Court filing
Transcript of Jury Trial Proceedings, Volume 1 — Carla Jackson and Teldrin Foster
Summary
Transcript of jury trial proceedings, Volume 1, of February 5, 2024 before the Honorable J.P. Boulee, United States District Judge, filed June 14, 2024 as Document 1024 in United States v. Teldrin Foster, et al., Docket No. 1:20-CR-00296-JPB, in the U.S. District Court for the Northern District of Georgia, Atlanta Division. The appearances list counsel for the government and for defendants Teldrin Foster, Carla Jackson, and Jerry Baptist, who is marked not present. The Court states its intent to issue a warrant to have Mr. Baptiste brought to court, and a portion of the proceedings is marked under seal. The Court also states that a motion to exclude is denied and that a pretrial Daubert hearing is not necessary for the agent's testimony.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Transcript of Jury Trial Proceedings, Volume 1 — Carla Jackson and Teldrin Foster.”
Original at ecf.gand.uscourts.gov, No. 1:20-cr-00296-JPB-CMS, Doc. 1024. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-dixon/2024-02-05-jury-trial-transcript-vol1-dkt-1024/
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1 UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
2 ATLANTA DIVISION
3
4 UNITED STATES OF AMERICA, )
)
5 )
-VS- ) DOCKET NO. 1:20-CR-00296-JPB
6 ) VOLUME 1
TELDRIN FOSTER, ET AL, )
7 )
DEFENDANT. )
8
9 TRANSCRIPT OF JURY TRIAL PROCEEDINGS
BEFORE THE HONORABLE J.P. BOULEE
10 UNITED STATES DISTRICT JUDGE
FEBRUARY 5, 2024
11
APPEARANCES:
12
ON BEHALF OF THE GOVERNMENT:
13 TAL C. CHAIKEN, ESQ.
SAMIR KAUSHAL, ESQ.
14 BABASIJIBOMI MOORE, ESQ.
ASSISTANT UNITED STATES ATTORNEYS
15
ON BEHALF OF THE DEFENDANT - TELDRIN FOSTER:
16 LEIGH ANN WEBSTER, ESQ.
SARALIENE DURRETT, ESQ.
17
ON BEHALF OF THE DEFENDANT - CARLA JACKSON:
18 DAVID D. MARSHALL, ESQ.
19 ON BEHALF OF THE DEFENDANT - JERRY BAPTIST (NOT PRESENT)
DOUGLAS W. GILFILLAN, ESQ.
20 ADITYA SHRIVASTAVA, ESQ.
21
STENOGRAPHICALLY RECORDED BY:
22
PENNY PRITTY COUDRIET, RMR, CRR
23 OFFICIAL COURT REPORTER
UNITED STATES DISTRICT COURT
24 ATLANTA, GEORGIA
25
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2 (PROCEEDINGS HELD IN OPEN COURT AT 9:08 AM, ATLANTA, GEORGIA)
3 COURTROOM DEPUTY CLERK: The Court has set aside time
4 for a jury trial in Case Number 120-CR-296, the
5 United States v. Jackson, et al.
6 Counsel, will you please make your appearances for
7 the record.
8 MS. CHAIKEN: Good morning, Your Honor. Tal Chaiken
9 for the United States. I'm joined by my trial counsel, Samir
10 Kaushal and Siji Moore. Behind us is our Alisha Holland from
11 our office, as well as Special Agents Joe Stites and Stefan
12 Bublitz from the FBI.
13 THE COURT: Good to see all of you.
14 MS. WEBSTER: Good morning, Your Honor. Leigh Ann
15 Webster on behalf of Teldrin Foster, who is here. And then
16 Saraliene Durrett is downstairs.
17 THE COURT: All right. Thank you very much.
18 MR. MARSHALL: Good morning, Judge. David Marshall
19 on behalf of Defendant Carla Jackson. And with us at the
20 table is our paralegal, Ms. Sophia Ryan.
21 MR. GILFILLAN: Good morning, Your Honor. Doug
22 Gilfillan, standby counsel for Mr. Baptiste. I am here today.
23 THE COURT: All right. Good to see all of you.
24 All right. We have a couple unexpected issues that
25 have arisen over the last 24, 48 hours or so. Let me take the
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1 one that's just arisen in the last ten minutes or so.
2 Mr. Baptiste is not here. He's been duly notified of
3 this trial date and he's not here. And I understand that
4 we've made attempts to reach out to him to no avail. Is that
5 correct, Ms. Lee?
6 COURTROOM DEPUTY CLERK: Yes.
7 THE COURT: Is that correct, Mr. Gilfillan?
8 MR. GILFILLAN: Yes, Your Honor.
9 THE COURT: It's my intent, therefore, to issue a
10 warrant to have Mr. Baptiste brought to court.
11 Ms. Lee, if you could coordinate that with
12 Ms. Chaiken and with the US Marshal Service, I would
13 appreciate it.
14 The second issue is -- one moment.
15 Ms. Durrett, I'll ask you on this second issue.
16 Would you like me to go under seal for this discussion? I
17 know that you'd e-mailed the Court and the -- all the counsel
18 as to the issue, but I'd be happy to go under seal for this if
19 you'd like.
20 I think she can hear us, but we can't hear her
21 perhaps. So, yeah, she'll just call in.
22 (The following proceedings are under seal:)
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21 (Off-the-record discussion.)
22 (After a recess, the proceedings continued at
23 9:44 a.m. as follows:)
24 THE COURT: The record will reflect that I just
25 signed a warrant for the arrest of Jerry Baptiste. Thank you.
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1 We're off the record.
2 (Off-the-record discussion.)
3 (After a recess, the proceedings continued at 10:02
4 a.m. as follows:)
5 THE COURT: All right. Before we begin the trial, I
6 wanted to just follow up with some orders that I issued via
7 docket entry just in summary form last week. I wanted to
8 follow up and give more detail on my rulings of those.
9 I think it was January 31st I entered an order
10 denying Mr. Foster's motion to exclude expert testimony and
11 also his motion to sever.
12 As far as the motion to exclude the expert testimony,
13 it was 830. In short, the parties dispute what deadline for
14 expert disclosure applied to the government in this case. In
15 any event, the government's disclosure of its intent to call
16 Special Agent Jay Berni to testify as to cell site data on
17 January 19th, 2024, may have been untimely. And for the
18 purposes of this motion and my ruling, I'm going to assume it
19 was, but I recognize the government's arguments to the
20 contrary. And it's a little confusing.
21 On December 1st, 2022, the Federal Rule of Criminal
22 Procedure was amended to require that the Court, by order or
23 local rule, must set a time for the government to make its
24 disclosures. Under the rule, the time must be sufficiently
25 before trial to provide a fair opportunity for the defendant
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1 to meet the government's evidence.
2 After the rule was amended, this district implemented
3 a pretrial scheduling order that requires the government to
4 disclose its expert, if requested by the defendant, no later
5 than 14 days after the case is certified ready for trial, but
6 that scheduling order wasn't entered in this case because it
7 was before that.
8 Defendant argues for this case, the Court's local
9 rules provide that the deadline was, in fact, earlier, at the
10 time of the arrangement.
11 But, anyway, I'm going to assume it was untimely for
12 the purposes of my ruling.
13 If a party fails to comply with the requirements of
14 Rule 16, a trial court may, A, order that the party permit the
15 discovery or inspection, specify its time, place and manner
16 and prescribe other just terms and conditions; B, grant a
17 continuance; C, prohibit that party from introducing the
18 undisclosed evidence or enter any other order that is just
19 under the circumstances. And this Court has wide discretion
20 in deciding whether to admit the testimony. And also the
21 discretion to fashion other appropriate relief. That's the US
22 v. Perez case, 960 F.2d 1569 at 1572 from the Eleventh
23 Circuit.
24 In exercising its discretion, the district court must
25 weigh several factors, and if it decides a sanction is in
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1 order, should fashion the least severe sanction that will
2 accomplish the desired result, prompting full compliance with
3 the Court's discovery orders. That's US v. Euceda,
4 E-U-C-E-D-A, Hernandez, 768 F.2d 1307 at 1312, Eleventh
5 Circuit, 1985.
6 Among the factors the Court must weigh are the
7 reasons for the government's delay in affording the required
8 discovery, the extent of prejudice, if any, the defendant has
9 suffered because of the delay, and the feasibility of curing
10 such prejudice by granting a continuance or, if the jury's
11 been sworn and trial has begun, a recess.
12 The presence of a clear violation of a discovery
13 order does not excuse a trial from weighing these -- trial
14 judge from weighing these factors and imposing the least
15 severe but effective sanction.
16 Here, Defendant Foster has requested the government
17 be prohibited from introducing Special Agent Jay Berni's
18 expert testimony at trial. Exclusion of the evidence is an
19 extreme sanction. That's from Perez at 1573, quoting US v.
20 Turner, 871 F.2d 1574 at 1580, also the Eleventh Circuit. And
21 that was a cert denied case at 493 US 997 from 1989.
22 I'll also note that the purpose for requiring the
23 government to disclose evidence is to promote the fair and
24 efficient administration of criminal justice by providing the
25 defendant with enough information to make an informed decision
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1 as to a plea by minimizing the undesirable effect of surprise
2 at trial and by otherwise contributing to an accurate
3 determination of the issue of guilt or innocence.
4 That's also from Euceda-Hernandez. And that's
5 quoting a Federal Rule of Criminal Procedure, 16 Advisory
6 Committee Note.
7 By suppressing the government's evidence rather than
8 granting a continuance or recess, a trial judge may achieve a
9 speedier resolution to a criminal case and reduce his docket,
10 but he does so at the expense of sacrificing the fair
11 administration of justice and the accurate determination of
12 guilt and innocence. That's at 1312.
13 Weighing the circumstance surrounding the
14 government's arguably late disclosure here, the Court finds
15 that the extreme sanction of excluding evidence is unwarranted
16 in this instance. The Court is not convinced that the
17 January 19th, 2024, disclosure will unfairly prejudice Foster
18 such that the agent's testimony need to be admitted.
19 The record demonstrates that Foster possessed the
20 underlying evidence, the cell site location data, to which the
21 agent will be testifying for two-and-a-half years. The
22 government's offered -- and the government has represented
23 that the testimony is needed to rebut the proffered testimony
24 of Foster's own expert, who was disclosed on January 12th,
25 2024.
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1 Moreover, there's no allegation that the government's
2 late disclosure was done in bad faith.
3 However, to alleviate any potential prejudice in
4 accordance with Rule 16(d)(2)(D), which allows the Court to
5 enter any other order that is just under the circumstances, on
6 February 2nd, the Court ordered that the government make
7 Special Agent Berni available to defense counsel prior to
8 trial so that defense counsel had an opportunity to consult
9 with the expert before the testimony is elicited. And that
10 was docket entry 854.
11 And that's in part in response to, in the reply
12 brief, the defendant argued that the government's late
13 disclosure deprived Mr. Foster of the ability to meaningfully
14 consult with the expert to challenge the witness's testimony.
15 Moreover, the government (sic) is now going to direct
16 the government not to call Agent Berni before Thursday of this
17 week to give defense a little extra time to digest those
18 issues.
19 The Court finds that this is the least severe remedy
20 necessary to ensure -- these remedies are the least severe
21 necessary to ensure that Foster has adequate time to assess
22 the opinions that will be elicited at trial and to prepare
23 Mr. Foster's defense.
24 The motion to exclude, again, is denied.
25 Additionally, the Court is not persuaded that a
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1 pretrial Daubert hearing is necessary for the agent's
2 testimony. This type of expert testimony is routine for cases
3 involving cell site location information and its reliability
4 for determining the general location of a cell phone is well
5 established. United States v. Crumpton, 3:22-CR-12-TES-1,
6 2023 WL 6323792 at 4, Middle District of Georgia, from
7 September 28th, 2023, noting that district courts largely
8 agree on the reliability of historical cell site analysis.
9 While Daubert requires the district court to serve as
10 a gatekeeper, it need not conduct a formal hearing where the
11 reliability of an expert's methods is properly taken for
12 granted, US v. Rodriguez, 591 F.App'x 897 and 899, it's the
13 Eleventh Circuit from 2015, quoting Kumho Tire, 526 US 152.
14 However, if at the time of the testimony, defense
15 counsel believes Agent Berni's testimony doesn't meet the
16 requirements of 702, they may object at the time of trial.
17 Again, the request is denied.
18 And I will add, in deciding this, I noted that late
19 disclosure of evidence required to be turned over under
20 Rule 16 or a standing discovery order necessitates reversal
21 only when -- my decision would be reversed only if it violates
22 a defendant's substantial rights. So I thought about whether
23 or not this would violate substantial rights. And that's from
24 the Camargo-Vergara case, 57 F.3d at 993 at 998, Eleventh
25 Circuit, in 1995.
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1 And the factors there are substantial prejudicial
2 results if a defendant is unduly surprised and lacks an
3 adequate opportunity to prepare a defense.
4 And, again, I don't know that there is any undue
5 surprise here, especially given the extra time that's been
6 given and the opportunity to consult with the expert and,
7 frankly, the reason the government came in with the expert in
8 response to the defense expert. And I believe the defendant
9 has now had adequate opportunity to prepare the defense and
10 will have additional time to do so.
11 As far as the motion to sever, Docket 866, in the
12 Eleventh Circuit, the general rule is that defendants who are
13 jointly indicted should usually be tried together, US v.
14 Lopez, 648 F.3d at 1222, pinpoint's 1234, Eleventh Circuit,
15 from 2011.
16 This is especially true where defendants are charged
17 in a common conspiracy. This general rule reduces the risk of
18 inconsistent verdicts and the unfairness inherent in serial
19 trials, lightens the burden on victims and witnesses,
20 increases efficiency and conserves scarce judicial resources.
21 However, Federal Rule of Criminal Procedure 14(a)
22 provides if the joinder of offenses or defendants in an
23 indictment and information or consolidation for trial appears
24 to prejudice the defendant or the government, the Court may
25 order separate trials of counts, sever the defendants' trials,
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1 or provide any other relief that justice requires.
2 Thus, if a defendant is able to demonstrate that a
3 joint trial will result in specific and compelling prejudice
4 to the conduct of his defense, a Rule 14 severance may be
5 granted. That's the US v. Blasingame case, 219 F.App'x 934 at
6 948, Eleventh Circuit, 2007. To determine whether a defendant
7 has demonstrated compelling prejudice, the Court must assess
8 whether under all the circumstances of a particular case, as a
9 practical matter, it is within the capacity of the jury to
10 follow the instructions and, accordingly, appraise the
11 independent evidence against each defendant's own acts,
12 statements or conduct.
13 A defendant can show compelling prejudice by showing
14 that the jury would be unable to sift through the evidence and
15 make an individualized determination as to each defendant,
16 United States v. Cassano, 132 F.3d 646 at 651, Eleventh
17 Circuit, 1998.
18 Moreover, to show compelling prejudice warranting
19 severance, a defendant must show that the other remedies, such
20 as jury instructions, are not sufficient.
21 Here, the Court is not persuaded that the jury will
22 be unable to sift through the evidence and make an
23 individualized determination as to Mr. Foster, merely because
24 evidence introduced at trial makes reference to auto loans.
25 The government has previously represented that it will not
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1 introduce any affirmative evidence of auto loan fraud, and the
2 Court finds that, if needed, an appropriate limiting
3 instruction to the jury should guard against any prejudice
4 that would arise from the introduction of such evidence and/or
5 focus on it during potential cross-examination.
6 Thus, the motion to sever is denied.
7 And I'd be happy if -- whether it's this motion to
8 sever or the other motion to sever, again, if anyone wants a
9 jury instruction at any point, I'd be happy to review your
10 proposed instruction and entertain giving that at the
11 appropriate time. Just let me know and please present to me
12 whatever you might like and we can discuss it.
13 All right. That is all I needed to handle before we
14 got started this morning. But before we get started, before
15 we start this trial, I want to discuss the issue of
16 Mr. Baptiste's absence.
17 Again, at 9:00 he was not here. We attempted to
18 contact him. His standby counsel attempted to contact him.
19 All to no avail.
20 Waited a little while and then issued a warrant at
21 about 9:45 or so. It is now 10:15. So we have a few
22 options -- well, at least a couple.
23 One is we can start the trial without Mr. Baptiste,
24 which obviously would require us to try Mr. Baptiste at some
25 later date. And I'm aware of the fact that this is set to be
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1 probably about a two-week trial. That's option 1.
2 Option 2 is we could wait a little while to see if
3 the US Marshals are able to find Mr. Baptiste and bring him
4 here for trial. And I said a few, but I think it's just a
5 couple, unless, Ms. Chaiken, you can think of any other
6 options. And as far as how long we wait, that can be until
7 after lunch, that could be until tomorrow morning.
8 I've spoken with jury management and they have jurors
9 available for us now. Those jurors can wait and have a nice
10 long lunch and be here after lunch, or those jurors could come
11 back in the morning.
12 So happy to open the floor and hear from anyone as to
13 your thoughts on what we should do. I think it's probably
14 most relevant to hear from the government, but to the extent
15 that anyone else wants to be heard, I'd be happy to hear from
16 them as well.
17 MS. CHAIKEN: Could we have one moment, Your Honor?
18 THE COURT: Sure.
19 (Pause in the proceedings.)
20 MS. CHAIKEN: Your Honor, we'd like to give agents a
21 couple of hours to try to locate him and start after lunch, if
22 possible. We have several witnesses who we anticipate
23 testifying whose testimony will no longer be needed if
24 Mr. Baptiste is not part of the trial. And so if he's not
25 located, the trial will be shorter anyway. So we're not, you
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1 know -- we don't think we really lose much by waiting a couple
2 of hours.
3 But, obviously, if we do find him during that time,
4 that would eliminate the need for a whole second trial. So
5 while we don't want to wait too long, we do have some
6 potential addresses and potential things we can try to track
7 down that we think it's at least worth just waiting a couple
8 of hours to find.
9 THE COURT: Okay.
10 MS. CHAIKEN: Or to pursue.
11 THE COURT: Give me a better feel for -- and I
12 know -- I think your last estimate was probably about two
13 weeks, might go a little into the third week for this trial.
14 Tell me how the length of this trial is affected if he were
15 not here and how long you think it would take to try him
16 separately.
17 MS. CHAIKEN: I think if he were -- if he were not
18 here, this trial would probably be shortened by approximately
19 two days.
20 THE COURT: And I'm not going to hold you --
21 MS. CHAIKEN: Two to three days.
22 THE COURT: I'm just trying to get an estimate.
23 MS. CHAIKEN: Two days, I think. If we were to try
24 him alone, I think the trial would probably be three to five
25 days.
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1 THE COURT: Okay. Thank you.
2 Although I know perhaps there's not a dog in the hunt
3 exactly, but I'd be happy to hear from counsel for Ms. Jackson
4 or counsel for Mr. Foster, if you have any thoughts on this
5 issue.
6 MS. WEBSTER: I don't think that we have strong
7 feelings on how to move forward with this.
8 THE COURT: Very well.
9 MR. MARSHALL: Judge, I have no objection to the
10 government's recommendation. I had to do that in another case
11 of mine, we had to wait a few hours, so that's fine.
12 THE COURT: Okay. Let's do this, let's see where we
13 are at 1:00. And we'll decide then -- I'll let you know. I
14 mean, there's a possibility, obviously, at 1:00 Mr. Baptiste
15 will be here and hunky-dory and we'll start jury selection.
16 And if he's not, we may either move forward with jury
17 selection without him or I may decide to wait until tomorrow
18 morning to start jury selection.
19 I would like -- you know, I think as -- I mean,
20 coincidentally, I was just reading some of the materials on
21 the severance motion and some of the reasons you don't want to
22 sever, including judicial efficiency and whatnot. And I'd
23 like to, and I think it would serve justice, to try everyone
24 together here, if possible. So it may be that I decide to
25 wait until tomorrow morning anyway, but let's just at least
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1 see where we are at 1:00.
2 All right. So we will --
3 MR. MARSHALL: Your Honor?
4 THE COURT: Yes.
5 MR. MARSHALL: Can I address one matter before we
6 adjourn?
7 THE COURT: Yes.
8 MR. MARSHALL: I filed yesterday on ECF a motion in
9 limine. And I e-mailed a copy of that to chambers. And I
10 wanted --
11 THE COURT: I've got it right here in front of me.
12 MR. MARSHALL: Thank you, Judge.
13 And I know the government hasn't had a chance to
14 obviously file a written response, but I wanted to address it
15 before we started with opening statements for sure, Judge.
16 THE COURT: Okay. Thank you. Yes.
17 I was aware of it. Frankly, had it on the back
18 burner relative to some concerns we addressed under seal
19 earlier this morning involving some health issues and then
20 Mr. Baptiste's absence and the motions I wanted to get on the
21 record.
22 But, yes, I'm aware of that. Thank you.
23 And while we're at it, let me hear from the
24 government as to when might be a good time to respond.
25 Obviously, I'd like to decide that if I can before opening
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1 statements.
2 MS. CHAIKEN: I'm happy to respond now, Your Honor,
3 if that would be appropriate.
4 THE COURT: Well, it would had I read the motion yet.
5 And I have to confess that I haven't. So it probably would be
6 a more worthwhile response after I've read the motion, so --
7 MS. CHAIKEN: I can narrow the issues.
8 THE COURT: If you want to narrow the part of the
9 motion that's going to be relevant after you say something,
10 I'm happy to have you do that.
11 MS. CHAIKEN: Yes. So, Your Honor, we had been
12 preparing for a trial with four defendants, including John
13 Gaines, as to whom we had filed a 404(b) notice. He pled
14 guilty, I think, on Wednesday. We did not remove the exhibits
15 that we were planning to introduce. We had not, at the time
16 we shared our exhibits with the defense, sorted through what
17 we were and were not going to introduce now that he was no
18 longer part of the case.
19 So there were materials that Mr. Marshall had
20 identified in his motion that related to a Paycheck Protection
21 Program loan filed by a -- or prepared in connection with a
22 business called Roadrunner Automotive Group. We are not going
23 to be seeking to admit those materials at trial.
24 The only thing that we are seeking to admit at trial
25 related to Roadrunner Automotive Group is bank records that
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1 show that in June of 2020 Ms. Jackson and John Gaines were
2 signers together on that account and that money from the
3 Gaines Reservation & Travel PPP loan went from Gaines
4 Reservation & Travel to Darrell Thomas's company, Bellator
5 Phront Group, and then to Roadrunner. And that those were
6 proceeds of the same loan with which Ms. Jackson is charged
7 with laundering money that went to a separate account that she
8 was a signer on. And, actually, at the time it went to that
9 account she was the only signer on the account. John Gaines
10 was added to that account a little bit after that.
11 And so the -- you know, I understand the Court may
12 want to read the motion and then hear my argument about why
13 it's intrinsic evidence in our view, but everything other than
14 that that's addressed in the motion we're not planning to
15 introduce.
16 THE COURT: All right. Well, so since we're so far
17 down the road already, why don't you go ahead and make your
18 argument. And then I'll adjust your argument from the written
19 record after I've read the motion.
20 So go ahead.
21 MS. CHAIKEN: Our view is that it's intrinsic
22 evidence because it's necessary to understand the crime
23 charged. It's necessary to understand the Gaines Reservation
24 & Travel loan and where those proceeds went. And we have to
25 prove that the Gaines Reservation & Travel loan was
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1 fraudulent.
2 We have to -- even though Ms. Jackson is not charged
3 with the fraud itself, we have to prove as a third element of
4 money laundering that the money did come from an unlawful
5 activity, which is wire fraud. The fact that that money was
6 used to go to the account of Darrell Thomas, who was involved
7 in the submission and preparation of the Gaines Reservation &
8 Travel loan and then went back to John Gaines and Carla
9 Jackson is relevant to proving that that loan was fraudulent.
10 And it's also part of the same series of transactions that
11 Ms. Jackson is charged with, the movement of the money from
12 the Gaines Reservation & Travel loan.
13 THE COURT: All right. Thank you.
14 Mr. Marshall, anything in reply?
15 MR. MARSHALL: Judge, I just think it -- that
16 reference, if they introduce the signature card, that makes
17 the jurors think that somehow she's involved some way with
18 Darrell Thomas and John Gaines involved in those moneys.
19 She's not charged in a conspiracy count, Judge. She's charged
20 with two counts related to Management Resource Services, which
21 is her company.
22 So one thing I could suggest, if the government's
23 fine, I don't mind this stuff coming in if we could redact
24 Ms. Jackson's name on the signature card. You know, it
25 doesn't need to be there to show that she was a signer on the
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1 account. Mr. Gaines was a signer on the account, and I think
2 that's what they're trying to aim for, is the movement of
3 money and the activities of John Gaines and Darrell Thomas,
4 not my client.
5 I think it improperly puts my client's character at
6 issue for a charge that she's not -- she hasn't been charged
7 with any of these, the conspiracy count, or any of the other
8 charges, Judge.
9 MS. CHAIKEN: Your Honor, Mr. Gaines was not a signer
10 on the account at the time that the money came in. And so to
11 redact her name from the signature card would leave the jury
12 with having no idea who the signer was on the account at the
13 time the money went into it.
14 And it's also highly relevant evidence to the jury's
15 understanding of Ms. Jackson's relationship and connection to
16 John Gaines, who we understand is going to be a defense
17 witness at trial. And she is charged with Mr. Gaines in money
18 laundering -- in the money laundering counts related to
19 Management Resource Services. And this is part of their
20 understanding of what John Gaines' and Carla Jackson's
21 financial entanglements were at that point in time.
22 It's the exact same time period, June 2020, in which
23 she's charged with money laundering proceeds of the same loan
24 that went into another account. It shows the jury that
25 there's two separate accounts that went in there.
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1 THE COURT: Thank you, Ms. Chaiken.
2 Mr. Marshall, your motion, so I'll give you the last
3 word.
4 MR. MARSHALL: Again, I think it would have been more
5 appropriate if, for instance, the government had filed a
6 404(b) notice at the start against my client to give an
7 indication that they were going to introduce any records
8 related to Roadrunner. And she's just not charged with any of
9 the conspiracy counts, what expands it, and it gives the jury
10 a thought to think that she's involved in another company, in
11 other activities, and I just think it broadens it, Judge, and
12 it's not permissible. It's not intrinsic evidence.
13 THE COURT: All right. Thank you.
14 I will review the motion and then I'll look back over
15 the court reporter's record of this conversation and I'll
16 circle back and let you know what my ruling is, or I may have
17 some follow-up questions at that time when I'm a little bit
18 better informed.
19 All right. It is 10:28. Can anyone else think of
20 any productive use of our time or should we just recess till
21 1:00?
22 MS. CHAIKEN: Your Honor, Mr. Kaushal has a couple
23 more things.
24 MR. KAUSHAL: Your Honor, just one issue that we are
25 now -- since we've talked about the potential of John Gaines
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1 being called, I just want to flag for Your Honor that there
2 may be a question as to whether witnesses that are called by
3 the defense need to be advised of their Fifth Amendment rights
4 to remain silent when they testify.
5 For example, Mr. Gaines has a pending sentencing
6 before Your Honor. I've -- we've loosely discussed the matter
7 with defense counsel, but I think -- we don't need a final
8 answer right now. I just wanted to flag it for your Honor's
9 consideration as we move through the trial and reach that
10 point. We can have the discussion at that time, but I just
11 wanted to raise it for Your Honor, that that may be an issue
12 that comes up.
13 MR. MARSHALL: Judge, can I address that too?
14 THE COURT: Yes.
15 MR. MARSHALL: Judge, while I would hope that the
16 government also provided that same type of cautionary
17 instruction or discussion with Darrell Thomas, who is expected
18 to testify for the government, I don't know if they've done
19 that.
20 I've had communications with Mr. John Gaines'
21 counsel, Ms. Wiley, and she indicated that there were
22 discussions with the government -- I'm summarizing, Judge, I'm
23 not -- as I understood it, was that there was some indication,
24 some kind of -- I don't want to call it a threat -- an implied
25 threat would be the worst I would say, Judge, of a possible
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1 obstruction charge. If not an obstruction charge, that
2 Mr. John Gaines would face an elevated sentencing guideline if
3 he testified.
4 And if that wasn't enough, I think there was a
5 suggestion that he could take the Fifth, invoke his Fifth
6 Amendment right on the stand. I consider that interfering
7 with the witness, Judge. I think if I were doing that to a
8 witness that the government was intending to call, I think
9 there would be a lot of concern for me.
10 So I think Ms. Wiley is the one who needs to have
11 that communicated to by the government, and Ms. Wiley can
12 decide if she wants to discuss that with him or not.
13 MR. KAUSHAL: Your Honor, this is a serious
14 accusation from the defense, and I don't think that they're
15 thinking through what actually occurred. The defense counsel
16 was not involved in the conversation that we had with the
17 defendant, Mr. Gaines' counsel. Mr. Gaines was not on that
18 phone call, to our knowledge.
19 We were discussing, in the context of a plea
20 negotiation, the possibility that there could be something
21 that occurs when the defendant testifies and that that could
22 raise a risk of something occurring with the guidelines. We
23 did not threaten the witness. We did not suggest that the
24 defendant would be charged with obstruction. We merely noted
25 that there is a possibility that somebody who testifies and
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1 has exposure could potentially receive an enhancement under
2 the guidelines.
3 So if defense wants to level this accusation, I think
4 they shouldn't be allowed to do it in this way. They should
5 formalize their accusation if they are serious about it. But
6 that is not what occurred. And that is not what the
7 government was doing when it had a discussion with defense
8 counsel about a possible risk in the context of a plea
9 negotiation.
10 There is a distinguishing factor between these
11 particular -- for example, Mr. Gaines, who has a pending
12 sentencing, and any potential cooperator in this case, and,
13 you know, the government has not -- the individuals who may
14 testify in this case have entered into plea agreements with
15 the government. They -- those plea agreements formalize their
16 cooperation.
17 And, again, that's an issue. If the defense has a
18 concern, we can talk about whether there's a necessity to
19 advise those individuals as well, if they really believe
20 that's necessary. This is not an attempt to intimidate any
21 witness. I was just raising the issue so that the Court would
22 be aware that there's a potential that this may occur.
23 And there is at least one other witness that the
24 government is aware of that may be called by a defense party,
25 not Mr. Marshall, but the government learned that counsel for
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1 Mr. Foster may be having a witness appear, Ricky Dixon, which
2 is another individual who may testify on behalf of the
3 defense. And if he testifies, the same issue comes up.
4 According to the docket, he is pro se at this time and he has
5 a pending 2255.
6 So this is an issue that there just needs to be a
7 frank discussion about. This is not an effort to influence
8 any particular witness's testimony. It is simply a way to
9 protect those defendants' rights. That is all the government
10 has proposed and tossed out there for the Court to consider as
11 we approach these -- as we move towards that part of the case.
12 THE COURT: All right. Thanks, everyone.
13 Please just remind me when we get to -- if and when
14 Mr. Gaines is called and if and when Mr. Dixon is called, we
15 can address that issue then. It may be that they have counsel
16 with them when they appear or may not --
17 MS. WEBSTER: I'm sorry, Your Honor, I can't hear
18 you.
19 THE COURT: Sure. It may be that they have counsel
20 with them when they appear and that might affect how we handle
21 the issue. But I'm always happy to read somebody their
22 constitutional rights when necessary. Just let me know.
23 All right?
24 MR. KAUSHAL: Thank you, Your Honor.
25 THE COURT: Okay. What else, if anything, can we do
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1 to occupy our time or have we completed the list?
2 MS. WEBSTER: Your Honor, we were going to address
3 this ex parte, but I think that for Mr. Dixon and any other
4 witness, I think it's appropriate for counsel to be appointed
5 at some point to advise them as to their rights. I think it's
6 a little different with Mr. Gaines, because he currently has
7 counsel, but for Mr. Dixon, I think it would be appropriate
8 for the Court to appoint counsel to advise him before he
9 testifies.
10 THE COURT: He's currently pro se?
11 MS. CHAIKEN: That's our understanding, Your Honor.
12 He filed a pro se 2255 challenging his conviction on the basis
13 that his attorney was ineffective. And so unless a new
14 attorney has in some way been appointed for him that we're not
15 aware of, he's pro se.
16 THE COURT: I'm happy to let him talk to an attorney
17 and do that, if we can get those documents drawn up, and if he
18 wants to speak with someone, he can. Okay.
19 Ms. Mueller, if you can perhaps assist with that.
20 Thank you.
21 All right. Anything else?
22 MS. CHAIKEN: Your Honor, I just want to preview for
23 the Court that if Mr. Baptiste ultimately does not show up,
24 we -- with the way we've scheduled our witnesses and with the
25 Court's order now that Mr. Berni -- or Agent Berni cannot
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1 testify until Thursday, we may end up having some dead time on
2 Wednesday. We are working --
3 THE COURT: Let's do it -- I just want to give the
4 defense a little extra time. And, frankly, we've now got a
5 few hours here with nothing to do. So would noon Wednesday be
6 workable for the government? I don't want to inconvenience
7 the government too much, but at the same time, I want to make
8 sure Defendant Foster has a little extra time.
9 Would noon Wednesday be better?
10 MS. CHAIKEN: It's fine with us. We --
11 THE COURT: I would like to avoid dead time, and
12 you're telling me that there's dead time if it's not until
13 Thursday?
14 MS. CHAIKEN: Well, we're calling -- we have several
15 witnesses who are not scheduled to arrive until late
16 Wednesday, and we've asked our witness coordinators to get in
17 touch with all of them and see if they can come earlier. And
18 so we're working on it as we speak. I just wanted to preview
19 that we don't -- we're not 100 percent sure we can fill all
20 that time because we're going to lose several witnesses if
21 Mr. Baptiste is not here.
22 THE COURT: All right. If you make efforts to fill
23 time and you can wait until Thursday to call him, let's do
24 that.
25 MS. CHAIKEN: Okay.
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1 THE COURT: But if there's going to be dead time and
2 you tell me you've made efforts to fill it and otherwise he's
3 who we've got here and ready, I'd be inclined to let you call
4 him on Wednesday afternoon.
5 And if at that point, Ms. Webster, you need an
6 additional half day to prepare for that testimony, let me know
7 as they call him and I'll cross that bridge when we come to
8 it. Okay?
9 MS. WEBSTER: Thank you, Your Honor.
10 MS. CHAIKEN: Thank you, Your Honor.
11 MR. MARSHALL: Has the government provided -- have
12 you provided a full witness list yet?
13 MS. CHAIKEN: No. We're planning on providing our
14 witnesses the evening before each --
15 MR. MARSHALL: Day before each one?
16 MS. CHAIKEN: Yeah. We have provided last night our
17 witnesses for today.
18 THE COURT: All right. Thanks, everyone. We'll see
19 you at 1:00. Thanks for everyone's patience. Take care.
20 (After a recess, proceedings were continued as
21 follows:)
22 THE COURT: It is about 1:00. Back on the record.
23 Do we have any report from the marshals?
24 MS. CHAIKEN: Your Honor, we have a -- some updated
25 information we would like to provide to the Court but not in
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1 open court.
2 THE COURT: Okay. If I could ask everyone to step
3 out except Ms. Chaiken and government counsel for a moment.
4 Is it something that not even the other counsel could
5 hear?
6 MS. CHAIKEN: That would be our preference, Your
7 Honor. It relates to ongoing investigative --
8 THE COURT: Can you give me just like subject matter
9 so I can make a record of that.
10 MS. CHAIKEN: Just ongoing investigative efforts to
11 locate Mr. Baptiste.
12 THE COURT: All right.
13 Counsel, any objection to stepping out for a moment
14 just while I discuss that issue with the government?
15 MS. WEBSTER: I don't think so, Your Honor.
16 THE COURT: Thanks, everyone. If you'll step out
17 just for a moment.
18 (Courtroom cleared of all but United States
19 Attorney's Office personnel.)
20 (The following proceedings are under seal.)
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21 (Record is unsealed and the courtroom open.)
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23 THE COURT: We are back out under seal and back on
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25 I've had a conversation with the government about their
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1 efforts to locate Mr. Baptiste, the sum and substance of which
2 is that they have not located Mr. Baptiste, but they think
3 there's a possibility they might be able to locate him this
4 afternoon.
5 I'm an optimist and I'm hopeful that we will be able
6 to have Mr. Baptiste here tomorrow morning so that we can have
7 this trial with the three remaining defendants all at one
8 time. And I think it's worthwhile to give it the afternoon to
9 see if that is possible or not.
10 Also, I'm cognitive of the fact it's 1:15 almost
11 already, and it would probably be another 15 minutes before
12 all the jurors are shuffled in if we went forward without him
13 this afternoon. And who knows what we have for juror
14 conflicts and et cetera, the 5:00 hour with childcare. So I
15 don't know how much we would get through of voir dire today
16 anyway.
17 Therefore, I would like everyone to report tomorrow
18 at 9:00 at which time it will be my intent to bring the jury
19 up, whether we have Mr. Baptiste or whether we don't have
20 Mr. Baptiste.
21 And at that time if we don't have Mr. Baptiste,
22 Mr. Gilfillan, I'll release you and your co-counsel. I know
23 that you've already spent a lot of time here waiting to see
24 what happens. And I thank you for your service to the Court.
25 All right. Would anyone like to be heard before we
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1 recess for the day?
2 MS. WEBSTER: I just have one issue, Your Honor.
3 Specifically we had filed the request for -- about
4 Ricky Dixon and the writ, for him to be produced ex parte and
5 under seal.
6 THE COURT: Sorry, I couldn't hear you.
7 MS. WEBSTER: We had filed our request for Ricky
8 Dixon to be produced, the petition for writ under seal and
9 ex parte. And to my knowledge, no one knew about it but us
10 and the Court and the judge that signed it. So it's
11 concerning to us that things that were filed ex parte and that
12 relate to our defense strategy have been disclosed without our
13 knowledge to the government. So I would like to address that.
14 THE COURT: Okay. You're addressing it now. Go
15 ahead. You would like to address it, so go ahead and make
16 your record.
17 MS. WEBSTER: I would like to know how that happened.
18 We are filing and have filed a number of things ex parte and
19 under seal, and I want to have some indication that that is --
20 those are going to be ex parte and under seal and not
21 disclosed to the government.
22 THE COURT: All right. And I don't -- I still don't
23 know what happened. Can you fill me in? I would expect that
24 if you filed something under seal, it would have been handled
25 under seal. Was there a mistake or did something go wrong?
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1 MS. WEBSTER: I don't know what happened, Your Honor.
2 Sorry. That's what I'm trying to say. When Mr. Kaushal said
3 earlier today that they are aware that we have tried to get --
4 or are trying to get Mr. Dixon here, that's the first time I
5 had any indication that anyone other than us knew about that.
6 So that's what I'm concerned about.
7 THE COURT: I guess I'm in the dark, too, but I would
8 be happy to hear from the government.
9 MS. CHAIKEN: Your Honor, we have not seen any
10 ex parte filings that the defense has made. We were contacted
11 by a BOP administrative person at the facility where Mr. Dixon
12 is being held because she had not seen a writ that looked the
13 way his writ looked and she called us to see if we needed him.
14 And we told her it was not our writ and it was probably issued
15 by one of the defense attorneys and she should look for a name
16 on the documentation. And that's how that was brought to our
17 attention. We have not seen any ex parte filings on that or
18 on anything else that the defense has made.
19 THE COURT: Okay. I don't know what we can do
20 differently on that front if somebody calls up and asks them a
21 question.
22 MS. WEBSTER: Sure. I understand. I just wanted to
23 sort of just note it was concerning to us, but I understand
24 how it happened. And we just wanted some assurance that that
25 was not coming from anyone in the courthouse, I guess. So I
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1 think we have that now. Thank you.
2 THE COURT: Okay. Very well. Okay. I hope everyone
3 has an unexpectedly relaxing afternoon, and we'll see you in
4 the morning right after I hear from Mr. Marshall.
5 MR. MARSHALL: Sorry, Judge.
6 Can I ask you to possibly revisit one of your orders.
7 It was a small administrative motion that I filed. And I
8 didn't know what the Court's position was on this. I filed a
9 motion to try to see if my client would be able to have access
10 to her phone during the trial.
11 That's just more logistics, like I've had this happen
12 where I've had somebody in the cafeteria and I can't find them
13 and I need to get them to court and all that. That's really
14 it, Your Honor. I wouldn't need anything else, but it would
15 be -- it would help quite a bit. But if the Court doesn't
16 normally do that for defendants during trials, I understand,
17 but I wanted to ask.
18 THE COURT: All right. Motion to reconsider denied,
19 I'm sorry.
20 MR. MARSHALL: Thank you, Judge.
21 THE COURT: I understand how that would in some ways
22 make things logistically perhaps a bit easier. There's some
23 downsides there, too, to opening the floodgates to letting
24 defendants come on in with their cell phones unfortunately.
25 And, you know, I think it's probably an instance in
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1 which a few bad apples have spoiled the barrel for everyone.
2 I don't doubt perhaps it wouldn't be an issue here, but I'm
3 worried about setting a precedent that's going to cause me
4 trouble down the line.
5 MR. MARSHALL: Yes, Your Honor. Thank you.
6 THE COURT: I'll certainly understand if there's ever
7 a slight delay getting somebody back into the courtroom after
8 a break or something for that reason. And I'll try to be
9 really clear how long our breaks will be for comfort breaks,
10 lunch breaks, et cetera.
11 All right. Anything else?
12 MS. CHAIKEN: No, Your Honor.
13 THE COURT: Hearing nothing, enjoy that relaxing
14 afternoon. See y'all in the morning.
15 (After a recess taken at 1:15 PM, proceedings were
16 continued as follows on February 6, 2024:)
17 ___________________________
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1 C E R T I F I C A T E
2
3 UNITED STATES DISTRICT COURT
4 NORTHERN DISTRICT OF GEORGIA
5
6 I do hereby certify that the foregoing pages are a true
7 and correct transcript of the proceedings taken down by me in
8 the case aforesaid.
9
This the 5th Day of February, 2024.
10
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13
14 ________________________________
15 PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
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1 404(B [2] - 24:13, 28:6 ACCOUNTS [1] - 27:25
48 [1] - 2:25 ACCURATE [2] - 14:2, 14:11
1 [2] - 1:6, 20:1 493 [1] - 13:21 ACCUSATION [3] - 30:14, 31:3, 31:5
100 [1] - 34:19 ACHIEVE [1] - 14:8
10:02 [1] - 11:3
10:15 [1] - 19:21
5 ACTIVITIES [2] - 27:3, 28:11
ACTIVITY [1] - 26:5
10:28 [1] - 28:19 5 [1] - 1:10
ACTS [1] - 18:11
120-CR-296 [1] - 2:4 526 [1] - 16:13
ADD [1] - 16:18
1222 [1] - 17:14 57 [1] - 16:24
ADDED [1] - 25:10
1234 [1] - 17:14 591 [1] - 16:12
ADDITIONAL [2] - 17:10, 35:6
12TH [1] - 14:24 5:00 [1] - 40:14
ADDITIONALLY [1] - 15:25
1307 [1] - 13:4 5TH [1] - 45:9
ADDRESS [7] - 23:5, 23:14, 29:13,
1312 [2] - 13:4, 14:12 32:15, 33:2, 41:13, 41:15
132 [1] - 18:16 6 ADDRESSED [2] - 23:18, 25:14
14 [2] - 12:5, 18:4 6 [1] - 44:16 ADDRESSES [1] - 21:6
14(A [1] - 17:21 6323792 [1] - 16:6 ADDRESSING [1] - 41:14
15 [1] - 40:11 646 [1] - 18:16 ADEQUATE [3] - 15:21, 17:3, 17:9
152 [1] - 16:13 648 [1] - 17:14 ADITYA [1] - 1:20
1569 [1] - 12:22 651 [1] - 18:16 ADJOURN [1] - 23:6
1572 [1] - 12:22 ADJUST [1] - 25:18
1573 [1] - 13:19
1574 [1] - 13:20
7 ADMINISTRATION [2] - 13:24, 14:11
ADMINISTRATIVE [2] - 42:11, 43:7
1580 [1] - 13:20 702 [1] - 16:16
ADMIT [3] - 12:20, 24:23, 24:24
16 [3] - 12:14, 14:5, 16:20 768 [1] - 13:4
ADMITTED [1] - 14:18
16(D)(2)(D [1] - 15:4 ADVISE [3] - 31:19, 33:5, 33:8
1985 [1] - 13:5 8 ADVISED [1] - 29:3
1989 [1] - 13:21 830 [1] - 11:13 ADVISORY [1] - 14:5
1995 [1] - 16:25 854 [1] - 15:10 AFFECT [1] - 32:20
1998 [1] - 18:17 866 [1] - 17:11 AFFECTED [1] - 21:14
19TH [2] - 11:17, 14:17 871 [1] - 13:20 AFFORDING [1] - 13:7
1:00 [6] - 22:13, 22:14, 23:1, 28:21, 897 [1] - 16:12 AFORESAID [1] - 45:8
35:19, 35:22 899 [1] - 16:12 AFTER [1] - 1:7
1:15 [2] - 40:10, 44:15 AFTERNOON [6] - 35:4, 40:4, 40:8,
1:20-CR-00296-JPB [1] - 1:5
1ST [1] - 11:21
9 40:13, 43:3, 44:14
AGENT [1] - 14:21
90 [1] - 1:5
AGENT [6] - 11:16, 13:17, 15:7, 15:16,
2 934 [1] - 18:5
16:15, 33:25
948 [1] - 18:6
2 [1] - 20:2 AGENT'S [2] - 14:18, 16:1
960 [1] - 12:22
2007 [1] - 18:6 AGENTS [1] - 20:20
993 [1] - 16:24
2011 [1] - 17:15 AGENTS [1] - 2:11
997 [1] - 13:21
2015 [1] - 16:13 AGREE [1] - 16:8
998 [1] - 16:24
2020 [2] - 25:1, 27:22 AGREEMENTS [2] - 31:14, 31:15
9:00 [2] - 19:17, 40:18
2022 [1] - 11:21 AHEAD [4] - 25:17, 25:20, 41:15
9:08 [1] - 2:2
2023 [2] - 16:6, 16:7 AIM [1] - 27:2
9:44 [1] - 10:23
2024 [6] - 1:10, 11:17, 14:17, 14:25, AL [1] - 1:6
9:45 [1] - 19:21
44:16, 45:9 AL [1] - 2:5
219 [1] - 18:5 ALISHA [1] - 2:10
2255 [2] - 32:5, 33:12
A ALLEGATION [1] - 15:1
24 [1] - 2:25 A.M [2] - 10:23, 11:4 ALLEVIATE [1] - 15:3
28TH [1] - 16:7 ABILITY [1] - 15:13 ALLOWED [1] - 31:4
2ND [1] - 15:6 ABLE [5] - 18:2, 20:3, 40:3, 40:5, 43:9 ALLOWS [1] - 15:4
ABSENCE [2] - 19:16, 23:20 ALMOST [1] - 40:10
3 ACCESS [1] - 43:9 ALONE [1] - 21:24
ACCOMPLISH [1] - 13:2 AM [1] - 2:2
31ST [1] - 11:9 ACCORDANCE [1] - 15:4 AMENDED [2] - 11:22, 12:2
3:22-CR-12-TES-1 [1] - 16:5 ACCORDING [1] - 32:4 AMENDMENT [2] - 29:3, 30:6
ACCORDINGLY [1] - 18:10 AMERICA [1] - 1:4
4 ACCOUNT [11] - 25:2, 25:7, 25:9, 25:10, AN [1] - 1:2
4 [1] - 16:6 26:6, 27:1, 27:10, 27:12, 27:24 ANALYSIS [1] - 16:8
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 48 of 55
2
AND [2] - 1:4, 1:7 BAD [2] - 15:2, 44:1 16:8, 43:24
ANN [1] - 2:14 BANK [1] - 24:25 CERT [1] - 13:21
ANN [1] - 1:16 BAPTIST [1] - 1:19 CERTAINLY [1] - 44:6
ANSWER [1] - 29:8 BAPTISTE [18] - 2:22, 3:2, 3:10, 10:25, CERTIFIED [1] - 12:5
ANTICIPATE [1] - 20:22 19:23, 19:24, 20:3, 20:24, 22:14, CERTIFY [1] - 45:6
ANY [1] - 1:9 33:23, 34:21, 36:11, 40:1, 40:2, 40:6, CETERA [2] - 40:14, 44:10
ANYWAY [4] - 12:11, 20:25, 22:25, 40:19, 40:20, 40:21 CHAIKEN [27] - 1:13, 2:8, 20:17, 20:20,
40:16 BAPTISTE'S [2] - 19:16, 23:20 21:10, 21:17, 21:21, 21:23, 24:2, 24:7,
APPEAR [3] - 32:1, 32:16, 32:20 BARREL [1] - 44:1 24:11, 25:21, 27:9, 28:22, 33:11,
APPEARANCES [1] - 2:6 BASIS [1] - 33:12 33:22, 34:10, 34:14, 34:25, 35:10,
APPEARANCES [1] - 1:11 BE [2] - 1:3, 1:4 35:13, 35:16, 35:24, 36:6, 36:10, 42:9,
APPLES [1] - 44:1 BEFORE [1] - 1:9 44:12
APPLIED [1] - 11:14 BEGIN [1] - 11:5 CHAIKEN [5] - 2:8, 3:12, 20:5, 28:1,
APPOINT [1] - 33:8 BEGUN [1] - 13:11 36:3
APPOINTED [2] - 33:4, 33:14 BEHALF [3] - 2:15, 2:19, 32:2 CHALLENGE [1] - 15:14
APPRAISE [1] - 18:10 BEHALF [4] - 1:12, 1:15, 1:17, 1:19 CHALLENGING [1] - 33:12
APPRECIATE [1] - 3:13 BEHIND [1] - 2:10 CHAMBERS [1] - 23:9
APPROACH [1] - 32:11 BELIEVES [1] - 16:15 CHANCE [1] - 23:13
APPROPRIATE [7] - 12:21, 19:2, 19:11, BELLATOR [1] - 25:4 CHARACTER [1] - 27:5
24:3, 28:5, 33:4, 33:7 BERNI [5] - 11:16, 15:7, 15:16, 33:25 CHARGE [3] - 27:6, 30:1
ARE [1] - 1:8 BERNI'S [2] - 13:17, 16:15 CHARGED [12] - 17:16, 25:6, 25:23,
ARGUABLY [1] - 14:14 BETTER [3] - 21:11, 28:18, 34:9 26:2, 26:11, 26:19, 27:6, 27:17, 27:23,
ARGUED [1] - 15:12 BETWEEN [1] - 31:10 28:8, 30:24
ARGUES [1] - 12:8 BIT [4] - 25:10, 28:17, 43:15, 43:22 CHARGES [1] - 27:8
ARGUMENT [3] - 25:12, 25:18 BLASINGAME [1] - 18:5 CHILDCARE [1] - 40:14
ARGUMENTS [1] - 11:19 BOP [1] - 42:11 CIRCLE [1] - 28:16
ARISE [1] - 19:4 BOULEE [1] - 1:9 CIRCUIT [9] - 12:23, 13:5, 13:20, 16:13,
ARISEN [2] - 2:25, 3:1 BREAK [1] - 44:8 16:25, 17:12, 17:14, 18:6, 18:17
ARRANGEMENT [1] - 12:10 BREAKS [3] - 44:9, 44:10 CIRCUMSTANCE [1] - 14:13
ARREST [1] - 10:25 BRIDGE [1] - 35:7 CIRCUMSTANCES [3] - 12:19, 15:5,
ARRIVE [1] - 34:15 BRIEF [1] - 15:12 18:8
ASIDE [1] - 2:3 BRING [2] - 20:3, 40:18 CITE [1] - 1:5
ASSESS [2] - 15:21, 18:7 BROADENS [1] - 28:11 CLEAR [2] - 13:12, 44:9
ASSIST [1] - 33:19 BROUGHT [2] - 3:10, 42:16 CLEARED [1] - 36:18
ASSISTANT [1] - 1:14 BUBLITZ [1] - 2:12 CLERK [2] - 2:3, 3:6
ASSUME [2] - 11:18, 12:11 BURDEN [1] - 17:19 CLIENT [3] - 27:4, 28:6, 43:9
ASSURANCE [1] - 42:24 BURNER [1] - 23:18 CLIENT'S [1] - 27:5
AT [1] - 2:2 BUSINESS [1] - 24:22 CM/ECF [2] - 1:3, 1:5
ATLANTA [3] - 1:2, 1:24, 2:2 BY [3] - 1:4, 1:6, 1:21 CO [1] - 40:22
ATTACHED [1] - 1:6 CO-COUNSEL [1] - 40:22
COGNITIVE [1] - 40:10
ATTACHING [1] - 1:9 C
ATTEMPT [1] - 31:20 COINCIDENTALLY [1] - 22:20
CAFETERIA [1] - 43:12 COMFORT [1] - 44:9
ATTEMPTED [2] - 19:17, 19:18
CAMARGO [1] - 16:24 COMING [2] - 26:23, 42:25
ATTEMPTS [1] - 3:4
CAMARGO-VERGARA [1] - 16:24 COMMITTEE [1] - 14:6
ATTENTION [1] - 42:17
CANNOT [1] - 33:25 COMMON [1] - 17:17
ATTORNEY [3] - 33:13, 33:14, 33:16
CAPACITY [1] - 18:9 COMMUNICATED [1] - 30:11
ATTORNEY'S [1] - 36:19
CARD [3] - 26:16, 26:24, 27:11 COMMUNICATIONS [1] - 29:20
ATTORNEYS [1] - 1:14
CARE [1] - 35:19 COMPANY [3] - 25:4, 26:21, 28:10
ATTORNEYS [1] - 42:15
CARLA [1] - 1:17 COMPELLING [4] - 18:3, 18:7, 18:13,
AUTO [2] - 18:24, 19:1
CARLA [3] - 2:19, 26:8, 27:20 18:18
AUTOMOTIVE [2] - 24:22, 24:25
CASE [16] - 11:14, 12:5, 12:6, 12:8, COMPLETED [1] - 33:1
AVAIL [2] - 3:4, 19:19
12:22, 13:21, 14:9, 16:24, 18:5, 18:8, COMPLIANCE [1] - 13:2
AVAILABLE [2] - 15:7, 20:9
22:10, 24:18, 31:12, 31:14, 32:11, COMPLY [1] - 12:13
AVOID [1] - 34:11
45:8 CONCERN [2] - 30:9, 31:18
AWARE [7] - 19:25, 23:17, 23:22, 31:22,
CASE [1] - 2:4 CONCERNED [1] - 42:6
31:24, 33:15, 42:3
CASES [1] - 16:2 CONCERNING [2] - 41:11, 42:23
CASSANO [1] - 18:16 CONCERNS [1] - 23:18
B CAUTIONARY [1] - 29:16 CONDITIONS [1] - 12:16
BABASIJIBOMI [1] - 1:14 CELL [6] - 11:16, 14:20, 16:3, 16:4,
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 49 of 55
3
CONDUCT [3] - 16:10, 18:4, 18:12 COURTHOUSE [1] - 42:25 DESIRED [1] - 13:2
CONFESS [1] - 24:5 COURTROOM [1] - 36:18 DETAIL [1] - 11:8
CONFLICTS [1] - 40:14 COURTROOM [2] - 2:3, 3:6 DETERMINATION [4] - 14:3, 14:11,
CONFUSING [1] - 11:20 COURTROOM [4] - 39:21, 39:22, 39:24, 18:15, 18:23
CONNECTION [2] - 24:21, 27:15 44:7 DETERMINE [1] - 18:6
CONSERVES [1] - 17:20 COURTS [1] - 16:7 DETERMINING [1] - 16:4
CONSIDER [2] - 30:6, 32:10 CRIME [1] - 25:22 DIFFERENT [1] - 33:6
CONSIDERATION [1] - 29:9 CRIMINAL [3] - 11:21, 14:5, 17:21 DIFFERENTLY [1] - 42:20
CONSOLIDATION [1] - 17:23 CRIMINAL [2] - 13:24, 14:9 DIGEST [1] - 15:17
CONSPIRACY [4] - 17:17, 26:19, 27:7, CROSS [2] - 19:5, 35:7 DIRE [1] - 40:15
28:9 CROSS-EXAMINATION [1] - 19:5 DIRECT [1] - 15:15
CONSTITUTIONAL [1] - 32:22 CRR [2] - 1:22, 45:15 DISCLOSE [2] - 12:4, 13:23
CONSULT [3] - 15:8, 15:14, 17:6 CRUMPTON [1] - 16:5 DISCLOSED [3] - 14:24, 41:12, 41:21
CONTACT [2] - 19:18 CURING [1] - 13:9 DISCLOSURE [7] - 11:14, 11:15, 14:14,
CONTACTED [1] - 42:10 14:17, 15:2, 15:13, 16:19
CONTEXT [2] - 30:19, 31:8 D DISCLOSURES [1] - 11:24
CONTINUANCE [3] - 12:17, 13:10, 14:8 DISCOVERY [5] - 12:15, 13:3, 13:8,
DARK [1] - 42:7
CONTINUED [4] - 10:22, 11:3, 35:20, 13:12, 16:20
DARRELL [5] - 25:4, 26:6, 26:18, 27:3,
44:16 DISCRETION [3] - 12:19, 12:21, 12:24
29:17
CONTRARY [1] - 11:20 DISCUSS [4] - 19:12, 19:15, 30:12,
DATA [2] - 11:16, 14:20
CONTRIBUTING [1] - 14:2 36:14
DATE [2] - 3:3, 19:25
CONVERSATION [3] - 28:15, 30:16, DISCUSSED [1] - 29:6
DAUBERT [2] - 16:1, 16:9
39:25 DISCUSSING [1] - 30:19
DAVID [1] - 2:18
CONVICTION [1] - 33:12 DISCUSSION [7] - 3:16, 10:21, 11:2,
DAVID [1] - 1:18
CONVINCED [1] - 14:16 29:10, 29:17, 31:7, 32:7
DAYS [1] - 1:5
COOPERATION [1] - 31:16 DISCUSSIONS [1] - 29:22
DAYS [5] - 12:5, 21:19, 21:21, 21:23,
COOPERATOR [1] - 31:12 DISPUTE [1] - 11:13
21:25
COORDINATE [1] - 3:11 DISTINGUISHING [1] - 31:10
DEAD [4] - 34:1, 34:11, 34:12, 35:1
COORDINATORS [1] - 34:16 DISTRICT [1] - 16:6
DEADLINE [2] - 11:13, 12:9
COPY [1] - 23:9 DISTRICT [6] - 1:1, 1:1, 1:10, 1:23, 45:3,
DECEMBER [1] - 11:21
CORRECT [3] - 3:5, 3:7, 45:7 45:4
DECIDE [5] - 22:13, 22:17, 22:24, 23:25,
COUDRIET [2] - 1:22, 45:15 DISTRICT [4] - 12:2, 12:24, 16:7, 16:9
30:12
COUNSEL [26] - 2:6, 2:9, 2:22, 3:17, DIVISION [1] - 1:2
DECIDES [1] - 12:25
15:7, 15:8, 16:15, 19:18, 22:3, 22:4, DIXON [8] - 32:1, 32:14, 33:3, 33:7,
DECIDING [2] - 12:20, 16:18
29:7, 29:21, 30:15, 30:17, 31:8, 31:25, 41:4, 41:8, 42:4, 42:11
DECISION [2] - 13:25, 16:21
32:15, 32:19, 33:4, 33:7, 33:8, 36:3, DOCKET [4] - 11:7, 14:9, 15:10, 32:4
DEFENDANT [17] - 11:25, 12:4, 12:8,
36:4, 36:13, 39:24, 40:22 DOCKET [1] - 17:11
13:8, 13:25, 15:12, 17:2, 17:8, 17:24,
COUNT [2] - 26:19, 27:7 DOCKET [2] - 1:6, 1:5
18:2, 18:6, 18:13, 18:15, 18:19, 30:17,
COUNTS [4] - 17:25, 26:20, 27:18, 28:9 DOCUMENT [1] - 1:10
30:21, 30:24
COUPLE [7] - 2:24, 19:22, 20:5, 20:21, DOCUMENTATION [1] - 42:16
DEFENDANT [4] - 1:7, 1:15, 1:17, 1:19
21:1, 21:7, 28:22 DOCUMENTS [1] - 33:17
DEFENDANT [3] - 2:19, 13:16, 34:8
COURT [7] - 3:10, 12:14, 12:24, 16:9, DOG [1] - 22:2
DEFENDANT'S [2] - 16:22, 18:11
28:15, 36:1, 43:13 DONE [2] - 15:2, 29:18
DEFENDANTS [7] - 17:12, 17:16, 17:22,
COURT [24] - 2:3, 3:17, 11:22, 12:19, DORY [1] - 22:15
24:12, 40:7, 43:16, 43:24
13:6, 14:14, 14:16, 15:4, 15:6, 15:19, DOUBT [1] - 44:2
DEFENDANTS' [2] - 17:25, 32:9
15:25, 17:24, 18:7, 18:21, 19:2, 25:11, DOUG [1] - 2:21
DEFENSE [25] - 15:7, 15:8, 15:17,
31:21, 32:10, 33:8, 33:23, 35:25, DOUGLAS [1] - 1:19
15:23, 16:14, 17:3, 17:8, 17:9, 18:4,
40:24, 41:10, 43:15 DOWN [4] - 21:7, 25:17, 44:4, 45:7
24:16, 27:16, 29:3, 29:7, 30:14, 30:15,
COURT [61] - 1:4, 1:7, 1:10, 1:1, 1:23, DOWNSIDES [1] - 43:23
31:3, 31:7, 31:17, 31:24, 32:3, 34:4,
1:23, 2:2, 2:13, 2:17, 2:23, 3:7, 3:9, DOWNSTAIRS [1] - 2:16
41:12, 42:10, 42:15, 42:18
10:24, 11:5, 20:18, 21:9, 21:11, 21:20, DRAWN [1] - 33:17
DELAY [3] - 13:7, 13:9, 44:7
21:22, 22:1, 22:8, 22:12, 23:4, 23:7, DULY [1] - 3:2
DEMONSTRATE [1] - 18:2
23:11, 23:16, 24:4, 24:8, 25:16, 26:13, DURING [4] - 19:5, 21:3, 43:10, 43:16
28:1, 28:13, 29:14, 32:12, 32:19, DEMONSTRATED [1] - 18:7
DEMONSTRATES [1] - 14:19 DURRETT [2] - 2:16, 3:15
32:25, 33:10, 33:16, 34:3, 34:11, DURRETT [1] - 1:16
34:22, 35:1, 35:18, 35:22, 36:2, 36:8, DENIED [5] - 13:21, 15:24, 16:17, 19:6,
36:12, 36:16, 39:23, 41:6, 41:14, 43:18
41:22, 42:7, 42:19, 43:2, 43:18, 43:21, DENYING [1] - 11:10 E
44:6, 44:13, 45:3, 45:15 DEPRIVED [1] - 15:13 E-MAILED [2] - 3:17, 23:9
COURT'S [4] - 12:8, 13:3, 33:25, 43:8 DEPUTY [2] - 2:3, 3:6 EASIER [1] - 43:22
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 50 of 55
4
ECF [1] - 23:8 12:4, 13:18, 14:24, 15:9, 15:14, 16:2, FOSTER [10] - 2:15, 13:16, 14:17,
EFFECT [1] - 14:1 17:6, 17:7, 17:8 14:19, 15:13, 15:21, 18:23, 22:4, 32:1,
EFFECTIVE [1] - 13:15 EXPERT'S [1] - 16:11 34:8
EFFICIENCY [2] - 17:20, 22:22 EXPOSURE [1] - 31:1 FOSTER [2] - 1:6, 1:15
EFFICIENT [1] - 13:24 EXTENT [2] - 13:8, 20:14 FOSTER'S [3] - 11:10, 14:24, 15:23
EFFORT [1] - 32:7 EXTRA [4] - 15:17, 17:5, 34:4, 34:8 FOUR [1] - 24:12
EFFORTS [4] - 34:22, 35:2, 36:10, 40:1 EXTREME [2] - 13:19, 14:15 FRANK [1] - 32:7
EITHER [1] - 22:16 FRANKLY [3] - 17:7, 23:17, 34:4
ELEMENT [1] - 26:3 F FRAUD [3] - 19:1, 26:3, 26:5
ELEVATED [1] - 30:2 FRAUDULENT [2] - 26:1, 26:9
F.2D [3] - 12:22, 13:4, 13:20
ELEVENTH [9] - 12:22, 13:4, 13:20, FROM [1] - 1:9
F.3D [3] - 16:24, 17:14, 18:16
16:13, 16:24, 17:12, 17:14, 18:6, FRONT [2] - 23:11, 42:20
F.APP'X [2] - 16:12, 18:5
18:16 FULL [2] - 13:2, 35:12
FACE [1] - 30:2
ELICITED [2] - 15:9, 15:22 FULL [1] - 1:9
FACILITY [1] - 42:11
ELIMINATE [1] - 21:4
FACT [4] - 12:9, 19:25, 26:5, 40:10
END [1] - 34:1
FACTOR [1] - 31:10 G
ENHANCEMENT [1] - 31:1
FACTORS [4] - 12:25, 13:6, 13:14, 17:1 GAINES [23] - 24:13, 25:1, 25:3, 25:9,
ENJOY [1] - 44:13
FAILS [1] - 12:13 25:23, 25:25, 26:7, 26:8, 26:12, 26:18,
ENSURE [2] - 15:20, 15:21
FAIR [3] - 11:25, 13:23, 14:10 27:1, 27:3, 27:9, 27:16, 27:17, 28:25,
ENTANGLEMENTS [1] - 27:21
FAITH [1] - 15:2 29:5, 30:2, 30:17, 31:11, 32:14, 33:6
ENTER [2] - 12:18, 15:5
FAR [4] - 11:12, 17:11, 20:6, 25:16 GAINES' [3] - 27:20, 29:20, 30:17
ENTERED [4] - 11:9, 12:6, 31:14, 39:22
FASHION [2] - 12:21, 13:1 GATEKEEPER [1] - 16:10
ENTERTAIN [1] - 19:10
FBI [1] - 2:12 GENERAL [3] - 16:4, 17:12, 17:17
ENTRY [2] - 11:7, 15:10
FEASIBILITY [1] - 13:9 GEORGIA [4] - 1:1, 1:24, 2:2, 45:4
ENTRY [1] - 1:6
FEBRUARY [3] - 15:6, 44:16, 45:9 GEORGIA [1] - 16:6
ESPECIALLY [2] - 17:5, 17:16
FEBRUARY [1] - 1:10 GILFILLAN [3] - 1:19, 2:21, 3:8
ESQ [8] - 1:13, 1:13, 1:14, 1:16, 1:16,
FEDERAL [3] - 11:21, 14:5, 17:21 GILFILLAN [3] - 2:22, 3:7, 40:22
1:18, 1:19, 1:20
FEELINGS [1] - 22:7 GIVEN [2] - 17:5, 17:6
ESTABLISHED [1] - 16:5
FEW [5] - 19:21, 20:4, 22:11, 34:5, 44:1 GOVERNMENT [36] - 11:14, 11:23,
ESTIMATE [2] - 21:12, 21:22
FIFTH [3] - 29:3, 30:5 12:3, 13:16, 13:23, 14:22, 15:6, 15:15,
ET [1] - 1:6
FILE [1] - 23:14 15:16, 17:7, 17:24, 18:25, 20:14,
ET [3] - 2:5, 40:14, 44:10
FILED [3] - 1:3, 1:8, 1:10 23:13, 23:24, 28:5, 29:16, 29:18,
EUCEDA [2] - 13:3, 14:4 29:22, 30:8, 30:11, 31:7, 31:13, 31:15,
FILED [12] - 23:8, 24:13, 24:21, 28:5,
EUCEDA [1] - 13:4 31:24, 31:25, 32:9, 34:6, 34:7, 35:11,
33:12, 41:3, 41:7, 41:11, 41:18, 41:24,
EUCEDA-HERNANDEZ [1] - 14:4 36:3, 36:14, 39:25, 41:13, 41:21, 42:8
43:7, 43:8
EVENING [1] - 35:14 GOVERNMENT [1] - 1:12
FILING [1] - 41:18
EVENT [1] - 11:15 GOVERNMENT'S [11] - 11:15, 11:19,
FILINGS [2] - 42:10, 42:17
EVIDENCE [18] - 12:1, 12:18, 13:18, 12:1, 13:7, 14:7, 14:14, 14:22, 15:1,
FILL [4] - 34:19, 34:22, 35:2, 41:23
13:23, 14:7, 14:15, 14:20, 16:19, 15:12, 22:10, 26:22
FINAL [1] - 29:7
18:11, 18:14, 18:22, 18:24, 19:1, 19:4, GRANT [1] - 12:16
FINANCIAL [1] - 27:21
25:13, 25:22, 27:14, 28:12 GRANTED [2] - 16:12, 18:5
FINE [3] - 22:11, 26:23, 34:10
EX [8] - 33:3, 41:4, 41:9, 41:11, 41:18, GRANTING [2] - 13:10, 14:8
FIRST [1] - 42:4
41:20, 42:10, 42:17 GROUP [3] - 24:22, 24:25, 25:5
FIVE [1] - 21:24
EXACT [1] - 27:22 GUARD [1] - 19:3
FLAG [2] - 29:1, 29:8
EXACTLY [1] - 22:3 GUESS [2] - 42:7, 42:25
FLOODGATES [1] - 43:23
EXAMINATION [1] - 19:5 GUIDELINE [1] - 30:2
FLOOR [1] - 20:12
EXAMPLE [2] - 29:5, 31:11 GUIDELINES [2] - 30:22, 31:2
FOCUS [1] - 19:5
EXCEPT [1] - 36:3 GUILT [2] - 14:3, 14:12
FOLLOW [4] - 11:6, 11:8, 18:10, 28:17
EXCLUDE [3] - 11:10, 11:12, 15:24 GUILTY [1] - 24:14
FOLLOW-UP [1] - 28:17
EXCLUDING [1] - 14:15
FOLLOWING [2] - 3:22, 36:20
EXCLUSION [1] - 13:18
EXCUSE [1] - 13:13
FOLLOWING [1] - 1:2 H
FOLLOWS [4] - 10:23, 11:4, 35:21, HALF [2] - 14:21, 35:6
EXERCISING [1] - 12:24
44:16 HANDLE [2] - 19:13, 32:20
EXHIBITS [2] - 24:14, 24:16
FOR [2] - 1:5, 1:1 HANDLED [1] - 41:24
EXPANDS [1] - 28:9
FOREGOING [1] - 45:6 HAPPY [11] - 3:18, 19:7, 19:9, 20:12,
EXPECT [1] - 41:23
FORM [1] - 11:7 20:15, 22:3, 24:2, 24:10, 32:21, 33:16,
EXPECTED [1] - 29:17
FORMAL [1] - 16:10 42:8
EXPENSE [1] - 14:10
FORMALIZE [2] - 31:5, 31:15 HAS [1] - 1:8
EXPERT [12] - 11:10, 11:12, 11:14,
FORWARD [3] - 22:7, 22:16, 40:12
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 51 of 55
5
HEALTH [1] - 23:19 INFORMED [2] - 13:25, 28:18 JUROR [1] - 40:13
HEAR [13] - 3:20, 20:12, 20:14, 20:15, INHERENT [1] - 17:18 JURORS [5] - 20:8, 20:9, 20:10, 26:17,
22:3, 23:23, 25:12, 32:17, 36:5, 41:6, INNOCENCE [2] - 14:3, 14:12 40:12
42:8, 43:4 INSPECTION [1] - 12:15 JURY [1] - 1:9
HEARD [2] - 20:15, 40:25 INSTANCE [3] - 14:16, 28:5, 43:25 JURY [15] - 2:4, 18:9, 18:14, 18:20,
HEARING [3] - 16:1, 16:10, 44:13 INSTRUCTION [4] - 19:3, 19:9, 19:10, 18:21, 19:3, 19:9, 20:8, 22:15, 22:16,
HELD [1] - 42:12 29:17 22:18, 27:11, 27:24, 28:9, 40:18
HELD [1] - 2:2 INSTRUCTIONS [2] - 18:10, 18:20 JURY'S [2] - 13:10, 27:14
HELP [1] - 43:15 INTENDING [1] - 30:8 JUSTICE [4] - 13:24, 14:11, 18:1, 22:23
HEREBY [1] - 45:6 INTENT [3] - 3:9, 11:15, 40:18
HERNANDEZ [2] - 13:4, 14:4 INTERFERING [1] - 30:6 K
HIGHLY [1] - 27:14 INTIMIDATE [1] - 31:20
KAUSHAL [3] - 2:10, 28:22, 42:2
HISTORICAL [1] - 16:8 INTRINSIC [3] - 25:13, 25:21, 28:12
KAUSHAL [4] - 1:13, 28:24, 30:13,
HOLD [1] - 21:20 INTRODUCE [6] - 19:1, 24:15, 24:17,
32:24
HOLLAND [1] - 2:10 25:15, 26:16, 28:7
KIND [1] - 29:24
HONOR [32] - 2:8, 2:14, 2:21, 3:8, INTRODUCED [1] - 18:24
KNOWLEDGE [3] - 30:18, 41:9, 41:13
20:17, 20:20, 23:3, 24:2, 24:11, 27:9, INTRODUCING [2] - 12:17, 13:17
KNOWS [1] - 40:13
28:22, 28:24, 29:1, 29:6, 29:11, 30:13, INTRODUCTION [1] - 19:4
KUMHO [1] - 16:13
32:17, 32:24, 33:2, 33:11, 33:22, 35:9, INVESTIGATIVE [2] - 36:7, 36:10
35:10, 35:24, 36:7, 36:15, 41:2, 42:1, INVOKE [1] - 30:5
42:9, 43:14, 44:5, 44:12 INVOLVED [5] - 26:6, 26:17, 26:18,
L
HONOR'S [1] - 29:8 28:10, 30:16 LACKS [1] - 17:2
HONORABLE [1] - 1:9 INVOLVING [2] - 16:3, 23:19 LARGELY [1] - 16:7
HOPE [2] - 29:15, 43:2 IS [1] - 1:2 LAST [6] - 2:25, 3:1, 11:7, 21:12, 28:2,
HOPEFUL [1] - 40:5 ISSUE [19] - 3:9, 3:14, 3:15, 3:18, 14:3, 35:16
HOUR [1] - 40:14 19:15, 22:5, 27:6, 28:24, 29:11, 31:17, LATE [5] - 14:14, 15:2, 15:12, 16:18,
HOURS [6] - 2:25, 20:21, 21:2, 21:8, 31:21, 32:3, 32:6, 32:15, 32:21, 36:14, 34:15
22:11, 34:5 41:2, 44:2 LAUNDERING [5] - 25:7, 26:4, 27:18,
HOWEVER [1] - 1:8 ISSUED [3] - 11:6, 19:20, 42:14 27:23
HUNKY [1] - 22:15 ISSUES [4] - 2:24, 15:18, 23:19, 24:7 LEARNED [1] - 31:25
HUNKY-DORY [1] - 22:15 ITSELF [1] - 26:3 LEAST [8] - 13:1, 13:14, 15:19, 15:20,
HUNT [1] - 22:2 19:22, 21:7, 22:25, 31:23
J LEAVE [1] - 27:11
I J.P [1] - 1:9
LEE [2] - 3:5, 3:11
LEIGH [1] - 1:16
IDEA [1] - 27:12 JACKSON [8] - 2:5, 2:19, 22:3, 25:1,
LEIGH [1] - 2:14
IDENTIFIED [1] - 24:20 25:6, 26:2, 26:9, 26:11
LENGTH [1] - 21:14
IMPLEMENTED [1] - 12:2 JACKSON [1] - 1:17
LETTING [1] - 43:23
IMPLIED [1] - 29:24 JACKSON'S [3] - 26:24, 27:15, 27:20
LEVEL [1] - 31:3
IMPOSING [1] - 13:14 JANUARY [4] - 11:9, 11:17, 14:17,
LIGHTENS [1] - 17:19
IMPROPERLY [1] - 27:5 14:24
LIMINE [1] - 23:9
IN [3] - 1:3, 1:4, 2:2 JAY [2] - 11:16, 13:17
LIMITING [1] - 19:2
INCLINED [1] - 35:3 JERRY [1] - 10:25
LINE [1] - 1:7
INCLUDING [2] - 22:22, 24:12 JERRY [1] - 1:19
LINE [1] - 44:4
INCONSISTENT [1] - 17:18 JOE [1] - 2:11
LIST [2] - 33:1, 35:12
INCONVENIENCE [1] - 34:6 JOHN [11] - 24:12, 25:1, 25:9, 26:8,
LOAN [10] - 19:1, 24:21, 25:3, 25:6,
INCREASES [1] - 17:20 26:18, 27:3, 27:16, 27:20, 28:25,
25:24, 25:25, 26:8, 26:9, 26:12, 27:23
INDEPENDENT [1] - 18:11 29:20, 30:2
LOANS [1] - 18:24
INDICATED [1] - 29:21 JOINDER [1] - 17:22
LOCAL [2] - 11:23, 12:8
INDICATION [4] - 28:7, 29:23, 41:19, JOINED [1] - 2:9
LOCATE [4] - 20:21, 36:11, 40:1, 40:3
42:5 JOINT [1] - 18:3
LOCATED [2] - 20:25, 40:2
INDICTED [1] - 17:13 JOINTLY [1] - 17:13
LOCATION [3] - 14:20, 16:3, 16:4
INDICTMENT [1] - 17:23 JUDGE [7] - 13:14, 14:8, 22:9, 26:15,
LOGISTICALLY [1] - 43:22
INDIVIDUAL [1] - 32:2 29:13, 29:15, 41:10
LOGISTICS [1] - 43:11
INDIVIDUALIZED [2] - 18:15, 18:23 JUDGE [1] - 1:10
LOOK [2] - 28:14, 42:15
INDIVIDUALS [2] - 31:13, 31:19 JUDGE [11] - 2:18, 23:12, 23:15, 26:19,
LOOKED [2] - 42:12, 42:13
INEFFECTIVE [1] - 33:13 27:8, 28:11, 29:22, 29:25, 30:7, 43:5,
LOOSELY [1] - 29:6
INFLUENCE [1] - 32:7 43:20
LOPEZ [1] - 17:14
INFORMATION [4] - 13:25, 16:3, 17:23, JUDICIAL [2] - 17:20, 22:22
LOSE [2] - 21:1, 34:20
35:25 JUNE [2] - 25:1, 27:22
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 52 of 55
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LUNCH [5] - 20:7, 20:10, 20:21, 44:10 33:11, 33:22, 34:10, 34:14, 34:25, OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 1:23,
35:9, 35:10, 35:13, 35:16, 35:24, 36:6, 45:15
M 36:10, 36:15, 41:2, 41:7, 41:17, 42:1, ON [4] - 1:12, 1:15, 1:17, 1:19
42:9, 42:22, 44:12 ONE [15] - 3:1, 3:14, 19:23, 20:17, 23:5,
MAILED [2] - 3:17, 23:9
MUELLER [1] - 33:19 26:22, 28:24, 30:10, 31:23, 35:15,
MANAGEMENT [2] - 26:20, 27:19
MUST [6] - 11:23, 11:24, 12:24, 13:6, 40:7, 41:2, 41:9, 42:15, 43:6
MANAGEMENT [1] - 20:8
18:7, 18:19 ONGOING [2] - 36:7, 36:10
MANNER [1] - 12:15
ONLY [2] - 1:3, 1:7
MARSHAL [1] - 3:12
MARSHALL [6] - 2:18, 24:19, 26:14,
N OPEN [1] - 2:2
OPEN [3] - 20:12, 36:1, 39:21
28:2, 31:25, 43:4 NAME [3] - 26:24, 27:11, 42:15
OPENING [3] - 23:15, 23:25, 43:23
MARSHALL [16] - 1:18, 2:18, 22:9, 23:3, NARROW [2] - 24:7, 24:8
OPINIONS [1] - 15:22
23:5, 23:8, 23:12, 26:15, 28:4, 29:13, NECESSARY [7] - 15:20, 15:21, 16:1,
OPPORTUNITY [5] - 11:25, 15:8, 17:3,
29:15, 35:11, 35:15, 43:5, 43:20, 44:5 25:22, 25:23, 31:20, 32:22
17:6, 17:9
MARSHALS [1] - 35:23 NECESSITATES [1] - 16:20
OPTIMIST [1] - 40:5
MARSHALS [1] - 20:3 NECESSITY [1] - 31:18
OPTION [2] - 20:1, 20:2
MATERIALS [3] - 22:20, 24:19, 24:23 NEED [9] - 14:18, 16:10, 21:4, 26:25,
OPTIONS [2] - 19:22, 20:6
MATTER [4] - 18:9, 23:5, 29:6, 36:8 29:3, 29:7, 35:5, 43:13, 43:14
OR [1] - 1:9
MAY [2] - 1:3, 1:5 NEEDED [5] - 14:23, 19:2, 19:13, 20:23,
ORDER [12] - 11:9, 11:22, 12:3, 12:6,
MEAN [2] - 22:14, 22:19 42:13
12:14, 12:18, 13:1, 13:13, 15:5, 16:20,
MEANINGFULLY [1] - 15:13 NEEDS [2] - 30:10, 32:6
17:25, 33:25
MEET [2] - 12:1, 16:15 NEGOTIATION [2] - 30:20, 31:9
ORDERED [1] - 15:6
MERELY [2] - 18:23, 30:24 NEW [1] - 33:13
ORDERS [3] - 11:6, 13:3, 43:6
METHODS [1] - 16:11 NICE [1] - 20:9
OTHERWISE [2] - 14:2, 35:2
MIDDLE [1] - 16:6 NIGHT [1] - 35:16
OWN [2] - 14:24, 18:11
MIGHT [5] - 19:12, 21:13, 23:24, 32:20, NO [1] - 1:5
40:3 NOON [2] - 34:5, 34:9
MIND [1] - 26:23 NORMALLY [1] - 43:16 P
MINE [1] - 22:11 NORTHERN [2] - 1:1, 45:4 PAGE [1] - 1:7
MINIMIZING [1] - 14:1 NOT [1] - 1:19 PAGES [1] - 45:6
MINUTES [2] - 3:1, 40:11 NOTE [2] - 13:22, 42:23 PARALEGAL [1] - 2:20
MISTAKE [1] - 41:25 NOTE [1] - 14:6 PART [7] - 15:11, 20:24, 24:8, 24:18,
MOMENT [5] - 3:14, 20:17, 36:3, 36:13, NOTED [2] - 16:18, 30:24 26:10, 27:19, 32:11
36:17 NOTHING [2] - 34:5, 44:13 PARTE [8] - 33:3, 41:4, 41:9, 41:11,
MONEY [12] - 25:2, 25:7, 26:4, 26:5, NOTICE [2] - 24:13, 28:6 41:18, 41:20, 42:10, 42:17
26:11, 27:3, 27:10, 27:13, 27:17, NOTIFIED [1] - 3:2 PARTIAL [1] - 1:9
27:18, 27:23 NOTING [1] - 16:7 PARTICULAR [3] - 18:8, 31:11, 32:8
MONEYS [1] - 26:18 NUMBER [2] - 1:6, 1:7 PARTIES [1] - 39:22
MOORE [1] - 2:10 NUMBER [1] - 2:4 PARTIES [1] - 11:13
MOORE [1] - 1:14 NUMBER [1] - 41:18 PARTY [4] - 12:13, 12:14, 12:17, 31:24
MOREOVER [3] - 15:1, 15:15, 18:18 PATIENCE [1] - 35:19
MORNING [13] - 2:8, 2:14, 2:18, 2:21, O PAUSE [1] - 20:19
19:14, 20:7, 20:11, 22:18, 22:25, PAYCHECK [1] - 24:20
OBJECT [1] - 16:16
23:19, 40:6, 43:4, 44:14 PDF [1] - 1:2
OBJECTION [2] - 22:9, 36:13
MOST [1] - 20:14 PENDING [3] - 29:5, 31:11, 32:5
OBSTRUCTION [3] - 30:1, 30:24
MOTION [23] - 11:10, 11:11, 11:12, PENNY [2] - 1:22, 45:15
OBVIOUSLY [5] - 19:24, 21:3, 22:14,
11:18, 15:24, 17:11, 19:6, 19:7, 19:8, PERCENT [1] - 34:19
23:14, 23:25
22:21, 23:8, 24:4, 24:6, 24:9, 24:20, PEREZ [2] - 12:22, 13:19
OCCUPY [1] - 33:1
25:12, 25:14, 25:19, 28:2, 28:14, 43:7, PERHAPS [5] - 3:21, 22:2, 33:19, 43:22,
OCCUR [1] - 31:22
43:9, 43:18 44:2
OCCURRED [2] - 30:15, 31:6
MOTIONS [1] - 23:20 PERIOD [1] - 1:5
OCCURRING [1] - 30:22
MOVE [4] - 22:7, 22:16, 29:9, 32:11 PERIOD [1] - 27:22
OCCURS [1] - 30:21
MOVEMENT [2] - 26:11, 27:2 PERMISSIBLE [1] - 28:12
OF [11] - 1:2, 1:5, 1:6, 1:1, 1:4, 1:9, 1:12,
MR [20] - 2:18, 2:21, 3:8, 22:9, 23:3, PERMIT [1] - 12:14
1:15, 1:17, 1:19, 45:4
23:5, 23:8, 23:12, 26:15, 28:4, 28:24, PERSON [1] - 42:11
OFF-THE-RECORD [2] - 10:21, 11:2
29:13, 29:15, 30:13, 32:24, 35:11, PERSONNEL [1] - 36:19
35:15, 43:5, 43:20, 44:5 OFFENSES [1] - 17:22
PERSUADED [2] - 15:25, 18:21
MS [37] - 2:8, 2:14, 20:17, 20:20, 21:10, OFFERED [1] - 14:22
PETITION [1] - 41:8
21:17, 21:21, 21:23, 22:6, 24:2, 24:7, OFFICE [1] - 36:19
PHONE [3] - 16:4, 30:18, 43:10
24:11, 25:21, 27:9, 28:22, 32:17, 33:2, OFFICE [1] - 2:11
PHONES [1] - 43:24
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PHRONT [1] - 25:5 PROTECTION [1] - 24:20 RELIABILITY [3] - 16:3, 16:8, 16:11
PINPOINT'S [1] - 17:14 PROVE [2] - 25:25, 26:3 RELIEF [2] - 12:21, 18:1
PLACE [1] - 12:15 PROVIDE [4] - 11:25, 12:9, 18:1, 35:25 REMAIN [1] - 29:4
PLANNING [3] - 24:15, 25:14, 35:13 PROVIDED [4] - 29:16, 35:11, 35:12, REMAINING [1] - 40:7
PLEA [5] - 14:1, 30:19, 31:8, 31:14, 35:16 REMEDIES [2] - 15:20, 18:19
31:15 PROVIDES [1] - 17:22 REMEDY [1] - 15:19
PLED [1] - 24:13 PROVIDING [2] - 13:24, 35:13 REMIND [1] - 32:13
PM [1] - 44:15 PROVING [1] - 26:9 REMOVE [1] - 24:14
POINT [5] - 19:9, 27:21, 29:10, 33:5, PURPOSE [1] - 13:22 REPLY [2] - 15:11, 26:14
35:5 PURPOSES [2] - 11:18, 12:12 REPORT [2] - 35:23, 40:17
PORTION [1] - 1:5 PURSUE [1] - 21:10 REPORTER [4] - 1:4, 1:8, 1:23, 45:15
POSITION [1] - 43:8 PUTS [1] - 27:5 REPORTER'S [1] - 28:15
POSSESSED [1] - 14:19 REPRESENTED [2] - 14:22, 18:25
POSSIBILITY [4] - 22:14, 30:20, 30:25, Q REQUEST [3] - 16:17, 41:3, 41:7
40:3 REQUESTED [2] - 12:4, 13:16
QUESTIONS [1] - 28:17
POSSIBLE [5] - 20:22, 22:24, 29:25, REQUIRE [2] - 11:22, 19:24
QUITE [1] - 43:15
31:8, 40:9 REQUIRED [2] - 13:7, 16:19
QUOTING [3] - 13:19, 14:5, 16:13
POSSIBLY [1] - 43:6 REQUIREMENTS [2] - 12:13, 16:16
POTENTIAL [7] - 15:3, 19:5, 21:6, REQUIRES [3] - 12:3, 16:9, 18:1
28:25, 31:12, 31:22 R REQUIRING [1] - 13:22
POTENTIALLY [1] - 31:1 RAISE [2] - 29:11, 30:22 RESERVATION [6] - 25:3, 25:4, 25:23,
PPP [1] - 25:3 RAISING [1] - 31:21 25:25, 26:7, 26:12
PRACTICAL [1] - 18:9 RATHER [1] - 14:7 RESOLUTION [1] - 14:9
PRECEDENT [1] - 44:3 REACH [2] - 3:4, 29:9 RESOURCE [2] - 26:20, 27:19
PREFERENCE [1] - 36:6 READ [5] - 24:4, 24:6, 25:12, 25:19, RESOURCES [1] - 17:20
PREJUDICE [10] - 13:8, 13:10, 14:17, 32:21 RESPOND [2] - 23:24, 24:2
15:3, 17:24, 18:3, 18:7, 18:13, 18:18, READING [1] - 22:20 RESPONSE [4] - 15:11, 17:8, 23:14,
19:3 READY [2] - 12:5, 35:3 24:6
PREJUDICIAL [1] - 17:1 REALLY [4] - 21:1, 31:19, 43:13, 44:9 RESTRICTED [1] - 1:4
PREPARATION [1] - 26:7 REASON [2] - 17:7, 44:8 RESULT [2] - 13:2, 18:3
PREPARE [4] - 15:22, 17:3, 17:9, 35:6 REASONS [2] - 13:7, 22:21 RESULTS [1] - 17:2
PREPARED [1] - 24:21 REBUT [1] - 14:23 REVERSAL [1] - 16:20
PREPARING [1] - 24:12 RECEIVE [1] - 31:1 REVERSED [1] - 16:21
PRESCRIBE [1] - 12:16 RECESS [8] - 10:22, 11:3, 13:11, 14:8, REVIEW [2] - 19:9, 28:14
PRESENCE [1] - 13:12 28:20, 35:20, 41:1, 44:15 REVISIT [1] - 43:6
PRESENT [1] - 1:19 RECOGNIZE [1] - 11:19 RICKY [3] - 32:1, 41:4, 41:7
PRESENT [1] - 19:11 RECOMMENDATION [1] - 22:10 RIGHTS [6] - 16:22, 16:23, 29:3, 32:9,
PRETRIAL [2] - 12:3, 16:1 RECONSIDER [1] - 43:18 32:22, 33:5
PREVIEW [2] - 33:22, 34:18 RECORD [15] - 2:7, 10:20, 10:21, 10:24, RISK [3] - 17:17, 30:22, 31:8
PREVIOUSLY [1] - 18:25 11:1, 11:2, 14:19, 23:21, 25:19, 28:15, RMR [2] - 1:22, 45:15
PRITTY [2] - 1:22, 45:15 35:22, 36:9, 39:21, 39:24, 41:16 ROAD [1] - 25:17
PRO [4] - 32:4, 33:10, 33:12, 33:15 RECORDED [1] - 1:21 ROADRUNNER [4] - 24:22, 24:25, 25:5,
PROCEDURE [3] - 11:22, 14:5, 17:21 RECORDS [2] - 24:25, 28:7 28:8
PROCEEDINGS [1] - 1:9 REDACT [2] - 26:23, 27:11 RODRIGUEZ [1] - 16:12
PROCEEDINGS [9] - 2:2, 3:22, 10:22, REDUCE [1] - 14:9 ROUTINE [1] - 16:2
11:3, 20:19, 35:20, 36:20, 44:15, 45:7 REDUCES [1] - 17:17 RULE [7] - 11:21, 12:14, 14:5, 15:4,
PROCEEDS [3] - 25:6, 25:24, 27:23 REFERENCE [2] - 18:24, 26:16 16:20, 17:21, 18:4
PRODUCED [2] - 41:4, 41:8 REFERENCING [1] - 1:7 RULE [5] - 11:23, 11:24, 12:2, 17:12,
PRODUCTIVE [1] - 28:20 REFLECT [1] - 10:24 17:17
PROFFERED [1] - 14:23 RELATE [1] - 41:12 RULES [1] - 12:9
PROGRAM [1] - 24:21 RELATED [5] - 24:20, 24:25, 26:20, RULING [3] - 11:18, 12:12, 28:16
PROHIBIT [1] - 12:17 27:18, 28:8 RULINGS [1] - 11:8
PROHIBITED [1] - 1:9 RELATES [1] - 36:7 RYAN [1] - 2:20
PROHIBITED [1] - 13:17 RELATIONSHIP [1] - 27:15
PROMOTE [1] - 13:23 RELATIVE [1] - 23:18 S
PROMPTING [1] - 13:2 RELAXING [2] - 43:3, 44:13
SACRIFICING [1] - 14:10
PROPERLY [1] - 16:11 RELEASE [1] - 40:22
SAMIR [1] - 1:13
PROPOSED [2] - 19:10, 32:10 RELEVANT [4] - 20:14, 24:9, 26:9,
SAMIR [1] - 2:9
PROTECT [1] - 32:9 27:14
SANCTION [5] - 12:25, 13:1, 13:15,
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 54 of 55
8
13:19, 14:15 SOPHIA [1] - 2:20 TESTIFIED [1] - 30:3
SARALIENE [1] - 1:16 SORRY [5] - 32:17, 41:6, 42:2, 43:5, TESTIFIES [4] - 30:21, 30:25, 32:3, 33:9
SARALIENE [1] - 2:16 43:19 TESTIFY [6] - 11:16, 29:4, 29:18, 31:14,
SCARCE [1] - 17:20 SORT [1] - 42:23 32:2, 34:1
SCHEDULED [2] - 33:24, 34:15 SORTED [1] - 24:16 TESTIFYING [2] - 14:21, 20:23
SCHEDULING [2] - 12:3, 12:6 SPECIAL [4] - 2:11, 11:16, 13:17, 15:7 TESTIMONY [16] - 11:10, 11:12, 12:20,
SE [4] - 32:4, 33:10, 33:12, 33:15 SPECIFIC [1] - 18:3 13:18, 14:18, 14:23, 15:9, 15:14, 16:2,
SEAL [12] - 3:16, 3:18, 3:22, 23:18, SPECIFICALLY [1] - 41:3 16:14, 16:15, 20:23, 32:8, 35:6
36:20, 39:23, 41:5, 41:8, 41:19, 41:20, SPECIFY [1] - 12:15 THE [66] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10,
41:24, 41:25 SPEEDIER [1] - 14:9 1:1, 1:9, 1:12, 1:15, 1:17, 1:19, 2:13,
SECOND [3] - 3:14, 3:15, 21:4 SPENT [1] - 40:23 2:17, 2:23, 3:7, 3:9, 10:24, 11:5,
SEE [13] - 2:13, 2:23, 20:2, 22:12, 23:1, SPOILED [1] - 44:1 20:18, 21:9, 21:11, 21:20, 21:22, 22:1,
34:17, 35:18, 40:9, 40:23, 42:13, 43:3, SPOKEN [1] - 20:8 22:8, 22:12, 23:4, 23:7, 23:11, 23:16,
43:9, 44:14 STAND [1] - 30:6 24:4, 24:8, 25:16, 26:13, 28:1, 28:13,
SEEKING [2] - 24:23, 24:24 STANDBY [2] - 2:22, 19:18 29:14, 32:12, 32:19, 32:25, 33:10,
SELECTION [3] - 22:15, 22:17, 22:18 STANDING [1] - 16:20 33:16, 34:3, 34:11, 34:22, 35:1, 35:18,
SENTENCING [3] - 29:5, 30:2, 31:12 START [6] - 19:15, 19:23, 20:21, 22:15, 35:22, 36:2, 36:8, 36:12, 36:16, 39:23,
SEPARATE [3] - 17:25, 25:7, 27:25 22:18, 28:6 41:6, 41:14, 41:22, 42:7, 42:19, 43:2,
SEPARATELY [1] - 21:16 STARTED [3] - 19:14, 23:15 43:18, 43:21, 44:6, 44:13
SEPTEMBER [1] - 16:7 STATEMENTS [3] - 18:12, 23:15, 24:1 THEREFORE [2] - 3:9, 40:17
SERIAL [1] - 17:18 STATES [5] - 2:5, 2:9, 16:5, 18:16, THEY'VE [1] - 29:18
SERIES [1] - 26:10 36:18 THINKING [1] - 30:15
SERIOUS [2] - 30:13, 31:5 STATES [6] - 1:1, 1:4, 1:10, 1:14, 1:23, THIRD [2] - 21:13, 26:3
SERVE [2] - 16:9, 22:23 45:3 THOMAS [4] - 26:6, 26:18, 27:3, 29:17
SERVICE [1] - 40:24 STEFAN [1] - 2:11 THOMAS'S [1] - 25:4
SERVICE [1] - 3:12 STENOGRAPHICALLY [1] - 1:21 THOUGHTS [2] - 20:13, 22:4
SERVICES [2] - 26:20, 27:19 STEP [2] - 36:2, 36:16 THREAT [2] - 29:24, 29:25
SET [3] - 2:3, 11:23, 19:25 STEPPING [1] - 36:13 THREATEN [1] - 30:23
SETTING [1] - 44:3 STILL [1] - 41:22 THREE [3] - 21:21, 21:24, 40:7
SEVER [7] - 11:11, 17:11, 17:25, 19:6, STITES [1] - 2:11 THURSDAY [4] - 15:16, 34:1, 34:13,
19:8, 22:22 STRATEGY [1] - 41:12 34:23
SEVERAL [4] - 12:25, 20:22, 34:14, STRONG [1] - 22:6 TIRE [1] - 16:13
34:20 STUFF [1] - 26:23 TO [2] - 1:5, 1:9
SEVERANCE [3] - 18:4, 18:19, 22:21 SUBJECT [1] - 36:8 TODAY [4] - 2:22, 35:17, 40:15, 42:3
SEVERE [4] - 13:1, 13:15, 15:19, 15:20 SUBMISSION [1] - 26:7 TOGETHER [3] - 17:13, 22:24, 25:2
SHARED [1] - 24:16 SUBSTANCE [1] - 40:1 TOMORROW [5] - 20:7, 22:17, 22:25,
SHORT [1] - 11:13 SUBSTANTIAL [3] - 16:22, 16:23, 17:1 40:6, 40:17
SHORTENED [1] - 21:18 SUFFERED [1] - 13:9 TOSSED [1] - 32:10
SHORTER [1] - 20:25 SUFFICIENT [1] - 18:20 TOUCH [1] - 34:17
SHOW [6] - 18:13, 18:18, 18:19, 25:1, SUFFICIENTLY [1] - 11:24 TOWARDS [1] - 32:11
26:25, 33:23 SUGGEST [2] - 26:22, 30:23 TRACK [1] - 21:6
SHOWING [1] - 18:13 SUGGESTION [1] - 30:5 TRANSACTIONS [1] - 26:10
SHOWS [1] - 27:24 SUM [1] - 40:1 TRANSCRIPT [1] - 45:7
SHRIVASTAVA [1] - 1:20 SUMMARIZING [1] - 29:22 TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9, 1:9
SHUFFLED [1] - 40:12 SUMMARY [1] - 11:7 TRANSCRIPTS [1] - 1:3
SIC [1] - 15:15 SUPPRESSING [1] - 14:7 TRAVEL [6] - 25:3, 25:4, 25:24, 25:25,
SIFT [2] - 18:14, 18:22 SURPRISE [2] - 14:1, 17:5 26:8, 26:12
SIGNATURE [3] - 26:16, 26:24, 27:11 SURPRISED [1] - 17:2 TRIAL [1] - 1:9
SIGNED [2] - 10:25, 41:10 SURROUNDING [1] - 14:13 TRIAL [37] - 2:4, 2:9, 3:3, 11:5, 11:25,
SIGNER [6] - 25:8, 25:9, 26:25, 27:1, SWORN [1] - 13:11 12:5, 12:14, 13:11, 13:13, 13:18, 14:2,
27:9, 27:12 14:8, 15:8, 15:22, 16:16, 17:23, 18:3,
SIGNERS [1] - 25:2 18:24, 19:15, 19:23, 20:1, 20:4, 20:24,
T 20:25, 21:4, 21:13, 21:14, 21:18,
SIJI [1] - 2:10
TABLE [1] - 2:20 21:24, 24:12, 24:23, 24:24, 27:17,
SILENT [1] - 29:4
TAL [1] - 1:13 29:9, 40:7, 43:10
SIMPLY [1] - 32:8
TAL [1] - 2:8 TRIALS [4] - 17:19, 17:25, 43:16
SITE [4] - 11:16, 14:20, 16:3, 16:8
TELDRIN [2] - 1:6, 1:15 TRIED [2] - 17:13, 42:3
SLIGHT [1] - 44:7
TELDRIN [1] - 2:15 TROUBLE [1] - 44:4
SMALL [1] - 43:7
TEN [1] - 3:1 TRUE [2] - 17:16, 45:6
SOMEONE [1] - 33:18
TERMS [1] - 12:16 TRY [8] - 19:24, 20:21, 21:6, 21:15,
Case 1:20-cr-00296-JPB-CMS Document 1024 Filed 06/14/24 Page 55 of 55
9
21:23, 22:23, 43:9, 44:8 WAITED [1] - 19:20
TRYING [4] - 21:22, 27:2, 42:2, 42:4 WAITING [3] - 21:1, 21:7, 40:23
TURNED [1] - 16:19 WANTS [5] - 19:8, 20:15, 30:12, 31:3,
TURNER [1] - 13:20 33:18
TWO [8] - 14:21, 20:1, 21:12, 21:19, WARRANT [3] - 3:10, 10:25, 19:20
21:21, 21:23, 26:20, 27:25 WARRANTING [1] - 18:18
TWO-AND-A-HALF [1] - 14:21 WAYS [1] - 43:21
TWO-WEEK [1] - 20:1 WEBSTER [12] - 1:16, 2:14, 22:6, 32:17,
TYPE [2] - 16:2, 29:16 33:2, 35:9, 36:15, 41:2, 41:7, 41:17,
42:1, 42:22
U WEBSTER [2] - 2:15, 35:5
WEDNESDAY [6] - 24:14, 34:2, 34:5,
ULTIMATELY [1] - 33:23
34:9, 34:16, 35:4
UNABLE [2] - 18:14, 18:22
WEEK [4] - 11:7, 15:17, 20:1, 21:13
UNDER [18] - 3:16, 3:18, 3:22, 11:24,
WEEKS [1] - 21:13
12:19, 15:5, 16:19, 18:8, 23:18, 31:1,
WEIGH [2] - 12:25, 13:6
36:20, 39:23, 41:5, 41:8, 41:19, 41:20,
WEIGHING [3] - 13:13, 13:14, 14:13
41:24, 41:25
WHATNOT [1] - 22:22
UNDERLYING [1] - 14:20
WHOLE [1] - 21:4
UNDERSTOOD [1] - 29:23
WIDE [1] - 12:19
UNDESIRABLE [1] - 14:1
WILEY [3] - 29:21, 30:10, 30:11
UNDISCLOSED [1] - 12:18
WILL [1] - 1:4
UNDUE [1] - 17:4
WIRE [1] - 26:5
UNDULY [1] - 17:2
WITH [1] - 1:10
UNEXPECTED [1] - 2:24
WITNESS [10] - 27:17, 30:7, 30:8,
UNEXPECTEDLY [1] - 43:3
30:23, 31:21, 31:23, 32:1, 33:4, 34:16,
UNFAIRLY [1] - 14:17
35:12
UNFAIRNESS [1] - 17:18
WITNESS'S [2] - 15:14, 32:8
UNFORTUNATELY [1] - 43:24
WITNESSES [8] - 17:19, 20:22, 29:2,
UNITED [6] - 1:1, 1:4, 1:10, 1:14, 1:23,
33:24, 34:15, 34:20, 35:14, 35:17
45:3
WL [1] - 16:6
UNITED [5] - 2:5, 2:9, 16:5, 18:16, 36:18
WORD [1] - 28:3
UNLAWFUL [1] - 26:4
WORKABLE [1] - 34:6
UNLESS [2] - 20:5, 33:13
WORRIED [1] - 44:3
UNSEALED [2] - 10:20, 39:21
WORST [1] - 29:25
UNTIMELY [2] - 11:17, 12:11
WORTH [1] - 21:7
UNWARRANTED [1] - 14:15
WORTHWHILE [2] - 24:6, 40:8
UP [10] - 11:6, 11:8, 28:17, 29:12, 32:3,
WRIT [5] - 41:4, 41:8, 42:12, 42:13,
33:17, 33:23, 34:1, 40:19, 42:20
42:14
UPDATED [1] - 35:24
WRITTEN [2] - 23:14, 25:18
US [10] - 3:12, 12:21, 13:3, 13:19, 13:21,
16:12, 16:13, 17:13, 18:5, 20:3
Y
V Y'ALL [1] - 44:14
YEARS [1] - 14:21
VERDICTS [1] - 17:18
YESTERDAY [1] - 23:8
VERGARA [1] - 16:24
YOU [2] - 1:5, 1:8
VIA [1] - 11:6
VICTIMS [1] - 17:19
VIEW [2] - 25:13, 25:21
VIOLATE [1] - 16:23
VIOLATES [1] - 16:21
VIOLATION [1] - 13:12
VOIR [1] - 40:15
VOLUME [1] - 1:6
VS [1] - 1:5
W
WAIT [8] - 20:2, 20:6, 20:9, 21:5, 22:11,
22:17, 22:25, 34:23
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