple elements of the Government’s case against
her, drawn from pretrial interviews of three previously undisclosed material witnesses. She also
has access to impeachment evidence against Karnezis on key grounds for which she was
previously unable to impeach him—grounds that sever the ties Karnezis painted between himself
and Ms. Hockridge at trial. In short, this evidence “would have allowed [Ms. Hockridge] to attack
the government’s case from every angle,” id. at 491, and “the favorable evidence could reasonably
be taken to put the whole case in such a different light as to undermine confidence in the verdict.”
Strickler, 527 U.S. at 290 (quoting Kyles, 514 U.S. at 435). Thus, the evidence is material, and
Brady requires that Ms. Hockridge be given a new trial.
III. The Government’s Violation of Brady, in Combination with Other Trial Errors,
Warrants a New Trial in the Interest of Justice
As in Sipe, even if the Government’s wrongful withholding of favorable material evidence
were not enough on its own to require a new trial, Ms. Hockridge has also raised several other
substantial issues that, viewed together, show that a new trial is necessary in the interest of justice
under Rule 33. A “defendant’s ‘substantial rights’ [can be] harmed” by “the cumulative effect of
multiple errors” that undermine the fairness of the trial as a whole. United States v. Jindal, 621 F.
Supp. 3d 727, 735 (E.D. Tex. 2022) (emphasis added) (citing United States v. Bowen, 799 F.3d
336, 349 (5th Cir. 2015)). While the Government’s violation of Brady is sufficient, standing alone,
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to show that the Government has prejudicially violated Ms. Hockridge’s right to a fair trial, that
conclusion is inescapable in light of the numerous other flaws in the Government’s prosecution.
First, consider the bolstering effect of the newly withheld evidence upon the Court’s
decision not to provide numerous jury instructions that Ms. Hockridge requested. Cf. Mem. ISO
Mot. for New Trial (Doc. #269) at 18–24. If the Court had instructed the jury, as Ms. Hockridge
requested, that they could only convict Ms. Hockridge of conspiracy if they unanimously agreed
as to the particular conspiracy charged in the indictment, and if they had learned from the withheld
evidence that Karnezis was part of an entirely separate conspiracy from that alleged in Count One,
then the jury may very well have hung or acquitted on Count One. The Government’s failure to
make required disclosures thus reinforces the impact of instructional errors previously identified
by Ms. Hockridge.
Second, consider the Court’s initial exclusion of substantial evidence that Ms. Hockridge
took efforts to detect and prevent fraud at VIPPP. Cf. Mem. ISO Mot. for New Trial (Doc. #269)
at 25–33. Ms. Hockridge proffered numerous exhibits that impeached Karnezis’s credibility,
motives, and bias, but those documents were excluded when Karnezis was on the stand. Later, the
Court rightfully recognized that these documents should have been admitted, and it allowed Ms.
Hockridge to introduce some of those documents into evidence and show them to the jury in
closing. But by that time, the damage had already been done—Karnezis was off the stand, and Ms.
Hockridge was not able to cross-examine him with the exculpatory communications he had had
with her. Although the denial of that opportunity was highly prejudicial, Karnezis had provided
testimony at trial that allowed him to explain away the exculpatory communications as Ms.
Hockridge keeping a “clean paper trail.” The withheld evidence, which would have allowed Ms.
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Hockridge to impeach Karnezis’s coverup story, would have multiplied the effect of the
exculpatory evidence that was improperly excluded.
The foregoing examples are illustrative, not exhaustive. But they show the snowball effect
of errors in Ms. Hockridge’s trial that, taken together, undermine the “fairness of the trial.” United
States v. McRae, 795 F.3d 471, 481 (5th Cir. 2015). But it is not too late; the errors are not beyond
this Court’s power to correct. Especially given the added prejudice resulting from the
Government’s unexplained failure to disclose Brady materials that Ms. Hockridge could have used
to support her defense, the Court should conclude that the interest of justice justifies granting new
trial.
CONCLUSION
During closing argument and throughout the trial, Ms. Hockridge told the jury that the
Government had failed to present the full context of the case. The jury was convinced enough by
Ms. Hockridge’s argument that it acquitted her of four of the five charges against her. Yet now,
the recent disclosures establish that the Government not only failed to provide full context to the
jury, but materially deprived Ms. Hockridge of the ability to do so by withholding favorable
evidence that was material to her defense. The interest of justice, the Constitution, and Ms.
Hockridge’s fundamental right to a fair trial all require more. Ms. Hockridge therefore respectfully
requests that the Court vacate the jury’s verdict and grant her a new trial on Count One of the
Superseding Indictment.

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Dated: November 6, 2025
Respectfully submitted,

BRYAN CAVE LEIGHTON PAISNER LLP

/s/ Richard E. Finneran
RICHARD E. FINNERAN
MARK A. SRERE
KEVIN H. JENCO
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
Tel: (314) 259-2000
Fax: (314) 259-2020
richard.finneran@bclplaw.com
mark.srere@bclplaw.com
kevin.jenco@bclplaw.com

Attorneys for Defendant Stephanie Hockridge

CERTIFICATE OF SERVICE

I hereby certify that on November 6, 2025, a true and correct copy of the foregoing
document was served on all counsel of record by operation of the Court’s CM/ECF system.

/s/ Richard E. Finneran

RICHARD E. FINNERAN
Case 4:24-cr-00287-O Document 342 Filed 11/06/25 Page 30 of 30 PageID 8580

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Motion for New Trial — Hockridge, US v. Reis & Hockridge

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