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Transcript of Detention Review Hearing — United States v. Ahmed Sary
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“Transcript of Detention Review Hearing — United States v. Ahmed Sary.”
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 1 of 58
1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
2 NORTHERN DIVISION
3 UNITED STATES OF AMERICA, )
)
4 Plaintiff, )
vs. )
5 ) CRIMINAL NO.:
AHMED M. SARY, ) 1:22-mj-01286-JMC
6 )
Defendant. )
7 __________________________________)
8
Baltimore, Maryland
9 May 9, 2022
4:00 p.m.
10
11 TRANSCRIPT OF PROCEEDINGS
DETENTION REVIEW HEARING
12 BEFORE THE HONORABLE DEBORAH L. BOARDMAN
Courtroom 3A
13
14 For the Plaintiff:
15 Paul A. Riley, Esquire
Abigail E. Ticse, Esquire
16 Assistant U.S. Attorneys
17
For the Defendant:
18
Julie M. Reamy, Esquire
19
20 Also Present: Nevine Ibrahim, Interpreter
21 Proceedings recorded by mechanical stenography, transcript
produced by computer.
22
_____________________________________________________________
23
Patricia G. Mitchell, RMR, CRR
24 Federal Official Court Reporter
101 W. Lombard Street, 4th Floor
25 Baltimore, Maryland 21201
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 2 of 58
2
1 P R O C E E D I N G S
2 (4:21 p.m.)
3 THE COURT: Good afternoon, everyone. The Government
4 please call the case.
5 MR. RILEY: Good afternoon, Your Honor. Calling the
6 case of the United States of America versus Ahmed Sary, Case
7 Number 22-mj-1286-JMC. Assistant U.S. Attorneys Paul Riley and
8 Abigail Ticse on behalf of the Government. We're proceeding in
9 connection with an appeal of an Order Setting Conditions of
10 Release, Your Honor.
11 THE COURT: Okay, good afternoon to both of you.
12 Please have a seat. Ms. Reamy?
13 MS. REAMY: Good afternoon, Your Honor. For the
14 record, my name is Julie Reamy. I represent Ahmed Sary; he's
15 standing to my left at trial table.
16 THE COURT: Okay, good afternoon to you. Good
17 afternoon, Mr. Sary. I'm going to remove my mask because I'm
18 vaccinated. If you are fully vaccinated and are speaking, you
19 may remove your mask. If you're comfortable, you of course can
20 keep your mask on all the time. If you're not vaccinated, your
21 mask stays on. If you're not speaking, please wear your mask.
22 All right?
23 Let's swear the interpreter in, please.
24 (Interpreter duly sworn.)
25 THE CLERK: Could you please state your name for the
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1 record.
2 THE INTERPRETER: Nevine Ibrahim.
3 THE COURT: Are you certified interpreter of Arabic;
4 is that correct?
5 THE INTERPRETER: I am proficient interpreter, Your
6 Honor, towards the certification.
7 THE COURT: In Arabic, that's the language, correct?
8 THE INTERPRETER: Yes, yes.
9 THE COURT: Okay, you can have a seat, thank you.
10 THE INTERPRETER: Thank you.
11 THE COURT: We are here, as Mr. Riley said, on an
12 appeal of a detention -- excuse me, a release order issued
13 earlier today by Judge Hurson. The Government has appealed
14 that, and of course the Court reviews the pretrial release
15 order and any detention order de novo. I need to make an
16 independent determination of whether or not there are
17 conditions of release that will reasonably assure Mr. Sary's
18 appearance and the safety of the community.
19 So let me just tell you what I have reviewed so far.
20 I have reviewed Judge Hurson's release order. I have reviewed
21 the Government's May 8 filing in this case, document 15. I
22 have reviewed Ms. Reamy's submission, document 17. I have read
23 the criminal complaint and the affidavit in support of the
24 criminal complaint and the search warrant for various homes,
25 the Pretrial Services report, and I have the Government's
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1 exhibit and exhibit list from this morning.
2 So with that, Mr. Riley, I will hear from you.
3 MR. RILEY: Yes, Your Honor. I don't know that I
4 have received a copy of Judge Hurson's detention -- release
5 order in this case. It may have just been docketed. Obviously
6 I was present at the hearing so I don't know that I -- the most
7 important person to have a copy is you, Your Honor, but I will
8 note that I have not received that. And we are moving pretty
9 quickly here, given that the hearing before Judge Hurson was
10 just a few hours ago. I did want to note that.
11 THE COURT: I can make you a copy if that is at all
12 useful.
13 MR. RILEY: That would be helpful, Your Honor. I'm
14 happy to, if Your Honor likes, if we get the copy made, if I
15 could have even two minutes to review it --
16 THE COURT: Sure.
17 MR. RILEY: -- very brief period of time. I think I
18 have a good sense of what the ruling was, but the actual
19 written order, it would be nice to see that --
20 THE COURT: Absolutely.
21 MR. RILEY: -- I apologize.
22 THE COURT: No problem, we're moving fast.
23 Mr. Riley, Mr. Sary has been detained since April 29;
24 is that correct?
25 MR. RILEY: Let me check my calendar here -- April
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1 29, yes, that was Friday. Yes, Your Honor, that's correct. I
2 would note this matter was originally set in for a detention
3 hearing before Judge Copperthite on Wednesday last week. There
4 was a continuance asked for by counsel, granted by the Court,
5 which resulted in us being before Judge Hurson this morning.
6 THE COURT: Understood. Ms. Reamy, are the
7 third-party custodians that were part of the release order,
8 Ms. Sary and Ms. Derezinski, are they here?
9 MS. REAMY: Yes.
10 THE COURT: I see them raising their hand.
11 (Document tendered to counsel.)
12 MR. RILEY: Thank you, Your Honor. If I could have a
13 couple minutes to review this quickly.
14 THE COURT: Of course.
15 MR. RILEY: Thank you.
16 (Pause.)
17 MR. RILEY: Thank you, Your Honor.
18 THE COURT: I'm ready to hear from you, Mr. Riley.
19 MR. RILEY: Thank you for your patience, Your Honor.
20 I know Your Honor is reviewing -- for the record, Your Honor,
21 I'm vaxed and boosted so I'll be removing my mask.
22 THE COURT: Okay. If we could all slow down one
23 step. I'm reminding myself as well, so the interpreter can
24 interpret us in real time.
25 MR. RILEY: Thank you, Your Honor. I do have a
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1 tendency to speak quickly, so I'll do my best. Your Honor, the
2 Government would ask this Court to revoke the release order
3 entered earlier today and enter an order of detention. The
4 Government is seeking detention on the basis of risk of flight
5 as well as economic danger to the community. The Government
6 also submits that there is a serious risk that this defendant
7 will obstruct justice or attempt to obstruct justice.
8 Your Honor has reviewed the complaint, Your Honor has
9 reviewed the Government's submission in support of detention.
10 I don't want to belabor the points made and the facts in those
11 documents, but I want to touch briefly on a couple of the
12 3142(g) factors that support detention here.
13 With respect to the nature and circumstances of the
14 offense, Your Honor, this defendant is charged in connection
15 with a sophisticated and far-reaching scheme involving the
16 submission of numerous Paycheck Protection Program loans,
17 Economic Injury Disaster Loans, both of which were provided in
18 connection with the CARES Act in light of the pandemic. These
19 were loans meant to help small business owners across the
20 country.
21 The Government's investigation has revealed that this
22 defendant submitted millions of dollars' worth of loans on
23 behalf of various purported businesses, and then he received
24 kickbacks as a result of his submission of these loans,
25 sometimes amounting to as much as 30 percent of the loan
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1 amount. These loans were obtained by purported businesses
2 across the country, California, New York, New Jersey, Virginia,
3 Texas, Maryland and so on. And this scheme involved multiple
4 co-conspirators, multiple shell companies that were used to
5 launder these kickbacks. The PPP loan applications submitted
6 by this defendant were backed by fake documents such as fake
7 bank statements and fake IRS forms.
8 The complaint references, Your Honor, 40 Paycheck
9 Protection Program loans, 10 million -- amounting to
10 $10 million worth of losses and $2.5 million in kickback
11 payments paid to entities associated with this defendant, Your
12 Honor, as well as entities associated with his
13 co-conspirators.
14 Now from the Government's perspective, Your Honor,
15 these 40 loans, this $10 million is the tip of the iceberg in
16 connection with this fraud, in connection with this scheme, and
17 based on the results of the search warrant executed on Friday
18 two weeks ago, the Government has identified 54 EIDL
19 applications that come back to an IP address associated with
20 this defendant's purported business located at 1600 Hanover
21 Street.
22 Moreover, Your Honor, a search of an apartment,
23 Apartment B at 1600 Hanover Street adjacent to this defendant's
24 business, a search of that location revealed more than 90
25 files, hard copy files meticulously organized that reflected
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1 businesses -- business submissions for PPP loans. These files
2 contained numerous amounts of PII, copies of driver's licenses,
3 Social Security numbers, bank statements, tax documents, as
4 well as copies of checks and PPP application paperwork. Some
5 of the files, Your Honor, contained doctored bank statements as
6 well.
7 These files weren't located in this defendant's
8 business address, Your Honor. They weren't located at 1600
9 Hanover Street. They were located in an adjacent apartment
10 next to the business -- hidden, from the Government's
11 perspective.
12 Based on the revelations from the search warrant
13 conducted on the 29th of April, the Government is still
14 wrapping its arms around the scope of this defendant's fraud,
15 but it appears to be larger and more far-reaching based on
16 those 90-plus files we obtained, Your Honor, than we had first
17 suspected. So all of this is to say, Your Honor, that the
18 fraud scheme at issue here, what's charged in this case, it's a
19 far-reaching scheme involving many loans, involving potentially
20 quite high loss amounts.
21 I note too, Your Honor, the fact that this offense
22 involved fake bank statements, fake tax forms, this underscores
23 not only the seriousness of this offense, but perhaps suggests
24 a facility by this defendant to obtain other fake documents,
25 either obtain them or create them, Your Honor. I will
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1 acknowledge, Your Honor -- and Judge Hurson asked me about this
2 this morning -- the Government did not find any holograms or
3 any documents suggesting that he was creating fake passports or
4 fake licenses, I acknowledge that.
5 The point I'm making, Your Honor, is there's at least
6 some facility there or at least some facility to get in touch
7 with the right person and get those potentially fake travel
8 documents, like new driver's licenses, new passport and so on.
9 The type of items that could facilitate flight from justice.
10 And so too, Your Honor, is the fact that what was -- based on
11 what was recovered during the search, this defendant had access
12 to huge, a huge amount of PII, new Social Security numbers,
13 numerous copies of driver's licenses, banking information and
14 so on.
15 THE COURT: Is there any evidence that he stole that
16 information, or was it provided to him by people who
17 participated in this alleged fraud?
18 MR. RILEY: From the Government's perspective, we
19 understand it to be the latter, Your Honor, that the potential
20 loan applicants were arguably part of the scheme to defraud. I
21 don't want to foreclose the possibility there might be a victim
22 here or there, but that doesn't change the fact -- even if the
23 loan applicants were involved in the scheme, Your Honor, there
24 is applicant 1 referenced in the complaint who obtained a
25 $250,000-plus PPP loan, paid out 25 percent plus in kickbacks
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1 to this defendant, purchased a Mercedes, purchased a luxury
2 apartment and so on. So it's possible, Your Honor, that some
3 folks could be victims, but the Government has the latter
4 understanding that Your Honor referenced.
5 The point I was making, Your Honor, is that this
6 defendant had access to a huge amount of PII, and he may still
7 potentially have access to it if he is released to his home.
8 I'd also note, Your Honor, that during the searches
9 conducted on the 29th, law enforcement recovered numerous,
10 numerous vehicle titles, original vehicle titles, and those
11 titles were not all in this defendant's name, further
12 underscoring this defendant's access to important documents,
13 the type of documents that would potentially allow him or
14 bespeak his ability to obtain or gain possession of a vehicle
15 that law enforcement might not know about, further underscoring
16 the risk of flight.
17 With respect to the weight of the evidence, the
18 weight of the evidence is quite strong here, Your Honor, as set
19 out in our detention submission. Entities that this defendant
20 controlled, and that were at least on paper controlled by his
21 associates, received numerous kickbacks from businesses that
22 received PPP loans. I'll just give two examples for two
23 purported entities tied to this defendant.
24 There's the Am Halal Meat company. Am Halal Meat
25 received $301,000 approximately in kickback payments from 15
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1 different entities that received PPP loans. AMEX Financial
2 Group, another one of the defendant's purported businesses,
3 received $758,341.15 worth of kickback loans from 32 different
4 entities that received PPP loans. And there were multiple
5 other entities involved in this case that, from the
6 Government's perspective, we understand were used to launder
7 these kickback payments
8 At times, as with applicant 1, Your Honor, there were
9 kickback checks made out to just two entities. Certain other
10 occasions, there were kickback checks made out to up to nine
11 different entities to launder, to break up these proceeds.
12 I'd note as well, Your Honor, that law enforcement,
13 during the search conducted of Apartment B, 1600 Hanover
14 Street, located blank checks associated with two entities that
15 weren't in defendant's name; that were in the name of
16 defendant's associates, blank checks that were signed by
17 authorized signatories but with the payee left blank and with
18 the amount left blank, indicating, Your Honor, this defendant's
19 control over some of those entities that weren't in his name
20 that were used to launder funds.
21 THE COURT: So, wait, who were those blank checks
22 signed by, according to you?
23 MR. RILEY: They were signed by authorized
24 signatories on the accounts, not this defendant. So, for
25 example, Your Honor, without getting into the specific name,
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1 one of the entities used to launder funds, from the
2 Government's perspective, received 173,000-plus in kickback
3 payments from a number of PPP loan recipients. During the
4 search for that purported business, law enforcement found
5 checks that were signed by an authorized signatory, not the
6 defendant, that were blank. No payee information --
7 THE COURT: Help me understand how that is evidence
8 of fraud. Are you alleging that he forged their name?
9 MR. RILEY: I apologize -- no, I am not. I am
10 suggesting this shows this defendant's control.
11 THE COURT: Okay, I understand.
12 MR. RILEY: So the entities that were in this
13 defendant's name, his businesses, purported businesses like Am
14 Halal, AMEX Financial Group, they received kickbacks from
15 numerous entities. Other entities that weren't in his name
16 received kickback payments.
17 THE COURT: Okay.
18 MR. RILEY: And two of -- for two of those entities,
19 there were signed checks. Again suggesting that -- his sort of
20 key role in this conspiracy even if his name isn't on the
21 purported business. Is that responsive to Your Honor?
22 THE COURT: It is. I understand, I believe. I was
23 looking at, I think, your exhibits, Exhibit 1 with various
24 blank checks.
25 MR. RILEY: Yes, Your Honor. Those blank checks are
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1 not what I was referring to. These blank checks actually play
2 a different role in the scheme. Your Honor, I'll direct the
3 Court to Exhibit 1.
4 Exhibits 1 through 3, Your Honor, all reflect checks
5 from purported businesses that received PPP funds.
6 THE COURT: Okay.
7 MR. RILEY: All of these checks were seized during
8 the execution of the search warrant on the 29th. Take
9 Exhibit 1, for example, Your Honor. This business, this
10 purported business -- bear with me for one second, I apologize.
11 This purported business received $195,650 PPP loan,
12 paid kickbacks amounting to 22 percent of the loan value to
13 various entities, including AMEX Financial Group which is the
14 defendant's purported business. But what we have here, Your
15 Honor, is blank checks signed. We understand this to be an
16 authorized signatory. Numerous blank checks: $15,000, $15,000,
17 $4,000, $5,000, $5,000.
18 We understood that it was part of this defendant's
19 scheme to assist loan applicants with getting the PPP loans and
20 then request that signed checks with no payee information, with
21 no pay information and no date, he left with that. And that he
22 would be the one who would write out who -- the entities that
23 would receive these checks. So we understand that the
24 defendant was in control of the process to write out the
25 kickback checks, get them deposited. And the Government's
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1 understanding is supported by what applicant 1 referred to in
2 the complaint said about the person who he knew as "Adam."
3 He said that Adam, he met Adam at the address at 1600
4 Hanover Street, that Adam submitted the PPP loan, that Adam
5 told him to sign checks, to make out the checks but to leave
6 payee blank.
7 THE COURT: Okay.
8 MR. RILEY: He saw those -- I'm sorry, Your Honor?
9 THE COURT: I understand now your point with these.
10 MR. RILEY: Okay. The same goes with Exhibit 2,
11 another purported business. This business received a $421,000
12 PPP loan, paid kickbacks amounting to 10 percent loan amount,
13 including Am Halal Meat, one of the defendant's businesses.
14 Exhibit 3, this entity received a PPP loan for over
15 $950,000, paid kickbacks amounting to 19 percent of the loan
16 amount, including over $70,000 to Am Halal Meat.
17 The pattern we've seen with respect to the kickbacks,
18 these blank checks secured by law enforcement consistent
19 with -- they corroborate our understanding of the scheme and
20 they corroborate what applicant 1 told law enforcement when
21 interviewed.
22 Applicant 2, not referenced in the complaint,
23 explained a similar experience. He said similar things to
24 applicant 1, Your Honor. His purported business received a
25 loan in excess of $250,000, and he paid approximately $75,000
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1 in kickbacks after receiving a loan. It's approximately 30
2 percent of the loan value. He said that he met someone named
3 Adam at an address at Hanover Street and that he had never seen
4 the loan application, never seen the supporting documents
5 submitted with the loan application, such as a purported IRS
6 Form 940.
7 The IRS, of course, confirms that they have no record
8 of a Form 940 being filed in connection with applicant 2's
9 business. Applicant 2 noted further, with respect to the
10 kickback checks, that Adam told him to provide signed checks
11 with the amounts filled in but with the payee blank and that he
12 did so, again, consistent with what applicant 1 said and
13 consistent with the results of the search and consistent with
14 the flow of funds that we can see in connection with the
15 kickback payments.
16 So all this is to say the scheme, the laundering of
17 money is sophisticated, it involves multiple entities. This
18 defendant's own entities --
19 THE COURT: Let me just, so I don't want to repeat,
20 it's ten to 5:00. I want to cut to some things that I think
21 are important.
22 MR. RILEY: Yes, Your Honor.
23 THE COURT: So I definitely want to get to why you
24 think that he's a serious flight risk.
25 MR. RILEY: Yes, Your Honor.
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1 THE COURT: But before we do that, as I read the
2 complaint, clearly one of the concerns the Court has is whether
3 or not an individual has stolen Social Security numbers, has
4 lied about his own identity or Social Security numbers. I'm
5 not at all diminishing the alleged fraud you described, but
6 when I read this, I don't see that he's lied about his address
7 or his Social Security number. Everything was submitted under
8 his name. Is that right?
9 MR. RILEY: Or his own purported businesses.
10 THE COURT: Or his own purported businesses which I
11 understand your view is those are either sham businesses or he
12 lied about the nature of the businesses.
13 MR. RILEY: And those businesses were used to launder
14 funds in connection with numerous other fraud --
15 THE COURT: For other fraudulent applications.
16 MR. RILEY: Yes, Your Honor. With respect to lies
17 and perhaps omissions, I'd note that the Pretrial Services
18 report references the defendant's -- just one purported
19 business. There's a business called Sary Stars that the
20 defendant says employs him. Sary Stars, Your Honor, is a
21 business that received kickback loans in connection with this
22 scheme, $218,857 from at least eight different entities that
23 received PPP loans.
24 He didn't reference to Pretrial Services --
25 Ms. Jackson is not here -- didn't reference Am Halal Meat,
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1 didn't reference to Pretrial Services his employment by Am Ex
2 Financial Group. So those aren't lies, Your Honor, but they
3 are omissions and material ones. Apart from the Sary Stars
4 employment information, the Government is not aware of this
5 defendant's other employment apart from being self-employed.
6 Now I want to talk about this defendant's history and
7 characteristics which I think informs the Government's view
8 about risk of flight. This defendant has multiple family
9 members in Egypt. Over the past two years, he's taken seven
10 trips to Egypt. He stayed there for at least two weeks.
11 There's one one-month trip, there was a five-week trip, there's
12 a seven-week trip. The defendant just returned from Egypt on
13 April 9, 2022. Extensive travel to Egypt, extensive travel to
14 Egypt during the heart of this conspiracy.
15 I appreciate what counsel said in her submission and
16 the defendant's submission with respect to deaths in the family
17 during this time period as well. I appreciate the desire to be
18 with family during those times. But we're not talking about
19 one or two trips, Your Honor. We're talking about numerous
20 trips to Egypt.
21 I'd note as well, Your Honor, that the Government is
22 very concerned about access to at least one international
23 account. During a search of this defendant incident to his
24 arrest, his wallet, law enforcement seized a bank card for a
25 bank out of Egypt, in addition to numerous other bank cards.
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1 THE COURT: Was that bank involved in this alleged
2 fraud?
3 MR. RILEY: Your Honor, at this time the Government
4 has no visibility into that account, so --
5 THE COURT: Okay. But the funds that were obtained
6 weren't directed to that account as far as you know?
7 MR. RILEY: Not as far as I know, Your Honor.
8 THE COURT: All right, go ahead.
9 MR. RILEY: At this time I don't have visibility into
10 that account. So I would submit, Your Honor, that the foreign
11 bank account is troubling to the Government; this defendant's
12 extensive travel to Egypt is troubling to the Government.
13 One of the questions that Judge Hurson had for me a
14 few hours ago was, "Well, what is the current state of play
15 with respect to this defendant's bank accounts?" I don't have
16 up-to-date information, Your Honor, as to how much this
17 defendant currently has in his bank accounts. What I have --
18 and I didn't have this earlier this morning -- is historical
19 information.
20 I have one account, the ending date for this is June
21 2021, balance of $31,000 plus. Another account, the ending
22 date is October 10, '21, balance of $41,500 plus. Another
23 account, this is an account for Am Halal Meat business, ending
24 date May 31, 2021, balance of $340,150.67. AMEX Financial
25 Group, another account, another purported business, ending date
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1 May 31, 2021, balance of $147,785. And there are accounts --
2 two accounts associated with his wife at different banks. One
3 has just under $10,000, ending date October 19, '21; the other
4 $9,500, ending date for which we have information October 4,
5 2021.
6 So, in addition -- again, this is historical
7 information. I don't have updated information. We haven't
8 gotten the subpoena responses back yet as to the current state
9 of play. Those are not insignificant funds, not an
10 insignificant amount of money. So that coupled with the
11 international bank account that we, again, don't have
12 visibility into, potentially suggests that this defendant has
13 the resources to flee. And again, this is only the account the
14 Government knows about, Your Honor.
15 THE COURT: You have in the complaint that the funds
16 went into certain accounts, like an M&T account and other
17 accounts --
18 MR. RILEY: Yes, Your Honor.
19 THE COURT: Do you have access to what's in those
20 accounts and the current state of those accounts?
21 MR. RILEY: Currently, no, Your Honor. Those
22 accounts that -- I gave Your Honor historical information and
23 listed the last information that we have. I don't know what
24 the current state of those accounts are.
25 THE COURT: Let me ask you this. When was, according
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1 to you, that you know of, the last transmission of fraudulent
2 funds into one of those accounts? It looks like it ended at
3 the end of last year; is that correct?
4 MR. RILEY: Well, Your Honor, I don't know when the
5 last transmission of funds is. I do know, Your Honor, that
6 there was a submission or there were submissions of
7 applications as late as December 30, 2021. Submissions for PPP
8 EIDL loans. I can't speak to the flow after that, Your
9 Honor.
10 THE COURT: Okay.
11 MR. RILEY: This defendant is a naturalized U.S.
12 citizen. He had a U.S. passport. The Government seized his
13 passport. I do understand -- this is Government's Exhibit 4 --
14 that among the items seized by law enforcement was an Egyptian
15 ID card. I can't speak to this defendant's citizenship in
16 Egypt. I inquired with Department of Homeland Security, with
17 the State Department; they can't tell me whether he has a dual
18 citizenship with Egypt. What we see from the ID card, it's
19 some sort of formal relationship with the state of Egypt. The
20 Government's not aware of any law that would prevent the
21 Egyptian embassy from getting this defendant a new passport if
22 he were to go --
23 THE COURT: Do you know if he -- this is not an
24 Egyptian passport. This is an ID card. So do we know if he
25 has an Egyptian passport?
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
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1 MR. RILEY: I found out this morning when counsel
2 noted that he has an expired Egyptian passport, so I can't
3 speak to whether he has a current passport, and I can't speak
4 to what would happen if he were to go and try to obtain an
5 Egyptian passport.
6 THE COURT: Do we know if the Egyptian passport
7 that's expired is from 25 years ago or if it's from two years
8 ago?
9 MR. RILEY: I don't --
10 THE COURT: You don't know.
11 MR. RILEY: I think counsel said it expired in 2005?
12 I'm sure she'll correct me. I've seen some nods here. That's
13 old, Your Honor, but I think Your Honor -- I hope Your Honor
14 understands my point.
15 I guess what I'm getting at, Your Honor, is there's
16 no -- the fact that we have his American passport isn't
17 dispositive in this analysis.
18 THE COURT: What about the fact that he has five
19 American children here and a wife in the home? What do I do
20 about that fact?
21 MR. RILEY: Certainly those are ties. Those are ties
22 to Maryland, he simply wants to be with his family. I
23 understand that. At the same time, Your Honor, he's looking at
24 very significant punishment if he proceeds to trial, or if he
25 pleads guilty, the offense is severe here. I can see incentive
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1 to flee.
2 I can't speak to his relationship with his family.
3 By all accounts, he's a loving father and loving husband, but
4 the Government is concerned about --
5 THE COURT: So let me just understand. The basis for
6 the proffer of the serious risk of flight is he's a naturalized
7 citizen from Egypt, he has traveled to Egypt several times for
8 significant periods over the last several years, he has an
9 Egyptian ID card on him, and there were several hundred
10 thousand dollars in various accounts as of last fall.
11 MR. RILEY: There's significant dollar amounts. I
12 think probably if you add it up, we're getting pretty high up
13 there in terms of the amount, the total amount. Probably north
14 of 100, 150 -- I'm sorry, north of a half million dollars, Your
15 Honor. That plus the fact that we have zero -- we are aware of
16 a foreign bank account that unfortunately we have zero
17 visibility into, and coupled with just the nature of this
18 scheme, Your Honor --
19 THE COURT: Well, the nature of the scheme, the
20 allegations are serious, without a doubt. What I'm trying to
21 decide is if there are any conditions of release that will
22 reasonably assure the safety of the community. I'm looking at
23 whether or not I can trust Mr. Sary to report to Court.
24 Indicia of not being able to trust someone is, in my view,
25 certainly alleged fraudulent activity, there's deception,
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1 there's the creation of I guess IRS documents.
2 But I don't see, as you've admitted, that there's a
3 demonstrated or evidence of an ability to create a passport, a
4 travel document -- I guess I'm just having a hard time
5 detaining someone when they've got five children, a wife, a
6 house that will be posted, no criminal history, no acts of
7 violence, serious allegations of fraud against the Government
8 without a doubt. But when the standard is reasonable
9 assurance... I'm just not sure the Government has met its
10 burden by a preponderance, that there's a serious risk of
11 flight.
12 You mentioned obstruction of justice. Let me hear
13 about that.
14 MR. RILEY: Yes, Your Honor. From the Government's
15 perspective, there is a serious risk that at this defendant's
16 release, that he will obstruct or attempt to obstruct justice.
17 This case involves numerous co-conspirators, the folks who
18 submitted -- who this defendant facilitated the submission of
19 PPP applications for, as well as the various folks involved
20 with the laundering of the money through these purported
21 entities.
22 I want to talk about a phone call that was made to
23 this defendant's wife on May 2, 2022, which is one of the
24 primary -- I think this was one of the primary motivations from
25 the Government's perspective in raising the risk of obstruction
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1 of justice. During this call, essentially in substance, this
2 defendant's wife asked about who she should tell about what
3 happened to the defendant, presumably referring to his arrest
4 and the fall-out of his arrest.
5 This defendant says, quote, "Nevine and Rehab and
6 Mohamed, those are the people you need to keep close for sure,"
7 end quote.
8 Nevine is a reference to -- at least as the
9 Government understands it, Nevine Kamel. Her purported
10 business received a PPP loan of $104,000, and it also received
11 kickbacks from at least 15 entities that received PPP loans in
12 the total amount of $266,714.39.
13 Rehab, the Government understands is a reference to
14 Rehab Saad; a number of her purported businesses received
15 kickback payments too. One purported business received 15
16 payments from loan recipients totaling over $313,000. Another
17 purported business received two payments totaling over $23,000.
18 The third person that the Government understands the
19 defendant was referring to, the Mohamed, we understand was a
20 reference to one of Mr. Sary's other associates, Mohamed
21 Elessawy. One of his purported businesses received 17
22 kickbacks totaling over $173,000. Another received 18 kickback
23 checks totaling over $276,000.
24 There may be an innocent explanation for "these are
25 the people you need to keep close for sure," Your Honor, but
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1 every single person referred to by this defendant is a
2 potential co-conspirator in this case based on what I've just
3 said. The use of their purported businesses to launder these
4 kickback funds. So if conditions -- if the Court does not
5 revoke the order set by Judge Hurson, we are relying on this
6 defendant's wife to report honestly to Pretrial Services about
7 contact with these witnesses, these potential co-conspirators.
8 I don't think -- based on this phone call, I don't think we
9 have a good basis to rely on her to report honestly to Pretrial
10 Services.
11 The last point, Your Honor, kind of dovetails with my
12 next point which is Ms. Sary is not a suitable third-party
13 custodian for this --
14 THE COURT: Tell me why you don't think so.
15 MR. RILEY: To begin with, she hasn't been vetted by
16 Pretrial Services.
17 THE COURT: Is Ms. Sary here?
18 MS. REAMY: Yes, Your Honor.
19 THE COURT: Okay, go ahead.
20 MR. RILEY: She was listed as a signatory on one of
21 the bank accounts associated with this fraud scheme, Your
22 Honor. That is the bank account tied to AMEX Financial Group,
23 one of the defendant's purported businesses. This is the
24 purported business that had, at least as of May 31, 2021,
25 $147,785.82. So she's a signatory on the account. She's
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1 part -- she's in the scheme, from the Government's perspective,
2 and I don't think that she can be trusted to report violations
3 to Pretrial Services.
4 I note, Your Honor, that when law enforcement went to
5 this defendant and his wife's house, the defendant was not
6 there, Your Honor. He was traveling with his son -- there was
7 a reference to a 9-year-old son in counsel's letter. That's
8 not right. The son was older than 18 years old. They were
9 traveling to the hospital for nose surgery, I think it was.
10 When law enforcement asked Ms. Sary, "Where's your husband?"
11 she said, "I don't know." "I don't know." Lying to law
12 enforcement.
13 She did eventually acknowledge that she lied to law
14 enforcement, but the point I'm making, Your Honor, is that
15 given -- given the charges, given the scheme, given that she
16 was signatory on one of the accounts that received a large
17 amount of fraud funds, given her misstatement to law
18 enforcement, given the fact that she loves her husband and
19 doesn't want him to be detained, she's not in a position to
20 report honestly violations if this defendant wants to have
21 contact with co-conspirators or witnesses. They could come to
22 his house and visit. If she doesn't report it, we're not
23 protected against that, Your Honor.
24 THE COURT: Let me ask you this. I understand one of
25 the conditions that Judge Hurson imposed was -- I'm looking at
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1 the release order -- 8(d), "Post with the Court the following
2 proof of ownership of the designated property" and it refers to
3 the -- is that Magie Street home?
4 MR. RILEY: Yes, Your Honor.
5 THE COURT: It's not clear to me if he was requiring
6 the recording of a lien against the home as a secured property?
7 Do you know?
8 MR. RILEY: That was my -- I agree, Your Honor, it's
9 not clear from the record. That was my understanding, that the
10 home, whatever equity the defendant has in the home be put up
11 as security as a nonappearance bond, that he would risk losing
12 his equity if he fled.
13 THE COURT: Do you have any reason to believe or
14 disbelieve what's reported in the pretrial report which is that
15 the residence is worth about 400,000 and there's $150,000
16 mortgage?
17 MR. RILEY: Well, I know that's -- I think that's
18 self-reported information, Your Honor, so I do have a healthy
19 skepticism of what the defendant has told Pretrial, given that
20 he only told Pretrial about one of his purported businesses.
21 Standing here right now, I can't speak to how much equity he
22 has unfortunately.
23 THE COURT: I understand.
24 MR. RILEY: Your Honor, I'm happy to answer any
25 questions if the Court has them.
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1 THE COURT: Let me go to Ms. Reamy. Thank you very
2 much, Mr. Riley. I'm trying to get to the right result and
3 comply with the Bail Reform Act. Some of the things the
4 Government is telling me is troubling as to whether or not I
5 can trust -- Ms. Reamy, if you don't mind standing unless you
6 need to sit. It's just easier for me to see you, thank you --
7 whether or not I can trust his wife as a third-party custodian.
8 There seems to be a lot of money involved here and resources to
9 flee.
10 So if you could just cut to the heart of your
11 argument, address these more difficult questions, I would
12 appreciate that.
13 MS. REAMY: Yes. Starting with Mrs. Sary, I had a
14 discussion with her about what happened when the search warrant
15 was executed, and she indicated to me that she did tell the
16 officers she didn't know. She didn't know because she knew
17 that Mr. Sary was going to be at the hospital for some part of
18 the time --
19 THE COURT: Can you bring the microphone closer to
20 you.
21 MS. REAMY: She knew her husband was going to be at
22 GBMC with her son. That was an error on my part saying the
23 9-year old. It was the 20-year-old son that was having nasal
24 surgery. She also knew he had planned to go to the office
25 because the surgery was going to take a number of hours, so
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1 that was what she meant in that situation. She was not lying
2 to the agent. She did not know where he was at that time.
3 This was early in the morning, she wasn't sure where he was.
4 So her position is that she was never trying to mislead or lie
5 to the officer. She just really did not know where he was and
6 took the question quite literally.
7 The passport, the Egyptian passport expired in 2005.
8 Mr. Sary says that he does not have it --
9 THE COURT: Is your client an Egyptian citizen?
10 MS. REAMY: I believe he is. I believe he does have
11 a dual citizenship, but he does not have a recent passport, it
12 expired in 2005. He's never renewed another one -- he's
13 indicating to me that he would not obtain a new passport.
14 But over the last 20 years, he's been making more --
15 he's been building deep roots in the United States. Again, as
16 the Court said, he's got three children -- that's very
17 distracting, I'm sorry.
18 (Discussion off the record regarding audio issues.)
19 THE COURT: Okay, Ms. Reamy.
20 MS. REAMY: Thank you, Your Honor. As I was saying,
21 Mr. Sary has three children under the age of 10 who have always
22 only known the United States as their home. The two older
23 children, twin boys, 20 years old, they were naturalized as
24 United States citizens in 2017. They both have their own lives
25 here. One is enrolled in Salisbury State University, one is
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1 enrolled in college of -- Anne Arundel Community College, the
2 younger children are in school. He has significant ties to the
3 community.
4 Now the references to bank accounts that have
5 relatively large balances in the fall of last year, these are
6 businesses. These are not personal bank accounts. So I don't
7 think that it's necessarily unusual to find business bank
8 accounts that have higher balances than what you would expect
9 to see in a personal bank account.
10 We've explained the trips to Egypt, and they all
11 surrounded his father's passing and then his mother's passing.
12 She was steadily declining and very sick with diabetes, and
13 then unfortunately she passed. Those trips all surrounded both
14 of those deaths and dealing with the aftermath of those
15 deaths.
16 Just a moment. I'm not sure -- can the Court help
17 focus me? There's a lot that I can go over. The Government
18 has been speaking for quite some time here so I'm trying to
19 organize --
20 THE COURT: I'm going to tell you this. I need more
21 information on the home and what the value is and what the
22 mortgage is because, to me, I think that Judge Hurson was
23 correct in requiring a posting of the house as security, and I
24 believe that's what he intended to do. But I need more
25 certainty that there's skin in the game in that home before I'd
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1 be willing to release Mr. Sary, given some of the information
2 that Mr. Riley has presented to me that I don't believe was
3 presented to Judge Hurson, particularly about the bank
4 accounts -- which I understand your view is it's a business
5 account -- but from the Government's perspective, there are
6 several accounts, some with hundreds of thousands of dollars in
7 them as of last year.
8 So I'm going to need more information about --
9 perhaps there needs to be a title search done on the house to
10 know what liens are on it and a bank statement of the
11 mortgage.
12 In addition, I'd like to know more about his
13 relationship or friendship with Linda Derezinski and her
14 husband Dan. Are they here?
15 MS. REAMY: Yes, Ms. Derezinski is right here.
16 THE COURT: Okay. Your wife is not here, sir --
17 MS. REAMY: She's here.
18 THE COURT: Oh, she is --
19 MS. DEREZINSKI: I'm Linda; my husband is not here.
20 THE COURT: I'm sorry. Your husband is not here?
21 MS. DEREZINSKI: Correct.
22 THE COURT: I'm sorry. Just with the mask and you
23 have short hair, I apologize, and far away from me.
24 How long have you known Mr. Sary?
25 MS. DEREZINSKI: 2006.
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1 THE COURT: Can you come forward and speak in the
2 microphone? Thank you. Thank you for being here. I know you
3 were here this morning and here this afternoon.
4 MS. DEREZINSKI: Yes, Your Honor.
5 THE COURT: Can you tell me when you met Mr. Sary and
6 how you know him.
7 MS. DEREZINSKI: I met him through his wife, Iza.
8 Our son was born in 2005 in February and she was -- I've been
9 working home, and she was watching my son while I was -- during
10 working hours. Then I met Ahmed through her.
11 THE COURT: Were they married at the time?
12 MS. DEREZINSKI: They got married while I knew
13 them.
14 THE COURT: You've known them as a married couple
15 since then?
16 MS. DEREZINSKI: Yes, ma'am. They usually are with
17 us for Thanksgiving, Easter, different holidays. My mother
18 calls her "sister" and "son."
19 THE COURT: I'm sorry?
20 MS. DEREZINSKI: I said my mother calls her another
21 daughter. My mother is their children's American
22 grandmother.
23 THE COURT: Understood.
24 MS. DEREZINSKI: We know them very well.
25 THE COURT: You know them very well.
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1 MS. DEREZINSKI: Yes, ma'am.
2 THE COURT: Would you say you interact with them on a
3 weekly or monthly basis?
4 MS. DEREZINSKI: I mean sometimes because of kids,
5 lately maybe I won't talk to them for a month or two. But then
6 we might talk every day, you know, it's just -- our son is 17
7 and, you know. With each kid, it gets complicated.
8 THE COURT: Would you be willing to house him in your
9 home pending trial if I --
10 MS. DEREZINSKI: If that needs to be. I prefer him
11 to be home, but yes, ma'am. Because of their youngest having
12 diabetes, you know, Ahmed has the touch with the girls.
13 THE COURT: I understand. Thank you very much.
14 Thank you for being here.
15 MS. DEREZINSKI: Yes, ma'am.
16 MS. REAMY: Your Honor, I do want to address the
17 Government's allegations, and we did this with Judge Hurson as
18 well, regarding this recorded jail call. The Government has
19 its interpretation, but I can tell you -- it does track
20 conversations that I had myself with Izabela Sary which is that
21 they are very embarrassed about this. What she's essentially
22 asking is that she doesn't want to just share all of their
23 business; this is a very embarrassing situation for them with
24 anyone in the community.
25 So I believe that's really the nature of the
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1 conversation, that there are certain people that they would
2 trust because they're going to have to rely on some individuals
3 for some help while this is -- while he's detained. She's
4 managing all these children by herself. It was not anything
5 more than that kind of discussion which was --
6 THE COURT: I think the Government has conceded some
7 limitations in its interpretation of that call. I think that
8 your interpretation is fair, perhaps their interpretation could
9 be fair. At this point I really don't place much sort of
10 credit on that call without more in order to show that there's
11 a serious risk of obstruction of justice. I don't know exactly
12 what that call said or what was meant by it. What, frankly, at
13 this point I'm most concerned about is whether or not there are
14 conditions that will reasonably assure me that Mr. Sary will
15 appear in court. Here's -- go ahead.
16 MS. REAMY: I would also tell the Court that we
17 surrendered five passports this morning to the Court. I just
18 received a receipt. All of the minor children's passports were
19 initially offered, and then the two 20-year-old boys also
20 offered their passports which were all surrendered in Judge
21 Hurson's courtroom earlier this morning. As I indicated to
22 Judge Hurson, Mr. Sary is certainly never going to leave his
23 family.
24 This was a gesture to impress upon the Court how
25 serious he is about his understanding of what his obligations
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1 would be and hopefully a showing that he has no intention of
2 fleeing this case. His children are very important to him, and
3 it's obviously taking a huge emotional toll on him.
4 Particularly the youngest one with the diabetes. I did want
5 the Court to know that gesture has been made.
6 THE COURT: The five passports are Mr. Sary's, his
7 wife's and his three minor children?
8 MS. REAMY: No, Mr. Sary's passport was seized by law
9 enforcement. Mrs. Sary's passport is expired, she doesn't know
10 where it is. She looked for it in advance of today's hearing.
11 She thinks maybe the officers took it but doesn't know where it
12 is. It has expired and she's agreed she would not get another
13 passport. The five passports turned over to the Court this
14 morning were the two 20-year-old twin boys and the minor
15 children.
16 THE COURT: The children's passports.
17 MS. REAMY: All the children's passports --
18 THE COURT: Understood.
19 MS. REAMY: -- were turned over. A lot of this is
20 laid out in the letters, but I do think the Court -- is there
21 anything else the Court would want me to address specifically?
22 THE COURT: No, I don't believe so. Just give me one
23 moment, please.
24 Mr. Riley, is there anything else you want to add in
25 response to my discussion with Ms. Reamy?
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1 MR. RILEY: Very briefly, Your Honor, with respect to
2 Ms. Derezinski. The Government is concerned that if
3 Ms. Derezinski is working from 7:00 a.m. to 3:00 p.m., even if
4 Your Honor were to put Mr. Sary in the custody of
5 Ms. Derezinski, because she's working, she's not going to be in
6 a position to monitor this defendant closely --
7 THE COURT: Mr. Riley, it's impossible to find an
8 absolute -- a person who's going to stand by someone 24/7.
9 That's just unrealistic.
10 MR. RILEY: I understand, Your Honor.
11 MS. REAMY: Judge, she works from home so she's in
12 the home.
13 THE COURT: Thank you for that.
14 All right. This case is before me on the
15 Government's motion for review of a release order that
16 Magistrate Judge Hurson issued today, May 9. Under 18 United
17 States Code § 3145(b), this Court reviews the magistrate
18 judge's pretrial detention decision de novo. That's a cite
19 against United States against Clark, 865 F.2d 1433 at 1436,
20 Fourth Circuit, from 1989. I make an independent determination
21 of the proper pretrial detention or conditions of release.
22 That's from United States against Stewart, a 2001 Fourth
23 Circuit case, 19 Federal App'x 46 at 48.
24 Under the Bail Reform Act, the Government bears the
25 burden of proving by a preponderance of the evidence that no
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1 condition or combination of conditions will reasonably assure
2 Mr. Sary's appearance. I won't go into safety of the community
3 because the Government has not sought detention based on safety
4 of the community, although economic harm is a factor that I
5 must consider as I analyze the Bail Reform Act factors and any
6 potential conditions of release.
7 The Bail Reform Act requires that I consider the
8 following factors:
9 The nature and circumstances of the offense charged.
10 Here the charged offense is by criminal complaint. It's wire
11 fraud and money laundering, so I have to consider whether the
12 offense involves a crime of violence. Of course, it does not.
13 A federal crime of terrorism, it does not. A minor victim, it
14 does not. A controlled substance, firearm explosive or
15 destructive device, it does none of those things.
16 I have to consider the weight of the evidence against
17 Mr. Sary, and the weight of the evidence appears to be strong.
18 Mr. Riley has proffered the evidence; I have reviewed a summary
19 of the nonexhaustive evidence that is in the criminal
20 complaint. There was a search warrant conducted at an
21 apartment adjacent to his property which apparently yielded
22 corroborating evidence of the alleged fraud scheme. So the
23 weight of the evidence is in favor of the Government. I think
24 it's no surprise that that's almost always the case in federal
25 court.
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1 I have to consider the history and characteristics of
2 Mr. Sary. That includes his character, physical and mental
3 condition, family ties, employment, financial resources, length
4 of residence in the community, community ties, past conduct,
5 history relating to drug or alcohol abuse, criminal history,
6 and his record concerning court appearances. Let me address
7 those factors in reverse order.
8 Mr. Sary, according to the Pretrial Services report,
9 is 43 years old and has no criminal history, no prior arrests,
10 no interactions with law enforcement that are reported by
11 Pretrial Services or the Government. Therefore, there is no
12 history of appearing at court appearances or problems of
13 failing to appear. There appears to be no drug or alcohol
14 problem.
15 With respect to length of residence in the community,
16 community ties, this factor, I think, weighs in favor of
17 Mr. Sary. In that regard, he has been a United States citizen
18 for some time. He came to this country, according to Pretrial
19 Services, in his early 20s -- perhaps at 21 years old -- from
20 Egypt; he's a naturalized citizen. He has been married to -- I
21 believe Ms. Sary is an American citizen -- to an American
22 citizen since the mid 2000s. They have three young children.
23 They have owned a home since 2015 here in Baltimore where they
24 live as a family. There is a family friend here who has known
25 them for, looks like, at least 15 years and has interacted with
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1 them on a regular basis and observed their family and
2 corroborated those family and community ties.
3 On the other side, as Mr. Riley points out, Mr. Sary
4 has traveled to Egypt several times in the past couple years.
5 That, frankly, does not trouble me too much because it makes
6 sense he would travel to Egypt several times in the past few
7 years with parents falling ill and ultimately dying. People
8 don't just go for funerals. They go when people are sick and
9 ill, and he does have siblings there.
10 Having said that, I can't ignore the fact that there
11 is another country that he would feel comfortable in if he were
12 fearful of a long prison sentence. It is a factor I have to
13 consider. I think, however, that I can address that particular
14 fact with conditions because really what the concern here is
15 are there conditions that will reasonably assure me that he
16 will appear in court. I don't have the crystal ball into the
17 future. I cannot guarantee -- and the Bail Reform Act does not
18 require me to guarantee -- appearance, although I take very
19 seriously that I have to reasonably assure that he will --
20 myself that he will appear in court. So the ties to Egypt,
21 while not troubling, are certainly a relevant factor as I
22 consider conditions of release.
23 I also have to consider financial resources.
24 Mr. Riley has brought to my attention several bank accounts
25 that are associated with Mr. Sary that as of at least six or
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1 seven months ago had significant balances in them. I am
2 confident Ms. Reamy and Mr. Sary have an explanation for that,
3 but the fact is there are several hundred thousand dollars, or
4 there were at least six or seven months ago, in bank accounts
5 that Mr. Sary had access to. I don't know what the status of
6 those bank accounts is. I don't know how much is in them now.
7 I don't know if Mr. Sary would use that money in some way to
8 try to flee, but, again, it's a factor I have to consider. I
9 do think that I can address that factor with conditions of
10 release.
11 I have to consider his employment. He has reported
12 working for and being self-employed with Sary Stars, a music
13 and entertainment business. I understand Mr. Riley's point
14 which is he did not report the other purported businesses that
15 he was associated with in connection with his application for
16 government loans, but it does appear that there has been
17 consistent employment. He supports his family, he owns a home.
18 I see no reason -- evidence that he's not had consistent
19 employment history.
20 I have to consider physical and mental condition.
21 There's no evidence of mental illness and his physical health
22 seems fair, although I do note some potential heart issues.
23 I also have to consider whether at the time of the
24 offense Mr. Sary was on probation, parole or any other order of
25 release pending trial. He was not, he has no criminal history.
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 41 of 58
41
1 And I have to consider the nature and seriousness of the danger
2 to any person or the community that would be posed by his
3 release.
4 First, let's address the obvious. The Government
5 appropriately, of course, has not alleged that Mr. Sary poses
6 any physical danger, that he's a violent person. There's no
7 evidence of that, that's not an issue here. I do believe, and
8 I think Mr. Riley was correct, that I have to consider and I
9 should consider the potential economic harm to the community or
10 any other person, and in this regard, I have considered
11 seriously the allegations against Mr. Sary. Mr. Riley, I
12 think, summarized them well.
13 The allegations are that Mr. Sary was the head of a
14 multibusiness, multibank account, multiperson alleged scheme to
15 defraud the federal government in applying for relief
16 associated with the CARES Act. Mr. Sary apparently submitted
17 applications on his behalf and on behalf of other businesses,
18 some of which were not actual businesses, and in doing so, he
19 allegedly defrauded the Government out of over $10 million, and
20 he and others he's associated with allegedly received about
21 $2.5 million in what Mr. Riley has characterized as kickbacks.
22 This is a serious scheme if it's proven to be true.
23 The question for me, though, on whether or not
24 release conditions can be set is whether or not I think that
25 Mr. Sary will continue to pose an economic harm to either the
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 42 of 58
42
1 government, and at this point -- I understand there are no more
2 particular loans available -- we can also -- I will certainly
3 restrict his access to any bank accounts.
4 What I did not hear from Mr. Riley, and I appreciate
5 his candor, is there were not, for instance, manufactured
6 driver's licenses or manufactured passports that to me would
7 suggest a willingness, ability or propensity to flee.
8 So for all of those reasons, I do find that there are
9 conditions of release that will reasonably assure me of
10 Mr. Sary's appearance in court and certainly the safety of the
11 community, but I'm not going to set a release order just yet.
12 I need to know more about the home. I want to know that the
13 home will be security that will reasonably assure me that
14 Mr. Sary will not flee. So at this point, I think we need to
15 continue the hearing to allow Ms. Reamy and her family --
16 Ms. Reamy and Mr. Sary's family to find the documentation that
17 I need.
18 Ms. Reamy, is that something you and your client's
19 family can get together, and if it can be done sooner than when
20 you return, I'm happy to consider the submission and not have a
21 hearing? Do you need a moment to talk?
22 MS. REAMY: Yes, Your Honor, I do need a moment if I
23 could.
24 (Defendant conferred with his counsel.)
25 MS. REAMY: May I step back a moment to speak with
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43
1 his wife?
2 THE COURT: Please, yes.
3 (Pause.)
4 MS. REAMY: Your Honor, the answer is I don't know.
5 We would certainly -- I will do everything I can to try to get
6 this together and get the documents by tomorrow morning. I
7 don't know that that's going to be possible.
8 THE COURT: Meaning by tomorrow morning or not
9 possible to find documents?
10 MS. REAMY: By tomorrow morning.
11 THE COURT: I'd be surprised if you could do it by
12 tomorrow morning because actually I think you'd need to go to
13 the land records.
14 MS. REAMY: Probably.
15 THE COURT: Are you saying tomorrow morning because
16 you go on vacation?
17 MS. REAMY: I'm leaving tomorrow afternoon, so yes,
18 if we could miraculously pull all the documents together that
19 the Court needed, but I think it's unlikely.
20 THE COURT: Okay, I'll wait to receive the documents.
21 If you can get them to me by midday, I'll review them. If I'm
22 comfortable with them, I can issue a release order while you're
23 away and work with Pretrial to have him released.
24 Here's ultimately where I'm at. To make me
25 reasonably assured, I need to know that the property has some
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 44 of 58
44
1 equity in it, and that's what I'm comfortable with.
2 MS. REAMY: I understand.
3 THE COURT: Okay? So there is an order of detention
4 right now, the stay in the execution of the release order
5 remains.
6 Let me ask the marshals, do I need to do anything
7 right now?
8 MARSHAL: I'd just ask Your Honor if you'd like us to
9 have him brought over tomorrow?
10 THE COURT: Why don't we do this. I will enter a
11 detention order; it will just be in effect. I think right now
12 the operative order is a release order. Mr. Riley, is that
13 your understanding?
14 MR. RILEY: Correct, Your Honor. The Government did
15 move to stay that, but correct, Your Honor.
16 THE COURT: All right. I will enter something on the
17 docket that indicates there is a stay in the release order so
18 he remains detained. I will not order him returned to the
19 courthouse until I know that I am comfortable issuing a release
20 order which will require me to review the documents. I'll be
21 in touch through chambers with Pretrial Services and the
22 marshals about when we want him brought over. Is that fair,
23 Marshal?
24 MARSHAL: Yes, ma'am.
25 THE COURT: Mr. Riley, anything else from your
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 45 of 58
45
1 perspective? Then, Ms. Reamy, I'll turn to you.
2 MR. RILEY: No, thank you, Your Honor.
3 THE COURT: Thank you very much for your
4 presentation. Ms. Reamy?
5 MS. REAMY: No, Your Honor. Thank you.
6 THE COURT: Thank you all.
7 THE CLERK: All rise. This Honorable Court is now
8 adjourned.
9 (Proceedings concluded at 5:41 p.m.)
10
I, Patricia G. Mitchell, RMR, CRR, do hereby certify
11 that the foregoing is a correct transcript from the
stenographic record of proceedings in the above-entitled
12 matter.
13 Dated this 12th day of May 2022.
14
15
16 __________________________
Patricia G. Mitchell
17 Official Court Reporter
18
19
20
21
22
23
24
25
Patricia G. Mitchell, RMR, CRR Federal Official Court Reporter
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 46 of 58
46
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 47 of 58
47
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 48 of 58
48
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 49 of 58
49
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 50 of 58
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effect 44:11. 12:7, 23:3, 36:25, 37:16, far 3:19, 18:6, 18:7, 31:23.
Egypt 17:9, 17:10, 17:12, 17:13, 37:17, 37:18, 37:19, 37:22, far-reaching 6:15, 8:15,
17:14, 17:20, 17:25, 18:12, 37:23, 40:18, 40:21, 8:19.
20:16, 20:18, 20:19, 22:7, 41:7. fast 4:22.
30:10, 38:20, 39:4, 39:6, Ex 17:1. father 22:3, 30:11.
39:20. exactly 34:11. favor 37:23, 38:16.
Egyptian 20:14, 20:21, 20:24, example 11:25, 13:9. fearful 39:12.
20:25, 21:2, 21:5, 21:6, 22:9, examples 10:22. February 32:8.
29:7, 29:9. excess 14:25. Federal 1:47, 36:23, 37:13,
EIDL 7:18, 20:8. excuse 3:12. 37:24, 41:15.
eight 16:22. executed 7:17, 28:15. feel 39:11.
either 8:25, 16:11, 41:25. execution 13:8, 44:4. few 4:10, 18:14, 39:6.
Elessawy 24:21. Exhibit 4:1, 12:23, 13:3, 13:9, filed 15:8.
embarrassed 33:21. 14:10, 14:14, 20:13. files 7:25, 8:1, 8:5, 8:7,
embarrassing 33:23. Exhibits 12:23, 13:4. 8:16.
embassy 20:21. expect 30:8. filing 3:21.
emotional 35:3. experience 14:23. filled 15:11.
employment 17:1, 17:4, 17:5, expired 21:2, 21:7, 21:11, 29:7, Financial 11:1, 12:14, 13:13,
38:3, 40:11, 40:17, 29:12, 35:9, 35:12. 17:2, 18:24, 25:22, 38:3,
40:19. explained 14:23, 30:10. 39:23.
employs 16:20. explanation 24:24, 40:2. find 9:2, 30:7, 36:7, 42:8, 42:16,
end 20:3, 24:7. explosive 37:14. 43:9.
ended 20:2. Extensive 17:13, 18:12. firearm 37:14.
ending 18:20, 18:21, 18:23, . First 8:16, 41:4.
18:25, 19:3, 19:4. . five 21:18, 23:5, 34:17, 35:6,
enforcement 10:9, 10:15, 11:12, < F >. 35:13.
12:4, 14:18, 14:20, 17:24, F.2d 36:19. five-week 17:11.
20:14, 26:4, 26:10, 26:12, facilitate 9:9. fled 27:12.
26:14, 26:18, 35:9, facilitated 23:18. flee 19:13, 22:1, 28:9, 40:8, 42:7,
38:10. facility 8:24, 9:6. 42:14.
enrolled 29:25, 30:1. fact 8:21, 9:10, 9:22, 21:16, fleeing 35:2.
enter 6:3, 44:10, 44:16. 21:18, 21:20, 22:15, 26:18, flight 6:4, 9:9, 10:16, 15:24,
entered 6:3. 39:10, 39:14, 40:3. 17:8, 22:6, 23:11.
entertainment 40:13. factor 37:4, 38:16, 39:12, 39:21, Floor 1:48.
Entities 7:11, 7:12, 10:19, 10:23, 40:8, 40:9. flow 15:14, 20:8.
11:1, 11:4, 11:5, 11:9, 11:11, factors 6:12, 37:5, 37:8, focus 30:17.
11:14, 11:19, 12:1, 12:12, 38:7. folks 10:3, 23:17, 23:19.
12:15, 12:18, 13:13, 13:22, facts 6:10. following 27:1, 37:8.
15:17, 15:18, 16:22, 23:21, failing 38:13. foreclose 9:21.
24:11. fair 34:8, 34:9, 40:22, foregoing 45:12.
entity 14:14. 44:22. foreign 18:10, 22:16.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 51 of 58
51
forged 12:8. hair 31:23. huge 9:12, 10:6, 35:3.
Form 15:6, 15:8. Halal 10:24, 12:14, 14:13, 14:16, hundred 22:9, 40:3.
formal 20:19. 16:25, 18:23. hundreds 31:6.
forms 7:7, 8:22. half 22:14. Hurson 3:13, 3:20, 4:4, 4:9, 5:5,
forward 32:1. hand 5:10. 9:1, 18:13, 25:5, 26:25,
found 12:4, 21:1. Hanover 7:20, 7:23, 8:9, 11:13, 30:22, 31:3, 33:17, 34:21,
Fourth 36:20, 36:22. 14:4, 15:3. 34:22, 36:16.
frankly 34:12, 39:5. happen 21:4. husband 22:3, 26:10, 26:18,
fraud 7:16, 8:14, 8:18, 9:17, happened 24:3, 28:14. 28:21, 31:14, 31:19,
12:8, 16:5, 16:14, 18:2, 23:7, happy 4:14, 27:24, 42:20. 31:20.
25:21, 26:17, 37:11, hard 7:25, 23:4. .
37:22. harm 37:4, 41:9, 41:25. .
fraudulent 16:15, 20:1, head 41:13. < I >.
22:25. health 40:21. Ibrahim 1:39, 3:2.
Friday 5:1, 7:17. healthy 27:18. iceberg 7:15.
friend 38:24. hear 4:2, 5:18, 23:12, 42:4. ID 20:15, 20:18, 20:24,
friendship 31:13. HEARING 1:22, 4:6, 4:9, 5:3, 22:9.
fully 2:18. 35:10, 42:15, 42:21. identified 7:18.
funds 11:20, 12:1, 13:5, 15:14, heart 17:14, 28:10, 40:22. identity 16:4.
16:14, 18:5, 19:9, 19:15, Help 6:19, 12:7, 30:16, ignore 39:10.
20:2, 20:5, 25:4, 26:17. 34:3. ill 39:7, 39:9.
funerals 39:8. helpful 4:13. illness 40:21.
future 39:17. hereby 45:11. important 4:7, 10:12, 15:21,
. herself 34:4. 35:2.
. hidden 8:10. imposed 26:25.
< G >. high 8:20, 22:12. impossible 36:7.
G. 1:46, 45:11, 45:23. higher 30:8. impress 34:24.
gain 10:14. historical 18:18, 19:6, incentive 21:25.
game 30:25. 19:22. incident 17:23.
gave 19:22. history 17:6, 23:6, 38:1, 38:5, includes 38:2.
GBMC 28:22. 38:9, 38:12, 40:19, including 13:13, 14:13,
gesture 34:24, 35:5. 40:25. 14:16.
gets 33:7. holidays 32:17. independent 3:16, 36:20.
getting 11:25, 13:19, 20:21, holograms 9:2. indicated 28:15, 34:21.
21:15, 22:12. home 10:7, 21:19, 27:3, 27:6, indicates 44:17.
girls 33:12. 27:10, 29:22, 30:21, 30:25, indicating 11:18, 29:13.
give 10:22, 35:22. 32:9, 33:9, 33:11, 36:11, Indicia 22:24.
given 4:9, 26:15, 26:17, 26:18, 36:12, 38:23, 40:17, 42:12, individual 16:3.
27:19, 31:1. 42:13. individuals 34:2.
gotten 19:8. Homeland 20:16. information 9:13, 9:16, 12:6,
grandmother 32:22. homes 3:24. 13:20, 13:21, 17:4, 18:16,
granted 5:4. honestly 25:6, 25:9, 26:20. 18:19, 19:4, 19:7, 19:22,
Group 11:2, 12:14, 13:13, 17:2, Honorable 1:23, 45:7. 19:23, 27:18, 30:21, 31:1,
18:25, 25:22. hope 21:13. 31:8.
guarantee 39:17, 39:18. hopefully 35:1. informs 17:7.
guess 21:15, 23:1, 23:4. hospital 26:9, 28:17. initially 34:19.
guilty 21:25. hours 4:10, 18:14, 28:25, Injury 6:17.
. 32:10. innocent 24:24.
. house 23:6, 26:5, 26:22, 30:23, inquired 20:16.
< H >. 31:9, 33:8. insignificant 19:9, 19:10.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 52 of 58
52
instance 42:5. kickback 7:10, 10:25, 11:3, 11:7, 42:6.
intended 30:24. 11:9, 11:10, 12:2, 12:16, lie 29:4.
intention 35:1. 13:25, 15:10, 15:15, 16:21, lied 16:4, 16:6, 16:12,
interact 33:2. 24:15, 24:22, 25:4. 26:13.
interacted 38:25. kickbacks 6:24, 7:5, 9:25, 10:21, lien 27:6.
interactions 38:10. 12:14, 13:12, 14:12, 14:15, liens 31:10.
international 17:22, 19:11. 14:17, 15:1, 24:11, 24:22, lies 16:16, 17:2.
interpret 5:24. 41:21. light 6:18.
interpretation 33:19, 34:7, kid 33:7. likes 4:14.
34:8. kids 33:4. limitations 34:7.
INTERPRETER 1:39, 2:23, kind 25:11, 34:5. Linda 31:13, 31:19.
2:24, 3:2, 3:3, 3:5, 3:8, 3:10, know. 26:11. list 4:1.
5:23. known 29:22, 31:24, 32:14, listed 19:23, 25:20.
interviewed 14:21. 38:24. literally 29:6.
investigation 6:21. knows 19:14. live 38:24.
involved 7:3, 8:22, 9:23, 11:5, . lives 29:24.
18:1, 23:19, 28:8. . loan 6:25, 7:5, 9:20, 9:23, 9:25,
involves 15:17, 23:17, < L >. 12:3, 13:11, 13:12, 13:19,
37:12. laid 35:20. 14:4, 14:12, 14:14, 14:15,
involving 6:15, 8:19. land 43:13. 14:25, 15:1, 15:2, 15:4, 15:5,
IP 7:19. language 3:7. 24:10, 24:16.
IRS 7:7, 15:5, 15:7, 23:1. large 26:16, 30:5. Loans 6:16, 6:17, 6:19, 6:22,
issue 8:18, 41:7, 43:22. larger 8:15. 6:24, 7:1, 7:9, 7:15, 8:1, 8:19,
issued 3:12, 36:16. last 5:3, 19:23, 20:1, 20:3, 20:5, 10:22, 11:1, 11:3, 11:4,
issues 40:22. 22:8, 22:10, 25:11, 29:14, 13:19, 16:21, 16:23, 20:8,
issues. 29:18. 30:5, 31:7. 24:11, 40:16, 42:2.
issuing 44:19. late 20:7. located 7:20, 8:7, 8:8, 8:9,
items 9:9, 20:14. lately 33:5. 11:14.
Iza 32:7. latter 9:19, 10:3. location 7:24.
Izabela 33:20. launder 7:5, 11:6, 11:11, 11:20, Lombard 1:48.
. 12:1, 16:13, 25:3. long 31:24, 39:12.
. laundering 15:16, 23:20, looked 35:10.
< J >. 37:11. looking 12:23, 21:23, 22:22,
Jackson 16:25. law 10:9, 10:15, 11:12, 12:4, 26:25.
jail 33:18. 14:18, 14:20, 17:24, 20:14, looks 20:2, 38:25.
Jersey 7:2. 20:20, 26:4, 26:10, 26:11, losing 27:11.
Judge 3:13, 3:20, 4:4, 4:9, 5:3, 26:13, 26:17, 35:8, loss 8:20.
5:5, 9:1, 18:13, 25:5, 26:25, 38:10. losses 7:10.
30:22, 31:3, 33:17, 34:20, least 9:5, 9:6, 10:20, 16:22, lot 28:8, 30:17, 35:19.
34:22, 36:11, 36:16, 17:10, 17:22, 24:8, 24:11, loves 26:18.
36:18. 25:24, 38:25, 39:25, loving 22:3.
Julie 1:36, 2:14. 40:4. luxury 10:1.
justice 6:7, 9:9, 23:12, 23:16, leave 14:5, 34:22. Lying 26:11, 29:1.
24:1, 34:11. leaving 43:17. .
. left 2:15, 11:17, 11:18, .
. 13:21. < M >.
< K >. length 38:3, 38:15. M&T 19:16.
Kamel 24:9. letter 26:7. M. 1:10, 1:36.
keep 2:20, 24:6, 24:25. letters 35:20. ma'am 32:16, 33:1, 33:11, 33:15,
key 12:20. licenses 8:2, 9:4, 9:8, 9:13, 44:24.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 53 of 58
53
Magie 27:3. monthly 33:3. none 37:15.
Magistrate 36:16, 36:17. months 40:1, 40:4. nonexhaustive 37:19.
managing 34:4. morning 4:1, 5:5, 9:2, 18:18, north 22:13, 22:14.
manufactured 42:5, 42:6. 21:1, 29:3, 32:3, 34:17, NORTHERN 1:3.
married 32:11, 32:12, 32:14, 34:21, 35:14, 43:6, 43:8, nose 26:9.
38:20. 43:10, 43:12, 43:15. note 4:8, 4:10, 5:2, 8:21, 10:8,
MARSHAL 44:8, 44:23, mortgage 27:16, 30:22, 11:12, 16:17, 17:21, 26:4,
44:24. 31:11. 40:22.
marshals 44:6, 44:22. mother 30:11, 32:17, 32:20, noted 15:9, 21:2.
Maryland 1:2, 1:16, 1:49, 7:3, 32:21. novo 3:15, 36:18.
21:22. motion 36:15. Number 2:7, 12:3, 16:7, 24:14,
mask 2:17, 2:19, 2:20, 2:21, motivations 23:24. 28:25.
5:21, 31:22. move 44:15. numbers 8:3, 9:12, 16:3,
material 17:3. moving 4:8, 4:22. 16:4.
matter 5:2, 45:14. multibank 41:14. Numerous 6:16, 8:2, 9:13, 10:9,
mean 33:4. multibusiness 41:14. 10:10, 10:21, 12:15, 13:16,
Meaning 43:8. multiperson 41:14. 16:14, 17:19, 17:25,
meant 6:19, 29:1, 34:12. multiple 7:3, 7:4, 11:4, 15:17, 23:17.
Meat 10:24, 14:13, 14:16, 16:25, 17:8. .
18:23. music 40:12. .
mechanical 1:41. myself 5:23, 33:20, 39:20. < O >.
members 17:9. . obligations 34:25.
mental 38:2, 40:20, 40:21. . observed 39:1.
mentioned 23:12. < N >. obstruct 6:7, 23:16.
Mercedes 10:1. name 2:14, 2:25, 10:11, 11:15, obstruction 23:12, 23:25,
met 14:3, 15:2, 23:9, 32:5, 32:7, 11:19, 11:25, 12:8, 12:13, 34:11.
32:10. 12:15, 12:20, 16:8. obtain 8:24, 8:25, 10:14, 21:4,
meticulously 7:25. named 15:2. 29:13.
microphone 28:19, 32:2. nasal 28:23. obtained 7:1, 8:16, 9:24,
mid 38:22. naturalized 20:11, 22:6, 29:23, 18:5.
midday 43:21. 38:20. obvious 41:4.
million 7:9, 7:10, 7:15, 22:14, nature 6:13, 16:12, 22:17, 22:19, Obviously 4:5, 35:3.
41:19, 41:21. 33:25, 37:9, 41:1. occasions 11:10.
millions 6:22. necessarily 30:7. offense 6:14, 8:21, 8:23, 21:25,
mind 28:5. need 3:15, 24:6, 24:25, 28:6, 37:9, 37:10, 37:12,
minor 34:18, 35:7, 35:14, 30:20, 30:24, 31:8, 42:12, 40:24.
37:13. 42:14, 42:17, 42:21, 42:22, offered 34:19, 34:20.
minutes 4:15, 5:13. 43:12, 43:25, 44:6. office 28:24.
miraculously 43:18. needed 43:19. officer 29:5.
mislead 29:4. needs 31:9, 33:10. officers 28:16, 35:11.
misstatement 26:17. Nevine 1:39, 3:2, 24:5, 24:8, Official 1:47, 45:24.
Mitchell 1:46, 45:11, 45:23. 24:9. Okay 2:11, 2:16, 3:9, 5:22,
Mohamed 24:6, 24:19, New 7:2, 9:8, 9:12, 20:21, 12:11, 12:17, 13:6, 14:7,
24:20. 29:13. 14:10, 18:5, 20:10, 25:19,
moment 30:16, 35:23, 42:21, next 8:10, 25:12. 29:19, 31:16, 43:20,
42:22, 42:25. nice 4:19. 44:3.
money 15:17, 19:10, 23:20, 28:8, nine 11:10. old 21:13, 26:8, 28:23, 29:23,
37:11, 40:7. NO. 1:9. 38:9, 38:19.
monitor 36:6. nods 21:12. older 26:8, 29:22.
month 33:5. nonappearance 27:11. omissions 16:17, 17:3.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 54 of 58
54
One 5:22, 11:2, 12:1, 13:10, 35:9, 35:13. points 6:10, 39:3.
13:22, 14:13, 16:2, 16:18, passports 9:3, 34:17, 34:18, pose 41:25.
17:11, 17:19, 17:22, 18:13, 34:20, 35:6, 35:13, 35:16, posed 41:2.
18:20, 19:2, 20:2, 23:23, 35:17, 42:6. poses 41:5.
23:24, 24:15, 24:20, 24:21, past 17:9, 38:4, 39:4, 39:6. position 26:19, 29:4, 36:6.
25:20, 25:23, 26:16, 26:24, patience 5:19. possession 10:14.
27:20, 29:12, 29:25, 35:4, Patricia 1:46, 45:11, 45:23. possibility 9:21.
35:22. pattern 14:17. possible 10:2, 43:7, 43:9.
one-month 17:11. Paul 1:29, 2:7. Post 27:1.
ones 17:3. Pause. 5:16, 43:3. posted 23:6.
operative 44:12. pay 13:21. posting 30:23.
Order 2:9, 3:12, 3:15, 3:20, 4:5, Paycheck 6:16, 7:8. potential 9:19, 25:2, 25:7, 37:6,
4:19, 5:7, 6:2, 6:3, 25:5, 27:1, payee 11:17, 12:6, 13:20, 14:6, 40:22, 41:9.
34:10, 36:15, 38:7, 40:24, 15:11. potentially 8:19, 9:7, 10:7,
42:11, 43:22, 44:3, 44:4, payments 7:11, 10:25, 11:7, 10:13, 19:12.
44:11, 44:12, 44:17, 44:18, 12:3, 12:16, 15:15, 24:15, PPP 7:5, 8:1, 8:4, 9:25, 10:22,
44:20. 24:16, 24:17. 11:1, 11:4, 12:3, 13:5, 13:11,
organize 30:19. pending 33:9, 40:25. 13:19, 14:4, 14:12, 14:14,
organized 7:25. People 9:16, 24:6, 24:25, 34:1, 16:23, 20:7, 23:19, 24:10,
original 10:10. 39:7, 39:8. 24:11.
originally 5:2. percent 6:25, 9:25, 13:12, 14:12, prefer 33:10.
others 41:20. 14:15, 15:2. preponderance 23:10,
own 15:18, 16:4, 16:9, 16:10, perhaps 8:23, 16:17, 31:9, 34:8, 36:25.
29:24. 38:19. Present 1:39, 4:6.
owned 38:23. period 4:17, 17:17. presentation 45:4.
owners 6:19. periods 22:8. presented 31:2, 31:3.
ownership 27:2. person 4:7, 9:7, 14:2, 24:18, presumably 24:3.
owns 40:17. 25:1, 36:8, 41:2, 41:6, Pretrial 3:14, 3:25, 16:17, 16:24,
. 41:10. 17:1, 25:6, 25:9, 25:16, 26:3,
. personal 30:6, 30:9. 27:14, 27:19, 27:20, 36:18,
< P >. perspective 7:14, 8:11, 9:18, 36:21, 38:8, 38:11, 38:18,
p.m. 1:18, 2:2, 36:3, 45:9. 11:6, 12:2, 23:15, 23:25, 43:23, 44:21.
paid 7:11, 9:25, 13:12, 14:12, 26:1, 31:5, 45:1. pretty 4:8, 22:12.
14:15, 14:25. phone 23:22, 25:8. prevent 20:20.
pandemic 6:18. physical 38:2, 40:20, 40:21, primary 23:24.
paper 10:20. 41:6. prior 38:9.
paperwork 8:4. PII 8:2, 9:12, 10:6. prison 39:12.
parents 39:7. place 34:9. Probably 22:12, 22:13,
parole 40:24. Plaintiff 1:7, 1:27. 43:14.
part 5:7, 9:20, 13:18, 26:1, planned 28:24. probation 40:24.
28:17, 28:22. play 13:1, 18:14, 19:9. problem 4:22, 38:14.
participated 9:17. pleads 21:25. problems 38:12.
particular 39:13, 42:2. Please 2:4, 2:12, 2:21, 2:23, proceeding 2:8.
Particularly 31:3, 35:4. 2:25, 35:23, 43:2. Proceedings 1:21, 1:41, 45:9,
passed 30:13. plus 9:25, 18:21, 18:22, 45:13.
passing 30:11. 22:15. proceeds 11:11, 21:24.
passport 9:8, 20:12, 20:13, point 9:5, 10:5, 14:9, 21:14, process 13:24.
20:21, 20:24, 20:25, 21:2, 25:11, 25:12, 26:14, 34:9, produced 1:42.
21:3, 21:5, 21:6, 21:16, 23:3, 34:13, 40:13, 42:1, proffer 22:6.
29:7, 29:11, 29:13, 35:8, 42:14. proffered 37:18.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 55 of 58
55
proficient 3:5. receipt 34:18. relying 25:5.
Program 6:16, 7:9. receive 13:23, 43:20. remains 44:5, 44:18.
proof 27:2. received 4:4, 4:8, 6:23, 10:21, reminding 5:23.
propensity 42:7. 10:22, 10:25, 11:1, 11:3, remove 2:17, 2:19.
proper 36:21. 11:4, 12:2, 12:14, 12:16, removing 5:21.
property 27:2, 27:6, 37:21, 13:5, 13:11, 14:11, 14:14, renewed 29:12.
43:25. 14:24, 16:21, 16:23, 24:10, repeat 15:19.
protected 26:23. 24:11, 24:14, 24:15, 24:17, report 3:25, 16:18, 22:23, 25:6,
Protection 6:16, 7:9. 24:21, 24:22, 26:16, 34:18, 25:9, 26:2, 26:20, 26:22,
proven 41:22. 41:20. 27:14, 38:8, 40:14.
provide 15:10. receiving 15:1. reported 27:14, 38:10,
provided 6:17, 9:16. recent 29:11. 40:11.
proving 36:25. recipients 12:3, 24:16. Reporter 1:47, 45:24.
pull 43:18. record 2:14, 3:1, 5:20, 15:7, represent 2:14.
punishment 21:24. 27:9, 29:18, 38:6, 45:13. request 13:20.
purchased 10:1. recorded 1:41, 33:18. require 39:18, 44:20.
purported 6:23, 7:1, 7:20, recording 27:6. requires 37:7.
10:23, 11:2, 12:4, 12:13, records 43:13. requiring 27:5, 30:23.
12:21, 13:5, 13:10, 13:11, recovered 9:11, 10:9. residence 27:15, 38:4,
13:14, 14:11, 14:24, 15:5, reference 16:24, 16:25, 17:1, 38:15.
16:9, 16:10, 16:18, 18:25, 24:8, 24:13, 24:20, 26:7. resources 19:13, 28:8, 38:3,
23:20, 24:9, 24:14, 24:15, referenced 9:24, 10:4, 39:23.
24:17, 24:21, 25:3, 25:23, 14:22. respect 6:13, 10:17, 14:17, 15:9,
25:24, 27:20, 40:14. references 7:8, 16:18, 30:4. 16:16, 17:16, 18:15, 36:1,
put 27:10, 36:4. referred 14:1, 25:1. 38:15.
. referring 13:1, 24:3, 24:19. response 35:25.
. refers 27:2. responses 19:8.
< Q >. reflect 13:4. responsive 12:21.
question 29:6, 41:23. reflected 7:25. restrict 42:3.
questions 18:13, 27:25, Reform 28:3, 36:24, 37:5, 37:7, result 6:24, 28:2.
28:11. 39:17. resulted 5:5.
quickly 4:9, 5:13, 6:1. regard 38:17, 41:10. results 7:17, 15:13.
quite 8:20, 10:18, 29:6, regarding 29:18, 33:18. return 42:20.
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 56 of 58
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set 5:2, 10:18, 25:5, 41:24, sorry 14:8, 22:14, 29:17, 31:20, suitable 25:12.
Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 57 of 58
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summarized 41:12. took 29:6, 35:11. 31:4, 33:13, 36:10, 40:13,
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Case 1:23-cr-00344-RDB Document 28 Filed 05/12/22 Page 58 of 58
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