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Home Court filings U.S. v. Carlos Vazquez Transcript of Detention Hearing (Mar. 29, 2021) — United States v. Carlos Vazquez

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Transcript of Detention Hearing (Mar. 29, 2021) — United States v. Carlos Vazquez

No. 1:21-cr-20231-DMM · Doc. 59 · Docket on CourtListener

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Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 1 of131



 1                         UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF FLORIDA
 2
                           CASE NO. 21-CR-20231-DMM
 3
       UNITED STATES OF AMERICA,
 4                                             Miami, Florida
                        Plaintiff(s),
 5                                             March 29, 2021
                  vs.
 6
       CARLOS VAZQUEZ,
 7
                      Defendant(s).       Pages 1 - 31
 8     -----------------------------------------------------------

 9                             DETENTION HEARING
                    TRANSCRIBED FROM DIGITAL AUDIO RECORDING
10                   BEFORE THE HONORABLE JONATHAN GOODMAN
                         UNITED STATES MAGISTRATE JUDGE
11
       APPEARANCES:
12
       FOR THE PLAINTIFF(S):     HAYDEN O'BYRNE, ESQ.
13                               UNITED STATES ATTORNEY'S OFFICE
                                 99 N.E. 4th Street
14                               Miami, FL 33132-2211
                                 305-961-9447
15                               hayden.obyrne@usdoj.gov

16

17     FOR THE DEFENDANT(S):     JACOB A. COHEN, ESQ.
                                 LAW OFFICES OF JACOB A. COHEN, PLLC
18                               750 S. Dixie Highway
                                 Boca Raton, FL 33432
19                               561-715-7866
                                 jacob@jacobcohenlaw.com
20

21

22     TRANSCRIBED BY:           Joanne Mancari, RPR, CRR, CSR
                                 Court Reporter
23                               jemancari@gmail.com

24

25
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 2 of231



 1     Thereupon,

 2     the following proceedings were held via Zoom videoconference:
 3                THE COURT:   Before we start, let me just make an

 4     announcement.

 5                As required by Federal Rule of Criminal Procedure

 6     5(f), the United States is ordered to produce all exculpatory

 7     evidence to the defendant pursuant to Brady v. Maryland and its

 8     progeny.    The government has a duty to disclose any evidence

 9     that goes to negating the defendant's guilt, the credibility of

10     a witness, or that would reduce a potential sentence.          The

11     defendant is entitled to this information without a request.

12     Not making these disclosures in a timely manner may result in

13     sanctions, including exclusion of evidence, adverse jury

14     instructions, dismissal of charges, and contempt proceedings.

15                We are on page 1, Carlos Vazquez.

16                Does Mr. Vazquez need an interpreter?

17                THE MARSHAL:   He does not, your Honor.

18                THE COURT:   Good afternoon, Mr. Vazquez.

19                THE DEFENDANT:    Good afternoon, Judge Goodman.

20                THE COURT:   Tell me, please, sir, your full name and

21     your date of birth.

22                THE DEFENDANT:    Carlos Vazquez, January 18, 1964.

23                THE COURT:   All right.    Sir, I'm going to be reading

24     your rights in just a minute.

25                Do I have your agreement to have this hearing this
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 3 of331



 1     afternoon by computer with an audio and video connection

 2     instead of in person in the courtroom?

 3               THE DEFENDANT:     Yes, sir, you do.

 4               THE COURT:    All right.

 5               THE DEFENDANT:     Thank you.

 6               THE COURT:    So I am going to be explaining your rights

 7     to you.   By the way, let me just ask, is there anybody here at

 8     this hearing observing from either Channel 10 or any of the

 9     media outlets?

10               A VOICE:    Judge, if I may.    It's Tony from IT.     They

11     were in the waiting room, but they disconnected at some point.

12     I don't see them on here.      They may be on, but at least what

13     identified them as Channel 10 I no longer see.

14               THE COURT:    All right.    I think they were here for a

15     defendant who they expected to see this afternoon and who I

16     expected, in fact, to see this afternoon, but who apparently is

17     not here because he didn't get to the cellblock in time, and so

18     that gentleman, Drew Curtis Sykes, is scheduled for first

19     appearance tomorrow afternoon at 1:30.

20               In any event, Mr. Vazquez, if you cannot afford an

21     attorney and you want the court to appoint one for you free of

22     charge, you will be placed under oath and asked questions about

23     your financial condition to determine if you qualify for the

24     appointment of counsel.      You must demonstrate to me that you

25     are indigent to qualify for court-appointed counsel at no
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 4 of431



 1     charge to you.    In other words, you need to establish that you

 2     don't have enough money or property to hire an attorney.

 3               You have the right to have your attorney present at

 4     all court proceedings.

 5               You are not required to make any statements, but any

 6     statement you choose to make may be used against you.          If you

 7     start to make a statement but then change your mind, you may

 8     stop at any time and say nothing further.

 9               You are entitled to a bond hearing or a detention

10     hearing if the government is requesting that you be held

11     without bond.    At that time the court will determine if you

12     will be detained or released on bond.        If you are released on

13     bond, then you are subject to arrest and revocation of release

14     and to various civil and criminal sanctions and penalties if

15     you violate any of the conditions of the bond.

16               If you have not been indicted, then you are entitled

17     to a preliminary hearing within 14 days of your appearance here

18     in court if you are held in custody or within 21 days if you

19     are released on bond.

20               At this hearing the government will be required to

21     present evidence to show that there is probable cause to

22     believe that a crime was committed and that you are the person

23     that committed that crime.

24               A defendant who is not a United States citizen may

25     request that an attorney for the government or a federal law
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 5 of531



 1     enforcement official notify a consular officer from the

 2     defendant's country of nationality that the defendant has been

 3     arrested, but even without that request a treaty or other

 4     international agreement may require consular notification.

 5                So, Mr. Vazquez, you are here this afternoon because

 6     you have been accused by the government of committing wire

 7     fraud.    Are you going to be hiring your own lawyer or would you

 8     like me to see whether you qualify for the appointment of

 9     counsel?

10                MR. COHEN:   Your Honor, good afternoon.      Jacob Cohen

11     on behalf of Mr. Vazquez.      I will enter a temporary notice of

12     appearance once the case appears on Pacer.

13                THE COURT:   All right.    Who is here for the United

14     States?

15                MR. O'BYRNE:   Good afternoon.     Assistant United States

16     attorney Hayden O'Byrne on behalf of the United States.

17                As a preliminary matter I would move to unseal the

18     complaint in this matter, 21-MJ-02512, McAliley, and also a

19     search warrant, 21-MJ-02531, Torres.

20                THE COURT:   Very well.    That request is granted and

21     those two documents are unsealed.

22                So what is happening, folks?

23                MR. O'BYRNE:   Good afternoon, your Honor.       Mr. Vazquez

24     is a risk of flight and a danger to the community, but,

25     nevertheless, we have spoken with Mr. Cohen.         We are going to
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 6 of631



 1     recommend a bond.     Some conditions of that are agreed upon and

 2     some are not.    So if you'd like, let me go through with you the

 3     conditions that we have agreed upon and then I will list the

 4     additional conditions that the government is seeking and then,

 5     if you'd like, we can provide some argument as to why we

 6     believe those conditions are necessary to secure Mr. Vazquez's

 7     appearance.

 8                MR. COHEN:   Mr. Vazquez, are you all right?

 9                THE DEFENDANT:    Yes, sir.   Yes.

10                THE COURT:   So, first, Mr. O'Byrne, what is the amount

11     of the bond that you and Mr. Cohen have negotiated?

12                MR. O'BYRNE:   We have not agreed to an amount, your

13     Honor.    The United States is proposing a $900,000 personal

14     surety bond with a cosigner and a $50,000 10 percent bond with

15     Nebbia.

16                MR. COHEN:   Your Honor, our position with respect to

17     that is, against the financial background of Mr. Vazquez, that

18     would be tantamount to no bond.       He doesn't have -- there is no

19     one who will sign for him who could pledge those kinds of

20     assets.    I know in the PTD report his girlfriend said she

21     would.    She doesn't have the money to do that and is not

22     inclined to do that.

23                Essentially, it is our respectful position that that

24     is not a fair requirement, even though the loss amount in this

25     case is in the same general area of the 900,000.         He just
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 7 of731



 1     doesn't have the money or anyone who will sign for him.

 2               I think there are other conditions, other combinations

 3     of conditions, that can get us there and assure the safety of

 4     the community and --

 5               THE COURT:    Mr. Cohen, can you keep your voice up.

 6     Maybe get closer to your microphone.

 7               MR. COHEN:    Your Honor, can you hear me now?

 8               THE COURT:    I mean, I can basically hear you before,

 9     but you were trailing off at the end.        Sometimes people when

10     they come to the end of their comments, they kind of trail off

11     sort of like that at the end.      Do you know what I mean?

12               MR. COHEN:    Sorry, Judge.    I am going to have my face

13     right into the video here.

14               THE COURT:    So the amount of the bond and whether or

15     not there is a cosigner and whether or not there is a Nebbia

16     condition, that is one source of disagreement.         Tell me the

17     items that you have agreed on and then we will talk about the

18     other items of disagreement.

19               MR. O'BYRNE:    Certainly, Judge.     The defendant has

20     agreed to stay with his girlfriend, Ms. Annabelle Lee, at 15479

21     Southwest 35th Terrace, Miami, Florida.

22               The defendant has agreed to the special condition of

23     refraining from possessing a firearm, destructive device, or

24     other dangerous weapon.

25               In connection with that, the defendant shall not go to
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 8 of831



 1     his apartment at 5249 Northwest 7th Street, apartment 408,

 2     Miami, Florida, until the case agents in this case seize a

 3     firearm that is there, and we will be submitting a search

 4     warrant to you today to recover that firearm.         That is agreed.

 5               The additional agreed-upon conditions, report to

 6     Pretrial Services as directed, surrender all passports and

 7     travel documents, if any, to Pretrial Services, and not obtain

 8     any travel documents during the pendency of this case.           None of

 9     the signatories may pledge, sell, mortgage, hypothecate,

10     encumber any real property they own until the bond is

11     discharged or otherwise modified by the court.         And the

12     defendant shall participate in mental health and substance

13     abuse assessment and/or treatment as directed by Pretrial

14     Services.   The defendant shall have no contact with witnesses,

15     and we will send a list of those witnesses to Mr. Cohen today.

16               Those are the agreed-upon conditions.

17               THE COURT:    All right.    So I will entertain argument

18     on the amount of the bond and the other matters that you

19     indicated you could not agree on.

20               MR. O'BYRNE:    OK.

21               THE COURT:    So let me hear first from you and then I

22     will hear from Mr. Cohen in a little greater detail.

23               MR. O'BYRNE:    OK.   Your Honor, Mr. Vazquez has a

24     lengthy criminal history in the Pretrial Services report.

25     Unfortunately, we are still trying to figure out the exact
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 9 of931



 1     extent of it due to some confusion with respect to his name.

 2     In here I see that he was sentenced to three years for

 3     transport of drugs in 1987.      I realize that is old, but it is

 4     still a drug trafficking conviction.        Then more recently he has

 5     a 2004 resisting an officer with violence, fleeing, alluding,

 6     tampering with evidence, resisting an officer without violence.

 7     My fault.    He was convicted of all of those charges.        Then more

 8     recently there are a couple of cases that were no actioned, but

 9     he was still arrested in 2017 for false imprisonment and

10     battery and aggravated battery on the elderly.

11                Additionally, your Honor, Mr. Vazquez is not a U.S.

12     citizen.    He is a citizen of Cuba.     ICE has tried twice to

13     deport him and been unsuccessful in those efforts.          He is

14     classified --

15                THE COURT:   Sir, wait just a minute.      It says here

16     that he indicated he is a naturalized U.S. citizen.          That is

17     what it says in the Pretrial Services report.

18                Whoever has the dog barking, maybe if you could turn

19     your microphone off, unless it is you, Mr. O'Byrne.          Is that

20     your dog?

21                MR. O'BYRNE:   Yes.   I'm sorry, your Honor.      Somebody

22     knocked on my front door.

23                THE COURT:   Your dog is a good watchdog, so that is a

24     positive thing.

25                My point is, in the Pretrial Services report it says
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 10 of1031



 1     that Mr. Vazquez indicated that he is a naturalized United

 2     States citizen.     Are you suggesting that that is false, he is

 3     not a naturalized U.S. citizen?

 4                MR. O'BYRNE:    Yes, your Honor.     My understanding is

 5     that ICE tried to deport him as late as 2017.

 6                THE COURT:    Mr. Cohen, is it your understanding that

 7     your client is a naturalized U.S. citizen?

 8                MR. COHEN:    Your Honor, I just want the record to

 9     reflect that I was not the attorney present during that PTD

10     hearing.

11                The direct answer to your question as to whether or

12     not he is a citizen, I don't know the answer to that question,

13     your Honor.    He came here very young from Cuba to Chicago and

14     eventually made it to Miami.       I think Mr. Vazquez in good faith

15     is relying on the fact that he is a citizen based on some of

16     the (inaudible) laws.

17                THE COURT:    Can't hear you, Mr. Cohen.

18                MR. COHEN:    Your Honor, Mr. Vazquez has a good faith

19     belief that he is a United States citizen, but that is an issue

20     that needs to be further explored through the immigration

21     process.    It is something we will be doing during the pendency

22     of the case.

23                To answer your question directly, your Honor, I don't

24     know if he is a United States citizen.

25                THE COURT:    What did you mean when you said you were
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 11 of1131



 1     not the attorney at the detention hearing?

 2                MR. COHEN:    Not at the detention hearing, your Honor.

 3     It was during the pretrial detention process, I was not the

 4     lawyer.

 5                THE COURT:    I'm having a great deal of difficulty

 6     hearing you.

 7                MR. COHEN:    Your Honor, there was another lawyer who

 8     was present for that hearing.        It wasn't me.

 9                THE COURT:    I guess my question is, what kind of

10     hearing are you talking about?

11                MR. COHEN:    Your Honor, it wasn't a hearing.        When

12     they made statements to the pretrial detention officer.

13                THE COURT:    OK.    You're talking about the Pretrial

14     Services interview.

15                MR. COHEN:    Correct.

16                THE COURT:    OK.

17                MR. GARCIA:    Your Honor, if I may.      Robert Garcia on

18     behalf of U.S. Probation.

19                Your Honor, he did tell us he is a naturalized U.S.

20     citizen, but right after that mention in the report, we did

21     check with Immigration.        Immigration says that he has an

22     outstanding warrant of removal pending.         So we listed both

23     pieces of information in there, your Honor.

24                THE COURT:    Right.    Right.   You have the defendant

25     saying I think I'm a naturalized U.S. citizen and then you have
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 12 of1231



 1     ICE telling you that there is an outstanding warrant of removal

 2     pending.

 3                MR. GARCIA:    Right, your Honor.

 4                THE COURT:    All right.    I get it.    Thank you.

 5                MR. COHEN:    Your Honor, just one more thing.        The

 6     decisive point is we turned him into the IRS office this

 7     morning.    (Inaudible) he's complying with the system.          They

 8     reflect that he is not a flight risk because he is in custody

 9     and he voluntarily went into custody with all of this in the

10     background.

11                THE COURT:    So according to the Pretrial Services

12     report there is a reference to Ms. Lee, Annabelle Lee.            Does

13     she own any real estate?

14                MR. COHEN:    Your Honor, she does, but she indicated to

15     me that she doesn't feel comfortable cosigning for a $900,000

16     bond because she can't --

17                THE COURT:    Well, what amount of money would she be

18     comfortable signing for?

19                MR. COHEN:    Your Honor, she would be comfortable with

20     the $50,000 10 percent bond with the Nebbia requirement.            She

21     would write a check for $5,000, your Honor, in order to secure

22     Mr. Vazquez's release from custody.

23                THE COURT:    So let me ask you this, Mr. Cohen.        What

24     message should I draw or what inference should I draw that the

25     person you are suggesting as a cosigner says I'm really not
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 13 of1331



 1     comfortable cosigning a bond of more than $50,000?           Doesn't

 2     that sort of suggest that somebody who is close to him and

 3     somebody who knows him well is not willing to sign on a bond --

 4                MR. COHEN:    Your Honor --

 5                THE COURT:    Gosh, if I could just finish, that would

 6     be a wonderful thing.

 7                And if a person who knows him well is unwilling to

 8     sign on a bond, why should I grant his request and lower the

 9     bond from $900,000 to $50,000?

10                MR. COHEN:    Your Honor, I think we are being unclear.

11     There are two conditions.       The prosecutor wants a $900,000

12     personal surety bond with a cosigner.         His girlfriend is

13     uncomfortable signing that.       She doesn't have the assets to

14     back that up.     However, in terms of the $50,000 10 percent

15     bond, she has no problem with that.        She could do that.      She

16     just doesn't have the assets to back the $900,000.

17                THE COURT:    I'm not confused.     I understand.

18                What kind of real estate does she own and how much is

19     it worth?

20                MR. COHEN:    Your Honor, she has a house that is worth

21     $500,000, and that address was given to the prosecutor.

22                THE COURT:    Now when you say that it is worth

23     $500,000, does she have $500,000 of equity in the home or is

24     the house just one with a fair market value of $500,000?

25                MR. COHEN:    Your Honor, she maintains that she has
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 14 of1431



 1     $500,000 equity in that home.

 2                THE COURT:    Right.    So in terms of her potential

 3     financial exposure, you say to me, well, she's willing to sign

 4     a $50,000 10 percent bond.        So she would be putting up $5,000

 5     and she would be at risk for $50,000.         But then when it comes

 6     to a $900,000 bond, she is not comfortable signing, whether she

 7     has a house worth that much money or not or other assets worth

 8     that much money or not.      So I'm just saying from my

 9     perspective, Mr. Cohen, do you think that is a favorable thing

10     or a source of concern?

11                A VOICE:   Excuse me, Judge.      I apologize to interrupt.

12     It's Tony from IT.      I see the person from Channel 10 is back in

13     the waiting room.     Maybe I could admit him and you could

14     address him as soon as they come in.

15                THE COURT:    Sure.

16                A VOICE:   All right.     They're coming in.

17                THE COURT:    Folks, bear with me just one minute.

18                (Pause)

19                THE COURT:    Mr. Cohen, my point is, I understand that

20     your client's friend, Ms. Lee, is willing to sign a $50,000

21     bond.   So that is somewhat impressive, I guess.          But when it

22     comes to signing a more -- the fact that Ms. Lee doesn't want

23     to sign a bond in a greater amount, and that is the person

24     you're putting up as a cosigner, you think that is a positive

25     or a negative development?
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 15 of1531



 1                MR. COHEN:    Your Honor, I think it is a negative

 2     development.

 3                THE COURT:    Right.   I mean, this is the person who is

 4     being listed as a cosigner and the fact that she is nervous and

 5     concerned about being exposed to anything more than $50,000,

 6     while not dispositive, is certainly a significant factor that I

 7     am going to consider.

 8                MR. COHEN:    Your Honor, respectfully, I want you to

 9     take into account that Mr. Vazquez turned himself in today

10     voluntarily.

11                THE COURT:    I understand.    Has Mr. Vazquez, through

12     you, been in negotiations with the United States for a while or

13     he just heard that they were looking for him and then decided

14     it would be easiest to turn himself in?

15                MR. COHEN:    Your Honor --

16                THE COURT:    Can't hear you again, Mr. Cohen.

17                MR. COHEN:    -- through his previous lawyer it was

18     communicated to him that he needed to turn himself in Monday

19     morning, and that's what we did.        I became involved in the case

20     Friday night and formally retained yesterday and have worked

21     very hard preparing for the case in understanding all the

22     factual assertions underlying the allegations in the case.

23                THE DEFENDANT:    Could I ask this honorable court to

24     respectfully say something at this second, please?

25                THE COURT:    Well, Mr. Vazquez, just bear with me for a
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 16 of1631



 1     minute.    I am not going to prevent you from saying something,

 2     but usually defense lawyers do not want their clients to just

 3     be blurting something out to a judge in the middle of a hearing

 4     because what you say, you may not realize it, but it may hurt

 5     your case in some way.      Normally defense lawyers advise their

 6     clients to not speak.

 7                Mr. Cohen, I will give you an opportunity.         Do you

 8     want to pass on that comment to Mr. Vazquez?

 9                MR. COHEN:    Your Honor, I agree 100 percent with what

10     you said.

11                Mr. Vazquez, I'm handling the situation for you.

12                THE DEFENDANT:    I want to respectfully bring something

13     up to this court that Mr. O'Byrne said.         In 2017 I was arrested

14     on a case and tried to be framed by the City of Miami police,

15     and you've been provided with the two affidavits of the

16     supposed victims who have sworn under oath that they were

17     trying to be coached by the Miami police into saying something

18     that would put me in a bad situation.         I want to bring this

19     out.   You have both affidavits of Rosa Hernandez and the other

20     lady who with was a tenant of hers.        Both of them signed under

21     oath to dismiss the case because it was totally false what the

22     police was trying to get them to say.         That is number one.

23                Number two, I have zero substance abuse.         I've never

24     had a problem of substance abuse.        I've never had a DUI.      I've

25     never been anything having to do with drugs.          So I respectfully
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 17 of1731



 1     and from the bottom of my heart, I mean, I feel bad sitting

 2     here saying that they have to send me to substance abuse

 3     because this case has nothing to do with that and I've never in

 4     my life had a problem with that.        And the 2017 arrest, if you

 5     have two affidavits proving that I had absolutely nothing to do

 6     with that -- as a matter of fact, I was taking care of these

 7     individuals under my own recognizance because of the hurricane,

 8     and they were supposed to be there in my house because there

 9     was no power and light anywhere else.

10                So I do take offense to the fact that those charges

11     being brought up without my attorney refreshing this court.

12     Those cases were dismissed, and not only dismissed by the

13     government, they were dismissed on the basis that both

14     witnesses claimed that they were being coached into saying this

15     by the Miami police department.

16                I chose not to take any action.       I don't like to go

17     against the government or law enforcement agency.           I let it be.

18     But that is totally false.       And as far as substance abuse, your

19     Honor is concerned, you can check my record.          Since I was a

20     little kid, I've been playing professional sports and amateur

21     sports since the age of 10, and I've never in my life had a

22     problem with drugs or substance abuse or alcohol.           I don't even

23     drink.    So I don't know where that came from, and I would like

24     to respectfully request that my attorney defend me in that

25     manner and the court as well.
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 18 of1831



 1                MR. COHEN:    Your Honor, in terms of defending my

 2     client on that matter, the record is clear that in 2017 there

 3     was no action on that case and it was dropped.          The last

 4     contact with the system in terms of a conviction was 2012, and

 5     that's in the record and that is why it was not brought up.

 6                The prosecutor also mentioned that it was no actioned.

 7     So that is where we are in terms of that, your Honor.

 8                THE COURT:    All right, folks.     Thank you for all of

 9     your information and your arguments.         The bond will be as

10     follows.    It will be a two-part bond.

11                The first one will be a $500,000 bond to be cosigned

12     by the defendant's long-time friend Annabelle Lee.           There will

13     also be a second bond.      It will be a $50,000 10 percent bond

14     with a Nebbia condition.

15                Mr. Cohen, I typically use a Nebbia form.         I don't

16     have a need to review bank records or real estate records or

17     other financial documents.       Instead, you will present those to

18     the prosecutor and then, assuming that he agrees, you simply

19     submit this form, the Nebbia form, which you sign and the

20     prosecutor signs and there is a spot for about a two- or

21     three-sentence succinct estimation of the nature of the money

22     or property used to satisfy the Nebbia requirements.           If you

23     need a copy of the Nebbia form that I use -- if we were in the

24     courtroom, I would just say it is on the bench in front of me

25     and you could just walk up and get one, but we are not in that
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 19 of1931



 1     situation.    So if you'd like that Nebbia form, I can have my

 2     courtroom deputy email the form over to you.          Would you like

 3     that?

 4                MR. COHEN:    Yes, your Honor.

 5                THE COURT:    If you don't mind giving us your e-mail

 6     address and say it slowly, please.

 7                MR. COHEN:    Jacob@jacobcohenlaw.com.

 8                THE COURT:    Let's make sure that my courtroom deputy

 9     got that.

10                Trina, do you have it or would you like it repeated

11     one more time?

12                THE DEPUTY CLERK:     I have it, Judge.     I have it.

13                THE COURT:    You have it?

14                THE DEPUTY CLERK:     I have it, Judge.     Yes.

15                THE COURT:    All right.    So Trina will send that to

16     you.

17                So here are the other conditions.        Mr. Vazquez will

18     need to surrender his passport and travel documents and may not

19     seek or apply for any additional passports or travel documents.

20     He will need to report to Pretrial Services as directed.            He

21     will have no contact with victims or witnesses except through

22     counsel or counsel's legal team, such as paralegals or private

23     investigators, but only pursuant to a written list of witnesses

24     that the prosecutor will send to defense counsel, and that no

25     contact prohibition will activate only upon receipt of that
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 20 of2031



 1     list.

 2                In addition, the defendant may not possess firearms,

 3     ammunition, or other dangerous devices.         In the meantime, the

 4     defendant shall not go to his apartment until the case agents

 5     execute a search warrant and seize a firearm.

 6                Now, I know there was some mention that the government

 7     was going to be submitting to me an application for a search

 8     warrant, but I have no idea what is going to be in that

 9     affidavit.    I don't always grant search warrant requests simply

10     because the government asks for it.        So this is in a way

11     dependent on me issuing a search warrant, Mr. O'Byrne.            If it

12     turns out that I turn you down for some reason, then we will

13     need to make other arrangements to have this firearm removed

14     from the home.

15                So I guess what I should say is that the defendant may

16     not go to his home -- I'm sorry, may not go to his apartment

17     until the case agents seize a firearm or if no warrant is

18     issued until other people have made necessary arrangements to

19     remove firearms, ammunition, and dangerous devices.

20                In addition, neither the defendant nor the cosigner,

21     Ms. Lee, may encumber any real estate.         So since Ms. Lee is

22     going to be a required cosigner on a $500,000 bond, she will

23     not be able to do anything to affect the title to her real

24     estate.

25                In addition, I am going to require the defendant to
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 21 of2131



 1     stay with Ms. Lee, and I am going to require mental health

 2     assessment and, if necessary, treatment.         Pretrial Services has

 3     not suggested substance abuse testing and/or treatment, and I

 4     don't see anything in the Pretrial Services report that would

 5     justify such a request.      So that will not be part of the bond.

 6                Are there any --

 7                MR. O'BYRNE:    Your Honor.    I apologize, your Honor.

 8     If I may, with respect to the drug abuse, there was a prior

 9     search warrant served at the premises last week and marijuana

10     was discovered at this apartment belonging to Mr. Vazquez, but

11     it also appeared that nobody had been in the apartment in some

12     time.   So that is the basis of the --

13                MR. COHEN:    Your Honor, our counterargument to that is

14     that there is no direct evidence connecting Mr. Vazquez to that

15     marijuana.    The presumption of innocence should inure to the

16     benefit of Mr. Vazquez regarding that issue.

17                THE COURT:    Let me ask the government, where was this

18     marijuana found?     In an apartment where Mr. Vazquez was

19     residing?

20                MR. O'BYRNE:    Yes, your Honor.     The case agent,

21     Giovanni Donies, who executed that warrant, is on the line.             So

22     please correct me if I'm incorrect, but my understanding is

23     that the marijuana was found in the master bedroom, by the bed,

24     out in the open, and it appeared that Mr. Vazquez had been

25     living there but nobody had been in the apartment for some
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 22 of2231



 1     time.

 2                AGENT DONIES:    That's correct.

 3                MR. COHEN:    Your Honor, the --

 4                THE COURT:    Wait just a minute, Mr. Cohen.

 5                Let me ask the agent.      Agent Donies, how much

 6     marijuana are we talking about?

 7                AGENT DONIES:    There was a bag, kind of hefty-size

 8     bag, that was halfway filled.       It was turned over to the local

 9     police officer.     We did not weigh the bag so I don't know

10     specifically how much was in it.

11                THE COURT:    You're saying a hefty garbage bag size?

12                AGENT DONIES:    Not hefty.    It was about this much of

13     marijuana that was found in a plastic bag, and then there was

14     another small container with marijuana also found inside that

15     also had cigarettes and rolling paper for the marijuana.

16                THE COURT:    Right.   So I am going to also include

17     substance abuse testing and/or treatment.

18                MR. COHEN:    That will be over defense's objection,

19     your Honor, based on the arguments.

20                THE COURT:    Of course.    I understand that.

21                Listen, if you want to later, Mr. Cohen, file a motion

22     to modify the bond to remove that requirement and you want to

23     have an evidentiary hearing to explain how that marijuana got

24     into your client's apartment and maybe some other

25     circumstances, I will be happy to entertain the motion.            But
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 23 of2331



 1     for right now that will be a part of the bond.

 2                Any other special conditions suggested by the U.S.

 3     Attorney's Office?

 4                MR. O'BYRNE:    Yes, your Honor.     We'd also recommend

 5     GPS monitoring or at least a restriction that the defendant

 6     stay within the Southern District of Florida.          Last week when

 7     the search warrant was executed and an attorney reached out, he

 8     advised that Mr. Vazquez was out of state and he wouldn't be

 9     able to get back until today.       We don't know where he was, but

10     we know he was traveling somewhere around the country.

11                THE COURT:    Mr. O'Byrne, are you a relatively new AUSA

12     in the office?

13                MR. O'BYRNE:    I've been here about a year and a half,

14     your Honor.

15                THE COURT:    All right.    So, Mr. Garcia, correct me if

16     I'm wrong, but doesn't the bond conditions, the standard bond

17     conditions, include a provision that the defendant cannot leave

18     the Southern District of Florida?

19                MR. GARCIA:    That's correct, your Honor.       It's a

20     standard condition of the bond, yes.

21                THE COURT:    All right.    So, Mr. O'Byrne, you're

22     basically asking me to include as a special condition something

23     that is already part of the standard conditions.

24                MR. O'BYRNE:    OK.   Thank you, your Honor.

25                THE COURT:    Any other special condition suggested by
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 24 of2431



 1     Pretrial Services?

 2                MR. GARCIA:    Your Honor, I believe we do not have

 3     Annabelle Lee's address and I believe the court ordered that he

 4     reside with Ms. Lee.      If Mr. Cohen can provide Ms. Lee's

 5     address so we can properly supervise Mr. Vazquez.

 6                THE COURT:    Mr. Cohen, do you have that information

 7     handy?

 8                MR. COHEN:    Your Honor, I have that information.         I

 9     sent that to the prosecutor.

10                MR. GARCIA:    Yes, your Honor.     I received it.     I

11     believe I read it into the record, but let me read that in

12     again.    Just a second.

13                THE COURT:    All right.    Slowly, please.

14                MR. GARCIA:    Ms. Annabelle Lee, 15479 Southwest 35th

15     Terrace, Miami, Florida 33185-4745.

16                THE COURT:    I'm sorry.    Somebody was making a noise

17     while you were speaking.       Did you say 34th or 35th Terrace?

18                MR. GARCIA:    35th Terrace.

19                THE COURT:    OK.

20                MR. GARCIA:    Three five.

21                THE COURT:    All right.    Thank you.

22                So I am also going to schedule a preliminary hearing

23     for arraignment for April 12th, and I will also schedule that

24     for a report re counsel.

25                Hopefully, Mr. Cohen, by then you will know whether or
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 25 of2531



 1     not you're in the case permanently.

 2                MR. COHEN:    Correct, your Honor.

 3                THE COURT:    All right.    Anything further this

 4     afternoon from either side?

 5                MR. COHEN:    Your Honor, can we readdress some issues

 6     at the end of the docket?       I just got a text from Ms. Lee and

 7     she wanted to discuss some issues that the court may have to

 8     know about.    Is that OK?

 9                THE COURT:    Is there any reason why we can't do it

10     right now?

11                MR. COHEN:    Your Honor, I need to know whether or not

12     she will cosign with respect to the $500,000 because if she is

13     saying no, then we are not going to be able to achieve that

14     condition.    I need about five minutes to talk to her, your

15     Honor.

16                THE COURT:    All right.    Well, there are other matters

17     on the docket.

18                MR. COHEN:    We will wait until the end.

19                THE COURT:    I know, but let me just finish what I was

20     going to say.     In the meantime, I have Mr. Vazquez sitting on a

21     bench there in the cellblock.       Normally at the end of the bond

22     hearing the deputy marshals would probably make arrangements to

23     remove that defendant from that bench and continuing whatever

24     processing or other arrangements they were going to be making

25     with Mr. Vazquez.     But as a result of your request, he is going
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 26 of2631



 1     to have to be basically sitting there in limbo until the end of

 2     the calendar.     It is not that long of a calendar today.         We

 3     just have two other defendants.

 4                Candido, is there a problem with your operation if

 5     Mr. Vazquez stays there for another 15 or 20 minutes?

 6                THE MARSHAL:    No, Judge.    It is not a problem.

 7                THE COURT:    All right.    So, Mr. Cohen, we will keep

 8     this matter in sort of a procedural purgatory, if you will,

 9     until the end of the hearing, and then we will come back.

10                MR. GARCIA:    Your Honor, can I interject for one

11     moment.    I would like to instruct Mr. Vazquez, he needs to

12     report to the U.S. Probation Office on the ninth floor of the

13     building where he is right now.

14                THE COURT:    Wait, Mr. Garcia.     That is unlikely to be

15     a practical comment today because, number one, Mr. Cohen is

16     suggesting to me that the cosigner may not sign the bond and,

17     number two is, they still have to post the cash money into the

18     court registry and get the Nebbia requirement fulfilled.            So it

19     is highly unlikely, even under the best of circumstances, that

20     he will be getting actually out today.

21                MR. GARCIA:    Very well.

22                THE COURT:    But thank you for that reminder.

23                Mr. Cohen, you will remember that when Mr. Vazquez

24     gets released, he needs to hustle on over to the Pretrial

25     Services office.     In the meantime, we will put Mr. Vazquez sort
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 27 of2731



 1     of on the back burner.

 2                (Recess)

 3                THE COURT:    Mr. Cohen, do you need additional time or

 4     can we call back Mr. Vazquez on page 1?

 5                Mr. Cohen, can you hear me?       Maybe he is speaking to

 6     Ms. Lee on the phone.      We will wait until we get connected to

 7     the visitor's room.

 8                OK.   Very good.

 9                Mr. Cohen, are we ready to go back to page 1, sir?

10     Mr. Cohen.    See, this is what I feared would happen.         He is not

11     finished speaking with his client.

12                Trina, do you have a phone number for Mr. Cohen, maybe

13     on a notice of appearance?       Or, Mr. O'Byrne, do you have an

14     email address for him?

15                MR. O'BYRNE:    Yes, your Honor.     Let me email him.

16     Just a second.

17                THE COURT:    The email should say the judge is ready

18     for you.

19                (Pause)

20                THE COURT:    Mr. Cohen is now back in the hearing.

21                MR. COHEN:    Your Honor, thank you very much.

22     Everything is going to go through the way you ordered.

23                THE COURT:    All right.    Very well.

24                MR. COHEN:    The only issue, we object to the GPS

25     monitoring.
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 28 of2831



 1                THE COURT:    I don't know if I necessarily included

 2     that.    It may have been requested.

 3                MR. COHEN:    I think the prosecutor brought it up.

 4                THE COURT:    Well, listen, prosecutors bring up a lot

 5     of things.

 6                Trina, did you have that as one of the special

 7     conditions for Mr. Vazquez?

 8                THE DEPUTY CLERK:      No.

 9                THE COURT:    Right.    I didn't include that.

10                MR. COHEN:    Thank you, your Honor.

11                Mr. Vazquez, I am working on everything with Ms. Lee

12     and we are going to get you out as soon as we can.

13                THE DEFENDANT:    OK.    Thank you, and thank this

14     honorable court.     I appreciate everybody taking an interest in

15     helping me in this situation.        Thank you.    God bless you.

16                THE COURT:    That is it for our needs in the marshal's

17     cellblock there.     Thank you for your help.

18                THE MARSHAL:    Judge, is he going to post that bond

19     today, sir?

20                THE COURT:    I doubt it, but let's find out.

21                MR. COHEN:    We are going to try to do it.

22                Mr. Garcia, can we access the court registry during

23     COVID?

24                MR. GARCIA:    That would be a question for the court or

25     for Trina.
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 29 of2931



 1                THE COURT:    What do you mean by accessing the court

 2     registry?

 3                MR. COHEN:    Your Honor, in terms of delivering a

 4     check.

 5                THE DEPUTY CLERK:      You can send over your bond

 6     information to me.      I can review it with the judge.       They have

 7     special times.     I believe they have an hour in the morning, an

 8     hour in the afternoon to pay your bond.

 9                MR. COHEN:    So I will email you, and thank you, Trina.

10                THE DEPUTY CLERK:      No problem.

11                THE COURT:    So, Trina, what you are saying is there is

12     some method which Mr. Cohen can use to actually post the money

13     into the court registry sometime this afternoon, but does that

14     require an in-person visit to the courthouse or is that done

15     through some sort of an internet connection?

16                THE DEPUTY CLERK:      In person.    One hour opening in the

17     afternoon.

18                THE COURT:    Right.    Well, it is 3:08 now.     I don't

19     know whether that one hour opening, whether that window has

20     already shut.

21                So, Mr. Cohen, you will do your best.        Maybe it is

22     feasible.    Maybe not.    I don't know what the ins and outs are

23     of the clerk's office procedure for that one-hour window.

24                MR. COHEN:    Your Honor, I will email Trina and we will

25     figure it out.
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 30 of3031



 1                THE COURT:    Don't forget, you also have the Nebbia

 2     requirement.

 3                MR. COHEN:    Yes.

 4                THE COURT:    OK.

 5                MR. COHEN:    Thank you, your Honor.

 6                THE MARSHAL:    Judge, this is Candido again.       Just to

 7     let all parties be aware, we only hold defendants here until

 8     about 5 p.m., which is about the time that the clerk's office

 9     routinely closes.     So if we don't hear anything by say 5:00, we

10     are going to roll him over to FDC.

11                THE COURT:    Thank you, Candido.

12                MR. GARCIA:    Your Honor, from Probation's perspective,

13     once Mr. Vazquez posts the bond he has to report to the U.S.

14     Probation Office on the ninth floor of the Ferguson U.S.

15     courthouse.    If Mr. Cohen can make a note of that as well and

16     remind his client of that requirement.         Thank you.

17                THE COURT:    Well, Mr. Garcia, just so there is no

18     confusion, let's say for the sake of discussion Mr. Vazquez is

19     released at ten minutes after 5 today and so by the time he

20     gets over to the Ferguson building it is 5:30.          Is your office

21     going to be open for him to visit with somebody there?

22                MR. GARCIA:    No, your Honor.     We will require him to

23     report within 24 hours.        He could come in to report tomorrow.

24                THE COURT:    There you go.

25                MR. GARCIA:    Absolutely.
Case 1:21-cr-20231-DMM Document 59 Entered on FLSD Docket 11/15/2021 Page 31 of3131



 1                THE COURT:    I just want to make it clear so people

 2     don't get unduly agitated and jazzed up.

 3                MR. GARCIA:    Right.

 4                THE COURT:    OK, folks.    Very well.    Does anybody else

 5     have any business with the court this afternoon?

 6                MR. COHEN:    Thank you, your Honor.

 7                THE COURT:    All right.

 8                MR. O'BYRNE:    I think that is it.      Thank you, your

 9     Honor.

10                THE COURT:    We will be in recess.      Take care.    Bye

11     now.

12                (Adjourned)

13

14                              C E R T I F I C A T E

15

16            I hereby certify that the foregoing is an accurate

17     transcription to the best of my ability of the digital audio

18     recording in the above-entitled matter.

19

20     November 1, 2021           s/ Joanne Mancari
                                  Joanne Mancari, RPR, CRR, CSR
21                                Court Reporter
                                  jemancari@gmail.com
22

23

24

25


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