Court filing
Jury Trial Transcript — Day 2 (March 29, 2023) — United States v. Bernard Okojie
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A jury trial transcript for the second day of trial, March 29, 2023, in United States v. Bernard Okojie, Case No. 4:22-cr-00084-LGW-BWC, before the Honorable Lisa Godbey Wood in the U.S. District Court for the Southern District of Georgia, entered as Document 109 and filed April 30, 2023. The 172-page transcript opens with an index of government witnesses and a list of government exhibits, among them documents on account information and specific transactions, a petition, a photocopy of a notebook and a stipulation. In the testimony shown, the government questions a witness about his own PPP and EIDL loan applications and about applications the defendant prepared for others and the fees charged. The closing pages record the admonition to the jury, a recess at 3:44 p.m. and a charge conference set for the next morning. The court reporter certifies the transcript on April 24, 2023.
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No. 4:22-cr-00084-LGW-BWC · Doc. 109 · Docket on CourtListener
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Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 1 of 172 136 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION UNITED STATES OF AMERICA ) ) ) CASE NO. ) 4:22-CR-00084-LGW-BWC-1 ) ) ) v. BERNARD OKOJIE, Defendant. JURY TRIAL BEFORE THE HONORABLE LISA GODBEY WOOD March 29, 2023; 9:02 a.m. Brunswick, Georgia APPEARANCES: For the Government: MATTHEW A. JOSEPHSON, Esq. JENNIFER STANLEY, Esq. U. S. Department of Justice United States Attorney's Office P. O. Box 8970 Savannah, Georgia 31401 (912) 652-4422 matthew.josephson@usdoj.gov jennifer.stanley@usdoj.gov For the Defendant: JOHN J. OSSICK, JR., Esq. John J. Ossick, Jr., PC P. O. Box 1087 Kingsland, Georgia 31548-9190 912.729.5864 ossick@tds.net Reported by: Debbie Gilbert, RPR, CCR Official Court Reporter 801 Gloucester Street Post Office Box 1894 Brunswick, GA 31521-1894 (912) 262-2608 or (912) 266-6006 debra_gilbert@gas.uscourts.gov - - - Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 2 of 172 137 I N D E X PAGE GOVERNMENT WITNESSES ANTHONY JUDSON Direct Examination By Mr. Josephson 140 GINELL ADAMS Direct Examination By Ms. Stanley Cross-Examination By Mr. Ossick 151 168 WANDA ANDERSON Direct Examination By Ms. Stanley Cross-Examination By Mr. Ossick 170 186 CHARLES BEY Direct Examination By Ms. Stanley Cross-Examination By Mr. Ossick 188 200 KATINA BANKS Direct Examination By Mr. Josephson Examination By Mr. Ossick Redirect Examination By Mr. Josephson 202 217 219 ANGELA LOVELADY Direct Examination By Ms. Stanley 220 PRINCEWILL MONEME Direct Examination By Ms. Stanley Cross-Examination By Mr. Ossick Redirect Examination By Ms. Stanley 233 242 244 RITA ADDO-MINTA Direct Examination By Ms. Stanley 245 MARIA PAGAN Direct Examination By Mr. Josephson 257 DEDRA WILLIAMS Direct Examination By Ms. Stanley 258 KIMBERLY JOHNSON Direct Examination By Mr. Josephson Cross-Examination By Mr. Ossick 262 271 Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 3 of 172 138 RONNIE MATHESON Direct Examination By Ms. Stanley Cross-Examination By Mr. Ossick Redirect Examination By Ms. Stanley 274 279 280 KASSANDRA HALEY-FIELDS Direct Examination By Ms. Stanley 281 OFFICER BRIAN CODER Direct Examination By Mr. Josephson 287 GOVERNMENT RESTS 293 DEFENSE RESTS 305 Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 4 of 172 139 E X H I B I T S GOVERNMENT'S EXHIBITS 14 15 16 17 18 19 20 21 22 23 24 25 DESCRIPTION I.D.'d ADMITTED No. 17A Document Entitled "Account Information" 262 265 No. 17B Document Entitled "Specific Transactions for INDPYMNT:SBA" 263 265 No. 17C Document Entitled "Specific Transactions for Proceeds:SBA" 264 265 No. 17D Document Entitled "SBA and Related Activity" 264 265 No. 18 Petition 283 284 No. 19 Photocopy of Notebook 290 291 No. 20 Stipulation 255 255 Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 5 of 172 140 1 P R O C E E D I N G S 2 (Call to order at 9:02 a.m.) 3 THE COURT: Good morning, let's bring in the jury. 4 (The jury enters the courtroom.) 5 THE COURT: Good morning and welcome back, members of 6 the jury. 7 way through the Government's witnesses. 8 Mr. Josephson, call your next. 9 MR. JOSEPHSON: 10 When we broke yesterday evening, we were making our Yes, Your Honor, the Government calls Anthony Judson. 11 ANTHONY JUDSON, 12 having been first duly sworn, was examined and testified as 13 follows: 14 15 THE CLERK: Thank you. You may be seated. And if you will please state your full name and spell your last name. 16 THE WITNESS: 17 THE CLERK: 18 THE WITNESS: 19 THE CLERK: 20 THE WITNESS: 21 Is it this? Yes. Anthony Lamont Judson. If you will spell your last name. J-u-d-s-o-n. DIRECT EXAMINATION 22 BY MR. JOSEPHSON: 23 Q. 24 Have we spoken on the phone before today? 25 A. Good morning, Mr. Judson. Yes, sir. My name is Matt Josephson. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 6 of 172 141 1 Q. Have you met with law enforcement a couple of times about 2 this case? 3 A. Somewhat, well, other than the phone call. 4 Q. Spoken with law enforcement on the phone about it? 5 A. Yes. 6 Q. What do you do for a living? 7 A. I'm an independent truck driver, owner-operator. 8 Q. Do you know the defendant in this case, Bernard Okojie? 9 A. Yes, sir. 10 Q. What was the name that you generally knew him by? 11 A. He just went by Ben. 12 Q. And how did you meet Ben or Mr. Okojie? 13 A. Well, it was another driver up in Michigan. 14 talking about as far as credit goes trying to get some credit 15 better and all that good stuff, and I was introduced to him, 16 introduced by phone number to him for just credit enhancement or 17 credit repair somewhat. 18 Q. 19 to repair your credit? 20 A. 21 to try to get a better score, better Beacon score. 22 Q. 23 help you with that? 24 A. Yes, sir. 25 Q. And you heard it from somebody at a truck stop? Tell the jury. Let me make sure I understood that. We were just So you were looking Not really repair but I guess like trade lines or whatnot And you heard that the defendant was someone who could Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 7 of 172 142 1 A. Yes. 2 Q. And that truck stop was where? 3 A. It was a TA, TA up in Michigan. 4 Q. TA in Michigan? 5 A. Yes, sir. 6 Q. What did you do hear about the defendant's professional 7 background? 8 MR. OSSICK: 9 MR. JOSEPHSON: 10 Objection, hearsay. Not submitted for the truth, just how he knew him, background of how the witness is relevant. 11 THE COURT: Overruled. Proceed. 12 THE WITNESS: 13 professionally, to be honest. 14 introduced to, like I say, help my credit score, but as far as 15 what he did for a living, I didn't have an idea what he did for 16 a living. 17 Q. 18 CPA of some kind? 19 A. To my knowledge, no, not to my knowledge. 20 Q. Does he have a financial advisory business of some kind? 21 A. I don't know about business but he had something about 22 enhancement of credit. 23 Q. 24 people with finances? 25 A. I didn't understand what he did (By Mr. Josephson) I just knew that it was To your knowledge, is the defendant a Does he have some kind of professional license to help Not to my knowledge, I can't say yes or no. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 8 of 172 143 1 Q. Any professional certifications, to your knowledge? 2 A. No, sir. 3 Q. Just if I understand your testimony, somebody who 4 generally helps people repair credit but you weren't aware of 5 any specific training or licenses that the defendant had? 6 A. No, sir. 7 Q. Did you submit your own PPP and EIDL applications? 8 A. I did. 9 Q. And did you get loan money? 10 A. Yes, sir. 11 Q. How much money did you get? 12 A. I think a total I think 17, seven, I think it was 17 and 13 17, and then for economic disaster, I think they gave me like 14 the advance that was, like I said, I guess it, I think that came 15 to like 9999.00, I believe. 16 Q. 17 you mean 17,000.00? 18 A. Yes, I'm sorry, 17,000.00. 19 Q. 17,000.00, was that a PPP loan? 20 A. I believe so, yes, sir. 21 Q. Did you get a $150,000.00 loan? 22 A. No. 23 Q. You did not? 24 A. No, sir. 25 Q. Did you get an EIDL loan as well? I did initially, yes. Let me break that down. So how much, when you say 17, do Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 9 of 172 144 1 A. Is that economic -- yeah, that was for the nine -- I think 2 they advanced the $9,999.00. 3 Q. An EIDL advance, is that what you -- 4 A. Yes, sir. 5 Q. And these were applications that you submitted yourself? 6 A. Yes, sir. 7 Q. Were those loan applications that you submitted accurate? 8 A. Yes, sir. 9 Q. Do you actually own your own trucking business? 10 A. Oh, yeah. 11 incorporated in the state of Georgia. 12 Q. Work a lot? 13 A. A whole lot. 14 Q. On the road a lot? 15 A. A whole lot. 16 Q. After you got those loans, did the defendant file loans on 17 your behalf or attempt to do so? 18 A. 19 whatever happened, the system really didn't like it so it booted 20 them out. 21 Q. So they were rejected? 22 A. Yes, sir. 23 Q. Was this after you had already gotten loan money? 24 A. Yes, sir. 25 Q. Did you provide your personal information to the defendant Since November the 9th, 2011 I've been Yes, sir, but for some reason, I don't think the system, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 10 of 172 145 1 so he could submit loan applications on your behalf? 2 A. 3 number and address, I believe. 4 Q. 5 goods sold information and employee information to the 6 defendant? 7 A. Not to my knowledge -- no, not to my knowledge. 8 Q. Do you remember? 9 A. No, sir -- I mean, I don't believe I did. 10 Q. You don't think you did, okay. 11 I think that was probably my name and social or my EIN Did you provide the gross revenue information, cost of Did you ever provide the defendant access to your e-mail 12 account? 13 A. Not my direct e-mail, no, sir. 14 Q. Did he give you a log-in and password so you could access 15 the SBA database? 16 A. 17 I can't remember if I had a log-in or not but I do remember 18 calling them trying to see what was going on, but they couldn't 19 really verify or tell me why it was rejected, though. 20 Q. 21 loan money when he filed the application? 22 A. 23 happened was I had qualified for that amount, but that amount 24 was, I guess, ate up so fast by the business I asked him if 25 there was any other way the business would qualify for the extra I can't remember. I can't recall it. I don't remember. Did the defendant know you had already received pandemic I believe so, because I was trying -- I think what Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 11 of 172 146 1 funding, but it didn't. It didn't qualify for extra funding. 2 Q. 3 that you had applied and he was trying to get you more money? 4 A. Yeah. 5 Q. Are you currently married to Ms. Ginell Adams? 6 A. I'm going through a divorce, but the decree hasn't been 7 signed yet, so I guess under law I'm still married to her. 8 Q. Did you introduce Ms. Adams to the defendant? 9 A. Yes, I did. 10 Q. Why did you do that? 11 A. I know she had a hair care -- you know, she did 12 cosmetology, hair business and whatnot, and I told her that, you 13 know, she probably be able to get money through her business or 14 EIDL or whatever she had going with her business. 15 Q. Did the defendant assist Ms. Adams with an EIDL loan? 16 A. As far as the EI -- I'm not sure. 17 one -- 18 Q. A SBA loan? 19 A. Yes. 20 Q. Did you ever speak on the phone with the defendant and 21 your wife about a SBA loan? 22 A. 23 number, and so they discussed whatever they had going on between 24 each other. 25 Q. If I understand your testimony, he was generally aware No. Yes, sir. But I know the other They -- I guess I gave her -- they had each other's Are you aware of a phone call between the two of them Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 12 of 172 147 1 about a SBA loan? 2 A. 3 at a time, so I couldn't tell you what day or what time that 4 they talked or not. 5 Q. 6 Adams and the defendant? 7 A. As far as phone number? 8 Q. Yes. 9 A. Yes, sir, I provided her with his phone number. 10 Q. Did you facilitate the exchange of any loan information? 11 A. No, sir. 12 Q. Did your wife pay the defendant to submit her SBA loan? 13 A. To submit it, I'm not sure. 14 Q. To prepare it, was there an exchange of money between Ms. 15 Adams and the defendant in connection with the loan? 16 A. 17 not sure what percentage or what amount was exchanged. 18 it was a percentage or whatever the approval was as a percent. 19 Q. When you say a fee, you mean a fee paid to the defendant? 20 A. Yes, sir. 21 Q. Was that a fee that he charged? 22 A. Yes, sir. 23 Q. And your understanding is that it was based on a 24 percentage of the loan? 25 A. Not so much. Like I said, I was on the road 10 to 14 days Did you facilitate the exchange of information between Ms. I don't think so. I think after the approval, there was like a fee, but I'm Yes, sir. I think Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 13 of 172 148 1 Q. Were you there when the money was exchanged between Ms. 2 Adams and the defendant? 3 A. Yes, I was there. 4 Q. Where was that? 5 A. We were in the parking lot of Navy Federal in -- I think 6 it's McDonough, Stockbridge, one of the two. 7 Q. Is that Navy Federal Credit Union? 8 A. Yes, sir. 9 Q. In McDonough? 10 A. McDonough, yeah. 11 Q. You were there? 12 A. Yes, sir. 13 Q. What was the nature of the payment, cash, check, crypto 14 currency? 15 A. 16 it was cash. 17 Q. It was cash? 18 A. I think -- yeah, I think she had to go inside and get the 19 money out of the bank to exchange as far as what fee. 20 Q. 21 involved? 22 A. Not to my knowledge. 23 Q. Ms. Roper, could you display Government Exhibit 12D. 24 we zoom in on the -- could we move to the second page, I 25 believe. What was the nature? I think it was -- I think it was cash, I believe. I think Was there ever a check or a cashier's check that was Zoom in on that check there from Navy Federal. Can Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 14 of 172 149 1 Do you recognize -- let me start by asking you: Who is 2 the remitter there? 3 A. That's my wife. 4 Q. And what's the name of the company listed, the entity that 5 received the check, above the remitter? 6 A. It's Regions Bank. 7 Q. That's the bank but it says "Pay to the Order of" -- 8 A. "Pay to the order of Kojie9, LLC. 9 Q. Do you know what Kojie9, LLC is? 10 A. No, sir. 11 Q. Do you recognize this check? 12 A. It may have been, like I said, the fee probably that I'm 13 thinking. 14 Q. Okay. 15 A. Yes, sir. 16 Q. Does that ring a bell to you? 17 that your wife paid? 18 A. 19 my wife. 20 Q. 21 while the exchange happened; correct? 22 A. 23 as the check go, I'm not sure. 24 check but -- on that amount, I'm not sure. 25 Q. The amount is 17,550.00? Do you recall the amount Not the exact amount, but I mean, yeah, that's -- that's That's my wife's name on that check. Just so I'm clear, you remember being in the parking lot Yeah, but -- I was in the car but I don't know -- as far I'm not sure if it was cash or a Do you know Wanda Anderson and Charles Bey? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 15 of 172 150 1 A. Yes, sir. That's my mother-in-law and that is her 2 boyfriend. 3 Q. Your mother-in-law, is that Ms. Ginell Adams' mother? 4 A. Mother, yes, sir. 5 Q. And Mr. Charles Bey is her boyfriend? 6 A. Yes, sir. 7 Q. Do you know Ms. Katina Banks? 8 A. That is one of my ex-wife's clients/friends. 9 Q. And what kind of client was she? 10 A. She did her hair. 11 for her. 12 Q. 13 stylist? 14 A. 15 beautician or cosmetologist. 16 Q. 17 gross over $200,000.00 a year? 18 A. 19 taxes, but I took care of truck, house, cars. 20 was constantly on the road working to take care of everything. 21 I was the sole, really the head of household and pretty much was 22 never home because I was always working, but as far as that 23 $230,000.00, that's not to my knowledge. 24 Q. 25 business? She was a client where she did her hair Did Ms. Adams cut hair for a living? Was she a beauty As far as -- yeah, as far as I knew, yes, sir, she was a To your knowledge, did your wife's business activities I -- I never seen it, you know, because we filed separate Like that's why I Did you ever see employees associated with your wife's Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 16 of 172 151 1 A. No, sir. 2 MR. JOSEPHSON: No further questions, Your Honor. 3 THE COURT: Cross-examination? 4 MR. OSSICK: No questions. 5 THE COURT: Any objection to this witness being excused? 6 MR. JOSEPHSON: 7 THE COURT: 8 THE WITNESS: 9 THE COURT: 10 MS. STANLEY: No, Your Honor. Sir, you may step down and you're excused. So I'm clear to leave? Yes, sir, thank you. 11 The Government calls Ginell Adams. GINELL ADAMS, 12 having been first duly sworn, was examined and testified as 13 follows: 14 15 THE CLERK: Thank you. You may be seated, and if you will please state your full name and spell your last name. 16 THE WITNESS: 17 It's Ginell Adams, last name A-d-a-m-s. DIRECT EXAMINATION 18 BY MS. STANLEY: 19 Q. Good morning, Ms. Adams. 20 A. Good morning. 21 Q. Where do you live generally? 22 A. In the Locust Grove area. 23 Q. Do you know the defendant, Bernard Okojie? 24 A. I don't know him personally. 25 Q. Have you ever spoken with him before? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 17 of 172 152 1 A. Over the telephone. 2 Q. Did you ever meet him in person? 3 A. Once, but I didn't get out of the car to meet him. 4 Q. Would you recognize him? 5 A. Possibility, it's possible. 6 Q. Do you see him in this room this morning? 7 A. He looks familiar over there. 8 Q. At the table right behind me? 9 A. Yes. 10 Q. How did you meet Mr. Okojie? 11 A. Through my husband. 12 Q. Who is your husband? 13 A. Anthony Judson. 14 Q. Did Mr. Okojie fill out an application for a SBA loan for 15 you in July of 2020? 16 A. Yes. 17 Q. Do you have a business? 18 A. I do. 19 Q. What kind of business? 20 A. Well, I have a few. 21 a business where I fix up houses and I also do events and party 22 planning. 23 Q. Do any of those businesses have names? 24 A. Well, I was GSH. 25 the State, but the one I do hair is Hair by Giselle, and the one I have a hair business. I also have That's the one that is registered with Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 18 of 172 153 1 that -- the party planner, my sister-in-law and I, we have that 2 and it's called -- what is it? -- Contrary Events. 3 birthday parties. 4 Q. Which of these businesses was the SBA loan for? 5 A. I don't know which one he did. 6 application. 7 Q. Do you work anywhere else? 8 A. Currently, yes, I work. 9 Q. Where do you work? 10 A. I work at Witmark. 11 Q. Do you have a health services business? 12 A. No, I don't. 13 Q. Ms. Adams, let's talk about July of 2020. 14 husband introduced you to Mr. Okojie? 15 A. Yes. 16 Q. Did he introduce you on a phone call where all three of 17 you were on the phone? 18 A. Right. 19 Q. Okay. 20 A. So I -- of course, I didn't know him, but I knew his name 21 because I heard my husband mention him before because he had 22 worked with him before. 23 Q. 24 what did the three of you discuss? 25 A. We do I never saw my You said your It was through a phone call but he knew him prior. During this phone call with Mr. Okojie and your husband, He just asked for the information because my husband and I Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 19 of 172 154 1 had already had a conversation prior about it. 2 were on the phone, it was a three-way -- well, not a three-way 3 call. 4 was beside him. 5 he and I never just held a conversation. 6 Q. What information did he tell you he needed? 7 A. My social, the correct spelling of my name and my address. 8 Q. Did he ask you if you had a business? 9 A. No. 10 Q. Did you tell him you had a business? 11 A. We never had a conversation. 12 Q. Do you have any employees? 13 A. No. 14 Q. Did Mr. Okojie ask you if you had any employees? 15 A. No, we never had a conversation. 16 Q. How much did you make approximately in the 12 months 17 before January 31st of 2020? 18 A. I don't know. 19 Q. Can you give me an estimate? 20 A. I don't know. 21 Q. The year before COVID started, so about 2019? 22 A. With my hair business or just any business? 23 Q. Let's start with your hair business. 24 A. 2019, my hair business, I probably -- I guess maybe about 25 30. It was on speakerphone. So when he and I He and Ben were on the phone. I He just told me what information he needed so It was COVID. I really don't know. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 20 of 172 155 1 Q. What about for the event-planning business? 2 operational in 2019? 3 A. We were doing -- 4 THE COURT: 5 THE WITNESS: 6 THE COURT: 7 Q. 8 Was that When you said 30, do you mean 30,000.00? Yes, ma'am, 30,000.00. All right, continue. (By Ms. Stanley) Thank you, Your Honor. What about your event-planning business? 9 operation in 2019? 10 A. 11 we didn't have the LLC at the time. 12 we were doing. 13 Q. Were you making money? 14 A. Yes. 15 Q. About how much money in 2019? 16 A. Maybe about 10 or 15. Was that in It was in operation, but it wasn't anything that we had -- 17 THE COURT: 18 THE WITNESS: It was just something that Again thousand? (By Ms. Stanley) Thousand, I'm sorry. 19 Q. And what about the house-flipping 20 business? 21 A. 22 that we lived in in Macon, but it was my mom's house, but we 23 were working on that. 24 Q. Did you sell that house in 2019? 25 A. It didn't get sold. Were you doing that in 2019? Started it because we were working on a project of a house It got rented, rented out. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 21 of 172 156 1 Q. 2 2019 period? 3 A. No. 4 Q. Did Mr. Okojie tell you that he was going to fill out the 5 loan application for you? 6 A. 7 Again, when we -- it was a conference -- well, not the 8 conference call, when he was on the phone and they were on the 9 speaker phone, it wasn't a conversation being held. 10 like they had their conversation. 11 He and I never had spoke on the phone outside of my husband. 12 was always on the speakerphone. 13 needed, and that was it. 14 Q. 15 business? 16 A. No. 17 Q. Ms. Roper, will you please display Government's 2A Page 18 32. And can you zoom in on that column, the second from the 19 right, please. 20 Okay. Did Mr. Okojie ask you how much you made in the Well, I knew that from the conversation with my husband. It was just I gave him the information. It I gave the information that was Did he ask you to provide any documentation for a And let me ask you: Do you recognize that document, Ms. 21 Adams? 22 A. No. 23 Q. Do you mind looking at this? 24 small but can you tell the jury whether that's your information, 25 your name, address, phone number, your personal information? I know the font is very Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 22 of 172 157 1 A. Yes, it is. 2 Q. Is that your e-mail address? 3 A. Yes, it is. 4 Q. Bank account -- I'm sorry, strike that. 5 Do you see that number, the $233,900.00 number? 6 A. I do. 7 Q. Did you provide that number to Mr. Okojie as the amount of 8 money that you made at any point in time? 9 A. No, I didn't. 10 Q. Do you see down there at the bottom where it says 7? 11 A. Yes. 12 Q. Did you provide Mr. Okojie with seven employees as the 13 number of people you employed at any point in time? 14 A. No. 15 Q. Will you zoom back out, please, Ms. Roper. 16 in on the column on the left where it tells you what each line 17 is, far left. 18 Will you zoom And Ms. Adams, do you see Line 14? 19 A. Yes. 20 Q. Does that say that it's asking for gross revenues for the 21 12-month period prior to January 31st of 2020? 22 A. Yes. 23 Q. And then Line 33, is that asking for the number of 24 employees as of January 31st, 2020? 25 A. Yes. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 23 of 172 158 1 Q. 2 You can take that down, Ms. Roper. Did Mr. Okojie tell you or your husband when the 3 application had been submitted? 4 A. Yes. 5 Q. What happened next? 6 A. He told us -- well, told us over the phone that I needed 7 to go on and sign, so it was on speakerphone so he walked me 8 through to do the electronic signature and that was it. 9 Q. 10 SBA? 11 A. I believe so. 12 Q. And did you click on a link in that e-mail? 13 A. I'm -- I'm almost certain that I did. 14 remember but I'm sure I did. 15 Q. 16 the SBA's Web site? 17 A. Yes. 18 Q. And did you log into that Web site? 19 A. I don't recall logging in. 20 and it was a signature, an electronic signature page, and all I 21 remember is doing the e-signature. 22 Q. 23 to log in? 24 A. I don't remember. 25 Q. But you do remember digitally signing the document? Okay, so how did that go? Did you get an e-mail from the I don't quite Whether you clicked on a link or not, did you end up on Okay. I just remember going into it Do you remember if Mr. Okojie gave you a password Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 24 of 172 159 1 A. Yes. 2 Q. Do you remember if it was one document or more than one 3 document? 4 A. I recall one. 5 Q. Did you read that document? 6 A. It wasn't anything other than just a signature page, like 7 an e-signature and that's all I did and that was it. 8 the only time I went on the application, and it wasn't even an 9 application signature page. 10 Q. 11 loan money from the SBA? 12 A. I did. 13 Q. How much? 14 A. It was 117,000.00. 15 Q. Was that deposited into your Navy Federal Credit Union 16 account? 17 A. Right. 18 Q. Did you pay Mr. Okojie any of that money? 19 A. Yes, I did. 20 Q. How much? 21 A. It was 17,000.00. 22 it was $17,000.00. 23 Q. What was that payment for? 24 A. The process of the application. 25 a percentage that he mentioned that he charged, and that was the That was After you digitally signed that document did you receive I don't remember the dollar amount but That was his fee. It was Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 25 of 172 160 1 percentage. 2 Q. Did you negotiate that fee at all? 3 A. No, I did not. 4 Q. How did you pay him? 5 A. Cashier's check, I went to my bank and got the cashier's 6 check made out. 7 Q. Who was that check made out to? 8 A. I don't remember the company, but it was a company that he 9 provided for me to get the cashier's check made out to, but it 10 was a weird name. 11 Q. But he told you who to make the check out to? 12 A. Yes. 13 Q. Ms. Roper, will you pull up Government's Exhibit 12A, 14 please, and will you go to the second page and zoom into that 15 check. 16 that this loan money was a business loan? 17 A. I did. 18 Q. And did you know that it was a loan that you had to pay 19 back? 20 A. I did. 21 Q. When you went to the bank to get the cashier's check, was 22 your husband with you? 23 A. 24 I know he was with me when I made the payment. 25 Q. I don't remember exactly what it was. While they are pulling that up, Ms. Adams, did you know I don't recall him being with me when I got the check but When you gave the check to Mr. Okojie? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 26 of 172 161 1 A. Right. 2 Q. Where did you meet Mr. Okojie to give him the check? 3 A. In the parking lot of Navy Federal. 4 Q. Did you do that on the same day you got the check? 5 A. I don't recall. 6 Q. And did you hand the check physically to Mr. Okojie? 7 A. No, my husband did. 8 Q. Okay, did you get out of the car? 9 A. No. 10 Q. All right, Ms. Adams, if you will look at the screen, will 11 you let me know if you recognize this check? 12 A. Yes. 13 Q. And is that the check that you gave to Mr. Okojie? 14 A. Yes. 15 Q. Is it for $17,550.00? 16 A. Yes. 17 Q. Dated July 22nd, 2020? 18 A. Yes. 19 Q. Do you see who it's made payable to? 20 A. Right. 21 Q. Do you recognize that name? 22 A. I recognize it from getting the check made. 23 only time I've seen that name. 24 Q. Did you know what kind of business that was? 25 A. No. I can't remember. That's the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 27 of 172 162 1 Q. 2 You can take that down, Ms. Roper. After you paid Mr. Okojie his fee, what did you spend the 3 rest of the loan money on? 4 A. 5 my other business when I told you I was flipping. 6 my husband with his business because it was in the middle of 7 COVID. 8 during that time. 9 Q. 10 you buy for your businesses or business? 11 A. 12 tablecloths, centerpieces, flowers because I did weddings. 13 did birthday parties. 14 I bought dryers. 15 my area that I did hair in and things of that nature for my 16 business. 17 Q. 18 11A and go to Page 16, please. 19 top. 20 I spent it on my business. I invested, I got a house with I also helped No one was making money and whatever else I needed Other than purchasing the house, what kinds of things did Well, my event-planning business, I bought decorations, I With my hair business, I bought product. I bought stands. I bought things to decorate Ms. Roper, will you please pull up Government's Exhibit Will you zoom in up there at the Ms. Adams, these are the bank statements for your Navy 21 Federal Credit Union account. Do these show that $117,000.00 22 SBA loan money coming into that account? 23 A. Yes. 24 Q. Is that $17,550.00 withdrawal the check that we've just 25 talked about? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 28 of 172 163 1 A. Yes. 2 Q. And is the date next to that check withdrawal July 21st, 3 2020? 4 A. 5 date, but, yes, that's the date that was on the check. 6 Q. Do you see that on this statement on the left-hand column? 7 A. Yes. 8 Q. Can we go to Page 19, please, Ms. Roper. 9 That's what was on the check. I don't remember exact Ms. Adams, if you will look at this, do you see that 10 withdrawal in the amount of $28,000.00? 11 A. Yes. 12 Q. On July 28th of 2020? 13 A. Yes. 14 Q. What was that? 15 A. A house that I purchased. 16 Q. Where was that house? 17 A. In Macon. 18 Q. Do you still own it? 19 A. I sold it. 20 Q. How much did you sell it for? 21 A. I think 62,000.00. 22 Q. Are any of these other expenses on this page related to 23 your businesses? 24 A. I'm just looking. 25 Q. Sure, take your time. I fixed it and I sold it. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 29 of 172 164 1 A. 2 It does show personal. 3 Q. 4 a hotel payment? 5 A. No. 6 Q. Do you know what that was for? 7 A. America's Best, those are glasses. 8 Q. Can you go to Page 22, Ms. Roper. 9 withdrawal on September 22nd, Ms. Adams, what was that for? 10 A. September 22nd? 11 Q. Yes, ma'am, the last one on that. 12 A. I purchased a toy poodle. 13 Q. A toy poodle? 14 A. I did. 15 died. 16 toy poodle. 17 house because she was living with me because she couldn't go 18 upstairs. I went by the place. They had it. She asked did I 19 want it. We went in -- well, I went inside. I couldn't make 20 all the payment on one, so we -- we had to split it up. 21 gave me cash so I had to put what I could on my card and then I 22 paid the rest. 23 Q. 24 25 They are just all withdrawals and dentist appointments. Dr. -- Dentfirst, that's my dentist. Is that withdrawal on August 6th, America's Best, is that That last $2,000.00 My mom and I went half on it. My dad had just I always wanted -- I already had a dog, and I wanted a She just had surgery, so on the way back from her She had Let me ask you about one more, Page 25, please, Ms. Roper. Ms. Adams, the withdrawal for $2,000.00 on August 2nd, Maxie Price Chevro, what was that for? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 30 of 172 165 1 A. Car for my son. 2 Q. You can take that down, Ms. Roper. 3 Ms. Adams, did you also receive a PPP loan? 4 A. I did. 5 Q. Do you remember when that was? 6 A. I don't. 7 Q. Does April 2021 sound correct? 8 A. I'm not sure. 9 Q. Do you have any reason to believe that's inaccurate? 10 A. No, I don't. 11 Q. Do you remember how much that loan was for? 12 A. I don't remember the dollar amount. 13 Q. Does about $20,000.00 sound accurate? 14 A. It sounds close. 15 Q. Which business is that for? 16 A. Should have been my hair business. 17 Q. Did you fill out that application? 18 A. No, I did not. 19 Q. Did someone else do it for you? 20 A. Yes. 21 Q. Who was that? 22 A. I just know Steve. 23 Q. Is he your tax preparer? 24 A. He has done tax work for myself and my family, yes. 25 Q. Do you remember submitting your driver's license to get That's all I know his name is Steve. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 31 of 172 166 1 that loan? 2 A. Online, yes. 3 Q. Do you remember taking a selfie to verify your 4 identification to get that loan? 5 A. I believe, yes, online. 6 Q. Did you make $97,000.00 in 2020? 7 A. No. 8 Q. Did you know that's what the tax documents submitted with 9 that application said you made? 10 A. No, I did not. 11 Q. Did you pay Steve a fee? 12 A. I did. 13 Q. How much? 14 A. I don't remember the dollar amount. 15 Q. And what did you spend that loan money on? 16 A. Still my business. 17 Q. Ms. Roper, can you pull Government's Exhibit 12A back up 18 and go to Page 50 -- I'm sorry, not 12A. 19 please. 20 11, 11A go to Page 53, Can you zoom on that, please. Ms. Adams, do you see a $20,227.00 deposit on May 18th 21 entitled "PPP funding"? 22 A. Yes. 23 Q. Is this your Navy Federal Credit Union account? 24 A. It is. 25 Q. On May 20th, I guess let me ask you first: Are any of Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 32 of 172 167 1 those expenses immediately following, those withdrawals 2 immediately following that deposit, were those related to your 3 business? 4 A. 5 spend the money that doesn't relate to my business, but if 6 that's my account, you will see other things that I purchased, 7 made purchases with, so, yes. 8 Q. 9 PPP money, had to be used for your business? 10 A. Yes, it's used toward my business, yes. 11 Q. Is that payment, the 5/20 $50.00? 12 A. Which payment? 13 Q. The May 20th for $50.00, is that at a plastic surgeon's 14 office? 15 A. That was a consultation fee. 16 Q. At a plastic surgeon's? 17 A. It was over the phone. 18 Q. All right, you can take that down, Ms. Roper. 19 No, but I also had money, so you act like I'm -- I can't Do you know this loan money, either the EIDL money or the Who is Wanda Anderson? 20 A. That's my mother. 21 Q. Who is Charles Bey? 22 A. That's my stepdad. 23 Q. Do you know Katina Banks? 24 A. Yes, I do, that's my friend. 25 Q. Did you refer Mr. Okojie to her or her to Mr. Okojie? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 33 of 172 168 1 A. Yes, I did. 2 Q. And do you know Angela Lovelady? 3 A. That's her aunt, Katina's aunt. 4 Q. Have you ever spoken with her? 5 A. Spoken with who? 6 Q. Ms. Lovelady. 7 A. I've spoken with her before when I went to do a baby 8 shower for them before because, as I say, I do parties. 9 Q. Did you put her in touch with Mr. Okojie? 10 A. No, I did not. 11 MS. STANLEY: 12 THE COURT: Nothing further. Cross-examination, Mr. Ossick. 13 CROSS-EXAMINATION 14 BY MR. OSSICK: 15 Q. Good morning. 16 A. Good morning. 17 Q. I represent Mr. Okojie. 18 A. Okay, how are you? 19 Q. A couple of questions, Ms. Adams. 20 some point you logged into a SBA Web site? 21 A. I indicated that I signed an electronic document, yes. 22 Q. And your recollection is the only page that was available 23 to see when you did that was the signature page? 24 A. Yes. 25 Q. Do you recall being interviewed over the telephone or My name is John Ossick. You indicated that at Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 34 of 172 169 1 getting a call in February 14th of last year by Agent Dye? 2 A. Yes. 3 Q. And do you recall at some point asking him do you need a 4 lawyer? 5 A. Yes. 6 Q. And he told you he couldn't tell you whether you do or 7 not? 8 A. Yes. 9 Q. And you asked "Where is this going" and you cut off the 10 conversation and said "I've got to talk, see which of my lawyers 11 I need to use"? 12 A. Correct. 13 MR. OSSICK: Thank you. 14 THE WITNESS: You're welcome. 15 THE COURT: 16 MS. STANLEY: 17 THE COURT: 18 MS. STANLEY: 19 THE COURT: 20 21 Any redirect? No, Your Honor. Any objection to excusing this witness? No, Your Honor. All right. She may be excused. You may be excused. Call your next witness. MS. STANLEY: 22 The Government calls Wanda Anderson. WANDA ANDERSON, 23 having been first duly sworn, was examined and testified as 24 follows: 25 THE CLERK: Thank you. You may be seated. And if you Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 35 of 172 170 1 will please state your full name and then spell your last name. 2 THE WITNESS: 3 Wanda Anderson. A-n-d-e-r-s-o-n. DIRECT EXAMINATION 4 BY MS. STANLEY: 5 Q. Good morning, Ms. Anderson. 6 A. Good morning. 7 Q. Where do you live generally? 8 A. In Locust Grove, Georgia. 9 Q. Where do you work? 10 A. DaVita Dialysis. 11 Q. What do you do there? 12 A. I'm a dialysis nurse. 13 Q. Do you have a business? 14 A. Yes. 15 Q. What is it called? 16 A. Unique Pleasant & Smooth Souls. 17 Q. What kind of business is it? 18 A. Durable medical equipment business. 19 Q. What do you do? 20 A. We provide durable medical equipment such as diabetic 21 shoes, arthritic supplies like back braces, knee braces, things 22 like that. 23 Q. Do you know Charlie Bey or Charles Bey? 24 A. Yes. 25 Q. Who is that? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 36 of 172 171 1 A. My partner. 2 Q. Do you live together? 3 A. Yes. 4 Q. Do you own and operate Unique Pleasant & Smooth Souls with 5 him? 6 A. Yes. 7 Q. Do you have any other employees in this business besides 8 you and Mr. Bey? 9 A. Just me and Mr. Bey. 10 Q. How much money would you estimate this business made in 11 2019? 12 A. 13 really estimate. 14 Q. Would you say less than $40,000.00? 15 A. I would say probably less than that. 16 Q. What's the most it ever made in one year? 17 A. I would just estimate probably about 30 or close to 40. 18 Q. Did you and your husband first apply for an EIDL loan for 19 Unique Pleasant & Smooth Souls on your own? 20 A. Yes, I did. 21 Q. Did you get any money for that loan? 22 A. No. 23 Q. How did you find out about the EIDL loan program? 24 A. Heard it from, you know, it was advertised. 25 TV, Internet, about helping small businesses. I'm not sure, but it wasn't much. I'm not sure. I can't I heard it on Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 37 of 172 172 1 Q. Did you and your husband fill out that application 2 together? 3 A. No. 4 Q. When was that? 5 A. I'm not sure what date it was. 6 Q. Does April of 2020 sound accurate? 7 A. I'm not sure. 8 Q. Was it earlier in the pandemic? 9 A. It was during that time that the pandemic. 10 what date. 11 Q. 12 if you recognize the information on that document. 13 business name? 14 A. Yes. 15 Q. Is that your EIN? 16 A. I'm not sure if that's the correct number, but yes. 17 have an EIN number. 18 head. 19 Q. And "Unique Pleasant & Smooth Souls, LLC"? 20 A. Yes. 21 Q. Is that your address? 22 A. Yes. 23 Q. Phone number? 24 A. Yes. 25 Q. e-mail address? I filled it out. I'm not sure Let me show you a document, Ms. Anderson, and let me ask Is that your I do I don't know the number off the top of my Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 38 of 172 173 1 A. Yes. 2 Q. What number does it show for gross revenue in the 12 3 months prior to January 31st, 2020? 4 A. It's 38, 38,000.00. 5 Q. And seven dollars? 6 A. Yes. 7 Q. And how much, right below, does it show for the cost of 8 goods sold during that same time period? 9 A. Cost of goods, the same amount, 38,007.00. 10 Q. Do you remember putting those numbers in the first EIDL 11 application that you filled out? 12 A. 13 this is what's on here. 14 Q. 15 essentially spend what you brought in? 16 A. 17 I put in what we made. 18 Q. Does it say you had two employees? 19 A. Yes. 20 Q. And that's accurate; right? 21 A. Yes. 22 Q. Do you have any other businesses besides Unique Pleasant & 23 Smooth Souls? 24 A. I have a rental property business that I have. 25 Q. How many properties do you own? I mean, I filled out the application. I don't know if This is what I put in here. Are those numbers accurate for that time period? Did you Yes, because we didn't make any money during that time, so Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 39 of 172 174 1 A. One. 2 Q. Do you know the defendant, Bernard Okojie? 3 A. I don't know. 4 Q. Do you know someone named Ben? 5 A. Yes. 6 Q. Did he fill out a SBA loan application for you in July of 7 2020? 8 A. I don't know what date it was, but, yes, he did. 9 Q. Does that sound approximately right, July 2020? 10 A. I'm not sure what date it was, ma'am. 11 Q. Okay. 12 A. Yes. 13 Q. How many times? 14 A. One. 15 Q. Would you recognize him? 16 A. I'm not sure if I -- 17 Q. Do you see anyone in this room today who looks like him? 18 A. No, I'm not sure -- 19 Q. Okay. 20 A. -- if I can recognize him again. 21 Q. Did you initially speak to Ben on the telephone? 22 A. Yes, we talked on the phone. 23 Q. Did someone put you in touch with him? 24 A. Yes. 25 Q. Who was that? I don't know that name. He filled out one. Did you ever meet him in person? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 40 of 172 175 1 A. My son-in-law. 2 Q. Who was that? 3 A. Tony Judson. 4 Q. And did you call Ben or did Ben call you? 5 A. I'm not sure. 6 Q. Was it just you on the phone with him? 7 A. Yes. 8 Q. And what did you two discuss? 9 A. We discussed about applying for the loan. 10 Q. Did Mr. Okojie ask you if you had a business? 11 A. Yes. 12 Q. What did you tell him? 13 A. Yes. 14 Q. Did you tell him about Unique Pleasant & Smooth Souls? 15 A. Yes. 16 Q. Did he ask you how many employees you had? 17 A. I can't recall if he asked me that. 18 Q. Would you have told him -- what would you have told him if 19 he had asked? 20 A. Two. 21 Q. Did he ask you how much you made in the 12-month period 22 before January 31st, 2020? 23 A. I can't recall if he asked me that. 24 Q. Would you have told him you made $248,800.00 during that 25 period? I believe that I called Ben. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 41 of 172 176 1 A. No. 2 Q. Did Ben tell you he was going to fill out the loan 3 application for you? 4 A. Yes. 5 Q. Did he ask you to provide any documentation of your 6 business? 7 A. He -- he asked for some documentation. 8 Q. Like what? 9 A. I believe it was my social security number, address, 10 social security number, I believe. 11 Q. But he didn't ask you to provide any kind of tax document? 12 A. No. 13 Q. Any kind of license with the State? 14 A. No. 15 Q. Just your personal information? 16 A. Yes. 17 Q. Did you provide that to him? 18 A. Yes. 19 Q. On the phone? 20 A. Yes. 21 Q. Ms. Roper, will you pull up Government's 2B, Page 56. 22 you zoom into that middle section, Ms. Roper, the whole, all the 23 way across but just the middle row. 24 25 And I know this is very small, Ms. Anderson. personal information on this document? Can Is this your Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 42 of 172 177 1 A. That's my name. 2 Q. Is that your social security number? 3 A. Yes. 4 Q. Is that your address? 5 A. Yes. 6 Q. Is that your rental property? 7 A. Yes. 8 Q. Why did you provide him with your rental property address? 9 A. I don't know if I gave him my rental property address. 10 Q. How else would he have gotten that address? 11 A. I don't know. 12 Q. Do you see where it says $242,000.00, $242,800.00 gross 13 revenues? 14 A. Yes. 15 Q. You didn't provide him with that number? 16 A. No. 17 Q. And you did not have eight employees? 18 A. No. 19 Q. Do you see where it says eight, number of employees as of 20 January 31st, the last line visible on the screen? 21 A. Yes. 22 Q. You can take that down, Ms. Roper. 23 You see the Macon, Georgia address? Did he tell you when the application was done and had been 24 submitted? 25 A. I just assumed that it was done. I can't recall if he Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 43 of 172 178 1 just told me that it was done. I gave him the information or 2 whatever, so I can't say he called me and said it was done. 3 Q. 4 information? 5 A. 6 e-mail. 7 Q. 8 Administration? 9 A. Yes. 10 Q. What did that e-mail say? 11 A. That it was approved. 12 Q. And did you click on a link in that e-mail address, I 13 mean, in that e-mail, excuse me? 14 A. 15 know that I did get an e-mail saying that it was approved so ... 16 Q. 17 Administration Web site to sign something? 18 A. I'm not sure if I did that, no, ma'am. 19 Q. Did you meet with Special Agent Dye and Special Agent 20 Lott, Mr. Josephson and myself prior to today? 21 A. Yes. 22 Q. And did you speak with Agent Dye on the phone before that? 23 A. Yes. 24 Q. Do you remember telling Agent Dye, telling us that you did 25 sign something digitally? All right, what happened next after you gave him this He asked me to let him -- let him know when I got an Did you get an e-mail from the Small Business I'm not sure if I clicked on an e-mail, but I did let him Do you remember logging into the Small Business Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 44 of 172 179 1 A. I don't remember -- I don't remember saying that I did 2 sign it. 3 Q. Okay. 4 A. I don't remember if he gave me a password. 5 I think it was a password created. 6 password. 7 Q. 8 deposited into your bank account? 9 A. Yes. 10 Q. How much? 11 A. It was 200 and something. 12 amount. Do you remember if he gave you a password? I know that -- I'm not sure if I got the After the loan had been approved, did you get loan money 13 THE COURT: 14 THE WITNESS: I'm not sure the correct 200 and something dollars? Thousand. 15 Q. (By Ms. Stanley) 16 A. Yes. 17 Q. Ms. Roper, can you pull Government's 12E, please. 18 200-something thousand dollars? Is that your Cadence bank account there in the middle of 19 the page? 20 A. Yes. 21 Q. Do you see that deposit for $121,300.00? 22 A. Yes. 23 Q. Does that sound like the amount of money that you got from 24 the loan? 25 A. Yes, sorry, my correction. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 45 of 172 180 1 Q. 2 account? 3 A. Yes. 4 Q. Did you pay Ben any of that money? 5 A. Yes. 6 Q. How much? 7 A. I'm not sure the correct amount, but I think it was 20- 8 something thousand. 9 Q. How did you pay him? 10 A. Cashier check. 11 Q. Where? 12 A. He gave me directions of making a cashier check out to 13 some trucking company. 14 Q. You don't remember what that was called? 15 A. No, I don't recall what the name of it is. 16 Q. Can we go to Page 2, please, Ms. Roper, and zoom in on 17 that check. 18 Did you withdraw that full amount in cash from the bank I'm not sure. Is this the cashier's check you gave Ben? 19 A. Yes. 20 Q. And it's in the amount of $18,210.00? 21 A. Okay. 22 Q. Is that what it says? 23 A. Yes. 24 Q. Does that sound like what you paid Ben for his fee? 25 A. Yes, if that was on here, yes. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 46 of 172 181 1 Q. 2 this check payable to a freight company or a trucking company? 3 A. 4 requested that he wanted done so this is what I did. 5 ask no questions, no. 6 Q. 7 payment," under the memo, "leasing payment"? 8 A. Yes. 9 Q. Did he tell you to put that on the cashier's check? 10 A. I can't recall if he told me to put "leasing payment." 11 can't recall if he said that. 12 Q. Why else would you have put it on the check? 13 A. Like I said, ma'am, I can't recall if he told me to put 14 that on there. 15 16 Did it seem weird to you that he was asking you to make No, it didn't seem weird to me. This is what the man had I didn't Do you see there on the left where it says "leasing THE COURT: I She's asking you if you know of another reason why you would have done it. 17 THE WITNESS: No, I don't know of any other reason I 18 would have done it unless it was told for me to do it. 19 Q. 20 payment? 21 A. 22 I'm not sure. 23 Q. What was this check for? 24 A. To pay him. 25 Q. For what? (By Ms. Stanley) But you knew this wasn't a leasing I don't know whether it was a leasing payment or not. No, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 47 of 172 182 1 A. For doing the SBA loan for me. 2 Q. Why did you think that someone else would be able to get 3 SBA loan money for you when you had been unsuccessful the first 4 time? 5 A. 6 business at that time, and we was not able to do any work 7 because of the COVID. 8 get no -- no return or whether or not my application was 9 approved or not. 10 Because I have a business as well as other people had When I tried to do the SBA loan, I didn't So I don't know whether I had did it wrong or right, so I 11 didn't get no comment from the SBA loan whether I got it, 12 whether it was approved or not. 13 Q. Did you know this money was a business loan? 14 A. Yes. 15 Q. Did you know this money was to be used on business 16 expenses? 17 A. Yes. 18 Q. Did you know it was a loan that you had to pay back? 19 A. Yes. 20 Q. After you paid Ben his fee, what did you spend the rest of 21 the $121,000.00 on? 22 A. My business. 23 Q. Like what? 24 A. Business supplies, rent bills for the business. 25 Q. Did you spend it on personal bills? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 48 of 172 183 1 A. No. 2 Q. Did you spend it on gas money? 3 A. I may have because that's business. 4 clients. 5 Q. Do you recall if you spent any of it on car payments? 6 A. Yes. We have a business car. 7 Q. Okay. Have you been making payments on the loan? 8 A. No, not yet. 9 Q. Did you later try to apply for a third EIDL loan in the 10 name of Unique Pleasant & Smooth Souls? 11 A. 12 I didn't apply for a third loan. 13 because I didn't get no information or confirmation that I 14 had -- that I was approved, so I didn't know whether I had 15 put -- that I had did it wrong or whatever so I tried again. 16 Q. 17 I know I applied for another loan. We go out and see You said a third loan. I applied for a second one I'm sorry, I didn't mean to interrupt you. This is the second application that you personally filled 18 out? 19 A. Yes. 20 Q. And it was after you got the loan money through Ben? 21 A. I don't recall it being after I had got the money. 22 Q. Let me show you a document, Ms. Anderson. 23 if that's your personal information on that document? 24 A. Yes. 25 Q. Does this document look like the one that we just had up Can you confirm Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 49 of 172 184 1 on the screen for the loan that Ben did for you? 2 A. Yes. 3 Q. And does it say at the top one of those first lines, that 4 this was submitted in January of 2021? 5 A. Yes. 6 Q. Did you get any money from this attempt? 7 A. No. 8 Q. Why are those numbers for gross revenue and cost of goods 9 sold different from the ones on the first EIDL application that 10 you filled out? 11 A. The amount is lower. 12 Q. What are those numbers? 13 A. For the goods? 14 Q. Yes, ma'am. 15 A. $27,762.00, I believe. 16 Q. So it's different from the 38,000.00 that you put on your 17 first loan application? 18 A. Yes. 19 Q. Did you also get a PPP loan? 20 A. Yes. 21 Q. When was that? 22 A. I don't recall the date, ma'am. 23 Q. Does May or June of 2021 -- 24 A. I don't recall the date. 25 Q. Do you have any reason to believe that's wrong, May or Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 50 of 172 185 1 June of 2021? 2 A. I don't recall the date. 3 Q. How much money did you get from that loan? 4 A. I believe it was 20,000.00. 5 Q. Did you fill out and submit that application? 6 A. No, I did not. 7 Q. Who did? 8 A. My tax preparer. 9 Q. Who is that? 10 A. Steve Santos. 11 Q. Do you recall submitting your driver's license to get that 12 loan? 13 A. I'm not sure, ma'am. 14 Q. Do you recall taking a selfie to verify your identity to 15 get that loan? 16 A. Yes, I do. 17 Q. Do you know what kind of business that application said 18 you had? 19 A. No. 20 Q. Did you make $98,000.00 in 2020? 21 A. I'm not sure what I made. 22 that's what you're asking me? 23 Q. How much did you personally make? 24 A. I'm not sure what I made, ma'am. 25 Q. Was it $98,000.00? Maybe you gave it to Steve? On my -- on my personal job, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 51 of 172 186 1 A. I'm not sure. 2 Q. Does that seem way high or way -- you don't remember? 3 A. I don't remember because I worked a lot of hours. 4 know. 5 Q. Did you work as a hair stylist at all in 2020? 6 A. No. 7 Q. Do you know that that's what the tax documents submitted 8 with that application said you made? 9 A. No. 10 Q. And that's what you did? 11 A. No. 12 Q. And did you pay Steve a fee? 13 A. Yes. 14 Q. Do you remember how much? 15 A. I believe it was $2,000.00. 16 Q. And did you know that that money was a loan you had to pay 17 back? 18 A. Yes. 19 Q. What did you spend that loan money on? 20 A. On my business as well. 21 Q. Have you been making payments on that loan? 22 A. I haven't made no payments. 23 MS. STANLEY: 24 THE COURT: 25 Nothing further. Any cross-examination? CROSS-EXAMINATION I don't Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 52 of 172 187 1 BY MR. OSSICK: 2 Q. 3 Ossick. 4 Good morning. I represent Mr. Okojie. Let me ask you: My name is John Do you know who John Lehman is? 5 A. My attorney. 6 Q. And did you have a meeting with the Agent Dye and your 7 attorney and I believe Charles Bey in December of 2021? 8 A. I can't recall the date, but, yes, we did. 9 MR. OSSICK: Thank you. 10 THE COURT: Any redirect? 11 MS. STANLEY: 12 THE COURT: Any objection to this witness being excused? 13 MR. OSSICK: No. 14 MS. STANLEY: No, ma'am. 15 THE COURT: 16 THE WITNESS: 17 THE COURT: 18 THE WITNESS: 19 THE COURT: 20 MS. STANLEY: 21 Your Honor, may I approach and take those documents off 22 the witness stand. 23 THE COURT: 24 25 No, Your Honor. You're excused. I'm excused to leave? You are. Thank you. Go ahead and call your next witness. The Government calls Charles Bey. You may. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 53 of 172 188 1 CHARLES BEY, 2 having been first duly sworn, was examined and testified as 3 follows: 4 5 THE CLERK: Thank you. You may be seated and if you will please state your full name and spell your last name. 6 THE WITNESS: 7 Yes, ma'am, Charles Bey. DIRECT EXAMINATION 8 BY MS. STANLEY: 9 Q. Good morning, Mr. Bey. 10 A. Yes, ma'am. 11 Q. What area of Georgia do you live in generally? 12 A. Locust Grove. 13 Q. Where do you work? 14 A. I work at DaVita Dialysis, and I work for Southwest 15 Atlanta Nephrology and Unique Pleasant & Smooth Souls and Penny 16 Properties. 17 Q. What is Penny Properties? 18 A. Where I rehab houses. 19 Q. I want to talk to you about Unique Pleasant & Smooth 20 Souls. 21 Anderson? 22 A. Yes, ma'am. 23 Q. Are you the only two employees? 24 A. Yes, ma'am. 25 Q. How much money would you estimate that business made in We call it fix and flip. Do you operate that business with your partner, Wanda Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 54 of 172 189 1 2019? 2 A. '19, was that during the pandemic? 3 THE COURT: That was the year before. 4 THE WITNESS: Year before? If I'm not mistaken, maybe 5 40, 45, somewhere around there. 6 Q. 7 made in one year? 8 A. I'm sorry? 9 Q. What is the most money that business has ever made in one 10 year? 11 A. I think we did if I'm not mistaken no more than 60 so far. 12 Q. And did you and your wife or did your wife first apply for 13 an EIDL loan for Unique Pleasant & Smooth Souls on her own? 14 A. Yes, ma'am. 15 Q. Was that early in the pandemic? 16 A. Yes, ma'am. 17 Q. Does April of 2020 sound accurate as the date for when 18 that application was submitted? 19 A. Yes, ma'am. 20 Q. Were you a part of that process at all? 21 A. Well, I thought she could do it herself at the time, so I 22 kind of -- no, actually, no. 23 Q. Did you get any money from that loan application? 24 A. No. 25 Q. Do you know the defendant, Bernard Okojie? (By Ms. Stanley) What's the most that business has ever It was during the pandemic, yes, ma'am. But I knew it. Yes. I knew about it. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 55 of 172 190 1 A. I don't know by that name. 2 Q. Do you know someone who went by Ben? 3 A. Ben, yes, ma'am. 4 Q. Did he fill out and submit a Small Business Administration 5 loan application for you in August of 2020? 6 A. Yes, ma'am. 7 Q. Before that, had he submitted a loan application for your 8 wife -- excuse me, for your partner, Ms. Anderson? 9 A. Say that again. 10 Q. Before he filled out a SBA application for you, did he do 11 one for Wanda Anderson? 12 A. Yes. 13 Q. Did she get money from that loan? 14 A. Yes, ma'am. 15 Q. Did you ever meet Ben in person? 16 A. Yes, ma'am. 17 Q. Would you recognize him? 18 A. Yes, ma'am. 19 Q. Is he sitting in this room today? 20 A. Yes, ma'am. 21 Q. Can you point him out? 22 A. Yes, ma'am. 23 Q. Who put you in touch with Ben? 24 A. Wanda's daughter's husband, Tony. 25 Q. Is that Anthony Judson? At the table right behind me? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 56 of 172 191 1 A. Yes. 2 Q. Tony Judson? 3 A. Yes. 4 Q. Did you call Ben or did Ben call you? 5 A. I think Wanda had called him for me, if I'm not mistaken, 6 because she wanted to go through the process. 7 go through the process for the business so I think, if I'm not 8 mistaken, I think we called him. 9 Q. 10 have a call with Ben to ask about doing a loan for you? 11 A. 12 two processes going on at the same time, but I think Wanda's was 13 before mine. 14 Q. 15 LLC? 16 A. 17 yes. 18 Q. Did you tell him what kind of business it was? 19 A. Yes, yes. 20 Q. Did he ask you how many employees you had? 21 A. I don't remember. 22 Q. What would you have told him if he had asked you? 23 A. Right. 24 Q. Would you have told him that you had two employees? 25 A. Yes. Okay. She wanted us to After Wanda received her loan through him, did you I think it was almost during the same time, basically the Did Mr. Okojie know about Unique Pleasant & Smooth Souls, I had to give him that information. I think I did, yes, No, I don't think so. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 57 of 172 192 1 Q. 2 much you had made in the 12 months before January 31st, 2020? 3 A. I'm not sure. 4 Q. What would have told him if he had? 5 A. Whatever the -- whatever we had received on our taxes that 6 year, whatever we made that year. 7 Q. Would that be the 40,000.00? 8 A. Yeah, somewhere around in there. 9 Q. Not over $200,000.00? 10 A. No. 11 Q. Did you provide Ben with any other information? 12 A. I think I had to give my driver's license information, 13 social security, business information, whatever -- whatever was 14 required for the business. 15 Q. 16 business, like tax documents, business licenses? 17 A. No, I didn't have to give that, no. 18 Q. Okay. 19 loan application for you? 20 A. Yes, ma'am. 21 Q. Ms. Roper, will you please pull up Government's Exhibit 2H 22 Page 52 and again will you zoom in on that middle section all 23 the way across. 24 25 Did he ask how much money the business had made or how Did he ask you to provide any documentation of the And did Ben tell you he was going to fill out the Mr. Bey, this is a summary of the loan application that was submitted in your name. Can you look at that column and Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 58 of 172 193 1 tell us if that is your personal information? 2 A. Yes. 3 Q. Neither you or Unique Pleasant & Smooth Souls made 4 $238,000.00 in the year before January 31st, 2020; correct? 5 A. Correct. 6 Q. The business did not have six employees as is reflected on 7 that last line in the bottom; correct? 8 A. Correct. 9 Q. You can take that down, Ms. Roper. 10 the application was done and submitted? 11 A. I think -- I'm not sure. 12 Q. Let me ask you this. 13 you provided him with your information, what happened next? 14 A. 15 valid, I guess e-mail, so I guess, yeah, so I guess he had to 16 give me some type information that the application was done. 17 Q. 18 loan had been approved? 19 A. I can't remember. 20 Q. Did you ever give Ben access to your e-mail account? 21 A. Yes, ma'am. 22 Q. To your e-mail address, like you gave him your user name 23 and log-in for your e-mail account or did you just give him your 24 e-mail address? 25 A. Did Ben tell you when After you spoke to him on the phone, I was supposed to wait for I guess the information was Did you receive an e-mail from the SBA saying that your I believe it was the e-mail. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 59 of 172 194 1 Q. 2 into a Web site? 3 A. 4 it was. 5 Q. 6 anything? 7 A. No, ma'am. 8 Q. Ms. Roper, can you pull up Government's Exhibit 2H again 9 and go to Page 31, please. 10 Do you remember if he created a password for you to log I believe there was a password but I can't remember what Do you remember logging into the SBA's Web site to sign Do you remember ever seeing this document? 11 A. No. 12 Q. Can you zoom out, Ms. Roper, and go forward a couple -- I 13 think five pages. 14 document? 15 A. No, ma'am. 16 Q. After Ben completed the loan application for you, did you 17 get loan money from the SBA? 18 A. I did. 19 Q. How much? 20 A. If I'm not mistaken I got 119, 119. 21 Q. $119,000.00? 22 A. Yes. 23 Q. Did you pay Ben any of that money? 24 A. Yes, ma'am. 25 Q. How much? One more. Do you remember signing this Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 60 of 172 195 1 A. I believe it was 17,000.00. 2 Q. Was that his fee for filling out the loan application? 3 A. Yes, ma'am. 4 Q. Did you discuss that fee upfront? 5 A. I can't remember, but I thought -- I know that's what I 6 had to pay. 7 Q. 8 Okay. You can take that down, Ms. Roper. Mr. Bey, how did you pay Ben? 9 A. Cashier's check. 10 Q. Who was that made out to? 11 A. I can't remember exactly the company. 12 exactly the company offhand. 13 Q. Did Ben tell you who to make it out to? 14 A. Yes, ma'am. 15 Q. Did you, was your understanding that it was his company? 16 A. Yes. 17 Q. Ms. Roper, can you pull up Government's Exhibit 12K, 18 please. 19 the check. 20 I can't remember And if you will go to the second page and zoom in on Mr. Bey, do you recognize this check? 21 A. Yes, ma'am. 22 Q. Is that the check that you gave to Ben? 23 A. Yes. 24 Q. Is it made out to Kojie9, LLC? 25 A. Yes. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 61 of 172 196 1 Q. Where did you give him this check? 2 A. I met him and gave it to him. 3 Q. Where? 4 A. Right off of Highway 85. 5 Q. Where are you talking about? 6 A. It was right in front of a restaurant, Pleasant Hill, 7 Pleasant Hill Road. 8 Q. Like a parking lot? 9 A. Parking lot. 10 Q. Did it strike you as odd at all that he asked you to meet 11 him there? 12 A. No, not really, not to me, no. 13 Q. Do you know if he had an office? 14 A. No. 15 Q. You don't know or he did not? 16 A. Right. 17 Q. It was your understanding, was it your understanding that 18 this loan money was to be used for Unique Pleasant & Smooth 19 Souls, LLC? 20 A. Yes. 21 Q. And did you think it was strange at all that -- did you 22 believe that your wife's loan through him was also for Unique 23 Pleasant & Smooth Souls, LLC? 24 A. Yes. 25 Q. Did you know the money could only be used for business I don't know. I don't know about an office, no. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 62 of 172 197 1 expenses? 2 A. Yes. 3 Q. Do you think it was at all strange that you were together 4 able to get a total of $230,000.00 for a business that had never 5 made more than $60,000.00? 6 A. 7 think about it, to be honest with you. 8 business to be able to survive. 9 able to get, to be honest with you. 10 when we weren't able to get anything, so at that time I really 11 didn't even think about it. 12 Q. Did the loan amount seem high to you? 13 A. I mean, it was high. 14 was -- I was just thankful we got it. 15 Q. 16 remainder of the money on? 17 A. 18 cars, no jewelry or anything like that. 19 it on the business. 20 Q. What kinds of things for the business? 21 A. Bills. 22 gas, car payment, insurance, rent, Internet, just about 23 everything. 24 Q. 25 $200,000.00 into the business in 2020? At the time, I was -- we was drowning and I didn't even I just wanted the I wasn't sure how much we was If he had -- at first, like It was high, yes, definitely, but I After you paid Ben his fee, what did you spend the Just the business. I have no track record of buying no So we basically spent We have a car that's in the business name. Takes So you put that, together you and Ms. Anderson put about Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 63 of 172 198 1 A. No. We -- well, we put the money into the business but we 2 didn't put $200,000.00 into the business to pay bills. 3 Q. So do you have some of the money remaining? 4 A. Yes. 5 Q. Have you been making payments on the loan? 6 A. Not yet. 7 Q. Mr. Bey, did you also get a PPP loan? 8 A. Yes. 9 Q. When was that? 10 A. Yes, somewhere around there. 11 Q. Do you remember how much money that loan was? 12 A. I believe it was 30-something thousand, maybe 30-something 13 thousand. 14 Q. $20,000.00? 15 A. Something around there, close. 16 Q. Did you fill out and submit that application? 17 A. No. 18 Q. Who did? 19 A. An accountant, another gentleman. 20 Q. Did he also apply for a PPP loan for your wife? 21 A. Yes. 22 Q. For Ms. Anderson. 23 license and a selfie to verify your identity to get that loan? 24 A. I think so. 25 Q. Do you know what kind of business that application said Does 2021 sound accurate? Do you recall submitting your driver's I'm not sure. I think so. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 64 of 172 199 1 you had? 2 A. No. 3 Q. Did you make $98,000.00 in 2020? 4 A. How much? 5 Q. $98,000.00? 6 A. No. 7 Q. Did you work as a barber in 2020? 8 A. No. 9 Q. Did you know that's what the tax document submitted with 10 that application said that you made and what you did? 11 A. Now I do. 12 Q. Did you pay this preparer or accountant a fee? 13 A. I believe I did. 14 Q. Do you remember how much? 15 A. No. 16 Q. Did you know this PPP loan was a loan that you had to pay 17 back? 18 A. Oh, yes, definitely. 19 Q. Have you been making payments on that loan? 20 A. Not yet. 21 Q. What did you spend that money on? 22 A. I put everything into the business, nothing extravagant. 23 Everything went to the business. 24 MS. STANLEY: 25 THE COURT: Nothing further, Your Honor. Cross-examination, Mr. Ossick. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 65 of 172 200 1 CROSS-EXAMINATION 2 BY MR. OSSICK: 3 Q. Good morning, Mr. Bey. 4 A. Good morning. 5 Q. Couple of questions. 6 in December of 21 with Agents Lott and Dye? 7 A. Yes. 8 Q. Have you met Agents Lott and Dye? 9 A. Yes. 10 Q. Had you met them in December of 2021? 11 A. I believe it was around that time. 12 Q. But you had met them in person before this telephone 13 interview? 14 A. 15 we had a telephone ... 16 Q. Have you met them since then? 17 A. Yes. 18 Q. In person? 19 A. Yes. 20 Q. Talked with them? 21 A. Yes. 22 Q. Get ready for your court, talk with them? 23 A. Yes, sir. 24 Q. At that meeting, telephone conference in '21, December, 25 was an attorney on the line with you? No, not in person. Do you recall a telephone interview On the phone, I believe on the phone, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 66 of 172 201 1 A. Yes. 2 Q. And he was representing you and Ms. Anderson? 3 A. Yes. 4 Q. Did he ask them if you-all were targets? 5 A. I believe so. 6 Q. Do you recall what they said? 7 A. No. 8 Q. This other loan, this other person that helped you apply 9 for the other loan you referred to as an accountant, I believe? 10 A. Yes. 11 Q. Is his name Steve Santos? 12 A. Yes. 13 Q. How did you know him? 14 A. He had been doing my taxes. 15 MR. OSSICK: Thank you. That's all. 16 THE COURT: Any brief redirect? 17 MS. STANLEY: 18 THE COURT: 19 MS. STANLEY: 20 THE COURT: 21 THE WITNESS: 22 THE COURT: No, Your Honor. Any objection to this witness being excused? No, Your Honor. You may step down and you're excused. Thank you. Ladies and gentlemen of the jury, it's just 23 about exactly 10:30, so it's time for our mid-morning break so 24 we will break until approximately 10:45. 25 and every other break, don't discuss the case, don't make up Remember during this Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 67 of 172 202 1 your mind. 2 3 We will be in recess until 10:45. Let's rise for this jury. 4 (The jury exits the courtroom.) 5 THE COURT: Counsel, without pinning you down on the 6 exact number, approximately how many more witnesses in your case 7 in chief? 8 MR. JOSEPHSON: 9 THE COURT: 10 (Recess from 10:26 a.m. to 10:47 a.m.) 11 THE COURT: 12 (The jury enters the courtroom.) 13 THE COURT: 14 Approximately eight. We will be in recess until 10:45. Let's bring in the jury. Members of the jury, welcome back. We will continue with the Government's witnesses. 15 Mr. Josephson, call your next. 16 MR. JOSEPHSON: 17 The Government calls Katina Banks. KATINA BANKS, 18 having been first duly sworn, was examined and testified as 19 follows: 20 21 THE CLERK: Thank you. You may be seated and if you will please state your full name and spell your last name. 22 THE WITNESS: 23 Katina Banks, B-a-n-k-s. DIRECT EXAMINATION 24 BY MR. JOSEPHSON: 25 Q. Good morning, Ms. Banks. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 68 of 172 203 1 A. Good morning. 2 Q. Do you know the defendant, Bernard Okojie? 3 A. I know of him. 4 Q. How do you know of him? 5 A. I was introduced -- he was introduced to me as a financial 6 adviser. 7 Q. Who introduced him to you? 8 A. Ginell Adams. 9 Q. How do you know Ginell Adams? 10 A. She is my hair stylist. 11 Q. Have you met the defendant in person, Bernard Okojie? 12 A. In person, when I met him to give him the 15 percent. 13 Q. And when you say 15 percent, 15 percent of what? 14 A. Of the SBA loan that he prepared. 15 Q. Do you know what he looks like? 16 A. Vaguely. 17 Q. Do you see anyone in this room that looks like the man you 18 dropped the check off with? 19 THE COURT: 20 THE WITNESS: Do you need to stand up? 21 that I can recall, no. 22 Q. 23 attention -- 24 A. 25 do not recall. Yeah, because I am a little short. (By Mr. Josephson) Not So just I'm going to direct your Yeah, I figured, you know, after I seen them. I actually Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 69 of 172 204 1 Q. This is a specific question. 2 table here the man that you dropped the check off with, do you 3 know? 4 A. I don't recall. 5 THE COURT: 6 THE WITNESS: 7 him off. 8 9 Is the man seated at the He -- can I -- You can. Because the computer is kind of cutting Yes. MR. JOSEPHSON: Please let the record reflect that the witness has identified the defendant. 10 THE COURT: It will so reflect. 11 Q. (By Mr. Josephson) Ms. Banks, where do you currently 12 work? 13 A. 360care. 14 Q. What is 360care? 15 A. It's a mobile clinical service. 16 Q. And what type of service does the business provide? 17 A. Podiatry, dental, audiology and podiatry. 18 Q. Various medical services -- 19 A. Yes. 20 Q. -- sounds like. 21 A. I have a -- Princess House, I am a consultant for Princess 22 House. 23 Q. What is Princess House? 24 A. Cookware/dinnerware sales. 25 Q. Would it be accurate if someone said you sell these items Do you have a side job? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 70 of 172 205 1 on the side, a side job of some kind? 2 A. It's a part-time. 3 Q. Part-time job? 4 A. Yes. 5 Q. How much money, is that your main source of income? 6 A. No. 7 Q. How much money do you make at 360? 8 A. Right at 60. 9 Q. How much money do you make -- actually with the $60,000.00 10 that you make at 360care, do you receive a W-2 for that? 11 A. Correct. 12 Q. Does that mean that you're an employee of that business? 13 A. Correct. 14 Q. Princess House, how much money do you make doing cookware 15 and dinnerware through Princess House? 16 A. 17 it's anywhere from five to ten. 18 Q. When you say five to ten -- 19 A. Thousand. 20 Q. Five to ten thousand dollars? 21 A. Uh-huh. 22 Q. Did the defendant help you fill out and submit a SBA loan? 23 A. He did the total loan. 24 information. 25 Q. 360care is my main source of income. It varies. Okay. In the beginning it was a good bit, but now He just asked me for my I want to break that down a little bit. How did Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 71 of 172 206 1 that come about? How did he come to file and help you with an 2 SBA loan? 3 A. 4 advisor, that he have a couple of other businesses helping 5 people get a small business, recover credit, so forth. 6 introduced to him by Ginell, and she gave him my number and I 7 reached out to him and I pretty much asked him if he was helping 8 people during the pandemic, during the pandemic to get loans to 9 help small business. 10 business as, you know, being a consultant, and he asked me for 11 my information, name, date of birth, social, address. 12 it. 13 Q. 14 financial adviser; is that correct? 15 A. Correct, correct. 16 Q. Did you ever see any licenses or certifications of the 17 defendant -- 18 A. I didn't. 19 Q. -- that would show he is, in fact, a financial adviser? 20 A. I didn't. 21 Q. Was that information that Ginell just told you? 22 A. Correct. 23 Q. You mentioned that you considered Princess House your 24 business? 25 A. Well, like I said, he was introduced as a financial I was I considered Princess House my small That was You mentioned that the defendant was introduced as a 1099. I trusted Ginell's judgment. Do you receive a Form 1099? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 72 of 172 207 1 Q. 2 contractors? 3 A. Correct. 4 Q. Not business owners? 5 A. No. 6 Q. Ms. Roper, can you display Government 2D, and can we zoom 7 in on the top row, "General Company Information." 8 And is Form 1099 a form that's issued to independent Ms. Banks, is that your name next to the field "Legal 9 Name"? 10 A. Yes. 11 Q. I want to start by identifying the document which has been 12 entered into evidence. 13 loan files. 14 A. Okay. 15 Q. I'm going to be asking you some questions about what's on 16 this document. 17 "Business Full Address" field? 18 A. That was home, yes. 19 Q. And is the address 653 Little Neck Road, Apartment 2302, 20 Savannah, Georgia 31419? 21 A. Yes, it was at that time. 22 Q. Did you reside in Savannah while the application process 23 was going on? 24 A. Yes. 25 Q. Is that your e-mail, phone number on the right-hand side This is a certified copy of your SBA Is this your business address next to the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 73 of 172 208 1 there? 2 A. Yes, it is. 3 Q. 2D2, please, Ms. Roper. 4 of the loan. 5 Can we zoom in on 2D2, the amount Ms. Banks, if you could read out the number next to amount 6 in the "Loan Info" row? 7 A. $123,400.00. 8 Q. Is that the amount of money that you received from the 9 Small Business Administration? 10 A. Yes, before the 15 percent. 11 Q. And again, what is the 15 percent, the amount that you 12 paid -- 13 A. Of the total that was paid to Ben. 14 Q. Was this amount of money surprising to you? 15 A. In the beginning, yes, it was. 16 Q. How much money did you say you made from Princess House? 17 A. Five to ten. 18 Q. Five to ten thousand dollars? 19 A. Yes. 20 Q. And you got $123,400.00 from the SBA? 21 A. It was a surprise, but it was during the pandemic. 22 wasn't sure what the guidelines and all that was. 23 what the payout was really going to be. 24 Q. 25 amount was correct? I I didn't know Did you ask any questions about that, about whether the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 74 of 172 209 1 A. 2 keeping me posted of when it's to be expected and when it 3 actually was deposited. 4 Q. Did you ask him, "Hey, 123 looks too high"? 5 A. I didn't say it was too high. 6 you get that much?" 7 Q. Did you have any discussion about giving the money back? 8 A. To be honest with you, no, in the pandemic ... 9 Q. 2D55, please. 10 Industry," Line 31. 11 I did in the beginning when it first hit because he was I just said, "Wow, how did If we could scroll to the "Business/ Ms. Banks on Line 31, it says "Business Activity"? 12 A. Uh-huh. 13 Q. And what is the activity that's listed there? 14 A. It says health services. 15 Q. Do you have a health services business? 16 A. I do not. 17 Q. So that would be inaccurate? 18 A. Correct. 19 Q. Can we zoom in on Line 14, Ms. Roper. 20 that says "Gross Revenues for the 12 Months Prior to the Day of 21 the Disaster," COVID-19, in this case, January 31st, 2020. 22 much money does this form say that you made in gross revenues in 23 the year prior to the pandemic? 24 A. $246,800.00, which is definitely incorrect. 25 Q. Definitely incorrect? I'm reading Line 14 How Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 75 of 172 210 1 A. Correct. 2 Q. Did you say that you sell cookware and dinnerware as a 3 part of your Princess House? 4 A. 5 Princess House and I'm a consultant and what the items were. 6 Q. 7 sell a lot of cookware and dinnerware; correct? 8 A. 9 ... but that's extreme. 10 Q. That's a lot of pots? 11 A. Yes. 12 Q. Did you do that? 13 A. No. 14 Q. Can we zoom in on Line 33, "Number of Employees," Ms. 15 Roper. 16 Yeah. He did ask him the business name, and I told him To make $246,800.00 in gross revenue you would have to Yes. I mean, there are $150.00 or $200.00 pots, but still Ms. Banks, how many employees does your SBA application 17 represent that you employed as of January 31st, 2020? 18 A. It said seven. 19 Q. You had zero employees? 20 A. Yes. 21 Q. So seven would be inaccurate? 22 A. Yes. 23 Q. Did you tell Bernard Okojie that you had seven employees? 24 A. No. 25 Q. Did you tell him that you made $246,800.00? I had no employees. It's just me. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 76 of 172 211 1 A. Absolutely not. 2 Q. Did you tell him that you employed seven people? 3 A. No. 4 Q. What did you tell him? 5 A. I told him that I was a consultant for Princess House and 6 the type product that I did sell. 7 me nothing about employees. 8 Q. Did you give him your personal information? 9 A. Yes. 10 Q. And what type of information did you provide? 11 A. That I can recall, it was the name, of course, the 12 address, date of birth, social security number, Princess House 13 title consultant. 14 Q. 15 That was it. He didn't ask That was it. Please display Government's 12G, Ms. Roper, 12G. Ms. Banks, did you pay the defendant for completing the 16 application we just discussed? 17 A. Yes. 18 Q. Was that a percentage of the loan? 19 A. Correct. 20 Q. Do you recognize the bank statement that is excerpted on 21 Government 12G? 22 A. Yes. 23 Q. Is that your bank statement? 24 A. It is my bank statement. 25 Q. And on this bank statement, there is an entry on July the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 77 of 172 212 1 27th that says $123,300.00 with some fees was deposited into 2 your account? 3 A. Correct. 4 Q. Are these the loan proceeds? 5 A. Yes. 6 Q. You received these? 7 A. Correct. 8 Q. Can we move to 12G2? 9 the page. 10 Zoom in on the check at the top of Ms. Banks, do you recognize this check? 11 A. Yes. 12 Q. And what is the date of that check at the top right-hand 13 corner? 14 A. July 29th of 2020. 15 Q. And the amount? 16 A. $18,495.00. 17 Q. And is your name Katina L. Banks? 18 A. Correct. 19 Q. And this is your bank account? 20 A. Yes. 21 Q. Who is this check made out? 22 A. B&K Freight, LLC. 23 Q. Why did you make this check out to B&K Freight, LLC? 24 A. That's who he told me to make it out. 25 Q. Who is "he"? Who is the entity next to -- Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 78 of 172 213 1 A. Ben, that's who Ben told me to make it out to. I didn't 2 question it because he had multiple businesses. 3 and I trusted him. 4 Q. Do you know the defendant as Ben? 5 A. Ben, yes. 6 Q. Was it strange to you that you paid for loan processing 7 fees to a freight company? 8 A. 9 I knew he had multiple businesses. 10 choosing to put that funds somewhere else -- somewhere, wherever 11 he wanted it to be put. 12 Q. 13 high to you? 14 A. That is high. 15 Q. Had you ever paid a financial fee that high in your life? 16 A. No. 17 Q. Please display Government 16B. 18 let me start by asking you, have you been interviewed in this 19 case by the agents? 20 A. Correct. 21 Q. And have you provided some of the text messages between 22 you and the defendant? 23 A. Correct. 24 Q. Do you recognize this text message excerpt in Government 25 16B? It wasn't -- Like I said, it wasn't strange to me at that time because I just thought he was $18,000.00, $18,495.00 as a processing fee, does that seem If you could, Ms. Banks, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 79 of 172 214 1 A. Yes. 2 Q. Let's start at the top. 3 the text message in terms of who it is from? 4 A. "SBA Ben ATL." 5 Q. Is that how he was saved in your phone? 6 A. Yes. 7 Q. Why did you save him as "SBA Ben ATL"? 8 A. Because he had told me that he was from Atlanta and that 9 he was -- you know, he was doing the SBA, he was helping people 10 with the SBA loans. 11 Q. 12 with the SBA? 13 A. No. 14 Q. Did you just associate with him -- 15 A. Correct. 16 Q. -- because he was processing loans? 17 A. Correct. 18 Q. Could you read the text message? 19 A. "Hey beautiful sorry delayed response. 20 day for me all day. 21 have your information anymore but you can log in yourself and 22 see and I'm also positive I used sole proprietor I use to apply 23 for you. 24 account when I was doing the loan. 25 log in, put your e-mail as user name, then used this as password What does it say at the top of Did he represent or hold himself out as being affiliated Been a very busy I can't really remember because I don't Go back to the e-mail where they said create an Click on it where it says Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 80 of 172 215 1 and then 654321Ab. It should take you into your account and 2 there will be -- there will see the information you are asking 3 about." 4 Q. 5 defendant discussing how to get information about your 6 application -- 7 A. Correct. 8 Q. -- from the portal? 9 information? 10 A. 11 because it hit me after the fact that this was a lot. 12 curious to know what did this man put on my application, and 13 that's when I reached out to him and that was my question, "Do 14 you have a copy of my application?" 15 Q. Okay, and then -- 16 A. This is my -- this is the reply I got. 17 Q. From him? 18 A. To pretty much look in it, go into it myself. 19 Q. This is after you paid him $18,000.00? 20 A. Yes. 21 Q. And he told you basically "Figure it out yourself; this is 22 your information"? 23 A. Yes. 24 Q. In terms of the information he provides a password? 25 A. Correct. In general, is this a conversation between you and the What were you trying to get, what I wanted to see what exactly he put on that application I was Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 81 of 172 216 1 Q. What's the password that's listed there? 2 A. 654321Ab. 3 Q. And what does he direct you to use for the user name? 4 A. My e-mail address. 5 Q. Did you use that user name and password to log into the 6 SBA account? 7 A. 8 information to be able to get into the account. 9 to touch the account, not to touch anything in there until it 10 gets approved. 11 Q. 12 the account? 13 A. 14 type signature. 15 Q. In order to get the loan money, you had to sign something? 16 A. Correct. 17 Q. Did you read any of those documents? 18 A. No, I didn't. 19 Q. Did the defendant ever ask you for the names of other 20 people who might be good SBA loan customers? 21 A. 22 interested in a Small -- an SBA loan that have a small business, 23 yes. 24 Q. And did you make any referrals or recommend any names? 25 A. I did. Yes, because that's what he gave me. He gave me the I was told not Do you recall signing any documents when you logged into When he told me to go in, yes, I did. I did a digital He did ask me if I had anyone else that would be Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 82 of 172 217 1 Q. Who did you recommend? 2 A. My aunt, Angela Lovelady, and I did mention Kelvin 3 Fletcher. 4 Q. We talked about how you got $123,400.00 in the loan? 5 A. Uh-huh. 6 Q. Did you spend any of that money on personal expenses? 7 A. Credit cards. 8 Q. Did you use it to pay off a car? 9 A. Yes. 10 Q. And did you use it occasionally for rent money? 11 A. Yes. I paid off credit cards. 12 MR. JOSEPHSON: 13 THE COURT: No further questions, Your Honor. Cross-examination, Mr. Ossick. 14 EXAMINATION 15 BY MR. OSSICK: 16 Q. 17 with Agent Dye; is that correct? 18 A. Correct. 19 Q. And some were over the phone and some were in person? 20 A. Correct. 21 Q. When did you most recently talk with him? 22 A. I believe it was last week around pretrial kind of. 23 Q. Getting ready for? 24 A. Yes. 25 Q. Do you recall how many times you've talked with him? Ms. Banks, you indicated that you had some conversations Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 83 of 172 218 1 A. At least -- at least three total after I met with him. 2 Q. Three after you met with him? 3 A. Uh-huh. 4 Q. And you met him with at your house; is that correct? 5 A. Initially, yes. 6 Q. And that was in July of 2021? 7 A. Correct. 8 Q. And he interviewed you at that time? 9 A. Correct. 10 Q. In that meeting, do you recall him telling you that "You 11 know any loans that you were getting, that were received with 12 false statements or misrepresentations is a federal crime"? 13 A. Yes. 14 Q. Do you recall him telling you that "Right now you need to 15 think about yourself, that you may be able to help yourself"? 16 A. Yes. 17 Q. Told you he couldn't promise anything but maybe there's an 18 opportunity for you to help them out and provide things to them; 19 is that correct? 20 A. That's correct. 21 Q. And so you provided things; is that right? 22 A. That's right. 23 Q. And that's like this text that you did? 24 A. Correct. 25 Q. And you continued to talk, he continued to talk with you Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 84 of 172 219 1 about how that could help you out -- is that true -- during that 2 meeting? 3 A. Correct. 4 Q. And he told you, didn't he, that "If you are going to help 5 us, it has to be the way we say to do it; do you understand 6 that"? 7 A. I don't recall that. 8 Q. Do you recall him telling you about who you could or 9 couldn't discuss something with? 10 A. Yes. 11 Q. Did he tell you that if you didn't do it that you could 12 lose the opportunity to help yourself? 13 A. 14 was right. 15 Q. Not to help yourself? 16 A. Of course, I want to help myself, yeah. Do you recall him telling you something of that nature? I don't recall that. No, it was not -- no, I did it because I wanted to do what 17 MR. OSSICK: Okay, thank you. 18 THE COURT: Any brief redirect? 19 MR. JOSEPHSON: 20 Brief redirect, Your Honor. REDIRECT EXAMINATION 21 BY MR. JOSEPHSON: 22 Q. Ms. Banks, are you here today to tell the truth? 23 A. Yes. 24 Q. Are you here today just to say whatever you think the 25 Government wants you to hear -- let me ask that again. Are you Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 85 of 172 220 1 here today to testify to facts just because the Government wants 2 you to say something? 3 A. No. 4 Q. Has anybody from the United States Government, Agent Dye, 5 Ms. Stanley, Agent Lott has anybody ever promised you anything 6 with respect to this investigation? 7 A. No. 8 MR. JOSEPHSON: No further questions, Your Honor. 9 THE COURT: 10 MS. STANLEY: No, Your Honor. 11 MR. OSSICK: No. 12 THE COURT: Ms. Banks, you may be excused. 13 Call your next witness. 14 MS. STANLEY: Any objection to this witness being excused? 15 The Government calls Angela Lovelady. ANGELA LOVELADY, 16 having been first duly sworn, was examined and testified as 17 follows: 18 THE CLERK: Thank you. 19 MS. STANLEY: 20 THE CLERK: spell your last name. 22 THE WITNESS: Okay, my name is Angela Lovelady. L-o-v-e-l-a-d-y. 24 25 Good morning, Ms. Lovelady. If you will please state your full name and 21 23 You may be seated. DIRECT EXAMINATION BY MS. STANLEY: Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 86 of 172 221 1 Q. Ms. Lovelady, in what city and state do you live? 2 A. I live in Huntsville, Alabama. 3 Q. Where do you work? 4 A. My full time job, I work at NASA. 5 Q. And what do you do at NASA? 6 A. I am a program analyst, budget analyst at NASA. 7 Q. You work with finances? 8 A. Yes, ma'am. 9 Q. Do you also have a business? 10 A. Yes, ma'am. 11 Q. What kind of business is that? 12 A. It is a professional vocational business, coaching, event 13 coordinating, event planning and things like that, coaching. 14 Q. What's it -- go ahead, I'm sorry. 15 A. It's, like I said, coaching, event planning, event 16 coordinating, just, you know, doing things in the community to 17 help people plan events and things. Yes, ma'am. 18 THE COURT: What do you coach? 19 THE WITNESS: 20 destiny, destiny life coach. 21 Inspired By A Lovelady. 22 Q. (By Ms. Stanley) 23 A. No, ma'am. 24 Q. Do you know Bernard Okojie? 25 A. Yes, ma'am. It's people. It's a life coach, coaching The name of the business is Do you have a health services business? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 87 of 172 222 1 Q. Do you know him by another name? 2 A. Ben. 3 Q. Have you met with Ben before? 4 A. One time. 5 Q. Would you recognize him? 6 A. I would -- I would say so. 7 Q. Do you see him in this room? 8 individual sitting at the table to my left, is this the man that 9 you know as Ben? 10 A. Let me ask you this: Can I stand up? 11 THE COURT: 12 THE WITNESS: Okay, thank you. 13 MS. STANLEY: And let the record reflect that the 14 Is the Yes. Yes, ma'am. witness has identified the defendant. 15 THE COURT: It will so reflect. 16 Q. (By Ms. Stanley) How do you meet Ben, Ms. Lovelady? 17 A. My niece, she contacted me and told me about Mr. Ben's 18 services and what he was providing as far as, you know, being a 19 financial adviser, instructor, and so I met him through my 20 niece. 21 Q. Who is your niece? 22 A. Katina Banks. 23 Q. Do you know if Ben had gotten an SBA loan for her? 24 A. Yes, ma'am. 25 Q. Did Ben fill out an application for an SBA loan for you in That's how I contacted him. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 88 of 172 223 1 August of 2020? 2 A. Yes, ma'am. 3 Q. Did you speak with him on the phone around that time? 4 A. Yes, ma'am. 5 Q. Did you call him or did he call you? 6 A. I called him. 7 Q. Did Ben ask you if you had a business? 8 A. Yes, ma'am. 9 Q. What did you tell him? 10 A. Yes, ma'am. 11 Q. And what did you tell him about your business? 12 A. You know, I told him that, you know, I did coaching or 13 whatever, but we didn't really talk about the business much. 14 was mainly, you know, trying to establish that I did have a 15 business. 16 Q. Did you give him your personal information? 17 A. I did. 18 Q. Do you remember which pieces of personal information you 19 gave him? 20 A. Whew. 21 Q. Your name? 22 A. Yes. 23 Q. Social security number? 24 A. Yes. 25 Q. How about your date of birth? Of course. It Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 89 of 172 224 1 A. Date of birth, e-mail address, telephone number. 2 Q. Bank account information? 3 A. Bank account information. 4 Q. Did Mr. Okojie or Ben ask you if the business had any 5 employees? 6 A. 7 remember that conversation. 8 Q. 9 employees besides you? 10 A. No, ma'am. 11 Q. How much did that business make in the 12 months before 12 January 31st, 2020, so basically 2019? 13 A. 14 it was under $10,000.00. 15 Q. Has the business ever made more than that in a year? 16 A. No, ma'am. 17 Q. Did Mr. Okojie ask how much the business made during that 18 same time period? 19 A. 20 the income of that business and I told him it was under 10K. 21 Q. 22 application for you? 23 A. Yes, ma'am. 24 Q. Did he ask you to provide any documentation about the 25 business? I don't remember us talking about employees. I don't Does the business Inspired By A Lovelady have any It was under -- I don't know the exact amount but I know He did not ask -- he did not ask -- he just said what was Did Ben tell you that he was going to fill out the loan Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 90 of 172 225 1 A. 2 business bank account. 3 Q. Which bank account did you give him the information for? 4 A. It was a Regions Bank for the Inspired By A Lovelady 5 business. 6 Q. 7 and go to Page 71 and zoom in on that middle section, please. 8 No, ma'am, just the business bank account, that it was a Ms. Roper, will you please pull up Government's Exhibit 2I And I know the font is small, Ms. Lovelady. Looking at 9 Line 8, does it say Inspired By A Lovelady? 10 A. Yes. 11 Q. That's the name of your business? 12 A. Yes. 13 Q. Looking at Line 14 where it says gross revenues for the 12 14 months prior to the date of the disaster, January 31st, 2020, 15 what number is on that line? 16 A. $246,000.00. 17 Q. Is that how much money the business made during that time 18 period? 19 A. No, ma'am. 20 Q. And is that your address? 21 A. Yes, ma'am, it is. 22 Q. Is that your phone number? 23 A. Yes, ma'am. 24 Q. And is that your e-mail address? 25 A. Yes, ma'am. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 91 of 172 226 1 Q. 2 health services business? 3 A. That's what this says. 4 Q. And that is incorrect? 5 A. That's incorrect. 6 Q. Lastly the last line on the page, 33, how many employees 7 does it say that your business had? 8 A. Four. 9 Q. That is incorrect? 10 A. That's incorrect. 11 Q. Thank you. 12 Line 31, business activity, does that say that this is a Ms. Roper, you can take that down. Ms. Lovelady, when Ben had finished filling out the 13 application, did he tell you when it was done? 14 A. Yes. 15 Q. And what happened next in the process? 16 A. Okay, from what I can recall. 17 when he, you know, replied and said that "The information is in, 18 you can expect" -- well, I think when the information was in, I 19 had to, the document came, the promissory note, I guess you 20 could call it, it came where I would agree to pay for the, you 21 know, borrow the money, and I did sign that I would borrow the 22 money. 23 Q. 24 into a Web site? 25 A. When the information -- Do you remember if Ben created a password for you to log Yes, ma'am, I believe -- yes, ma'am. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 92 of 172 227 1 Q. Is that how you logged into the SBA Web site to sign the 2 promissory note? 3 A. Yes, ma'am. 4 Q. Did you ultimately get loan money from the SBA? 5 A. Yes, ma'am. 6 Q. How much? 7 A. 123,000.00. 8 Q. Was that deposited into your Regions Bank account? 9 A. Yes, ma'am. 10 Q. Did you pay Ben any of that money? 11 A. Yes, ma'am. 12 Q. How much? 13 A. It was around 18, it was more than 18,000.00. 14 18,243.00 or something like that, 18,000.00. 15 Q. Was that his fee for filling out the loan application? 16 A. Yes, ma'am. 17 Q. Did he tell you that it was a percentage of the loan 18 amount? 19 A. Yes, ma'am. 20 Q. And did he tell you what that percentage was upfront? 21 A. Yes, ma'am, I knew it upfront, yes, ma'am. 22 Q. Did that seem high? 23 A. I never -- I never had, you know, asked for services, you 24 know, before, so I thought that that was, you know -- that was 25 the fee and I -- you know, I agreed to pay the fee. Maybe Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 93 of 172 228 1 Q. 2 had never made more than $10,000.00? 3 A. 4 knew he knew more than me. 5 allowances, the special provisions and things like that, so I 6 actually thought that that was like the maximum amount that I 7 could borrow, so I agreed to pay the maximum amount to borrow. 8 That's, you know, so that's -- that's where I was. 9 thought that was the maximum amount that I could borrow. 10 Q. 11 and go to Page 2. 12 Did that loan amount seem high to you for a business that Well, I didn't know -- I paid for his services because I He knew, you know, maybe the You know, I Ms. Roper, will you please put Government's Exhibit 12L Ms. Lovelady, how did you pay Ben for his fee? 13 A. It was a cashier's check. 14 Q. Is this that check? 15 A. Yes, ma'am. 16 Q. Who is it made out to? 17 A. It is made out to B&K Freight, LLC. 18 Q. Did you know what that business was? 19 A. No, ma'am. 20 know. 21 make the check out to?" 22 did. 23 Q. 24 box is under the check number at the top? 25 A. It was -- you know, it was his business, you Like I said, I -- that's what he -- I asked, "Who do I That's what he said so that's what I Let me direct your attention, do you see where that red Yes, ma'am. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 94 of 172 229 1 Q. What does that say after your name? 2 A. "Truck leasing." 3 Q. Did you put that on the cashier's check? 4 A. Yes, ma'am. 5 Q. Did he tell you to do that? 6 A. Yes, ma'am. 7 Q. Did that seem strange to you? 8 A. No, ma'am. 9 Q. You knew this check wasn't for truck leasing? 10 A. Yes, ma'am. 11 do, so I thought that was the -- since he was a financial 12 wizard, if I may say that, I thought that that's what he wanted 13 this money to go, that's how he wanted it categorized for his, 14 you know -- where he wanted the check to go. 15 Q. Where did you meet him to give him this check? 16 A. I met him in -- in Tennessee. 17 Q. About how far is that from your home? 18 A. It's probably about hour and a half maybe or so. 19 Q. Where did you meet him in Chattanooga? 20 A. It was like on the main street, Broad Street, so it's kind 21 of like the Chattanooga hotel. 22 place to meet him that was, you know, that was easy to find. 23 Q. Did you know where he was living at the time? 24 A. I was told he lived in Atlanta. 25 Q. Did it seem strange to you -- did he -- let me back up. I mean, I didn't -- I did what he asked me to That's what I ... Chattanooga, Tennessee. I was just trying to find a Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 95 of 172 230 1 Did he ask to meet in Chattanooga or how did y'all decide 2 to meet in Chattanooga? 3 A. 4 going to be en route stopping at this place. 5 would be -- that would be fair to get a halfway point especially 6 since I was already, you know, going to be out, so I did choose 7 the place. 8 Q. Where did y'all meet in Chattanooga? 9 A. It was -- 10 Q. What establishment were you at? 11 A. It was the Chattanooga hotel. 12 name, but it was the main hotel in that area on Broad Street. 13 Q. Do you go into the hotel? 14 A. No, ma'am. 15 Q. You met in the parking lot? 16 A. Yes, ma'am, basically. 17 Q. Ms. Roper, will you please pull up Government's 16C and go 18 to Page 6. 19 No. I asked could I meet him in Chattanooga because I was So I thought that I can't remember the exact Ms. Lovelady, did you provide the Government with some 20 text messages between you and Ben? 21 A. Yes, ma'am. 22 Q. Are these those text messages? 23 A. Yes, ma'am. 24 Q. At the top where it says "SBA loan officer," is that how 25 you identified Ben in your phone? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 96 of 172 231 1 A. 2 was an SBA loan that I was trying to acquire, so I wanted to 3 make sure that I knew that that was -- that conversation. 4 Q. 5 Administration? 6 A. He did not. 7 Q. Did he tell you that he had a financial advisory company? 8 A. He did not tell me, but that's what I was told, that he 9 was, you know, a financial adviser. 10 Q. That's what your niece told you? 11 A. Yes, ma'am. 12 Q. Did he ever provide you with any kind of licenses or any 13 other indication of a financial business? 14 A. No, ma'am. 15 Q. Let me direct your attention, Ms. Lovelady, to that text 16 at the bottom of the page. 17 That's how I identified him in my phone because I knew it Did he tell you that he worked for the Small Business I know it's kind of small. Do you see where it says end of the sentence "fine," can 18 you read that next line for me, please? 19 A. "Cashier check should be B&K Freight, LLC." 20 Q. What about the text below that? 21 A. "If they ask purposes just tell them for truck leasing." 22 Q. Who is sending those text messages? 23 A. Ben. 24 Q. And did you respond to that? 25 A. "Okay, will do, thanks." Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 97 of 172 232 1 Q. 2 cashier's check that you gave to Ben? 3 A. Yes, ma'am. 4 Q. You can take that down, Ms. Roper. 5 And was this the discussion of how to address the Ms. Lovelady, did you know that this money was a business 6 loan? 7 A. Yes, ma'am. 8 Q. And did you know that the money was to be used on business 9 expenses? 10 A. Yes, ma'am. 11 Q. Did you know this money was a loan that you had to pay 12 back? 13 A. Yes, ma'am. 14 Q. After you paid Ben his fee, what did you spend the rest of 15 the loan money on? 16 A. 17 and materials and some equipment for the business. 18 company vehicle. 19 Q. 20 remember? 21 A. 22 cost. 23 Q. And did you treat some of the money as salary? 24 A. Yes -- I would say, yes, ma'am, because I used that to 25 survive during the pandemic to help support my family. I made payments to the SBA. Bought, of course, supplies I bought a About how much did you spend on that vehicle, do you It was around 40, about 45, 46K is how much the vehicle Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 98 of 172 233 1 MS. STANLEY: No further questions, Your Honor. 2 THE COURT: Cross-examination? 3 MR. OSSICK: No questions. 4 THE COURT: Any objection to this witness being excused? 5 MS. STANLEY: 6 THE COURT: 7 THE WITNESS: 8 THE COURT: 9 MS. STANLEY: No, ma'am. You may step down. Thank you. Call your next witness. 10 The Government calls Princewill Moneme. PRINCEWILL MONEME, 11 having been first duly sworn, was examined and testified as 12 follows: 13 THE CLERK: Thank you. 14 SPEAKER: 15 THE COURT: Continue, counsel. 16 THE CLERK: You may be seated. 17 And, sir, if you will please state your full name and Your Honor, I just wanted to note this. 18 spell your last name. 19 THE WITNESS: 20 You may be seated. Princewill Moneme. M-o-n-e-m-e, my last name. 21 DIRECT EXAMINATION 22 BY MS. STANLEY: 23 Q. Where do you live? 24 A. I live at 7545 Tyler Road, Jonesboro, Georgia. 25 Q. Can I ask you to lean forward a little closer to the mike Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 99 of 172 234 1 so we can all hear you and speak up as best you can. 2 What do you do for a living, Mr. Moneme? 3 A. Transportation. I drive Uber. 4 I'm a truck driver as well. 5 Q. Do you know the defendant, Bernard Okojie? 6 A. I've met him before. 7 Q. Would you recognize him? 8 A. Yes. 9 Q. Do you see him in the room this morning? 10 A. Yes. 11 Q. Can you identify him, where he is? 12 A. Right there. 13 MS. STANLEY: 14 has identified the defendant. 15 THE COURT: I drive Lyft. Thank you. I drive -- Let the record reflect that the witness It will so reflect. 16 Q. (By Ms. Stanley) How did you meet Mr. Okojie? 17 A. A friend of mine referred him to me. 18 Q. Why did he refer you to him? 19 A. I met him, he referred me to him prior to when I was 20 looking for a facilitator. 21 Q. A what? 22 A. A credit facilitator like a loan. 23 Q. A loan? 24 A. Yes, ma'am. 25 Q. Did he help you with your credit in any way, with your Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 100 of 172 235 1 credit score? 2 A. My credit score? 3 Q. Yes. 4 A. No. 5 Q. Did Mr. Okojie apply for an SBA loan for you? 6 A. Yes, he did. 7 Q. In July 2020? 8 A. I can't be exact with the date but in 2020. 9 Q. And a mutual friend put you in touch with him; correct? 10 A. My friend that referred him to him, to Mr. Ben? 11 Q. Yeah. 12 friend connected the two of you. 13 A. Yes, ma'am. 14 Q. And were you interested in getting an SBA loan? 15 tell your mutual friend that? 16 A. No. 17 Q. Your friend mentioned that he was doing SBA loans? 18 A. He didn't mention it was an SBA. 19 for a credit facility or a loan because I had an issue, so in 20 the course of discussion with my friend, he said, oh, he knows 21 one Ben that can help me to get a loan, so he give me his -- his 22 contact. 23 Q. Did you call him? 24 A. I did call him. 25 Q. And what did he tell you during that phone call? Is that what happened? I believe you said a mutual Did you I told him I was looking Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 101 of 172 236 1 A. 2 to assist with the loan application or to get a loan, so what 3 are the requirements?" 4 was going to send me the requirements and that was the 5 conversation we had. 6 Q. Did he ask you if you had a business? 7 A. No. 8 Q. Do you have a business? 9 A. I drive for myself, and I have a 1099, so I'm an 10 independent contractor. 11 Q. Do you have any employees? 12 A. No. 13 Q. So he didn't ask you if you had any employees? 14 A. No, he just send me a template on WhatsApp on what it was 15 I should give him, which includes just my name, phone number, 16 address, my account details, my e-mail. 17 Q. 18 and go to Page 2. 19 When I called him, I said, "My friend referred me to you That is what I asked him so he said he That was all. Ms. Roper, can you please pull up Government's Exhibit 16A Mr. Moneme, you mentioned that -- let me back up. Can you 20 identify this? 21 A. Yes. 22 Q. What is this? 23 A. So this was the -- the -- like the WhatsApp conversation 24 between the two of us after I called him. 25 requirements," so he said he's going to send it to me so he I said, "What are the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 102 of 172 237 1 sends the things needed to me, which include my name, address, 2 county where I live, date of birth, my basic information, so I 3 sent it to him. 4 Q. And was this the only information you provided to him? 5 A. Perfect. 6 Q. He didn't ask you about how much money you had made? 7 A. No. 8 Q. After this, did he fill out a loan application for you? 9 A. Whatever he did afterwards it was not privileged to me 10 because all he asked me, I asked him what are the requirements. 11 He sent this and this was my response to it and that was the 12 only thing I know of behind that. 13 Q. Did you receive an SBA loan? 14 A. I received a loan. 15 know the source but it was credited to my account. 16 Q. Do you know where that loan was from? 17 A. Yes. 18 Q. Was it from the Small Business Administration? 19 A. Yes, ma'am. 20 Q. Did you give Mr. Okojie access to your e-mail account? 21 A. Yes. 22 details so that he can be able to follow up with whatever it is, 23 the requirements are, because I drive most of the time. 24 be able to check real time online on my phone so I gave him 25 everything that he needed. Just after this conversation, that was it. At the time I received it, I didn't Because after I did, so he asked for my -- my log-in I can't Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 103 of 172 238 1 Q. 2 access those? 3 A. Yes. 4 Q. Ms. Roper, can you please pull up Government's Exhibit 2C 5 and go to Page 56. 6 the way across, please. 7 So if the SBA sent you e-mails, would he have been able to Will you zoom in on that middle section all Mr. Moneme, looking at the top of this section, Line 8 8 where it says "Business Legal Name," is that your name? 9 A. That was my name. 10 Q. Line Number 10, is that your social security number? 11 A. Yes, ma'am. 12 Q. Line Number 14 where it says "Gross Revenues for the 13 12-Month Prior to the Date of the Disaster, January 31st, 2020," 14 do you see that number? 15 A. Yes. 16 Q. What number is that? 17 A. $234,000.00. 18 Q. Did you make that much money in that period? 19 A. No. 20 Q. Did you tell Mr. Okojie you made that much money? 21 A. No. 22 Q. Is that your address, looking a little further down on the 23 page, in Jonesboro? 24 A. Yes, ma'am. 25 Q. Is that your telephone number? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 104 of 172 239 1 A. Yes, ma'am. 2 Q. Is that your e-mail address? 3 A. Yes, ma'am. 4 Q. Looking at the last line on the page, Number 3, "Number of 5 Employees as of January 31st of 2020," what number is in that 6 line? 7 A. Four. 8 Q. And you previously stated you don't have any employees; 9 correct? 10 A. Yes. 11 Q. You can take that down, Ms. Roper. 12 So you did not sign any documents to get this loan? 13 A. I did not. 14 Q. Is that correct? 15 A. I did not. 16 Q. Was that loan money from the SBA deposited into your bank 17 account? 18 A. Yes. 19 Q. Is that a Bank of America bank account? 20 A. Yes, ma'am. 21 Q. Did you pay Ben any of that money? 22 A. Yeah. 23 Q. Did you negotiate that fee? 24 A. Yeah, because I -- when he only told me about the fee, I 25 was like "20 percent is a whole lot because this is a loan I'm He took 12 percent of the -- of the amount. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 105 of 172 240 1 applying for and I have to pay it," so I told him no, so had to 2 kind of back and forth because he presented himself as "This is 3 what I do for a living," so I said okay, and we arrive at 12 4 percent. 5 Q. He initially asked you for 20 percent? 6 A. Yes, ma'am. 7 Q. How did you pay him? 8 A. When the money got credited to the account, we went to the 9 bank together so I got a cashier's check from the bank and gave 10 it to him. 11 Q. Did he go into the bank with you? 12 A. No. 13 check from the cashier in the bank. 14 premises. 15 check. 16 Q. Where was the bank? 17 A. Somewhere in Riverdale. 18 Q. In Georgia? 19 A. Yes, ma'am. 20 Q. Ms. Roper, will you please pull up Government's Exhibit 21 12F and go to the second page of that document. 22 in on the check at the bottom. 23 He was in the parking lot but I got the cashier's I came out of the banking I met him in the parking lot and I gave him the Will you zoom Is this the check that you gave Ben? 24 A. I didn't have a clear look at the check, so I can't be 25 able to say if it is yes or no. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 106 of 172 241 1 Q. Let me ask you this: 2 you see where it says "Remitter Purchased By"? 3 A. Do what? 4 Q. Can you read this, please? 5 A. "Remitter Purchased by Princewill Moneme." 6 Q. And this check is from Bank of America; is that correct? 7 A. Yes, ma'am. 8 Q. That's where you went to check get the cashier's check? 9 A. Yes. 10 Q. And what's the amount of this check? 11 A. $14,040.00. 12 Q. Did Mr. Okojie tell you who to make this check out to? 13 A. He gave me his company name. 14 Q. Is that what's reflected on this check? 15 A. Yes, ma'am. 16 Q. What's the name of that company? 17 A. B&K Freight, LLC. 18 Q. Did you think it was odd that you were paying this fee for 19 a financial service to a freight company? 20 A. No. 21 Q. Do you know what a freight company is? 22 A. No. 23 Q. Did you ask him any questions about what this business 24 was? 25 A. No. I know it's a little unclear, but do Say that again. He -- he just made himself look like "This is my Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 107 of 172 242 1 business and this is the business name," so I don't need to 2 start asking him what is the business for. 3 Q. Mr. Moneme, did you know that this was a business loan? 4 A. No. 5 My name is Princewill Moneme, and when I met him for this loan, 6 I asked for a personal loan with my name and my social security 7 number. 8 Q. Did you know that it was a loan that you had to pay back? 9 A. I apply for a loan to pay back, so I assumed that was a 10 loan to pay back and I've been paying my money. 11 12 I applied for a personal loan with my personal name. So that was all I know about it. MS. STANLEY: You can take that down, Ms. Roper. Nothing further. 13 THE COURT: Cross-examination. 14 CROSS-EXAMINATION 15 BY MR. OSSICK: 16 Q. Do you know Mrs. Okojie? 17 A. Mr. Okojie or Mrs. Okojie? 18 Q. Mrs., his wife. 19 A. I can't recognize her. 20 Q. You can't remember if you know her? 21 A. I can't recognize if I see her. 22 Q. You haven't seen her recently that you know of, then? 23 A. I haven't seen her recently. 24 Q. How many times have you talked with Agent Dye, FBI Agent 25 Dye? Have you ever talked with him? Let me start there, I Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 108 of 172 243 1 guess. 2 A. 3 year. 4 Q. So you've only had the one conversation with him? 5 A. No. 6 been subpoenaed to come and testify for this. 7 Q. And when was that? 8 A. I can't be exact with dates, but it's like two or three, 9 four weeks, two or three weeks ago. 10 Q. 11 telephone conversation; is that correct? 12 A. Yes, sir. 13 Q. Does November the 2nd of 2022 sound about right for when 14 that took place? 15 A. I can't be exact with the date. 16 Q. You just don't know? 17 A. I can't be exact the date I had the conversation with him. 18 Q. Well, do you recall in that Agent Dye asking you, "Did you 19 make anywhere near $234,000.00 in the year 2019?" 20 answering it and telling him most likely? 21 A. No. 22 Q. You didn't do that? 23 A. I can't recall. He called me sometime last year. I spoke with him last Then he was the one that called me again that I've Now the conversation, the first one you had with him was a 24 MR. OSSICK: Okay, thank you. That's all. 25 THE COURT: Any brief redirect? Do you recall Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 109 of 172 244 1 REDIRECT EXAMINATION 2 BY MS. STANLEY: 3 Q. 4 of how much money you did make in the 2019 period? 5 A. Did I do what? 6 Q. How much money did you make in 2019? 7 estimate? 8 A. I can't recall. 9 Q. Was it more than $200,000.00? 10 A. No. Briefly, Your Honor. 11 MS. STANLEY: 12 THE COURT: 13 MS. STANLEY: 14 THE COURT: 15 THE WITNESS: 16 THE COURT: 17 18 Mr. Moneme, do you have any estimate Do you have an Nothing further. Any objection to this witness being excused? No, Your Honor. Sir, you may step down and you're excused. Okay. Yes. Thank you, ma'am. All right, counsel, call your next witness. MS. STANLEY: 19 The Government calls Rita Addo-Minta. RITA ADDO-MINTA, 20 having been first duly sworn, was examined and testified as 21 follows: 22 23 24 25 THE CLERK: Thank you. You may be seated and if you will please state your full name and spell your last name. THE WITNESS: M-i-n-t-a. Rita Addo-Minta, last name A-d-d-o hyphen Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 110 of 172 245 1 DIRECT EXAMINATION 2 BY MS. STANLEY: 3 Q. Good morning, Ms. Addo-Minta. 4 A. Good morning. 5 Q. Where do you live? 6 A. 125 Brush Hollow Court, Fayetteville, Georgia. 7 Q. Where do you work? 8 A. Little Angels Academy and New Beginnings Academy. 9 Q. What are they? 10 A. They are both in Riverdale, Georgia. 11 Q. And what are they? 12 A. I have childcare centers. 13 Q. Do you know the defendant, Bernard Okojie? 14 A. Yes, ma'am. 15 Q. How did you meet him? 16 A. I met him at my former business in the mall, Southlake 17 Mall. 18 Q. What was that former business? 19 A. It was a line of cosmetics. 20 Q. So did you have a store at the mall? 21 A. Yes, ma'am. 22 Q. Did he stop by that store? 23 A. Yes, ma'am. 24 Q. Were you romantically involved with the defendant? 25 A. Yes, ma'am. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 111 of 172 246 1 Q. When was that? 2 A. About two years ago. 3 Q. 2021? 4 A. Around there. 5 Q. What about in 2020? 6 A. 2020? 7 Q. Are you involved with credit boosting? 8 A. No, ma'am. 9 Q. What is that, do you know what that is? 10 A. Credit boosting? 11 Q. Or credit repair. 12 A. Credit repair? 13 Q. Do you know what that is? 14 A. I know credit repair but ... 15 Q. You're not personally involved in doing credit repair? 16 A. No, ma'am. 17 Q. Do you know whether the defendant, Mr. Okojie, was 18 involved in credit repair? 19 A. No, ma'am. 20 Q. He was not or you don't know? 21 A. I don't know. 22 repair. 23 Q. Do you know a man named Brandon Richardson? 24 A. Yes, ma'am. 25 Q. How do you know him? Yeah, it was around 2020, around there. No. I don't know if he was involved in credit Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 112 of 172 247 1 A. Brandon does credit repair. 2 Q. And do you know what the purpose of credit repair is? 3 A. It's to fix your credit. 4 Q. Is that so that you can borrow more money? 5 A. Yeah. 6 Q. To increase your credit score? 7 A. It's to increase your credit score. 8 Q. Did you introduce Mr. Okojie to Brandon Richardson? 9 A. Yes, ma'am. 10 Q. How did you introduce them? 11 A. Mr. Okojie took Brandon's card -- Mr. Okojie took -- tried 12 to call Brandon. 13 Q. So you gave Mr. Okojie Brandon's card? 14 A. Not physically give him the card but he took the card to 15 call him. 16 Q. 17 number? 18 A. I don't understand that statement. 19 Q. Let me back up. 20 connected Mr. Okojie and Brandon Richardson; is that accurate? 21 A. Yes. 22 Q. How did you do that? 23 A. He took his business card and he called him. 24 Q. He took his business card from you? 25 A. Yes. So did you give Mr. Okojie Brandon Richardson's phone So you testified that you introduced, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 113 of 172 248 1 Q. And why did you give Mr. Okojie his business card? 2 A. He was looking to -- someone to repair credit, so that's 3 how come I give it to him. 4 Q. You knew that Mr. Richardson did credit repair? 5 A. Yes, that's his business. 6 Q. Did you ever talk about SBA loans with Brandon Richardson? 7 A. Brandon Richardson? 8 Q. Did you know that he was filling out SBA loan applications 9 for other people? 10 A. No. 11 Q. You did not know that? 12 A. No, ma'am. 13 Q. So what was the substance, what was your conversation with 14 him about SBA loans? 15 A. 16 said yes and he said he was also. 17 Q. That was it? 18 A. Yes. 19 Q. Where did that conversation take place? 20 A. We spoke on the phone. 21 Q. Do you remember when that was? 22 A. I don't recall. 23 Q. Was it 2020? 24 A. I don't remember. 25 Q. Was it after COVID-19 had started? Yes. He asked me if I was going to apply for my business, and I That was it. Does that sound accurate? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 114 of 172 249 1 A. It was after COVID-19 started. 2 Q. Did Mr. Richardson ever come to your house? 3 A. Yes, he did. 4 Q. And about how many times? 5 A. One time for barbecue. 6 Q. Is that when you gave him, is that when you had the 7 conversation about SBA loans? 8 A. No. 9 Q. That was on the phone? 10 A. That was on the phone. 11 Q. Later, at a later time? 12 A. I don't recall. 13 Q. You said that you were going to apply for SBA loans for 14 your businesses? 15 A. Yes, ma'am. 16 Q. Did you apply for SBA loans for your businesses? 17 A. Yes, ma'am. 18 Q. How many loans did you apply for? 19 A. One for each of my business. 20 Q. So two? 21 A. For my -- for my -- for all my businesses I had, I have. 22 Q. Do you have more than two businesses? 23 A. I have a cosmetic line also. 24 Q. Okay. 25 A. That's it. Is there anything else? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 115 of 172 250 1 Q. So you applied for three SBA loans? 2 A. Yes. 3 Q. And did you receive money from those loans? 4 A. Yes. 5 Q. About how much? 6 A. I don't recall. 7 Q. More than a hundred thousand dollars? 8 A. For my -- for my day care, yes. 9 Q. Total, would it be more than $500,000.00? 10 A. No. 11 Q. It was somewhere in between 100 thousand and 500 thousand 12 dollars total? 13 A. Yes. 14 Q. Did you ever talk about SBA loans with Bernard Okojie? 15 A. No. 16 Q. Never? 17 A. Never. 18 Q. Did you know that he was preparing SBA loans? 19 A. Never. 20 Q. So neither Brandon or Mr. Okojie filled out an SBA loan 21 application for you? 22 A. No, ma'am. 23 Q. Did anyone else help you with your loan application? 24 A. No, ma'am. 25 MS. STANLEY: One moment, Your Honor. Nothing further, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 116 of 172 251 1 Your Honor. 2 THE COURT: Cross-examination, Mr. Ossick. 3 MR. OSSICK: None. 4 THE COURT: Any objection to this witness being excused? 5 MS. STANLEY: 6 THE COURT: 7 THE WITNESS: 8 THE COURT: No, Your Honor. Ma'am, you may step down and be excused. Thank you. And ladies and gentlemen of the jury, it is 9 just about noon. So it's time for us to break for lunch. So we 10 will be on our lunch break from 12:00 until 1:15, so be in your 11 jury room in time for us to start promptly at 1:15. 12 Remember as we go out into the larger world, don't talk 13 about the case, don't make up your mind, don't do any research, 14 don't consume any media about the case. 15 With that, let's rise for the jury. 16 (The jury exits the courtroom.) 17 THE COURT: 18 (Recess from 11:56 a.m. to a 1:24 p.m.) 19 THE COURT: Counsel, we will be in recess until 1:15. Before we bring the jury in, I want to go on 20 the record and explain that, as we started to get back in 21 session after the lunch break, there's been some sort of a power 22 problem here. 23 systems go? 24 25 And Ms. Sharp, what does it affect as far as your THE CLERK: Judge, I don't believe -- it is not back on. I'm running on battery power. This system is running through a Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 117 of 172 252 1 hard power on the third floor, but I don't believe the 2 Government's table has power nor Defense nor the law clerks' 3 table or the jury box. 4 in here unless you wanted to test and see if we can display -- 5 THE COURT: So displaying evidence might be an issue We have a courtroom on the third floor that 6 has a jury box in it. It's going to be an effort for all of you 7 to take everything up there and I assume we will have the 8 ability to do all the electronics that we need up there. 9 THE CLERK: We should. 10 THE COURT: Including show the parties, they will be 11 able to show electronically their evidence? 12 THE CLERK: Yes, Your Honor. 13 THE COURT: We will have to do that, at least for this 14 session, from now until our afternoon break. 15 they have no idea what causes it. 16 before. 17 third floor. 18 They apparently We've never had it happen And we will have to just change courtrooms up to the As far as the jury room, we can use the visiting judge's 19 chambers sort of like we did for our large trial. 20 do recess or ask them to step out, we will escort them there. 21 There's restrooms and space and so forth in that room, and 22 meanwhile our IT people, Jeff, are you able to detect? 23 24 25 MR. MORGAN: And when we I don't see any breakers so I'm going to start at the source and work my way back. THE COURT: Let's bring in the jury. Counsel, any Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 118 of 172 253 1 objection to using the other courtroom? 2 MR. JOSEPHSON: No, Your Honor. 3 MR. OSSICK: No. 4 THE COURT: Let's bring in the jury. 5 (The jury enters the courtroom.) 6 THE COURT: Members of the jury, welcome back. While we 7 were at lunch, we had a systems failure in the courtroom 8 electronically, and as a result there are certain whole panels 9 of electricity that are not working. 10 waiting while the IT people and the electrical experts try to 11 fix it, we do have a smaller courtroom available up on the third 12 floor that will accommodate everybody and allows what we need to 13 do while they try to fix whatever happened in this courtroom. Rather than keep you 14 So in just a moment we're going to take a break just to 15 reposition ourselves and so the marshal will take you back into 16 your break room just very briefly. 17 Sharp, is it coming up? All of our exhibits -- Ms. 18 THE CLERK: Your Honor, I don't believe so. 19 THE COURT: Hope springs eternal. We're going to take 20 all of our exhibits and so forth up to the third floor and we 21 will proceed trying the case. 22 instructions and other instructions that I've given you will, of 23 course, apply. 24 25 All of the preliminary The only thing that is changing is we're going to continue with the trial in a smaller courtroom on the third Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 119 of 172 254 1 floor. 2 The good news for you is you will have a larger jury 3 room because we will set you up in a larger facility up there if 4 we're still trying the case when we come to our next break, and 5 as I say, if we do get the electrical panels repaired down here, 6 we will repair back here because it is a larger courtroom. 7 So all of the previous admonitions still apply and, 8 marshal, when we break in just a moment, if you will get them 9 comfortable in the jury room and then we will take them back up 10 and you will get a tour of more of our courtrooms. 11 All right, let's rise for the jury. 12 (The jury exits the courtroom.) 13 (Recess from 1:30 p.m. to 2:05 p.m.) 14 THE COURT: 15 Counsel, for the United States, are you situated 16 properly to proceed? 17 18 All right, let's bring in the jury. MR. JOSEPHSON: We are, Your Honor. We do have a stipulation we would like to read into the record at this time. 19 THE COURT: When the jury comes in, we will start there, 20 and counsel for the Defense, are you situated properly to 21 proceed? 22 MR. OSSICK: Fine, Your Honor, thank you. 23 THE COURT: All right, my law clerk is fine. 24 25 We had the EMT's come out but she's going to stay in chambers with Lori. (The jury enters the courtroom.) Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 120 of 172 255 1 THE COURT: All right, welcome back, members of the 2 jury. 3 everything we need and the parties are ready to proceed. 4 call your next witness. 5 MR. JOSEPHSON: 6 As I said, it's a little smaller setting but it has So Your Honor, at this time we would like to read a stipulation between the parties into evidence. 7 THE COURT: Proceed. 8 Ladies and gentlemen, at times the parties can agree on 9 certain facts. The parties in this case, both the Defense and 10 the Government, have agreed that certain facts are true. 11 facts are stated in what's called a stipulation, which Mr. 12 Josephson is about to read aloud to you. 13 facts as set forth in the stipulation as proven in the case. 14 Proceed. 15 MR. JOSEPHSON: 16 Government Exhibit 20. 17 Those You may accept those Following stipulation is marked as It reads as follows. PPP Round 3 applications, applications submitted after 18 January the 11th, 2021 were received through the Summit 19 platform, a cloud-based platform, utilizing AWS gov cloud 20 servers located in Oregon. 21 initial screen of the loan applications and sent the loan 22 details to Etran servers, which are in Sterling, Virginia. 23 Etran conducts additional validation and, if appropriate, the 24 application was processed into an SBA loan, creating a loan 25 number. The Summit platform performed an The Etran server would transmit back to the Summit Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 121 of 172 256 1 platform underwriting results for Summit to transmit the loan 2 number or other decision back to the lender. 3 received the SBA loan number, the lender processed the closing 4 loan documents, and PPP lender disbursed the funds to the 5 borrower. 6 SBA Etran system in Sterling, Virginia. 7 PPP processing to the lender through the FMS system to the 8 Treasury. 9 Virginia. 10 Once the lender PPP lenders submitted disbursement details into the Tran transmitted the The primary server for FMS system was in Sterling, That is the stipulation. It is signed by myself, 11 Jennifer Stanley, my cocounsel in the case, as well the 12 defendant and his attorney. 13 THE COURT: 14 stipulation accurately read? 15 MR. OSSICK: Yes. 16 THE COURT: With that, call your next witness. 17 MR. JOSEPHSON: 18 All right, and Mr. Ossick, was that The Government calls Maria Pagan, staff operation specialist for the FBI. 19 MARIA PAGAN, 20 having been first duly sworn, was examined and testified as 21 follows: 22 THE CLERK: Thank you. You may be seated. And if you 23 will please state your full name, spell your last, state your 24 occupation and your business address. 25 THE WITNESS: Maria Pagan, last name, P-a-g-a-n. I am a Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 122 of 172 257 1 tactical specialist with the FBI. 2 DIRECT EXAMINATION 3 BY MR. JOSEPHSON: 4 Q. 5 responsibilities as a staff operations specialist with the FBI? 6 A. 7 of investigations. 8 Q. Have you conducted a toll analysis in this case? 9 A. Yes, I have. 10 Q. What is a toll analysis, generally speaking? 11 A. It's basically summation of phone records, contacts, 12 between different phones. 13 Q. 14 defendant's phone and an individual named Brandon Richardson? 15 A. I did, yes. 16 Q. And what contacts did you see? 17 A. I saw two different contacts with the toll period that we 18 obtained. 19 Q. And what, when did those contacts take place? 20 A. Both contacts occurred in the same day and both were on 21 May 6th of 2021. Good afternoon, Ms. Pagan. What are some of your job I conduct analysis, research, on a daily basis in support Were you able to analyze the contacts between the 22 MR. JOSEPHSON: Okay, no further questions, Your Honor. 23 THE COURT: Any cross-examination, Mr. Ossick? 24 MR. OSSICK: No. 25 THE COURT: Any objection to this witness being excused? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 123 of 172 258 1 MR. JOSEPHSON: 2 THE COURT: 3 Ma'am, you may step down and you're excused. Call your next witness. 4 5 No, Your Honor. MS. STANLEY: Government calls SBA investigative analyst Dedra Williams. 6 DEDRA WILLIAMS, 7 having been first duly sworn, was examined and testified as 8 follows: 9 THE CLERK: Thank you. You may be seated and if you 10 will please state your full name, spell your last, state your 11 occupation and your business address. 12 THE WITNESS: My name is Dedra Williams, 13 W-i-l-l-i-a-m-s. 14 Office of Inspector General. 15 address. 16 I am with the US Small Business Administration I do not know the business DIRECT EXAMINATION 17 BY MS. STANLEY: 18 Q. Ms. Williams, how long have you worked at the SBA OIG? 19 A. It will be approximately three years in July of this year. 20 Q. What are your responsibilities as an investigative analyst 21 for the SBA? 22 A. 23 can vary depending on where an agent is in his or her case. 24 could be anything from researching information, preliminary 25 information on the background of subjects. As an analyst, I assist the agents. What that looks like It could also be It Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 124 of 172 259 1 something like analyzing bank statements that are tied to a 2 case. 3 Q. 4 between different SBA loans? 5 A. Yes. 6 Q. In December of 2021, were you asked to identify EIDL and 7 PPP loan applications linked to Bernard Okojie? 8 A. Yes. 9 Q. About how many applications did you identify that were 10 linked to Mr. Okojie? 11 A. About 42. 12 Q. How did you identify those as being linked to him? 13 A. There was some preliminary information provided by Agent 14 Justin Lott to include the social security for Mr. Okojie, and 15 that was bumped against the EIDL and PPP data that we have. 16 addition, there were some related applications that were 17 identified. 18 Q. 19 were related or connected among those applications? 20 A. 21 meaning that application was connected to his name as a contact. 22 There could have been also other applications that matched 23 either by EIN. 24 search by the address, the business address, mobile phone 25 number, e-mail addresses and bank accounts. Is one of your responsibilities identifying connections In And when you say they were related, what kinds of things So, for example, if there was an Okojie application, You may search by the EIN number. You could Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 125 of 172 260 1 Q. Were some of these application linked by IP address? 2 A. Yes. 3 Q. And would that be a IP address associated with the 4 application in some form or fashion? 5 A. Yes. 6 Q. You mentioned bumping Mr. Okojie's information against the 7 PPP loan database as well; is that correct? 8 A. Yes, that's correct. 9 Q. Did you check to see if any of those EIDLs that you just 10 talked about were connected to any PPP loan applications? 11 A. 12 in the 42 that were tied to EIDL were bumped against the PPP 13 files, and that identified an additional 16 PPP loans. 14 Q. 15 of those 58 applications? 16 A. About 1.5 million. 17 Q. In March of this year, were you asked to identify EIDL 18 loan applications linked to Brandon Richardson? 19 A. Yes. 20 Q. Was there an EIDL loan in the name of Credit Achieved, LLC 21 associated with Mr. Richardson? 22 A. I believe so, yes. 23 Q. Approximately how many EIDL applications did you identify 24 that were linked to Mr. Richardson? 25 A. Yes. So the social security numbers that were identified Do you know about how much money was disbursed as a result So there was one application that bore his name. The IP Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 126 of 172 261 1 address that was tied to that application was then bumped 2 against the EIDL database to identify any additional 3 applications, and there were hundreds that were tied to that IP 4 address. 5 Q. 6 those applications were submitted from that IP address? 7 A. I'm not sure I can answer that question. 8 Q. Might there be numerous IP addresses associated with a 9 single loan file? 10 A. There could be, yes. 11 Q. But you can say that the one IP address linked to Mr. 12 Richardson's loan file was in some way associated with hundreds 13 of other EIDL loan applications? 14 A. Is that IP address -- do you know whether that means that I'm not sure. Yes. 15 MS. STANLEY: Nothing else, Your Honor. 16 MR. OSSICK: Nothing. 17 THE COURT: Any objection to this witness being excused? 18 MS. STANLEY: 19 MR. JOSEPHSON: 20 No, Your Honor. The Government calls forensic accountant Kim Johnson with the FBI. 21 KIMBERLY JOHNSON, 22 having been first duly sworn, was examined and testified as 23 follows: 24 25 THE CLERK: Thank you. You may be seated. If you will please state your full name, spell your last, state your Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 127 of 172 262 1 occupation and your business address. 2 THE WITNESS: Kimberly Johnson, J-o-h-n-s-o-n. I'm a 3 forensic accountant for the Federal Bureau of Investigation, 4 2003 Chatham Center Drive, Savannah. 5 DIRECT EXAMINATION 6 BY MR. JOSEPHSON: 7 Q. Good afternoon, Ms. Johnson. 8 A. Good afternoon. 9 Q. Could you tell the jury a little bit about some of your 10 job responsibilities as a forensic accountant? 11 A. 12 financial transactions. 13 Q. 14 case? 15 A. I did. 16 Q. How long have you been a forensic accountant? 17 A. 25 years as a forensic accountant, and before that, I was 18 an internal auditor for the IRS. 19 Q. 20 order to become a forensic accountant? 21 A. 22 CIA. 23 Q. 24 identification. 25 that exhibit pulling up? I basically review financial records mainly and follow Did you conduct a financial analysis in this particular Have you received various trainings and certifications in Yes. I'm a certified fraud examiner. I am also a CPA and Can we display 7A just for the witness, Ms. Roper, for I meant 17A. If I said 7, I misspoke. 17A, is Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 128 of 172 263 1 THE CLERK: I think it's just for the witness, can you 2 see it, Mr. Josephson? 3 MR. JOSEPHSON: I see 17A. 4 Q. (By Mr. Josephson) Ms. Johnson, do you recognize 17A? 5 A. I do. 6 Q. What is it? 7 A. It is a list of bank accounts that I reviewed for this 8 case. 9 Q. 10 the holder, the name on the account, the taxpayer identification 11 number, the signer, the bank and the date range of the financial 12 record? 13 A. Yes, it does. 14 Q. Who did those bank accounts belong to? 15 the holder on these accounts? 16 A. 17 the control of Mr. Okojie. 18 Q. 19 Ms. Johnson, do you recognize 17B? 20 A. I do. 21 Q. What is 17B? 22 A. It is a list of deposits into Mr. Okojie's accounts from 23 various individuals. 24 Q. 25 the account to which the money was deposited, check numbers, Does it summarize the type of bank account, the number, Who is the name of The holders are businesses and then Mr. Okojie all under Can we display 17B for the witness for identification. Does this chart encapsulate the date of specific deposits, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 129 of 172 264 1 names of the person making the deposit as well the memo line and 2 comments on the check? 3 A. Yes, it does. 4 Q. Have you conducted an analysis of the financial accounts 5 that were listed in 17A and 17B? 6 A. Yes. 7 Q. Do these records involve multiple bank accounts? 8 A. Yes. 9 Q. Multiple people? 10 A. Yes. 11 Q. Do they capture multiple months of financial activity? 12 A. Yes. 13 Q. Are they generally high in volume? 14 A. Yes. 15 Q. Have you created summary charts that would condense that 16 information in a way that would relieve the jury of having to go 17 through boxes and boxes of financial records? 18 A. Yes. 19 Q. Do those charts -- Your Honor, at this time I would like 20 to enter into evidence Government Exhibit 17A through 17D. 21 and B have been shown to the witness. 22 the information on those two. 23 THE COURT: 24 MR. JOSEPHSON: 25 THE COURT: C and D are summaries of So you're saying 17, B, C and D? That's correct. Any objection? 17A Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 130 of 172 265 1 MR. OSSICK: No. 2 THE COURT: Admitted without objection. 3 Q. 4 Roper. 5 (By Mr. Josephson) Can we publish 17A for the jury, Ms. Ms. Johnson, what does 17A show? 6 A. It's a listing of all the accounts that I reviewed for 7 this investigation for Mr. Okojie. 8 Q. What does that column "Holder" mean? 9 A. That is the name that's listed on account based on the 10 signature cards. 11 Q. Can you read out the names of the accounts for the jury? 12 THE COURT: Let me pause you right there. I want to 13 make sure there's only two monitors that work at the box, but 14 there is the large screen that also shows it. 15 if you are on the jury and can't see the exhibits that are being 16 displayed. 17 can see them. 18 Q. 19 entire exhibit. 20 again. 21 Is anybody not able to see them? Raise your hand Okay, everybody Please proceed. (By Mr. Josephson) Ms. Roper, can we zoom back to the Now let's zoom in on the "Holder" column Ms. Johnson, could you read out the names of the entities 22 or individuals on the accounts? 23 A. 24 Okojie and Kojie9, LLC. 25 Q. B&K Automobile Sales, Inc., B&K Freight, LLC, Bernard Can we zoom out now on 17A. There's a column here that Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 131 of 172 266 1 says "Signers." 2 A. 3 the signatures actually on the signature card for the bank. 4 Q. 5 to withdraw money from the account? 6 A. Yes. 7 Q. Who is listed as the signer on every single account in 8 this chart? 9 A. Bernard Okojie. 10 Q. Please publish 17B. 11 A. It is a listing of deposits that went into Mr. Okojie's 12 accounts from various individuals. 13 Q. What does the column "Source and Description" mean? 14 A. The source is who the deposit came from and the 15 description is what was probably on the bank statement that came 16 in with the records. 17 Q. 18 "Source and Description" column? 19 A. 20 Katina Banks, Lenora Johnson, Angela Lovelady, Ginell Adams 21 Judson, Charlie Bey and Wanda Anderson. 22 Q. 23 What does this column represent? That is all individuals that are signers on the account so Is the signer generally the person who has the authority Ms. Johnson, what does 17B show? Can you read just the names that are listed there in the Princewill Moneme, Ardell Chatman, Frentres Winding, Will you zoom back out on 17B. The column "Deposit," does that list the amount of the 24 deposit? 25 A. Yes, that's the amount that was deposited into the Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 132 of 172 267 1 account. 2 Q. Are the amounts deposited all above $10,000.00? 3 A. Yes, they are. 4 Q. In addition to the deposits made by the people on Chart 5 17B, did you analyze the deposit of money that the defendant 6 received from the SBA? 7 A. I did. 8 Q. Please publish 17C. 9 A. It lists the money received directly by Mr. Okojie or his 10 entities. 11 Q. 12 the SBA as reflected on this chart? 13 A. $202,033.00. 14 Q. Did you analyze the withdrawal of money listed on 17B and 15 17C? Let me ask the question a little differently. 16 analyze the withdrawal of funds that made their way into Mr. 17 Okojie's bank accounts? 18 A. That left his account? 19 Q. Yes. 20 analysis? 21 A. I did. 22 Q. Will you publish 17D. 23 17D show? 24 A. 25 Okojie, the money received from the individuals in the prior What does 17C show? What is the total amount of money that was deposited from Did you Did you analyze withdrawals as part of your I did. All right, Ms. Johnson, what does It's basically consolidating SBA money received by Mr. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 133 of 172 268 1 schedule, and then the cash withdrawals. 2 Q. 3 just discussed? 4 A. It does. 5 Q. Okay, did you notice any pattern with respect to 6 withdrawals in your chart? 7 A. 8 receiving money either from individuals or from the SBA. 9 Q. 10 withdrawals either on the same day or near the same day in 11 amounts that would have exceeded $10,000.00? 12 A. Yes, there were some occurrences of that. 13 Q. Are you familiar with any banking regulations or 14 requirements regarding withdrawals that exceed $10,000.00? 15 A. 16 $10,000.00 a report must be filed. 17 Q. 18 $10,000.00, would that be reported to the federal government? 19 A. 20 feels like that's happening, they would also have to file a 21 report. 22 Q. If they catch it? 23 A. If they realize what's going on, yes. 24 Q. If they didn't realize what was going on, would that avoid 25 the reporting requirement? Okay, does this chart essentially combine the charts we Normally, there was a high amount of withdrawals after Were there any instances where the defendant made two Yes. If you have any cash transaction at a bank over If a transaction is structured in a way to be below Yes. If a teller or a bank person picks up on that or Could it be -- Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 134 of 172 269 1 A. 2 it may not be reported if somebody doesn't catch it. 3 Q. 4 last page for this chart. 5 that's listed in the withdrawal section in this chart? 6 A. $178,116.12. 7 Q. Was this the total amount of money -- what does this 8 figure reflects? 9 A. 10 are those that appear to be questionable as to that $10,000.00 11 amount. 12 account. 13 Q. 14 $10,000.00 threshold amount? 15 A. 16 $10,000.00. 17 Q. I want to walk through a few examples -- 18 A. Okay. 19 Q. -- for the jury. 20 Actually let's go to Page 2, August 24th, 2020. 21 sorry, August 24th. 22 It avoids the reporting. It should still be reported but All right, can we move to the bottom of the chart, the What is the total amount of money It reflects the withdrawals that are listed here, which It does not cover all cash withdrawals out of the Okay. These are just the ones that involved the On their face appear to be trying to elude that Let's move back to Page 1 of the chart. Page 3, I'm All right, Ms. Johnson, what happened on August the 24th, 23 2020? 24 A. 25 Anderson for $18,210.00 into B&K account ending in 4728 and The first thing that happened is a deposit from Wanda Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 135 of 172 270 1 then, I'm sorry -- 2 Q. Keep going. 3 A. You see withdrawals on 8/24 for $750.00 and $9,000.00, but 4 that's from a different account, but on 8/25, you see the same 5 thing, $750.00 cash withdrawal and a $9,000.00 cash withdrawal 6 from the same account that Ms. Anderson's funds were deposited 7 into. 8 Q. 9 the $10,000.00 reporting requirement? 10 A. $250.00 short of the reporting requirement. 11 Q. I want ask you now some questions about July the 31st, 12 2020. 13 on July 31st, 2020? 14 A. 15 18,495.00 into B&K Freight 4728 and a deposit made into Kojie9 16 from Ms. Winding for $15,510.00, and then you start to see 17 withdrawals out of the B&K Freight account, one for $6,000.00 18 and one for $2200.00 on the 31st, the same as the deposit, and 19 then on the 3rd, you see another $9500.00 and $750.00 withdrawn 20 on the 3rd of August. 21 Q. Was the 3rd of August a Monday? 22 A. Yes. 23 Q. So that was the next banking day? 24 A. Yes. 25 Q. How about the next two days on August the 4th and 5th? Is that amount, $9,000.00 and 750.00, is that just under If we could move to July the 31st, 2020. What happened There were two deposits made, one from Katina Banks for The 31st was a Friday and the 3rd is on Monday. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 136 of 172 271 1 Did that withdrawal pattern continue? 2 A. 3 see $750.00 cash, and then on the 7th, it's $7,000.00 and 4 $3,000.00 both on the 7th. 5 Q. 6 example, $9500.00 and $750.00 that were separated out in terms 7 of withdrawing the money? 8 A. Yes. 9 Q. And did that repeat itself over and over and over? 10 A. It did. 11 Q. If we could move to the last page again, Ms. Roper. 12 Yes. On the 4th, you see $9500.00 and then the 5th you So generally speaking, did you observe two amounts, for The total amount of money that exhibited this pattern was 13 what? The withdrawal, the amount withdrawn in that type of 14 pattern was what? 15 A. $178,116.12. 16 Q. The jury has heard a fair amount of evidence about the 17 defendant's finances in this case. 18 in this case see any evidence that four million dollars in gross 19 revenues made their way into the defendant's account or the 20 people who deposited checks into the defendant's accounts? 21 A. 22 accounts I reviewed was less than a million dollars. I did not. Did you I think the total activity I reviewed and the 23 MR. JOSEPHSON: 24 THE COURT: 25 I want to ask you: No further questions, Your Honor. Cross-examination, Mr. Ossick. CROSS-EXAMINATION Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 137 of 172 272 1 BY MR. OSSICK: 2 Q. 3 withdrawals; is that correct? 4 A. Withdrawals and deposits. 5 Q. So the currency, that's on the withdrawal side; right? 6 other words, that's what you're withdrawing, cash? 7 A. Correct. 8 Q. So the banking records reflect the source of the funds; 9 right? 10 A. 11 that what you mean? 12 Q. Right. 13 A. Yes. 14 Q. There's a check? 15 A. Yes. 16 Q. The record shows you who it's from? 17 A. That's correct. 18 Q. Shows you how much? 19 A. That's correct. 20 Q. So this isn't anything about explaining where money came 21 from, is it? 22 A. No. 23 Q. This is strictly there are withdrawals that are below a 24 reporting limit? 25 A. Just a couple of questions. So you've analyzed In Meaning the deposits coming in from the individuals; is The source of the funds into the account. It's very clear where the money came from. Correct. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 138 of 172 273 1 Q. But if you add them together, they might exceed it? 2 A. That's correct. 3 Q. But you can tell where every dollar came from that is 4 eventually withdrawn as currency? 5 A. That is correct. 6 MR. OSSICK: Thank you. 7 THE COURT: Any redirect? 8 MR. JOSEPHSON: 9 THE COURT: 10 MR. JOSEPHSON: 11 THE COURT: 12 No, Your Honor. Any objection to this witness being excused? No, Your Honor. Ma'am, you may step down, and you're excused. 13 Ms. Stanley, your next witness. 14 MS. STANLEY: 15 The Government calls Customs and Border Patrol Officer Ronnie Matheson. 16 RONNIE MATHESON, 17 having been first duly sworn, was examined and testified as 18 follows: 19 THE CLERK: Thank you. You may be seated. And if you 20 will please state your full name, spell your last, state your 21 occupation and your business address. 22 THE WITNESS: My name is Ronnie Lloyd Matheson. Last 23 name is spelled M-a-t-h-e-s-o-n. I am a first-line supervisor 24 for Homeland Security, which is Customs and Border Protection 25 out of the port of Atlanta. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 139 of 172 274 1 DIRECT EXAMINATION 2 BY MS. STANLEY: 3 Q. 4 worked with Customs and Border Patrol? 5 A. 21 years. 6 Q. What are some of your responsibilities as a CBP officer? 7 A. Most of my career has been as an enforcement supervisor or 8 ATCF team and port team. 9 Q. What does that entail on a day-to-day basis? 10 A. Basically we are in a port team where we have a variety of 11 jobs that we do. 12 flights. 13 outbound flights as far as outbound currency. 14 the cargo exams so we have a variety of jobs we do. 15 Q. 16 require people to declare large amounts of cash when they 17 travel? 18 A. Yes, ma'am. 19 Q. What are the requirements for declaring cash or currency 20 when you travel international? 21 A. 22 over $10,000.00 you must declare. 23 Q. Is there a form that you have to fill out to do that? 24 A. Actually, back in the old customs days, it actually was 25 the declaration you got on the plane and the first question Good afternoon, Officer Matheson. How long have you We do inbound flights where we target the We examine the flights with x-ray machines. We work We do NCIC's with Is one of your responsibilities enforcing the laws that International, if you travel inbound or outbound, anything Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 140 of 172 275 1 asked is: Are you carrying more than $10,000.00? If you are a 2 global entry person, the first question you answer is: 3 carrying more than $10,000.00? 4 to use. 5 Q. Is there something electronic that you use now? 6 A. We -- yes, everything -- everything has gone to, you know, 7 the computer system, but when we work outbound flights, when we 8 interact with people, we actually give them a pamphlet to report 9 the reporting requirements, and we explain to them why we're 10 stopping them and interviewing them at that time. 11 Q. 12 engage in is speaking with people on outbound flights? 13 A. Yes, ma'am, it's one of our jobs that we do. 14 Q. Do you remember seizing approximately $40,000.00 in cash 15 from an individual by the name of Bernard Okojie? 16 A. Yes, ma'am. 17 Q. Was that on or about December 28th of 2020? 18 A. Yes, ma'am. 19 Q. How did CBP come into contact with Mr. Okojie? 20 A. We -- that day we selected to work a couple of outbound 21 flights, one of them being Delta 54, so I sent my officers up 22 there to work the flight. 23 Q. 24 that flight number, is that flight number assigned to a 25 particular route? Are you So there are forms that we used Everything is automated how. Is that a routine process that you and other CBP officers And when you say Delta 54, is that a particular -- does Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 141 of 172 276 1 A. Yes, ma'am, it's an outbound Lagos flight. 2 Q. So from Atlanta to Nigeria? 3 A. Yes, ma'am. 4 Q. So on that day, what were your officers doing as far as 5 interacting with the passengers who were boarding that flight? 6 A. 7 operation, doing outboard currency, and basically what they do 8 is they go up the jetway, and as people come through, they stop 9 and interact with every person coming through and they ask them, 10 you know, the reason for the travel and if they are carrying 11 more than $10,000.00. 12 Q. 13 $10,000.00 in cash? 14 A. Yes, he did. 15 Q. Did the CBP officers start the process of having him fill 16 out a form to declare that money? 17 A. 18 requirements as far as the rules and regulations, and they have, 19 if they give you that form, they have you read the form and ask 20 you how much cash you're carrying and then they have the person 21 fill out the back of it and initial it. 22 Q. And so did Mr. Okojie fill out that form? 23 A. Yes, ma'am. 24 Q. Did the officers physically start counting the money that 25 he had with him? They were up there conducting an outbound enforcement And did Mr. Okojie say that he was carrying more than He declared, yes. They, they give him the 503 form, which is the reporting Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 142 of 172 277 1 A. Yes, ma'am. 2 Q. Was there a discrepancy between how much he said he had 3 with him and how much the officers were counting? 4 A. Yes, ma'am. 5 Q. Did you become involved at this point? 6 A. I become involved after I was notified the officers had 7 stopped the subject. 8 up to almost 39,000.00. 9 when we stop people and have that happen, I always make my 10 officers call out PE officers, who is our financial crimes 11 police, and run a check on the person to see if they have got 12 previous FinCEN's on file, which is where they had filed 13 previously. 14 inspection and bring him down to the F concourse, take his bags 15 off the plane, bring all his luggage and go ahead and do a 16 thorough exam at that point. 17 Q. 18 You said he had previously had a FinCEN? 19 A. Yes, ma'am. 20 Q. Can you explain to the jury what that means? 21 A. Basically what happens with a previous FinCEN means, if 22 you travel and you have more than $10,000.00 that you know the 23 reporting requirements; you saw the form yourself and turned it 24 in or you declare the money and fill the form out. 25 Q. He first declared 34,000.00, and they were I asked them had they -- had they -- He had, so I told them to go ahead and stop the I want to ask you to elaborate on something you mentioned. At some point, was Mr. Okojie asked whether he was Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 143 of 172 278 1 familiar with the laws requiring a person to declare cash when 2 traveling internationally? 3 A. 4 FinCEN on file. 5 Q. 6 reporting requirements? 7 A. It's common knowledge, yes, ma'am. 8 Q. Was Mr. Okojie transported to the F concourse with his 9 luggage at this point? 10 A. 11 inspection area. 12 Q. And what happened there? 13 A. I had my officers go ahead and do a thorough exam of his 14 checked luggage, go ahead -- go ahead and complete all the money 15 count there, and once we figured how much money we had, which I 16 was there present when they did the money count, I go ahead and 17 get notification to seize the money because he failed to 18 declare. 19 Q. And how much money in total was seized? 20 A. 39/7, $39,700.00. 21 Q. What did CBP do with the seized money at that point? 22 A. Once the money was seized, we automatically take it to our 23 seized property people, which they in turn take possession of it 24 and end up depositing it. 25 I can't answer that for myself, but he did have a previous So did that indicate to you that he was aware of the He was brought to the F concourse to our baggage MS. STANLEY: Nothing further. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 144 of 172 279 1 THE COURT: 2 Mr. Ossick, cross-examination. CROSS-EXAMINATION 3 BY MR. OSSICK: 4 Q. 5 first part you told about where he was first stopped and asked 6 to be -- asked did he have money, you were there for that? 7 A. No, sir. 8 Q. You're telling us what somebody told you? 9 A. That is what the officer reported to me. 10 Q. And they told you that when they asked him are you 11 carrying money in excess of $10,000.00, is that what they told 12 you they asked him? 13 A. That's what they always ask them, sir. 14 Q. And what did he tell them? 15 A. He said he had 34,000.00. 16 Q. So he told them about it? 17 A. Uh-huh. 18 Q. Then you seized it anyway, even though he declared it 19 then? 20 A. 21 $39,700.00, which he failed to declare the total amount. 22 Q. 23 whole 39? 24 A. 25 Just a couple of questions. No, sir. I guess I'm not clear. That We seized it after we found out he had So rather than the amount that he left out, you take the Yes, sir. MR. OSSICK: Okay, thank you. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 145 of 172 280 1 THE COURT: Any brief redirect? 2 MS. STANLEY: 3 Briefly, Your Honor. REDIRECT EXAMINATION 4 BY MS. STANLEY: 5 Q. 6 any of the cash he was carrying with him; is that correct? 7 A. Yes, ma'am, he did not. 8 Q. And was part of your decision to seize this money based on 9 the fact that he had a previous violation of the declaration 10 requirement? 11 A. 12 FinCEN on file. 13 wasn't at the time that we -- he declared 34 he actually had 14 39/7 on him. Officer Matheson, Mr. Okojie had not initially declared That was part of it because he would have had a previous He knew the reporting requirements and it That's why we decided to seize his money. 15 MS. STANLEY: That's all I have, Your Honor. 16 THE COURT: 17 MS. STANLEY: 18 THE COURT: 19 Mr. Josephson, call your next witness. 20 MS. STANLEY: Any objection to this witness being excused? No, Your Honor. You may step down. You're excused. The Government calls Kassandra Haley- 21 Fields, who is an FN&P officer with the Customs and Border 22 Patrol. 23 KASSANDRA HALEY-FIELDS, 24 having been first duly sworn, was examined and testified as 25 follows: Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 146 of 172 281 1 THE CLERK: Thank you. You may be seated. And if you 2 will please state your full name, spell your last, state your 3 occupation and your business address. 4 THE WITNESS: Kassandra Shamine Haley-Fields, H-a-l-e-y 5 hyphen F-i-e-l-d-s, and my occupation is fines, penalties and 6 forfeitures officer. 7 DIRECT EXAMINATION 8 BY MS. STANLEY: 9 Q. 10 the Customs and Border Patrol? 11 A. Yes. 12 Q. And are you assigned to a particular location? 13 A. Yes, the Atlanta port office. 14 Q. How long have you worked for CBP? 15 A. Over 20 years. 16 Q. What are your responsibilities as a fines, penalties and 17 forfeitures officer? 18 A. 19 adjudicate liquidated damages, penalties and seizure cases. 20 Q. 21 currency? 22 A. Yes, ma'am. 23 Q. Can you tell the jury what happens generally after cash is 24 seized by Customs and Border Patrol? 25 A. Ms. Haley-Fields, is that the position that you hold with As the fines, penalty and forfeiture officers, I When you say seizure cases, does that mean seizures of When currency is seized by US Customs and Border Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 147 of 172 282 1 Protection, this currency is transported over and that's another 2 area that I manage, the security of the seized property until it 3 is adjudicated, and we send out a note, what we call a notice of 4 seizure, and that's notifying the claimant that we have seized 5 their property and therefore they will get a notification what 6 that amount is of the currency. 7 well as US currency, we will identify that, and we will also 8 give them an election of proceedings form and a seized asset 9 claim form, and the notice will also give them instructions on 10 how they can claim the return of their seized property. 11 If it is foreign currency as The election proceedings form is where they can make a 12 choice for how they would like to proceed and the seized asset 13 claim form is what we use if they choose to go to court. 14 Q. 15 from Bernard Okojie to recover cash that had been seized from 16 him by CBP? 17 A. Yes, ma'am, we did. 18 Q. Was that about $39,700.00 in US dollars? 19 A. Yes, ma'am. 20 Q. Was Mr. Okojie sent an initial letter setting out his 21 options like the one that you just described? 22 A. 23 we have election of proceedings which determines, they have four 24 options or you can have the fourth one is where you have the 25 seized asset claim form if you want to go to court that you Did you and your office oversee and process a petition Yes. The -- the letter is the notice of seizure and then Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 148 of 172 283 1 would complete. 2 Q. Did he respond to that letter? 3 A. Yes, he did. 4 responded -- initially he responded that he wanted to do a 5 petition administratively, and then he also submitted another 6 form in regards to going to court, and what we do, if we get 7 where a person completes both forms, we will send back another 8 letter and what we call a dual response letter and let them know 9 that they responded in two ways and that for them to make a 10 choice on how they would like to proceed. 11 Q. 12 and show it to the witness only. 13 He responded that he would like to -- he Ms. Roper, can you please pull up Government Exhibit 18 Can you see that, Ms. Haley-Fields? 14 A. Yes. 15 Q. It's just showing me and the witness. 16 the first page that you're looking at on the screen? 17 A. Yes, ma'am. 18 Q. Ms. Roper, can you flip through the next few pages, 19 please, so the witness can review them. 20 Do you recognize Thank you, Ms. Roper. Ms. Haley-Fields, do you recognize these documents? 21 A. Yes, ma'am, I do. 22 Q. Can you briefly tell the jury what they are? 23 A. What it is is that it's a submission of what we would call 24 a petition, and that's when I said they did the dual and we had 25 election of proceedings. And on the election of proceedings, Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 149 of 172 284 1 you have four choices: One, a petition for it to be processed 2 administratively; two, you can submit an offer in compromise and 3 it would be processed administratively; three, you can outright 4 abandon the property and there would be no further action; and 5 four is where you would have the -- you would do a -- submit a 6 seized asset claim form, and that's where you have the choice to 7 go to court. 8 Q. 9 have his funds returned to him via administrative procedure? 10 A. 11 proceeding CAFRA form where he had requested the petition and 12 where he had requested the seized asset claim, and he responded 13 back to us with another one and said that he wanted to do the 14 election of proceedings petition. Do these documents reflect that Mr. Okojie petitioned to Yes. 15 This is where he had completed an election of MS. STANLEY: At this time we would move to admit 16 Government's Exhibit 18. 17 THE COURT: Any objection? 18 MR. OSSICK: No. 19 THE COURT: Admitted without objection. 20 MS. STANLEY: 21 this to the jury. 22 Q. 23 please. 24 25 (By Ms. Stanley) Would you please publish this? Publish Ms. Roper, would you go to Page 3, Ms. Haley-Fields, this is the petition that Mr. Okojie submitted to get his money back? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 150 of 172 285 1 A. Yes, ma'am. 2 Q. Do you know if that was in February of 2021? 3 the date of this? 4 A. 5 would have been February the 24th. 6 Q. And briefly what did Mr. Okojie say in this petition? 7 A. Briefly he was stating that the -- in that petition that 8 it was his money and that his source was a valid source of 9 income and from his employment. 10 Q. 11 were the source of these funds? 12 A. 13 healthcare, and another one from Angela Lovelady and they both 14 were made out to the company B&K Freight, LLC. 15 Q. 16 able to rotate that? 17 Do you know It was February when he submitted it to our office. It Did he attach two checks to his petition that he claimed Yes, two checks, one from a Lenora Johnson, home and Ms. Roper, will you go to Page I believe it's 10. Are you Okay, is this the check from Lenora Johnson? 18 A. Yes. 19 Q. Can you read it? 20 for the jury the amount of this check? 21 A. $15,375.00. 22 Q. Can you go to Page 11? 23 I know it's upside down. Can you read Is this the other check that you mentioned, Ms. 24 Haley-Fields? 25 A. Yes. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 151 of 172 286 1 Q. Who is this one made out to? 2 A. This is made out to B&K Freight, LLC as well. 3 Q. Is this the one from Angela Lovelady? 4 A. Yes. 5 Q. What's the amount of that check? 6 A. $18,435.00. 7 Q. Did your office make a decision to return this money to 8 Mr. Okojie? 9 A. Yes, we did based on the information. 10 Q. Minus a penalty? 11 A. Yes. 12 penalty, and that is supported by our mitigation guidelines, and 13 in the mitigation guidelines, we have what we call a currency 14 and monetary -- currency and monetary instrument report 15 remission table, and that table has a range where we have a 16 standard amount of what our penalty amount would be, and for the 17 range, anything over the range of $25,001.00 to $40,000.00, we 18 have a standard amount of $2500.00 that we would deduct from the 19 seized amount. 20 Q. 21 Mr. Okojie? 22 A. 23 14th, 2022. 24 Q. Was the refund amount then approximately $36,900.00? 25 A. Yes. What we have is that, what we call a monetary Do you know approximately when this money was returned to It was approved on -- the refund was approved on October Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 152 of 172 287 1 MS. STANLEY: Nothing further. 2 THE COURT: Cross-examination, Mr. Ossick? 3 MR. OSSICK: No questions. 4 THE COURT: Any objection to this witness being excused? 5 MS. STANLEY: 6 THE COURT: 7 THE WITNESS: 8 THE COURT: 9 MR. JOSEPHSON: 10 Protection Officer Brian Coder. No, Your Honor. You may step down and you're excused. Thank you. Any other witnesses? 11 The Government calls Customs and Border OFFICER BRIAN CODER, 12 having been first duly sworn, was examined and testified as 13 follows: 14 THE CLERK: Thank you. You may be seated. And if you 15 will please state your full name, spell your last name, state 16 your occupation and your business address. 17 THE WITNESS: Brian Patrick Coder, C-o-d-e-r. I am an 18 officer with the US Customs and Border Protection and I didn't 19 catch what was the last thing. 20 THE CLERK: 21 THE WITNESS: 22 Your business address. Atlanta Hartsfield airport. DIRECT EXAMINATION 23 BY MR. JOSEPHSON: 24 Q. 25 job responsibilities as an officer with CBP? Officer Coder, can you tell the jury what are some of your Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 153 of 172 288 1 A. Inspecting passengers and goods entering and exiting the 2 country, looking for immigration violations to commerce 3 violations, whether it's narcotics, fraud, all kind of different 4 things, very large umbrella. 5 Q. Do you work at the Atlanta airport? 6 A. Yes. 7 Q. Are you part of the TTRT team? 8 A. I was at the time, yeah. 9 Q. What is TTRT team? 10 A. It was the tactical terrorism response team is what the 11 title stood for, and it was more of a -- an enhanced training 12 for interview techniques and search techniques that we would go 13 through. 14 Q. As part of your duties, do you conduct border searches? 15 A. Yes. 16 Q. Do you conduct interviews at the airport? 17 A. Yes. 18 Q. Do you execute warrants on occasion? 19 A. Yes. 20 Q. Did you interview the defendant, Bernard Okojie, at the 21 Atlanta airport on June the 19th of 2021? 22 A. Yes. 23 Q. Was he arriving in Atlanta or leaving Atlanta? 24 A. He was arriving from Lagos, Nigeria. 25 Q. Is that Flight DL55? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 154 of 172 289 1 A. Yes. 2 Q. When you interviewed Mr. Okojie, were you aware of any 3 other prior encounter with CBP? 4 A. 5 would query the systems, and I could see that he had a prior 6 money seizure going outbound, I think it was a year or so ahead 7 of time. 8 Q. Do you recall the approximate amount of the money seizure? 9 A. 39,000.00 and change. 10 Q. All right, during your interview with the defendant, did 11 he identify how he earned his income? 12 A. 13 of different scenarios that he proposed where he did crypto 14 currency trading and then he owns I think it was a logistics box 15 truck company and then he earned money helping people acquire 16 some loans and then some kind of credit boosting service that he 17 offered. 18 Q. 19 income? 20 A. Yes. 21 Q. Did he mention the helping individuals file SBA loan 22 applications? 23 A. Yes. 24 Q. And did he suggest that that was a legitimate way he made 25 money? Once I first got ahold or met him, I had a query where I Yeah. I asked him how he earned it and there was a couple Was there a variety of explanations for how he earned his Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 155 of 172 290 1 A. Yeah. 2 Q. During your interview, did you obtain any documents from 3 the defendant's pocket? 4 A. 5 or pocket litter which includes like credit cards, business 6 cards, copies of notebooks, different things like that, yes. 7 Q. 8 Exhibit 19 for identification if you could, Ms. Roper. 9 through Government 19 so the witness can become familiar with 10 that document. 11 Yeah. During the interview, we did a copy of pocket trash I'd like to display for the witness only Government Flip Officer Coder, are you familiar with Government Exhibit 12 19? 13 A. As far as the copies of the notebook, yes. 14 Q. What is it? 15 A. It was just a ledger book that he had in his possession. 16 As far as what was in it, I couldn't tell you exactly because it 17 really didn't pertain to my current inspection but ... 18 Q. 19 defendant's pocket? 20 A. Yeah, I think it was in a backpack. 21 Q. Was it on his person or his personal belongings? 22 A. It was on his personal belongings. 23 Q. Did you upload this pdf to, this copy to a file in this 24 case? 25 A. Is this a copy of the notebook that you pulled from the Yes. I can't ... Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 156 of 172 291 1 Q. Is the copy an accurate copy of what was reflected in the 2 notebook itself? 3 A. Yes. 4 Q. Was it altered in any way by you or anybody at CBP? 5 A. No. 6 7 MR. JOSEPHSON: Your Honor, at this time we would like to move to admit Government Exhibit 19. 8 THE COURT: Any objections? 9 MR. OSSICK: No. 10 THE COURT: Admitted without objection. 11 Q. 12 flip to Number 10 in the notebook. 13 10. 14 (By Mr. Josephson) All right, Ms. Roper, if you could There's a list at Number Start on Page 1 and work forward. Start, if you could, Officer Coder, read -- at the outset 15 I want to ask you, this was a notebook on the defendant's 16 person; correct? 17 A. Yes. 18 Q. If you could start and read Number 10. 19 A. Number 10, "Lord, protect me from police problem, court 20 problem. 21 Q. Number 11, please. 22 A. "Lord, give me victory on this matter with customs and DHS 23 and let all my money and phones be returned." 24 Q. Number 14, please. 25 A. I see it. I will not be implicated for what I did not know." It's right after 13? It looks like a 12. "Lord, make me a million Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 157 of 172 292 1 in dollars in 2021." 2 Q. Number 16, please. 3 A. "Lord, help me in 2021 to set up a business that will 4 bring me an income every day." 5 Q. Number 17. 6 A. "Lord, help me to" -- is that -- "own a fast food chain, 7 open a fast food chain." 8 Q. Next page, Ms. Roper, Number 18. 9 A. "Lord, help me to open a gas company in Nigeria, connect 10 me to the" -- I can't make that out -- "oil and gas industry in 11 Nigeria." 12 Q. 19. 13 A. "Lord, help my wife to start up a business she desire." 14 Q. 20. 15 A. "Lord, help me to acquire more" something "properties in 16 America and Nigeria." 17 MR. JOSEPHSON: 18 THE COURT: Cross-examination, Mr. Ossick? 19 MR. OSSICK: No questions. 20 THE COURT: Any objections to this witness being 21 I have no further questions, Your Honor. excused? 22 MR. JOSEPHSON: 23 THE COURT: 24 THE WITNESS: 25 THE COURT: No, Your Honor. Then you may be excused. Thank you. Thank you. On behalf of the prosecution, any additional Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 158 of 172 293 1 witnesses? 2 MS. STANLEY: 3 THE COURT: 4 MS. STANLEY: 5 THE COURT: 6 No, Your Honor. Do you rest your case? We do. If you will call out by number each exhibit that you have had introduced and admitted in this case. 7 MS. STANLEY: 8 or just the numbers? The exhibit number and the exhibit title 9 THE COURT: Yes. 10 MS. STANLEY: 11 THE COURT: 12 the numbers so we make sure. 13 MS. STANLEY: 1A is the EIDL loan file ending in -- You don't need to say what they are, just Okay. Exhibit 1A, 1B, 1C, 1D, 1E, 1F, 1G, 14 1H, 1I, 1J, 2A, 2B, 2C, 2D, 2E, 2F, 2G, 2H, 2I, 2J, 3A, 3B, 3C, 15 3D, 3E, 4A, 4B, 4C, 4E, 4F, 4G, 4I, 5A, 5B, 5C, 5D, 5E, 5F, 6, 16 7, 8, 10, 11A, 11B, 11C, 11D, 11E, 11F, 11G, 11H, 12A, 12B, 12C, 17 12D, 12E, 12F, 12G, 12H, 12I, 12J, 12K, 12L, 13, 14, 15, 16A, 18 16B, 16C, 17A, 17B, 17C, 17D, 18, 19 and 20. 19 20 THE COURT: All right, and with that, you rest your case in chief? 21 MS. STANLEY: 22 THE COURT: Yes, Your Honor, we do. Ladies and gentlemen of the jury, the 23 Government has completed its case in chief and it is time for 24 our mid-afternoon break, so we will break. 25 10 after 3:00, so we will be in recess until 3:25. It is actually about If you will Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 159 of 172 294 1 take the jury to the large jury room here on the third floor. 2 I've received communications while we've been in session 3 that they have fixed my courtroom downstairs, all the power. 4 are probably going to stay here because I'm going to have them 5 make sure and so we will probably stay up here for the balance 6 of the afternoon. 7 8 Remember, don't talk about the case. mind. You can leave your amenities pack in your chair because we will be coming back here this afternoon. 11 (The jury exits the courtroom.) 12 THE COURT: 13 Don't make up your Let's rise for this jury. 9 10 We Counsel, have a seat, just a few housekeeping matters to go through with you. 14 Mr. Ossick, do you anticipate putting on any witnesses? 15 MR. OSSICK: No. 16 THE COURT: All right, when we do return from break, I 17 will have you, call on you to present anything and you can say 18 that on the record. 19 either. 20 anticipate needing for closings? 21 MR. JOSEPHSON: And in that case we won't utilize rebuttal As far as closings go, approximately how long do you I anticipate about 20 minutes, maybe 25 22 minutes, and I would like if I could reserve some time for 23 rebuttal. 24 25 THE COURT: And you do, of course, have opening and closing arguments, and if you wanted to split that up, that's Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 160 of 172 295 1 fine or one person can do both. 2 Mr. Ossick, approximately how long do you think? 3 MR. OSSICK: No more than that, less probably. 4 THE COURT: Well, I will, you know, just so long as each 5 side keeps it under 45 minutes, that's going to be -- we won't 6 stop you before then, but 45 minutes a side should be plenty. 7 8 Mr. Ossick, do you have any motions to make at this point? 9 10 MR. OSSICK: We would like to make a Rule 29 motion on Counts 1 and 3 on sufficiency basis. 11 THE COURT: What -- 12 MR. OSSICK: Those are the conspiracy counts, Your 14 THE COURT: Yes. 15 MR. OSSICK: While there's been a lot of evidence as to 13 Honor. 16 substantive violations, in terms of showing any evidence 17 sufficient to show an agreement with some other party or person, 18 I don't believe there's been sufficient evidence of that 19 whatsoever to show anybody else in common agreement knowingly 20 and joining for the same purpose, someone -- of course, I'm not 21 going to -- The Court knows -- just who unwittingly acts in 22 furtherance of or just acts in the same way but without joining 23 any agreement, that's the crux of it, with knowledge of the 24 unlawful objective of the agreement. 25 There's been a lot of people who have participated in Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 161 of 172 296 1 various actions but none of which have said they were in 2 agreement with anything in an unlawful way and joined with that. 3 So I don't believe there's been any, especially as to 4 the money-laundering charges, there has been nothing to suggest 5 anyone's participation in what would be that substantive offense 6 and he's charged not with money laundering but with conspiracy 7 to commit money laundering, and the same is true -- and I 8 understand we're down to, in Count 1, only the wire fraud, and 9 while they may well could have done nine more substantive wire 10 fraud counts, perhaps very compellingly, from the various 11 individuals, they haven't had one that showed that there is 12 someone in agreement, and to the extent you look at the evidence 13 concerning the owned entities of him, it's sole, no showing that 14 any person other than him had complete control, and you can't be 15 a coconspirator with an entity that you solely own and control, 16 so I don't believe there has been sufficient evidence for the 17 jury to go as to Counts 1 and 3. 18 19 THE COURT: On behalf of the United States, your response. 20 MR. JOSEPHSON: Yes, Your Honor. That motion should be 21 denied. There is overwhelming evidence of a crime as alleged in 22 all three counts. 23 commit wire fraud, there's a massive fraudulent scheme that has 24 been perpetrated in this case. 25 also involves the people who received kickbacks for getting the With respect to Count 1, the conspiracy to It involves the defendant. It Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 162 of 172 297 1 fraudulent loan. 2 As The Court is well aware, a conspiracy can be proven 3 through conduct. 4 require a formal agreement. 5 It can be proven in indirect ways. It doesn't You have a situation here where lots of people received 6 fraudulent loans. 7 were itself a percentage of the loan. 8 They paid inflated fees, extensive fees that The checks were dropped off in various ways, anything 9 from a hotel in Chattanooga to off the highway at a gas station. 10 The defendant had no, no financial background at all in terms of 11 the ability to process loans or provide financial advice. 12 We've submitted significant statistical evidence, 13 significant financial record evidence, significant loan record 14 evidence. 15 the gross revenues for the defendant's loans as well as the 16 people who paid the defendant to assist them with the loans were 17 staggering, like astronomical numbers, four million in gross 18 revenues, 132 people that the evidence shows the overwhelming 19 number of whom didn't exist at all. We've summarized that in charts. We've shown that 20 We've shown the loan amounts also were fraudulent. 21 approved amounts, we have over 1.4 million dollars that the 22 United States Government paid out as part of the fraudulent 23 scheme. 24 25 The The kickbacks paid, $165,000.00 for nine applications. There's evidence in the record that those applications were Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 163 of 172 298 1 filled in fraudulently, which, if supported, would take no more 2 than five minutes or so. 3 THE COURT: Just to sort of focus to the precise point 4 Mr. Ossick is arguing is that even if one were to concede that 5 there's massive evidence of fraud, what is the evidence of the 6 conspiracy, the agreement with another human? 7 MR. JOSEPHSON: Yes, Your Honor. There is evidence of 8 an agreement. 9 themselves that the individuals are writing are made out to fake 10 businesses for loan preparation. 11 that is being put on the check at the direction of the 12 defendant. 13 You have some people that deny certain knowledge, looking the 14 other way. 15 instruction, but they all admitted to writing checks that were 16 itself the proceeds of a fraudulent loan, and they did so 17 knowing that the check they wrote was not to him, not to a 18 financial services company, not to a brokerage. 19 they were writing it to an entity for a purpose that made no 20 sense. 21 I would point out first that the checks You have B&K Freight, Kojie9 You have every single person going along with that. We are going to request a deliberate ignorance They knew that So we do think there is an agreement based on the checks 22 and the kickbacks. I also think that that plays both for Count 23 1 and Count 3. 24 concealment, the conspiracy to conceal, that is an act of 25 concealment to write out checks in payment for the fraudulent I know counsel has moved on both counts. The Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 164 of 172 299 1 loan in the name of a shell company that has nothing to do with 2 loan preparation. 3 course, other acts that the defendant engaged in to further 4 conceal down the chain. 5 THE COURT: That is an act in furtherance. There are, of You're saying because there's evidence that 6 checks were made out that said like "for truck leasing" and to 7 B&K Transport and things of that nature? 8 MR. JOSEPHSON: That's correct, and then that money is 9 structured out by the defendant and stuffed in a suitcase and 10 taken to, an attempt to take to Nigeria, so we do ask that The 11 Court deny the motion. 12 I would also point out there's multiple-object 13 conspiracy alleged in Count 3. 14 The proceeds of the money laundering are above $10,000.00. 15 Every single check that each person wrote is over $10,000.00, 16 and it is the direct proceeds of the fraud, so that is an object 17 of the conspiracy in addition to the concealment, so we would 18 ask that The Court deny for that basis, too. 19 THE COURT: There is a 1957 part to it, too. All right, I am not going to grant that 20 motion at this point, so we will send the case on to the jury 21 for the jury's consideration. 22 Let me take up with you, I did notice that apparently 23 the parties have agreed on some cleaning up of the indictment 24 and I do want to confirm on the record that both sides agree to 25 that; is that correct, Mr. Josephson? Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 165 of 172 300 1 MR. JOSEPHSON: That's correct, Your Honor. We have 2 agreed to drop the bank fraud object of the conspiracy alleged 3 in Count 1. 4 conspiracy in Count 3 regarding the transaction-reporting 5 requirement. 6 We've also agreed to drop the object of the We are moving forward on other two objects of the 7 conspiracy, namely proceeds exceeding $10,000.00 and 8 concealment. 9 and 3, and we have conferred with counsel, and we are in 10 agreement that that makes sense to present a cleaned-up 11 indictment for the jury's roadmap. 12 13 14 We've dropped two objects of the conspiracy in 1 THE COURT: And I assume you would not object to dropping those parts from the indictment? MR. OSSICK: No. We're in agreement, and it did not 15 change any of the other language, so it just took out an 16 underlying offense, basically. 17 THE COURT: And so it will be that version that counsel 18 has during trial agreed to that we will send back to the jury 19 during deliberations because I do let them have a copy of the 20 indictment, so we will utilize the one that both have agreed to. 21 Does that also clear up some of the few disagreements regarding 22 the charge? 23 24 25 MR. OSSICK: Can I ask, are we going to have a charge conference? THE COURT: Well, we are, but I want to -- Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 166 of 172 301 1 2 MR. OSSICK: It cleared up -- that's what I was trying -- 3 THE COURT: It cleared up one of yours; right? 4 MR. OSSICK: Yes, it cleared up a lot of -- because the 5 bank fraud is not in it now. 6 THE COURT: Right. 7 MR. OSSICK: So it does change. 8 THE COURT: Because you had asked for a substantive bank 9 fraud to be at least added into the conspiracy part. 10 11 MR. OSSICK: So that there would be an underlying THE COURT: So they would know what bank fraud was, but offense. 12 13 there is no need for that because they are dropping that from 14 Count 1. 15 16 MR. OSSICK: Correct, but we want to be able to confer about the charge but nothing to do with banking. 17 THE COURT: We have to do that, according to the rules. 18 So the verdict form, I saw there was a cleaned-up 19 submission with regard to the verdict form. Is that agreed to 20 now or is that something we still have to take up? 21 MR. OSSICK: I don't believe I've seen -- 22 MS. STANLEY: We've e-mailed it out over the lunch 23 break. 24 can provide to the Defense before the charge conference. 25 We did copy you. THE COURT: I think we have a copy here that we What we're going to do in just a moment, we Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 167 of 172 302 1 will bring the jury back in. 2 the Defense is resting their case. 3 We will confirm on the record that At that point I'm going to let the jury know that we 4 have some housekeeping business to take up with y'all. We will 5 go ahead and get a draft of the proposed charge and the verdict 6 form for y'all to take home, and first thing tomorrow morning, 7 we will meet outside the presence of the jury to hear any 8 objections or exceptions that y'all have to the proposed charge. 9 I do want you to be very careful, look at the draft very 10 carefully tonight. It's an important part of the case, and we 11 will meet at 8:30 tomorrow on the second floor in that courtroom 12 to have the charge conference and review the charge and the 13 verdict form, and then at nine o'clock we will have the jury 14 join us and we will start with closing arguments and charge and 15 then get the case to the jury. 16 If the defendant were to be convicted, are you going to 17 request that the jury be retained for forfeiture purposes or do 18 you waive that? 19 20 21 22 23 MR. OSSICK: Are you asking the Government are they moving forward with it? THE COURT: There was a forfeiture count in the indictment. MR. JOSEPHSON: There is a forfeiture count in the 24 indictment. If I could consult with the agencies. 25 we have anything identified. I'm not sure Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 168 of 172 303 1 THE COURT: You're not going to go forward? 2 MR. JOSEPHSON: I don't think so. If I could confer 3 with them to get that final, because there's administrative 4 forfeiture as well as -- 5 THE COURT: 6 MR. JOSEPHSON: 7 THE COURT: Well, do that right now. Okay. We're not moving forward. Then I have the requested charges from each 8 of you based on how the trial actually played out. 9 any additional charges that either side wishes to add? 10 MS. STANLEY: Are there Your Honor, we did make some changes to 11 the request to charge and we forwarded a copy to Ms. Sharp a few 12 hours ago. We're happy to file that on the record as well. 13 THE COURT: What were the nature of the changes? 14 MS. STANLEY: They were only to the substantive offense 15 instructions. As to the conspiracy, we took out references to 16 bank fraud. 17 another Eleventh Circuit pattern that we removed. 18 it strictly within the 1349 pattern instruction, and then as to 19 the money laundering, we removed a reference to the object of 20 the conspiracy that we removed and just moved a couple things 21 around to make it a cleaner, same language. There was also one sentence that was taken from 22 THE COURT: 23 MS. STANLEY: 24 THE COURT: 25 We just kept And have you provided that to Mr. Ossick? Yes, Your Honor. Other than that, there's no additional charges other than those revisions that you've -- okay. Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 169 of 172 304 1 MS. STANLEY: 2 THE COURT: No, Your Honor. On behalf of the Defense, I have the ones 3 that you requested before trial. 4 you would like to request? 5 MR. OSSICK: Are there any additions that Your Honor, I'm not sure if I included the 6 part about how a person can act in furtherance unless they've 7 actually joined in or not a member -- 8 9 10 THE COURT: You requested that in your initial round. Wait, you requested that it has to be another human. MR. OSSICK: And I'm not sure that I had that other part 11 and I think I would be wanting that if I haven't. 12 in the pattern. But it may be I can't recall. 13 THE COURT: Well, look at that tonight because -- 14 MR. OSSICK: I will. 15 THE COURT: Is there any other additional request that 16 the defendant wishes based on what actually transpired during 17 the trial? 18 MR. OSSICK: I don't believe so, Your Honor. 19 THE COURT: All right. Then we will break for just a 20 little bit and then do as I say, but I need for the parties to 21 either come back or send somebody back to pick up from Ms. Sharp 22 at about 4:30 the proposed charge so that you can take your time 23 with it tonight and see any suggestions, corrections or 24 objections that you'll have and then we will meet at 8:30. 25 right, let's take our brief break. We will be in recess. All Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 170 of 172 305 1 (Recess from 3:26 p.m. to 3:39 p.m.) 2 THE COURT: 3 (The jury enters the courtroom.) 4 THE COURT: Let's bring in the jury. Ladies and gentlemen, welcome back. When we 5 broke, we had completed the Government's case in chief. We will 6 turn to the Defense. 7 put up any evidence or any witnesses or prove anything. 8 that, Mr. Ossick, any witnesses that you would like to call? 9 10 11 Recall that the defendant does not have to With MR. OSSICK: No, and we would rest at this time, Your THE COURT: All right, ladies and gentlemen of the jury, Honor. 12 that means that you have heard all of the evidence that you will 13 hear in the case. 14 I will tell you that we're progressing a little bit 15 ahead of time. 16 I need to cover with the attorneys that will require some time 17 so I'm going to excuse you early for the day. 18 I have some significant housekeeping issues that I'll have you come back just as you did today by nine 19 o'clock to be in your jury room so we can start promptly at 9:00 20 tomorrow. 21 signals from a gentleman on the front. 22 they have everything fixed in my courtroom, so we should be on 23 the second floor tomorrow, but the marshals will have up-to-date 24 information in the morning, but we do anticipate being back on 25 the second floor tomorrow. When we do start at 9:00 tomorrow -- and I see hand All I'm hearing is that Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 171 of 172 306 1 So when we do begin tomorrow at 9:00, we will begin with 2 the closing arguments from each side in which they will be 3 summarizing and recalling the evidence as they believe that it 4 went in. 5 you will use in deciding the case in reaching your verdict and 6 at last at that point you will retire to the jury room to reach 7 your verdict. 8 After that, I'll give you the charge on the law that So as we leave the courthouse for the evening, remember 9 the familiar admonition: Don't make up your mind; don't talk 10 about the case; don't do any research; don't consume any media 11 about the case. 12 With that, let's rise for the jury. 13 (The jury exits the courtroom.) 14 THE COURT: All right, counsel, we will proceed then as 15 discussed during your previous break. The only slight 16 alteration is if you will make arrangements with Ms. Sharp to 17 receive those charges, I think they will be ready right at about 18 five o'clock so if you want to get them electronically or stay 19 here, either way, but when I step off, if you will just make 20 those arrangements with Ms. Sharp and then I will look forward 21 to seeing you what we believe to be on the second floor tomorrow 22 at 8:30 for our charge conference. 23 All right, we will be in recess. 24 (Proceeding concluded at 3:44 p.m.) 25 Case 4:22-cr-00084-LGW-BWC Document 109 Filed 04/30/23 Page 172 of 172 307 1 CERTIFICATION 2 3 I certify that the foregoing is a true and correct 4 transcript of the stenographic record of the above-mentioned 5 matter. 6 7 9 __________________________________ 04/24/2023 10 Debra Gilbert, Court Reporter Date 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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