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Transcript of Jury Trial Proceedings, Volume 4 (PM Session) — Carla Jackson and Teldrin Foster
Summary
Transcript of the Volume 4 (PM Session) jury trial proceedings in United States v. Carla Jackson and Teldrin Foster, Docket No. 1:20-CR-00296-JPB, in the United States District Court for the Northern District of Georgia, Atlanta Division, before the Honorable J.P. Boulee on February 8, 2024; it is Document 1027, filed June 14, 2024. The index lists Joseph Stites (direct examination continued, then cross-examination by Marshall and by Webster) and Salvatore Hazel (direct examination). In the questioning that follows, Tal C. Chaiken has Agent Stites identify Government Exhibits, among them e-mails from a Teldrin Foster account to Darrell Thomas with Forms 941 and payroll spreadsheets for Infinite Education Services and for Advertising and Then Some.
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 4 (PM Session) — Carla Jackson and Teldrin Foster.”
Original at ecf.gand.uscourts.gov, No. 1:20-cr-00296-JPB-CMS, Doc. 1027. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-dixon/2024-02-08-jury-trial-transcript-vol4-dkt-1027/
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UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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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 4 (PM SESSION)
CARLA JACKSON AND )
7 TELDRIN FOSTER, )
)
8 DEFENDANTS. )
9
TRANSCRIPT OF JURY TRIAL PROCEEDINGS
10 BEFORE THE HONORABLE J.P. BOULEE
UNITED STATES DISTRICT JUDGE
11 FEBRUARY 8, 2024
12
13 APPEARANCES:
14 ON BEHALF OF THE GOVERNMENT:
TAL C. CHAIKEN, ESQ.
15 SAMIR KAUSHAL, ESQ.
BABASIJIBOMI MOORE, ESQ.
16 ASSISTANT UNITED STATES ATTORNEYS
17
ON BEHALF OF THE DEFENDANT - TELDRIN FOSTER:
18 LEIGH ANN WEBSTER, ESQ.
SARALIENE DURRETT, ESQ.
19
20 ON BEHALF OF THE DEFENDANT - CARLA JACKSON:
DAVID D. MARSHALL, ESQ.
21
22
23 STENOGRAPHICALLY RECORDED BY:
24 PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
25 UNITED STATES DISTRICT COURT
ATLANTA, GEORGIA
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1 I N D E X
2 WITNESS: PAGE:
3 1. JOSEPH STITES
4 DIRECT EXAMINATION (CONT'D)................163
5
2. SALVATORE HAZEL
6
DIRECT EXAMINATION.........................209
7
8 3. JOSEPH STITES (RESUMED)
9
CROSS-EXAMINATION (MARSHALL)...............215
10 CROSS-EXAMINATION (WEBSTER)................237
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1 (PROCEEDINGS HELD IN OPEN COURT AT 1:44 PM, ATLANTA, GEORGIA)
2 THE COURT: Y'all can be seated. Let's bring out the
3 jury.
4 MS. CHAIKEN: Your Honor?
5 THE COURT: One moment.
6 Yes.
7 MS. CHAIKEN: We have another witness whose testimony
8 we anticipate being brief who has a scheduling conflict. His
9 flight is leaving tomorrow morning at 11:45 a.m. We've
10 discussed with defense counsel putting him up after Agent
11 Stites's direct and before his cross, if the Court is amenable
12 to that.
13 Everybody consents?
14 MR. MARSHALL: Yes, Judge.
15 MS. WEBSTER: Yes.
16 THE COURT: Yeah, that's fine.
17 MS. CHAIKEN: He's on his way. We've asked him to
18 come as soon as he can to the courthouse.
19 THE COURT: No problem.
20 (The jury entered the courtroom at 1:45 p.m.)
21 THE COURT: Off the record.
22 (Off-the-record discussion.)
23 THE COURT: Y'all can be seated. Thank you.
24 Ladies and gentlemen of the jury, I hope you had a
25 wonderful lunch and that you're enjoying our delightful
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1 federal courthouse cafeteria as much as I do.
2 All right. Ms. Chaiken, you have the floor.
3 MS. CHAIKEN: Thank you, Your Honor.
4 DIRECT EXAMINATION
5 BY MS. CHAIKEN:
6 Q. All right. Agent Stites, we are going to move on to
7 talking about Infinite Education Services, okay?
8 A. Okay.
9 Q. Is that another one of the PPP loans involved in your
10 investigation?
11 A. It is.
12 MS. CHAIKEN: Could you please publish Government
13 Exhibit 2431.
14 BY MS. CHAIKEN:
15 Q. What's 2431?
16 A. This is an e-mail from Teldrin Foster iCloud account to
17 Darrell Thomas on April 27, 2020, at 3:29 p.m. And it's a
18 forward of a message from Teldrin Foster Yahoo! account to
19 Teldrin Foster iCloud account. The subject is Infinite.
20 MS. CHAIKEN: And could you please publish 2431C and
21 D side by side.
22 BY MS. CHAIKEN:
23 Q. Are these 941s that were attached to Mr. Foster's e-mail?
24 A. Yes.
25 Q. And then are these 941s stamped?
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1 A. No, they're not.
2 Q. Do they include the same numbers that we looked at
3 earlier for all of the businesses that submitted identical
4 forms?
5 A. Yes.
6 MS. CHAIKEN: Could you please publish 2413A and
7 2431B side by side.
8 BY MS. CHAIKEN:
9 Q. Is 2431B a 940 that Teldrin Foster sent to Darrell
10 Thomas?
11 A. Yes.
12 Q. And is 2413A a 940 that was prepared for Bellator Phront
13 Group?
14 A. Yes, it is.
15 Q. And are the numbers on those documents identical?
16 A. They're identical.
17 Q. Was anything changed?
18 A. Just the information changed to Infinite Education
19 Services and the EIN number and then the address information
20 for Infinite Education Services.
21 MS. CHAIKEN: If you could please publish Government
22 Exhibit 2436. And if you could pull that out, please. Thank
23 you.
24 BY MS. CHAIKEN:
25 Q. What's Government Exhibit 2436?
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1 A. It's an e-mail from Teldrin Foster iCloud account to
2 Darrell Thomas on April 28th, 2020, at 1:13 a.m. It's a
3 forward of a message from Utwuan Cooper to Teldrin Foster
4 iCloud account.
5 Q. And, again, did you speak to Teldrin Foster about Utwuan
6 Cooper in your interview?
7 A. Yes.
8 Q. And does Teldrin Foster know Utwuan Cooper?
9 A. He does.
10 MS. CHAIKEN: And if you could scroll down.
11 BY MS. CHAIKEN:
12 Q. Was there an attachment embedded within the e-mail?
13 A. Yes.
14 Q. And what was that?
15 A. It's a Form 941 for 2020, first quarter for Infinite
16 Education Services, Inc. It shows 66 employees. And the
17 wages were 959,946.42. And it does have stamps on it.
18 Q. And what quarter did you say this was for?
19 A. The first quarter.
20 Q. Of 2020?
21 A. Of 2020.
22 Q. Okay. So it ended in March of 2020?
23 A. Yes.
24 Q. What was the date of the stamp on the form?
25 A. It says April 22nd of 2019.
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1 Q. So is it stamped as being received before the quarter
2 even ended?
3 A. Yes.
4 MS. CHAIKEN: If you could please publish 2318 and
5 2318A side by side. And if you could pull out that second
6 message, please, Ms. Holland.
7 BY MS. CHAIKEN:
8 Q. Was this a document that Darrell Thomas sent to Teldrin
9 Foster on May 5th of 2020?
10 A. Yes.
11 Q. What was the document?
12 A. It is a document from Internal Revenue Service to
13 Infinite Education Services, Inc., a letter thanking them for
14 the inquiry on March 29th, 2017, and providing an EIN number.
15 MS. CHAIKEN: If you could please go to 2445 and
16 2445G.
17 BY MS. CHAIKEN:
18 Q. Is this the same e-mail we've looked at with the
19 identical payroll spreadsheets for various businesses?
20 A. Yes.
21 Q. Was there a spreadsheet for Infinite Education?
22 A. Yes.
23 Q. Again, was this that spreadsheet that used the template
24 that was created by Gena Pyfrom-Foster for Bellator?
25 A. Yes.
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1 MS. CHAIKEN: Could you please publish 2332, page 2.
2 BY MS. CHAIKEN:
3 Q. And could you please just read the conversation to the
4 jury.
5 A. So Darrell Thomas says, Resend Infinite 941 forms.
6 And Teldrin Foster replied, SMH, or shaking my head.
7 Q. And what was the date of those messages?
8 A. 6/16/2020.
9 Q. At this point in time had Darrell Thomas already begun
10 communicating directly with Gena Pyfrom-Foster via WhatsApp?
11 A. Yes.
12 Q. And who did Darrell Thomas send this WhatsApp message to
13 when he wanted the Infinite 941 forms to be re-sent?
14 A. To Teldrin Foster.
15 MS. CHAIKEN: Could you please publish 2513.
16 BY MS. CHAIKEN:
17 Q. And tell me what that exhibit is?
18 A. It's an e-mail from Teldrin Foster Yahoo account to
19 Darrell Thomas on June 25th, 2020, at 12:58 a.m.
20 Q. And what did that e-mail attach?
21 A. It attached payroll reports for Infinite Education
22 Services, 941s for 2019 and a -- let's see. That's it.
23 MS. CHAIKEN: Could you please publish 2513C.
24 BY MS. CHAIKEN:
25 Q. Is this the payroll spreadsheet that was sent by Teldrin
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1 Foster at Yahoo?
2 A. Yes.
3 Q. Did it change the amount of the payroll from the
4 spreadsheet that had previously been sent by Teldrin Foster at
5 iCloud?
6 A. Yes.
7 Q. Did it change the names?
8 A. Yes.
9 Q. And did this happen in June after Gena Pyfrom-Foster
10 started communicating directly with Darrell Thomas via
11 WhatsApp?
12 A. Yes.
13 MS. CHAIKEN: Could you please publish 2513F.
14 BY MS. CHAIKEN:
15 Q. Is this one of the Form 941s that the Yahoo account sent?
16 A. Yes, it is.
17 Q. And are the numbers on this 941 different from the
18 numbers that teldrinfoster@icloud had previously sent?
19 A. Yes.
20 Q. Was this document stamped?
21 A. No.
22 MS. CHAIKEN: Could you go to 2474, please.
23 I'm sorry, before we get to 2474.
24 Your Honor, I'm going to --
25 Can you go back to 2513 real quick, please.
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1 Okay. I'm going to move to admit 2348, which was
2 previously authenticated by Candace Hunter.
3 MS. WEBSTER: No objection.
4 THE COURT: Mr. Marshall?
5 MR. MARSHALL: Yes, Judge, I'm pulling it up.
6 Okay. No objection.
7 THE COURT: It's admitted.
8 MS. CHAIKEN: Thank you.
9 Ms. Holland, could you please publish 2348.
10 BY MS. CHAIKEN:
11 Q. Is this a WhatsApp message from Darrell Thomas to Gena
12 Pyfrom-Foster?
13 A. Yes.
14 Q. Okay. And what did Darrell Thomas say in the first
15 message?
16 A. Good morning. Sounds great.
17 Q. What's the date of these messages?
18 A. 6/25 of 2020.
19 Q. Is that the same date that the Yahoo account sent the
20 Infinite Education documents?
21 A. Yes.
22 Q. And what did Gena Pyfrom-Foster say?
23 A. Okay. Did you get the three from yesterday?
24 Q. What did Darrell Thomas say?
25 A. Yeah, just waiting on him to knock the stamps out.
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1 MS. CHAIKEN: Could you pull that message out,
2 please, Ms. Holland.
3 BY MS. CHAIKEN:
4 Q. He said, Yeah, just waiting on him to knock the stamps
5 out?
6 A. Yes.
7 MS. CHAIKEN: If you could please publish 2474.
8 BY MS. CHAIKEN:
9 Q. What's 2474?
10 A. It's an e-mail message from Teldrin Foster iCloud account
11 to Darrell Thomas on June 26th, 2020, at 1:40 a.m.
12 Q. Is that late at night after the messages we just looked
13 at?
14 A. Yes.
15 Q. Did this e-mail come from the iCloud account?
16 A. It did.
17 MS. CHAIKEN: And if you could please publish 2474A
18 and B.
19 BY MS. CHAIKEN:
20 Q. Were these two of the attachments that were included in
21 that e-mail from the iCloud account?
22 A. Yes.
23 Q. And were they Form 941s for Infinite Education Services?
24 A. Yes.
25 Q. Did these have stamps on them?
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1 A. They do.
2 Q. So did this loan follow the same pattern where the iCloud
3 account sent identical documents, then the Yahoo account
4 changed those documents and the iCloud account stamped them?
5 A. Yes.
6 Q. Okay. Let's move on to Advertising and Then Some. Is
7 that the name of a business that was involved in your
8 investigation?
9 A. Yes.
10 MS. CHAIKEN: Could you please publish 2441.
11 BY MS. CHAIKEN:
12 Q. What's 2441?
13 A. It's an e-mail from Teldrin Foster iCloud account to
14 Darrell Thomas on May 6th, 2020, 11:12 p.m. And its subject
15 is Advertising.
16 MS. CHAIKEN: If you could please publish 2441A and B
17 side by side.
18 BY MS. CHAIKEN:
19 Q. Were these two of the attachments that were included in
20 the e-mail?
21 A. Yes.
22 Q. What were those attachments?
23 A. Form 941s for 2019, quarter 3 and quarter 4, for
24 Advertising and Then Some, Inc.
25 Q. Did these forms have the same numbers as the set of
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1 numbers we've looked at earlier?
2 A. Yes.
3 MS. CHAIKEN: If you could go to 2447, please.
4 BY MS. CHAIKEN:
5 Q. What's 2447?
6 A. It's an e-mail from Teldrin Foster iCloud to Darrell
7 Thomas on May 8th, 2020, at 12:51 a.m. And the subject is
8 Advertising and Then Some.
9 MS. CHAIKEN: If you could please put 2447A side by
10 side with 2445D.
11 BY MS. CHAIKEN:
12 Q. Is 2447 the payroll spreadsheet that was attached to the
13 iCloud e-mail for Advertising and Then Some?
14 A. Yes.
15 Q. And is 2445D the payroll spreadsheet we looked at earlier
16 for Gaines Reservation & Travel?
17 A. It is.
18 Q. Are they the same or different?
19 A. They are the same except for the company name.
20 Q. And the -- are the employee names different as well?
21 A. And the employee names, yes.
22 MS. CHAIKEN: Could you please publish 2322.
23 BY MS. CHAIKEN:
24 Q. Is this a series of messages from Darrell Thomas to
25 Teldrin Foster on May 12th of 2020?
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1 A. Yes, it is.
2 Q. And looking at the page, what did Darrell Thomas send to
3 Teldrin Foster?
4 A. Sending a business name, a QuickBooks login, letter of
5 incorporation, EIN, DL front and back, voided check, business
6 card, utility bill. It's a listing of things that were going
7 to be needed for the businesses.
8 Q. And looking down below, is there additional information
9 listed for more businesses?
10 A. Yes.
11 MS. CHAIKEN: And if you could scroll down,
12 Ms. Holland.
13 BY MS. CHAIKEN:
14 Q. Was there a long list of businesses?
15 A. Yes.
16 Q. Do you see Continuing Success on there in the middle?
17 A. Yes.
18 Q. Is that one of the businesses we've talked about?
19 A. Yes.
20 MS. CHAIKEN: Okay. And if you could go up a little
21 bit. Right there.
22 BY MS. CHAIKEN:
23 Q. Do you see Advertising and Then Some?
24 A. Yes, I do. Right at the bottom of the -- where the
25 government exhibit sticker is.
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1 MS. CHAIKEN: If you could go to 2512, please.
2 BY MS. CHAIKEN:
3 Q. What's 2512?
4 A. It's an e-mail from Teldrin Foster Yahoo account to
5 Darrell Thomas on June 15, 2020, at 9:20 p.m. And the subject
6 is Advertising and Then Some.
7 Q. And what did that e-mail attach?
8 A. Several 941s for 2019 and the first quarter of 2020. And
9 then payroll reports for 2019 and 2020.
10 MS. CHAIKEN: And if you could go to 2512D and 2512E.
11 BY MS. CHAIKEN:
12 Q. Are these two of the attachments that were attached to
13 the Yahoo e-mail?
14 A. Yes.
15 Q. And did these -- did these numbers in these documents
16 change from what Teldrin at iCloud had previously sent?
17 A. Yes.
18 Q. Was the 941 form stamped?
19 A. No.
20 MS. CHAIKEN: If you could please go to 2472.
21 BY MS. CHAIKEN:
22 Q. What's 2472?
23 A. It's an e-mail from Teldrin Foster iCloud to Darrell
24 Thomas, June 16th, 2020, at 5:37 a.m. And the subject is
25 Some, Inc.
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1 Q. Is this the day -- is this sent after the Yahoo e-mail?
2 A. Yes.
3 MS. CHAIKEN: Could you please publish 2472A and
4 2472B.
5 BY MS. CHAIKEN:
6 Q. Were these two of the forms that were attached to the
7 iCloud e-mail to Darrell Thomas?
8 A. Yes.
9 Q. And were these forms stamped?
10 A. Yes, they were.
11 MS. CHAIKEN: Ms. Holland, if you could blow up the
12 first half -- the top half of 2472B.
13 BY MS. CHAIKEN:
14 Q. What quarter was this 941 for?
15 A. What -- say it again.
16 Q. I'm sorry. What quarter was it for?
17 A. Quarter. The fourth quarter.
18 Q. Which months are those?
19 A. October, November, December.
20 Q. So when did the fourth quarter of 2019 end?
21 A. December 31st.
22 Q. Of 2019?
23 A. 2019.
24 Q. And do you see the stamp there in the middle of the page?
25 A. I do.
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1 Q. And what date is listed on that stamp?
2 A. 10/21/2019.
3 Q. Is it stamped as if it was received before the quarter
4 ended?
5 A. Yes.
6 MS. CHAIKEN: If you could please go to 2336. And if
7 you could blow up that green message, please, Ms. Holland.
8 BY MS. CHAIKEN:
9 Q. Did Darrell Thomas message anybody about the mistake in
10 the stamp?
11 A. Yes.
12 Q. Who did he message?
13 A. Teldrin Foster.
14 Q. And what did he say?
15 A. And fourth quarter Advertising you have to put the 2020
16 stamp on it.
17 Q. At this point in time was Darrell Thomas already
18 communicating via WhatsApp with Gena Pyfrom-Foster?
19 A. Yes.
20 Q. If he wanted Gena Pyfrom-Foster to fix the stamp, could
21 he have messaged her?
22 A. Yes.
23 Q. What was the date and time of this e-mail?
24 A. It would be 6/27/2020. And if you take it back the four
25 hours, then it would have been 6/26/2020.
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1 Q. Okay. So June 26th, 2020, at about 8:05?
2 A. 8:05.
3 MS. CHAIKEN: Okay. If you could please publish 2477
4 and 2477A.
5 BY MS. CHAIKEN:
6 Q. What's 2477?
7 A. It's an e-mail from Teldrin Foster iCloud account to
8 Darrell Thomas on June 27th, 2020, at 1:25 a.m. Subject is
9 Advertising.
10 Q. And is that a few hours after the WhatsApp message we
11 just looked at?
12 A. Yes.
13 Q. What was the attachment?
14 A. The Form 941 for 2019 fourth quarter for Advertising and
15 Then Some, with a corrected stamp.
16 Q. Okay. So the stamp now is a 2020 date?
17 A. Now the stamp's at 2020. It's January 24th, 2020.
18 Q. Okay. So Darrell Thomas WhatsApped Teldrin Foster to say
19 you need a 2020 stamp. And then the iCloud account sent a
20 Form 941 with a 2020 stamp?
21 A. Yes.
22 Q. Let's talk about D. Parker Holdings. Is that another
23 business that was involved in your investigation?
24 A. Yes.
25 MS. CHAIKEN: Could you please publish 2322, page 2.
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1 BY MS. CHAIKEN:
2 Q. Is this the list of businesses we were looking at before?
3 A. Yes.
4 Q. Was D. Parker on that list down towards the bottom?
5 A. Yes. Yes. Right -- kind of a little bit lower than the
6 middle.
7 Q. Did Darrell Thomas send the list of various documents?
8 A. Yes.
9 MS. CHAIKEN: Could you please publish 2324 and
10 2324A.
11 BY MS. CHAIKEN:
12 Q. Did Darrell Thomas send Teldrin Foster an image on the
13 late night of May 16th, 2020?
14 A. Yes, he did.
15 Q. What was that image?
16 A. An image that had a business name of D. Parker Holdings
17 with the address for D. Parker Holdings, a contact name of
18 Derek Parker, a phone number for Derek Parker, or for the D.
19 Parker Holdings, and then the EIN.
20 MS. CHAIKEN: Could you please go to 2464.
21 BY MS. CHAIKEN:
22 Q. Is this an e-mail from the iCloud account to Darrell
23 Thomas?
24 A. Yes.
25 Q. And is it sent on May 17th, 2020, at 3:24 a.m.?
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1 A. It is.
2 Q. Was that shortly after the WhatsApp message we just
3 looked at?
4 A. Yes.
5 MS. CHAIKEN: If you could go to 2464B and C, please.
6 BY MS. CHAIKEN:
7 Q. What were the attachments?
8 A. Form 941s for 2019, the fourth quarter and the third
9 quarter, for D. Parker Holdings.
10 Q. And did these 941s have the same numbers as forms we've
11 been looking at?
12 A. Yes, these are the ones that are exactly the same.
13 MS. CHAIKEN: Could you please go to 2329 and 2329A.
14 BY MS. CHAIKEN:
15 Q. Down at the bottom, the bottom message on the right, did
16 Darrell Thomas send Teldrin Foster a document?
17 A. Yes.
18 Q. What was that document?
19 A. A Bank of America bank statement for D. Parker Holdings
20 for the month of February 2020, with an account number ending
21 in 1920.
22 Q. Did you get bank records for this bank account?
23 A. Yes.
24 Q. Was this a real bank statement?
25 A. No.
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1 Q. And in your review of the WhatsApp messages between
2 Darrell Thomas and Teldrin Foster, did you see anything that
3 would explain why they were exchanging documents related to
4 all these businesses other than PPP program?
5 A. No.
6 MS. CHAIKEN: Could you go to 2467, please.
7 BY MS. CHAIKEN:
8 Q. What's 2467?
9 A. It's an e-mail from Teldrin Foster iCloud account to
10 Darrell Thomas on June 4th, 2020, at 12:55 a.m.
11 Q. Okay. And is this just about one day before Gena
12 Pyfrom-Foster and Darrell Thomas started communicating via
13 WhatsApp?
14 A. Yes.
15 MS. CHAIKEN: Could you do 2445D side by side with
16 2467A, please.
17 BY MS. CHAIKEN:
18 Q. Is 2467A what Teldrin at iCloud sent to Darrell Thomas on
19 June 4th?
20 A. Yes.
21 Q. And is 2445D the payroll spreadsheet we looked at before
22 for Gaines Reservation & Travel?
23 A. Yes.
24 Q. Are the numbers the same?
25 A. Numbers are the same.
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1 Q. Are the names the same?
2 A. The names are different.
3 Q. And is the business name the same?
4 A. The business name is different.
5 Q. Okay. So used the same numbers, different names?
6 A. Yes.
7 MS. CHAIKEN: Could you go to 2508, please.
8 BY MS. CHAIKEN:
9 Q. What's the date of this e-mail?
10 A. June 8th, 2020, at 7:39 p.m.
11 Q. And who is it from and to?
12 A. teldrin_foster@yahoo to Darrell Thomas. And the subject
13 is D. Parker Holdings, Inc.
14 Q. And is this document -- is this e-mail about four days
15 after the e-mail we just looked at from the iCloud account?
16 A. Yes.
17 Q. And is this e-mail after Gena Pyfrom-Foster started
18 communicating with Darrell Thomas via WhatsApp?
19 A. Yes.
20 MS. CHAIKEN: Could you go to 2508H side by side with
21 2467A, please.
22 BY MS. CHAIKEN:
23 Q. Is 2467A on the right the payroll spreadsheet that the
24 Teldrin iCloud account sent to Darrell Thomas?
25 A. Yes.
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1 Q. And is 2508H on the left the payroll document that
2 Teldrin at Yahoo sent to Darrell Thomas?
3 A. Yes.
4 Q. Did the numbers change in them?
5 A. Yes.
6 Q. Did the names change?
7 A. Yes.
8 Q. Is this the same pattern where the iCloud account
9 prepared the documents and then the Yahoo account came in and
10 changed them?
11 A. Yes.
12 Q. Let's go to ML Exotic Customs.
13 MS. CHAIKEN: Could you publish 2511, please.
14 BY MS. CHAIKEN:
15 Q. What's Government Exhibit 2511?
16 A. It's an e-mail from Teldrin Foster Yahoo account to
17 Darrell Thomas on June 14th, 2020, at 8:02 p.m. And the
18 subject is ML Exotic Customs.
19 Q. And this was after Darrell Thomas and Gena Pyfrom-Foster
20 were in communication?
21 A. Yes.
22 MS. CHAIKEN: If you could go to 2511E, please.
23 BY MS. CHAIKEN:
24 Q. Was this one of the attachments to the Yahoo e-mail?
25 A. Yes.
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1 Q. And was it a 941 for 2019?
2 A. Yes, it is.
3 Q. Was it stamped?
4 A. No.
5 MS. CHAIKEN: If you could go back to 2511.
6 BY MS. CHAIKEN:
7 Q. What was the date on that e-mail?
8 A. June 14th, 2020, at 8:02 p.m.
9 MS. CHAIKEN: If you could go to 2332, please. And
10 if you could pull out the big green message, please.
11 BY MS. CHAIKEN:
12 Q. What did Darrell Thomas text to Teldrin Foster on the
13 late night of June 15th, 2020?
14 A. What's the ETA on ML Customs?
15 Q. Okay. And was that about 8:28 p.m. June 15th?
16 A. Approximately, yes.
17 MS. CHAIKEN: Could you please publish 2471.
18 BY MS. CHAIKEN:
19 Q. And what's 2471?
20 A. An e-mail from Teldrin Foster iCloud to Darrell Thomas on
21 June 16th, 2020, at 4:14 a.m. Subject is ML Exotic Custom.
22 Q. Was that a few hours after the WhatsApp message we just
23 saw?
24 A. Yes.
25 MS. CHAIKEN: And if you could please publish 2471A
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1 and B.
2 BY MS. CHAIKEN:
3 Q. Were these the attachments to the e-mail from the iCloud
4 account?
5 A. Yes, they are.
6 Q. And this time were the Form 941s stamped?
7 A. Yes, they were.
8 Q. So the Yahoo account sent the 941s -- Darrell Thomas sent
9 a message on WhatsApp to Teldrin Foster and then the iCloud
10 account sent the stamped documents?
11 A. That's correct.
12 Q. All right. Is another loan involved in your
13 investigation Bellevie?
14 A. Yes.
15 MS. CHAIKEN: Could you please publish 2333 and
16 2333A. If you could pull out that message at the top right
17 corner, please.
18 BY MS. CHAIKEN:
19 Q. What did Darrell Thomas send to Teldrin Foster on
20 June 23rd, 2020?
21 A. A Paycheck Protection Program borrowing application for
22 Bellevie Corp.
23 Q. And at this point in time on June 23rd, 2020, was Darrell
24 Thomas already in direct communication via WhatsApp with Gena
25 Pyfrom-Foster?
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1 A. Yes.
2 Q. Could he have sent this to her?
3 A. He could have.
4 MS. CHAIKEN: Could you please go to 2514.
5 BY MS. CHAIKEN:
6 Q. What was 2514?
7 A. It's an e-mail from teldrin_foster@yahoo to Darrell
8 Thomas on June 26th, 2020, at 12:08 a.m.
9 Q. And did it attach payroll spreadsheets and 941s for
10 Bellevie?
11 A. Yes.
12 MS. CHAIKEN: If you could publish 2514G, please.
13 BY MS. CHAIKEN:
14 Q. Is this one of the 941s that was attached to the e-mail?
15 A. Yes.
16 Q. Were the 941 forms stamped?
17 A. No.
18 MS. CHAIKEN: Could you go to 2475, please.
19 BY MS. CHAIKEN:
20 Q. What's 2475?
21 A. An e-mail from Teldrin Foster iCloud account to Darrell
22 Thomas on June 26th, 2020, at 7:38 a.m.
23 MS. CHAIKEN: If you could please publish 2475A and
24 B. And if you could scroll down on 2475A, please.
25 BY MS. CHAIKEN:
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1 Q. Were these two of the attachments to the iCloud e-mail?
2 A. Yes.
3 Q. And were they 941 forms?
4 A. Yes.
5 Q. Were they stamped?
6 A. Yes.
7 Q. Did this loan follow the same pattern where the Yahoo
8 account sent the documents and then the iCloud account stamped
9 them?
10 A. Yes.
11 Q. Finally let's talk about Mickies Auto and Tire. Is that
12 another loan that was involved in your investigation?
13 A. Yes.
14 MS. CHAIKEN: Could you please publish 2516.
15 BY MS. CHAIKEN:
16 Q. What is 2516?
17 A. It's an e-mail from teldrin_foster@yahoo account to
18 Darrell Thomas. And the subject is Mickies Auto and Tire,
19 LLC.
20 Q. Did it attach payroll spreadsheets and 941s?
21 A. Yes.
22 MS. CHAIKEN: Could you go to 2516E, please.
23 BY MS. CHAIKEN:
24 Q. Is this one of the 941s that was attached to the e-mail?
25 A. Yes.
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1 Q. Was it stamped?
2 A. No.
3 MS. CHAIKEN: Could you go to 2479, please.
4 BY MS. CHAIKEN:
5 Q. What's 2479?
6 A. That's an e-mail from Teldrin Foster iCloud account to
7 Darrell Thomas on June 30th, 2020, 11:11 p.m. And the subject
8 is Mickies.
9 MS. CHAIKEN: And if you could go to 2479A and B,
10 please.
11 BY MS. CHAIKEN:
12 Q. Were these two of the attachments to the iCloud e-mail?
13 A. Yes.
14 Q. Were they Form 941s?
15 A. Yes.
16 Q. And were these copies of the 941s stamped?
17 A. Yes, they were.
18 Q. Of the 14 businesses that we've just talked about, is
19 Mickies Auto and Tire the only one that you didn't see
20 referenced in the WhatsApp communications between Darrell
21 Thomas and Teldrin Foster?
22 A. Yes.
23 Q. Did it follow the same pattern where the Yahoo account
24 sent the documents and then the iCloud account sent the
25 stamped documents?
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1 A. Yes, that's correct.
2 MS. CHAIKEN: Is 2348 in?
3 MS. HOLLAND: Yes.
4 MS. CHAIKEN: Could we please publish 2300, page 388,
5 side by side with 2348.
6 BY MS. CHAIKEN:
7 Q. On the left side, 2300, page 388, is that a string of
8 WhatsApps between Darrell Thomas and Teldrin Foster?
9 A. Yes.
10 Q. And on the right side, is that a string of WhatsApp
11 messages between Darrell Thomas and Gena Pyfrom-Foster?
12 A. Yes.
13 Q. Were both of these messages -- message strings on the
14 same date, June 25th of 2020?
15 A. Yes.
16 Q. And if Darrell Thomas wanted to be communicating with
17 Gena Pyfrom-Foster at this time, could he have -- would he
18 have messaged her?
19 A. Yes.
20 Q. And if he wanted to communicate with Teldrin Foster,
21 would he have messaged Teldrin Foster?
22 A. Yes.
23 Q. When you reviewed the WhatsApp messages between Darrell
24 Thomas and Teldrin Foster on the one hand and Darrell Thomas
25 and Gena Pyfrom-Foster on the other hand, did you notice a
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1 difference in communication styles between them?
2 A. Yes.
3 Q. Can you describe those?
4 A. Gena Pyfrom-Foster's messages with Darrell Thomas are a
5 little more verbose, you know, full sentences, a lot of
6 punctuation, capitalization. And even the -- even Darrell
7 Thomas's responses are a little more, you know, full
8 sentence-type structure; where the communication between
9 Mr. Foster and Darrell Thomas is more maybe traditional, sort
10 of short text messages, shortened words. You know, there's
11 curse words and stuff in the language, not really punctuating
12 or creating, you know, full sentences, but just very
13 shortened, to-the-point sort of messaging.
14 MS. CHAIKEN: Your Honor, I'm going to move to admit
15 2350, which was authenticated by Candace Hunter.
16 MS. WEBSTER: No objection.
17 MR. MARSHALL: No objection.
18 THE COURT: It's admitted.
19 MS. CHAIKEN: Thank you.
20 Could you publish 2350, please.
21 BY MS. CHAIKEN:
22 Q. Is this a string of text messages between Darrell Thomas
23 and Gena Pyfrom-Foster?
24 A. Yes.
25 Q. Okay. And can you just describe what you saw in the
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1 language that you were using now that -- the language that you
2 were describing now that you have this exhibit in front of
3 you?
4 A. Yes. Just on -- on Darrell Thomas's message, he's
5 writing pretty long, you know -- long sentences with
6 punctuation. And then when you get to the Gena response,
7 she's responding in longer sentences and clear words, not
8 shortened words with punctuation.
9 MS. CHAIKEN: If you could go down to page 2.
10 BY MS. CHAIKEN:
11 Q. Did Darrell Thomas say to Gena Pyfrom-Foster, Yeah, if it
12 isn't too much trouble --
13 A. Yes.
14 Q. -- in that message at the top?
15 A. Yes.
16 Q. Did you ever see him say anything like that when he was
17 talking to Teldrin Foster?
18 A. No.
19 Q. Did Darrell Thomas speak differently to Gena
20 Pyfrom-Foster than to Teldrin Foster?
21 A. Yes.
22 Q. Based on your review of all the evidence we've looked at
23 and the e-mails and the messages, did you determine that after
24 Gena Pyfrom-Foster began communicating directly with Darrell
25 Thomas via WhatsApp, that Teldrin Foster stayed involved and
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1 also continued working with Darrell Thomas?
2 A. Yes.
3 Q. Based on your review of the phone calls, did they
4 continue talking on the phone every day or nearly every day
5 during that period?
6 A. Yes.
7 Q. Based on your review of the WhatsApp messages between
8 Teldrin Foster and Darrell Thomas, was there anything else the
9 two of them could have been talking about daily other than the
10 PPP program?
11 A. No.
12 Q. In your interview with Teldrin Foster, did he tell you
13 how much money he got from Darrell Thomas since April of 2020?
14 A. Yes. He said between 50 and $60,000.
15 MS. CHAIKEN: Ms. Holland, could you publish 2250G,
16 please.
17 (Government Exhibit 2250G published.)
18 MS. CHAIKEN: And if you could go to 2879, please.
19 BY MS. CHAIKEN:
20 Q. Is this the check we looked at earlier that Teldrin
21 Foster got from Bellator Phront Group?
22 A. Yes.
23 Q. What did the memo line say?
24 A. Roswell Road office.
25 Q. Did you ever see anything in their conversations about a
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1 Roswell Road office?
2 A. No.
3 MS. CHAIKEN: Could you go to 2871, page 2, please.
4 BY MS. CHAIKEN:
5 Q. Was this the bank statement for Teldrin Foster that we
6 looked at earlier?
7 A. Yes.
8 Q. And do you see the deposit there of the $34,500 check?
9 A. I do.
10 MS. CHAIKEN: If you could scroll down to page 3,
11 Ms. Holland.
12 BY MS. CHAIKEN:
13 Q. What kind of transactions were in the account after that?
14 A. A little bit of cash withdrawal and a lot of Cash App
15 payments and Zelle payments. A little bit of purchasing.
16 MS. CHAIKEN: If you could go to 2872, page 2,
17 please.
18 BY MS. CHAIKEN:
19 Q. Is this the account statement for Teldrin Foster for the
20 following month, June 11th, 2020, to July 10th of 2020?
21 A. Yes.
22 Q. And what kinds of transactions were there in the account
23 that month?
24 A. Same sort of thing, purchases at retail stores, Zelle
25 transfers, some cash withdrawals, Cash App.
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1 Q. In your investigation did you get bank records for Gena
2 Pyfrom-Foster's bank account at Bank of America?
3 A. Yes.
4 MS. CHAIKEN: Your Honor, I'll move to admit
5 Government's Exhibits 2940 through 2943, pursuant to
6 Rule 902.11.
7 MS. WEBSTER: No objection.
8 MR. MARSHALL: No objection, Judge.
9 THE COURT: It's admitted. One moment.
10 MR. MARSHALL: No objection, I'm sorry.
11 THE COURT: Oh. Ms. Lee is indicating that she had
12 those admitted yesterday already.
13 MS. CHAIKEN: Okay.
14 THE COURT: They're either admitted now or admitted
15 twice now then.
16 Ladies and gentlemen of the jury, those are
17 definitely in.
18 MS. CHAIKEN: I was not trying to sneak them in, Your
19 Honor.
20 THE COURT: I understand.
21 MS. CHAIKEN: Okay. Could we publish 2943, please.
22 THE COURT: The record will reflect laughter in the
23 courtroom. That was all a joke. Nobody was being serious.
24 BY MS. CHAIKEN:
25 Q. Okay. What is 2943?
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1 THE COURT: The documents are in.
2 THE WITNESS: It is a check from Bellator Phront
3 Group to Pyfrom Exclusive Consulting on 6/11/2020 for $10,560.
4 And the memo line says, Payroll services accounting.
5 MS. CHAIKEN: Could you please publish Government
6 Exhibit 2940.
7 BY MS. CHAIKEN:
8 Q. Is this the signature card for the Pyfrom Exclusive
9 Consulting account?
10 A. Yes, it is.
11 Q. And whose name was on that account?
12 A. Gena Pyfrom-Foster.
13 Q. When was that account opened?
14 A. June 10th of 2020.
15 MS. CHAIKEN: Could you please go to 2941, page 3.
16 BY MS. CHAIKEN:
17 Q. Is this the bank statement for that Pyfrom Exclusive
18 Consulting account starting on June 10th, 2020?
19 A. Yes.
20 Q. Was the $10,560 check from Bellator deposited into this
21 account?
22 A. Yes, it was.
23 Q. What date was it deposited?
24 A. 6/11 of 2020.
25 Q. Was that the day after the account was opened?
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1 A. Yes.
2 MS. CHAIKEN: Could you go to 2942, page 3, please.
3 BY MS. CHAIKEN:
4 Q. Is this the bank statement for that account for July 1st
5 to July 31st of 2020?
6 A. Yes.
7 Q. Does it reflect an approximately $9,810 withdrawal from
8 that account --
9 A. Yes.
10 Q. -- on July 24th?
11 A. Yes.
12 Q. Was this money that represented a portion of that $10,560
13 check?
14 A. Yes, for sure.
15 Q. Did you ask Teldrin Foster about this payment from
16 Bellator Phront Group to Pyfrom Exclusive Consulting when you
17 interviewed him?
18 A. I did.
19 MS. CHAIKEN: Could you please publish Government
20 Exhibit 2250H.
21 (Government Exhibit 2250H published.)
22 MS. CHAIKEN: Your Honor, I previously moved to admit
23 2250I. I'm going to withdraw 2250I and move to admit 2250W in
24 its place pursuant to our conversation earlier?
25 MS. WEBSTER: No objection to that, Your Honor.
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1 THE COURT: It's admitted.
2 MS. CHAIKEN: Could you please publish 2250W.
3 (Government Exhibit 2250W published.)
4 BY MS. CHAIKEN:
5 Q. Did Mr. Foster tell you that the check that was made out
6 to Pyfrom Exclusive Consulting was actually a check for him?
7 A. That's what he said, yes.
8 Q. And he told you that he took that money from the account?
9 A. Yes.
10 Q. Did he tell you that he got the approximately $34,000
11 check and deposited it in his Navy Federal account?
12 A. Yes.
13 Q. Is that consistent with what you saw in the Navy Federal
14 account?
15 A. Yes.
16 MS. CHAIKEN: Could you please publish Government
17 Exhibit 1146, page 6.
18 BY MS. CHAIKEN:
19 Q. Is this a bank statement for Elite Executive Services,
20 Inc.?
21 A. Yes, it is.
22 Q. Is Elite Executive Services the business we talked about
23 yesterday that got the payroll payment from Gaines Reservation
24 & Travel?
25 A. Yes.
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1 Q. And did that business get payroll payments from other of
2 the businesses that we've been looking at?
3 A. Yes, they did.
4 Q. On May 22nd of 2020, did Darrell Thomas -- or did Elite
5 Executive Services make a Cash App payment?
6 MS. CHAIKEN: If we can pull or highlight that
7 May 22nd payment.
8 THE WITNESS: Yes, they made a Cash App payment on
9 May 22nd, 2020, and it says Teldrin, for 1,380.41.
10 BY MS. CHAIKEN:
11 Q. And I think I actually misspoke. The date that it was
12 posted was May 22nd?
13 A. Yes.
14 Q. Is there a different date listed in the description of
15 the transaction?
16 A. 5/21. 05/21.
17 MS. CHAIKEN: Is 2327 in?
18 Can we please publish 2327 and 2327A. Could you pull
19 out that top right message, please.
20 BY MS. CHAIKEN:
21 Q. Was this a WhatsApp that Darrell Thomas sent to Teldrin
22 Foster on May 20th of 2020?
23 A. Yes.
24 Q. What was the attachment?
25 A. It is information regarding a rapid! PayCard program,
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1 which is a corporate prepaid payroll card company, rapid!.
2 Q. Did you determine during the course of your investigation
3 what rapid! PayCard is?
4 A. Yes.
5 Q. What is it?
6 A. It's a payroll card company that allows companies to set
7 up an account, deposit funds into the account and then set up
8 prepaid debit cards for their employees and be able to
9 transfer money from the main account, the company account, to
10 those cards for payroll purposes.
11 Q. So instead of cutting checks to their employees, they can
12 load up their employees' debit cards?
13 A. Yes.
14 Q. Did you get -- and do you see that this document that
15 Darrell Thomas sent to Teldrin Foster is an agreement between
16 the Green Dot Corporation doing business as rapid! PayCard and
17 then Bellator Phront Group?
18 A. Yes.
19 Q. That's Darrell Thomas's company?
20 A. Yes.
21 Q. Did you get records from MetaBank for the rapid! PayCard
22 account that's associated with Bellator?
23 A. Yes, we did.
24 MS. CHAIKEN: Your Honor, I move to admit
25 Government's Exhibits 2950 through 2954, pursuant to
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1 Rule 902.11.
2 MS. WEBSTER: No objection.
3 MR. MARSHALL: No objection, Judge.
4 THE COURT: They're admitted.
5 BY MS. CHAIKEN:
6 Q. Based on your review of the MetaBank records, how was
7 Bellator's rapid! PayCard account used?
8 A. It was used to distribute funds to numerous individuals
9 in different names. Primarily there was a lot of names of
10 people that were involved in the PPP loans. And they would
11 distribute the money to the cards. Actually, the funding of
12 the account came from the various business owners' companies.
13 Once they got their PPP funding, there were deposits or
14 transfers made to the Bellator rapid! PayCard account, and
15 then the money was distributed to the cards.
16 Q. Okay. So when we were talking about Gaines Reservation &
17 Travel, we saw payments to Elite Executive Services for
18 payroll?
19 A. Yes.
20 Q. Later on with some of the business applications, the PPP
21 loan applications that were submitted later, did those
22 businesses send money to rapid! PayCard for payroll?
23 A. Yes.
24 Q. And did all of that money go to Bellator's rapid! PayCard
25 account?
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1 A. Yes. It was a single rapid! PayCard account in the name
2 of Bellator.
3 Q. And then were there various cards that were tied to that
4 account?
5 A. Yes.
6 MS. CHAIKEN: Could you please publish Government
7 Exhibit 2954 and pull out line 51, please. Scroll down,
8 please.
9 BY MS. CHAIKEN:
10 Q. Do you see line 51 there?
11 A. I do.
12 Q. Whose name -- is this a listing of the payroll cards that
13 were issued by Bellator Phront Group?
14 A. Yes, these are the rapid! PayCards.
15 Q. And whose name is associated with the PayCard that's on
16 line number 51?
17 A. Teldrin Foster.
18 Q. Was there also a card in the name of Gena Foster?
19 A. Yes, right below it.
20 Q. And the address that's listed there for Teldrin Foster,
21 is that his real address?
22 A. No.
23 Q. Do you still have that binder in front of you?
24 A. I do.
25 Q. Could you please review Government's Exhibits --
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1 Government Exhibit 3015 and tell me if you recognize it?
2 A. 3015?
3 Q. Yes.
4 A. There it is. It's the last one. Yes, I do.
5 Q. What do you recognize it as?
6 A. This is a listing of all the rapid! PayCard transactions
7 that were associated with the rapid! PayCard assigned to
8 Teldrin Foster.
9 MS. CHAIKEN: I move to admit Government
10 Exhibit 3015.
11 MR. MARSHALL: No objection from Ms. Jackson, Judge.
12 MS. WEBSTER: Can I have one second, Your Honor? I'm
13 sorry.
14 No objection.
15 THE COURT: It's admitted.
16 MS. CHAIKEN: Could you please publish 3015.
17 BY MS. CHAIKEN:
18 Q. Is this a summary of the transactions on the Teldrin
19 Foster rapid! PayCard?
20 A. Yes.
21 Q. And what was the time frame for these transactions?
22 A. Started June 2nd of 2020. And then at the bottom is
23 July 20th of 2020.
24 Q. And is the June 2nd of 2020 a transaction on the card?
25 A. No. That is just the creation of the card.
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1 Q. How much money was spent on the Teldrin Foster payroll
2 card in July of 2020?
3 A. It was approximately -- just a little over $8,000.
4 Q. Did the records that you got from T-Mobile for Teldrin
5 Foster's cell phone that we looked at yesterday, did those
6 include cell site location information?
7 A. Yes.
8 Q. Did you ask another agent to analyze those cell site
9 locations that Teldrin Foster's cell phone hit on the dates of
10 these transactions?
11 A. Yes.
12 Q. And who was that agent?
13 A. James Berni, Agent James Berni.
14 Q. Could you please take a look in your binder at 3005 and
15 tell me if you recognize it?
16 A. Yes.
17 Q. What is it?
18 A. These are call records between Teldrin Foster and Gena
19 Pyfrom-Foster.
20 MS. CHAIKEN: Your Honor, I move to admit
21 Government's Exhibit --
22 BY MS. CHAIKEN:
23 Q. And are these taken from the T-Mobile records for Teldrin
24 Foster?
25 A. Yes.
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1 MS. CHAIKEN: Your Honor, I move to admit Government
2 Exhibit 3005.
3 MS. WEBSTER: Your Honor, we object to relevance
4 on -- for at least part of this exhibit. It covers a very
5 long period of time that doesn't include -- or extends well
6 past the dates of the charged conspiracies.
7 THE COURT: Mr. Marshall?
8 MR. MARSHALL: I have no objection, Judge.
9 THE COURT: Let me pull it up.
10 All right. I guess, first off, which dates -- which
11 date ranges do you object to, what date range? This is a
12 26-page document.
13 MS. WEBSTER: Your Honor, we object to any -- to the
14 inclusion of calls outside of the August 2020 -- I believe
15 Darrell Thomas was arrested on August 6th, 2020, and we would
16 object to anything after that date.
17 THE COURT: All right. So you don't object to
18 pages 1, 2, and 3, and you object to pages 4 through 26?
19 MS. WEBSTER: Correct.
20 THE COURT: Ms. Chaiken?
21 MS. CHAIKEN: Your Honor, this is relevant to showing
22 that Teldrin Foster and Gena Pyfrom-Foster each had possession
23 of their own phone and continued to have possession of their
24 own phone after the relevant time period.
25 THE COURT: Well, you closed your argument with
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1 "after the relevant time period." So what's the relevance of
2 whether or not they had their own phones after the relevant
3 time period?
4 MS. CHAIKEN: Your Honor, the fact that they
5 continued calling each other on their phones for several
6 months after this time period that we're looking at is
7 relevant to the showing that during that time period they
8 would have each had their own phones and that they each used
9 their own phones separately, including to call each other.
10 THE COURT: I kind of feel like we're going in
11 circles, but why is it relevant after August 6th?
12 MS. CHAIKEN: Because it shows that Teldrin Foster
13 continued to have his phone, that this is his phone that he
14 used before, that he used during this time period, and that he
15 used after this time period is highly relevant to showing that
16 this is his phone. If the defense is not going to challenge
17 that he's the one using the phone, then we don't need to admit
18 the rest of these pages.
19 THE COURT: Ms. Webster?
20 MS. WEBSTER: We're challenging the fact that he was
21 not the only person with access to his WhatsApp account. So I
22 don't know -- but even in light of that argument, I'm not sure
23 what relevance calls after the relevant time period have to
24 whether or not he had -- he was the person who had access to
25 his WhatsApp -- the only person who had access to his WhatsApp
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1 account.
2 THE COURT: All right. I'll sustain the objection as
3 to pages 4 through 26.
4 Ms. Chaiken, I'm not convinced of why you're telling
5 me what happened after August 6th and who had the phone after
6 August 6th is -- has any relevance.
7 Go ahead.
8 MS. CHAIKEN: Okay. Your Honor, the version we have
9 in Trial Director has all of the pages, but can we publish it
10 and not go --
11 THE COURT: Just publish the first three and make
12 sure the hard copy document that goes to Ms. Lee just has the
13 first three, please.
14 MS. CHAIKEN: Okay.
15 THE COURT: Thank you.
16 MS. CHAIKEN: Could you please publish 3005.
17 BY MS. CHAIKEN:
18 Q. Okay. Is this a summary of the communications, phone
19 calls and texts between Gena Pyfrom-Foster and Teldrin Foster?
20 A. Yes.
21 Q. And is July 1st, 2020, the earliest date for which you
22 have this set of records from T-Mobile?
23 A. Yes.
24 Q. Is July 2020 the time frame for which you've summarized
25 the transactions in the rapid! PayCard account?
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1 A. Yes.
2 Q. And that's the same time frame for which you asked the
3 agent to analyze the cell site location for Teldrin Foster's
4 phone?
5 A. That's correct.
6 Q. And during this time frame did Teldrin Foster and Gena
7 Pyfrom-Foster regularly call each other?
8 A. Yes, calls and texts.
9 MS. CHAIKEN: If you could go down to page 2,
10 Ms. Holland.
11 BY MS. CHAIKEN:
12 Q. Did they continue communicating regularly throughout July
13 of 2020?
14 A. Yes.
15 Q. If Gena Pyfrom-Foster was the one who had Teldrin
16 Foster's phone during this time period, would you expect there
17 to be calls between Teldrin Foster and Gena Pyfrom-Foster?
18 A. No.
19 Q. Did you ask Teldrin Foster about the rapid! PayCard in
20 your interview?
21 A. Yes.
22 MS. CHAIKEN: Ms. Holland, could you please publish
23 2250T.
24 (Government Exhibit 2250T published.)
25 BY MS. CHAIKEN:
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1 Q. Did Mr. Foster tell you that the rapid! PayCard was going
2 to make it look like there was a paper trail of money going to
3 people?
4 A. Yes.
5 Q. And did he tell you that he got a rapid! PayCard from
6 Darrell Thomas?
7 A. Yes, he got a card.
8 Q. Did he tell you that he got some money off of it?
9 A. He said maybe a thousand dollars.
10 MS. CHAIKEN: Could you please publish 2250U.
11 (Government Exhibit 2250U published.)
12 BY MS. CHAIKEN:
13 Q. Did Mr. Foster tell you he knew what they did with
14 Bellator was wrong?
15 A. Yes.
16 Q. Did he tell you his motive was to try to get money back
17 from Darrell if he got a PPP loan?
18 A. Yes.
19 Q. When you interviewed Teldrin Foster, did he tell you he
20 knew that what he did with the Bellator loan would have
21 consequences?
22 A. Yes.
23 MS. CHAIKEN: Could you please publish 2250Q.
24 (Government Exhibit 2250Q published.)
25 MS. CHAIKEN: Your Honor, could I have a few moments,
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1 please?
2 THE COURT: I'm sorry?
3 MS. CHAIKEN: Could I have a few moments, please?
4 THE COURT: Of course.
5 MS. CHAIKEN: Thank you.
6 (Pause in proceedings.)
7 MS. CHAIKEN: Your Honor, I have no further questions
8 for this witness.
9 THE COURT: All right. Thank you.
10 Ladies and gentlemen of the jury, you'll recall this
11 morning we took one witness out of order, given some
12 scheduling issues. We've got something else like that now.
13 Normally what would happen after the government does their
14 direct examination of someone is that the defense attorneys
15 would take an opportunity and cross-examine that witness if
16 they chose to.
17 What we're going to do here instead is take a break
18 from Special Agent Stites's testimony and hear from a
19 different witness entirely. After that witness, we will have
20 Special Agent Stites back up if there's any cross-examination
21 of him.
22 So, sir, you can step down.
23 (Witness excused from the witness stand.)
24 THE COURT: And, Counsel, how long will this next
25 witness last?
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1 MR. MOORE: Less than 15 minutes, Your Honor.
2 THE COURT: Okay. Let's go ahead and call him or
3 her, please.
4 MR. MOORE: United States calls Salvatore Hazel.
5 THE COURT: Good afternoon, sir.
6 THE WITNESS: Good afternoon.
7 THE COURT: How are you?
8 THE WITNESS: I'm good. How are you?
9 THE COURT: I'm well, thank you.
10 _____________________________
11 SALVATORE HAZEL
12 a witness herein, being first duly sworn,
13 was examined and testified as follows:
14 ____________________________
15 DIRECT EXAMINATION
16 BY MR. MOORE:
17 Q. Please state and spell your name for the record.
18 A. My name is Salvatore Hazel. That's S-A-L-V-A-T-O-R-E.
19 Hazel, H-A-Z-E-L.
20 Q. Where do you work?
21 A. I work for the Internal Revenue Service.
22 Q. What is your title?
23 A. My current title is a court witness coordinator.
24 Q. Can you explain what a court witness coordinator does?
25 A. Yes, I can. As a court witness coordinator, I represent
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1 the Commissioner of the Internal Revenue Service as his role
2 of custodial records. I'm tasked with gathering these
3 records, certifying and testifying that they are, in fact, in
4 the possession of the IRS.
5 Q. In your time with the IRS have you become familiar with
6 how taxes are filed?
7 A. Yes, I have.
8 Q. Are you familiar with the IRS Form 941?
9 A. Yes, I am.
10 Q. What is that?
11 A. That is the quarterly form that's filed by an employer
12 just for the withholdings taken out of the employees'
13 paychecks each month.
14 Q. So that's filed four times a year?
15 A. Yes, it is, each quarter.
16 Q. Are you familiar with the IRS Form 940?
17 A. Yes, I am.
18 Q. What is that?
19 A. The Form 940 is an annual form. And that's a form that
20 the employers file to help fund the federal unemployment tax
21 system.
22 Q. Does the IRS have a recordkeeping system?
23 A. Yes, it does.
24 Q. Are you familiar with it?
25 A. Yes, I am.
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1 Q. Do you work in that system in the regular course of your
2 job?
3 A. Yes, I do.
4 Q. What is the name of that system?
5 A. The name of that system is the Integrated Data Retrieval
6 System. It's also known as the IDRS system.
7 Q. What is stored in the IDRS system?
8 A. Most of the taxpayer information. It's considered the
9 master file that IRS employees like myself have access to to
10 access information of taxpayers.
11 Q. Are those records regularly made and preserved as part of
12 the public business of the IRS?
13 A. Yes, they are.
14 Q. Can searches be ran in the IDRS system?
15 A. Yes, they can.
16 Q. Do you know how to conduct searches in the system?
17 A. Generally, most times I do, yes.
18 Q. And that's a regular part of your job?
19 A. Yes, it is.
20 Q. During this investigation, were you asked to check if 940
21 and 941 forms were filed for certain businesses?
22 A. Yes, I was.
23 Q. I'm going to list off a series of businesses, and could
24 you please tell the jury if these are the businesses you
25 looked for:
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1 Bellator Phront Group, Arcade Painting, Impact Creations,
2 Gaines Reservation & Travel, Transportation Management
3 Services, Lee Operations, D. Parker Holdings, All Star Room
4 and Board Services of Michigan, Continuing Success, ML Exotic
5 Customs, Bellevie, Advertising and Then Some, Infinite
6 Education, Mickies Auto and Tire, Roadrunner Automotive,
7 Management Resource Services, Technology Analysis System,
8 Premier Choice Office Supply, and A1 Cuts Barber Shop.
9 Did you look up 940s and 941s for those companies?
10 A. Yes, I did.
11 Q. Did any of those companies file a 940 or 941?
12 A. There might have been one or two filed for one or two of
13 the companies. I don't know the exact companies and filings
14 and so forth right now.
15 MR. MOORE: Can we publish 2116.
16 BY MR. MOORE:
17 Q. This is a document that had been previously shown to the
18 jury. Do you know if this document was filed to the IRS?
19 A. I do not believe so.
20 Q. Does the IRS stamp documents?
21 A. They do.
22 Q. Does the IRS send the documents back to the individuals
23 after they are stamped?
24 A. They do not.
25 Q. So in the typical course of business would a taxpayer
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1 have a stamped version of their document?
2 A. They would not.
3 MR. MOORE: Can we publish 2116 -- sorry. 2222.
4 BY MR. MOORE:
5 Q. So this is a 941 for a business purportedly called
6 Bellator Phront Group. Was this document filed with the IRS?
7 A. It was not.
8 Q. And, again, would you expect the taxpayer to have a
9 stamped version of the document as this taxpayer supposedly
10 had?
11 A. I would not.
12 MR. MOORE: Just one moment, Your Honor.
13 (Pause in proceedings.)
14 BY MR. MOORE:
15 Q. And just to be clear, you had said that they may have
16 filed a few tax documents, correct, the businesses I listed
17 off?
18 A. There might have been a couple 941s out of all those
19 companies.
20 Q. All right. But when we asked you to look for
21 specifically 2019 for 941s, were there any 941s filed in the
22 year 2019 for any of the companies that I listed?
23 A. No. Specifically for the tax year 2019, there were no
24 returns filed.
25 MR. MOORE: Okay. All right. Thank you. Nothing
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1 further.
2 THE WITNESS: You're welcome.
3 THE COURT: Any cross-examination?
4 MS. DURRETT: Your Honor, we have no questions for
5 this witness.
6 MR. MARSHALL: No questions, Judge.
7 THE COURT: All right. Sir, you can step down.
8 Thank you.
9 THE WITNESS: Thank you, Your Honor.
10 (Witness excused.)
11 THE COURT: Probably a decent time for us to take a
12 short comfort break, all right? Thank you.
13 MS. WEBSTER: Your Honor.
14 (After a recess at 3:03 p.m., the proceedings
15 continued at 3:19 p.m. as follows:)
16 MS. WEBSTER: Your Honor, assuming it's okay with
17 you, Mr. Marshall is going to do the first cross-examination
18 of Agent Stites.
19 THE COURT: That's fine.
20 MR. MARSHALL: That's fine, Judge.
21 THE COURT: Off the record.
22 (Off-the-record discussion.)
23 (The jury entered the courtroom at 3:20 p.m.)
24 THE COURT: All right. You can be seated. Thank
25 you.
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1 Mr. Marshall, your witness.
2 MR. MARSHALL: Thank you.
3 Ladies and gentlemen.
4 CROSS-EXAMINATION
5 BY MR. MARSHALL:
6 Q. Good afternoon, Agent Stites.
7 A. Good afternoon.
8 Q. So I want to do a little bit of overview of your
9 investigation. I know there's been a lot of evidence put on
10 the record, but you're just -- your overall view when you do
11 an investigation for a case like this, you interview the
12 witnesses that you find important to interview; correct?
13 A. Correct.
14 Q. And in this case, you also obtained records. And you do
15 that through subpoenas that get issued?
16 A. Yes.
17 Q. Search warrants occasionally --
18 A. Occasionally.
19 Q. -- right?
20 Did you do that in this case?
21 A. A couple. Actually, about -- if you include search
22 warrants for records, almost ten total --
23 Q. For the search warrants you have to go to a -- write out
24 an affidavit, an application, and present it to a judge and
25 get approved for a search warrant to be executed; correct?
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1 A. Yes.
2 Q. Okay. And in this case you've got, I guess, all of
3 these -- the WhatsApp messages and so forth. Where did -- did
4 that mostly come out of laptop analysis or what?
5 A. The WhatsApp came out of Darrell Thomas's phone.
6 Q. So that's one -- that's another thing you did in this
7 case; right?
8 A. We --
9 Q. Correct? Okay.
10 A. We processed phones, yes, and other devices. We
11 processed seized phones and other devices.
12 Q. This type of investigation, that could mean like cell
13 phones can be important, correct --
14 A. Yes.
15 Q. -- in the case?
16 Desktop computers can be important; correct?
17 A. Yes.
18 Q. Laptop computers, other digital devices; correct?
19 A. Yes.
20 Q. And you've done that in this case for at least Darrell
21 Thomas; right?
22 A. Correct.
23 Q. Just curious, in this case did you ever try to get any --
24 either a search warrant or any kind of effort to try to
25 analyze Ms. Jackson's devices?
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1 A. No.
2 Q. So you didn't get her cell phone; correct?
3 A. No.
4 Q. All right. You didn't get any laptops that she's used
5 during this time period of the investigation; correct?
6 A. No.
7 Q. Or any desktop computers?
8 A. No.
9 Q. Would you say that there could be information that might
10 be important on those devices if you had obtained some
11 authorizations to get those devices?
12 A. I wouldn't know if there is. I guess there could be.
13 Q. But you made no effort to get any of those devices;
14 correct?
15 A. No.
16 Q. All right. Let's go to the interviews again. You've
17 interviewed a lot of witnesses in this case; right?
18 A. Yes.
19 Q. I want to go over a little bit of the technique. You saw
20 Ms. Jackson on July 7th, 2020; is that correct?
21 A. That is correct.
22 Q. And you went over there with Agent Cromer. He's another
23 FBI agent --
24 A. Correct.
25 Q. -- right?
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1 I think it was about, what, 9:40 in the morning when you
2 went over there --
3 A. Yes.
4 Q. -- right?
5 Is it normally -- now, at that time you had a grand jury
6 subpoena in your possession; right?
7 A. I did.
8 Q. So it was twofold. You had two purposes. You wanted to
9 go over there, I guess, and question Ms. Jackson, but also you
10 wanted to serve the subpoena on her; is that right?
11 A. Correct.
12 Q. All right. Did you know her phone number at that time
13 before you went over there?
14 A. I'm sure we did. We would have done some analysis about
15 her before showing up.
16 Q. Did you think about making an attempt just to call her
17 before you went over there?
18 A. No.
19 Q. Is it normally just your best method just to show up and
20 do these interviews?
21 A. It depends. It depends on the situation. Every
22 investigation, every person we want to interview we think
23 through, you know, what's the best way to do it. And for
24 Ms. Jackson, it was -- we thought the best way to do it would
25 be a knock-and-talk and serve a subpoena.
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1 Q. These knock-and-talks, that's a phrase you use. These
2 knock-and-talks, how many do you think you've done in your
3 career similar to this type of investigation?
4 A. Hundred plus.
5 Q. Would you find it -- you're an FBI agent. Would you
6 agree with the statement that a lot of people are kind of
7 shocked and surprised when an FBI agent shows up at their
8 front door?
9 A. Some.
10 Q. Was Ms. Jackson, in your opinion, in the way she appeared
11 and answered, did she seem surprised?
12 A. She actually seemed pretty comfortable, to be honest.
13 Q. You didn't think she wanted to be somewhere else and be
14 working at the time?
15 A. She definitely was working, but she was willing to spend
16 the time that she spent with us. I think it was like 12 --
17 12, 13 minutes.
18 Q. Okay. I'm going to go over some of the things that y'all
19 talked about during your interview with her. And we already
20 had the recording played in court; correct?
21 A. Yes.
22 Q. Now, I think the government prosecutor asked you a couple
23 questions about some details that Ms. Jackson didn't provide
24 to you. For instance, this real estate project in Alabama, do
25 you remember her talking about that?
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1 A. Yes.
2 Q. And I think you mentioned that -- I think the prosecutor
3 asked you if Ms. Jackson provided any documentation similar
4 to, for instance, the proposal that she mentioned, any
5 documents related to this real estate project to you as part
6 of her response to your grand jury subpoena.
7 Do you remember that?
8 A. Correct, yes. I remember that.
9 Q. Now, you had just shown up at the front door with the
10 grand jury subpoena in your hand; right?
11 A. Yes.
12 Q. So you didn't know about a real estate project that she
13 had been working on at that time; right?
14 A. No.
15 Q. So that question for those types of records wouldn't have
16 been in that grand jury subpoena, in that request for records,
17 would it?
18 A. The grand jury subpoena was directed at any activities
19 associated with the inflow of the money that was associated
20 with the money that came in on that --
21 Q. Okay. But more specifically -- but in direct response to
22 my question, there was no question in the grand jury subpoena
23 requesting records about real estate projects and things like
24 that; right?
25 A. Right.
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1 Q. Or a proposal; correct? Any types of things like that,
2 contracts?
3 A. I don't believe so.
4 Q. Now, I think you asked (sic) a bunch of questions. I
5 think you mentioned Andre Gaines; is that right?
6 A. Yes.
7 Q. At that time you didn't mention John Gaines during that
8 first interview. Was he on your radar at that point?
9 A. We knew about John Gaines at that point.
10 Q. Now, this interview, it lasted probably about 13 minutes;
11 correct?
12 A. Correct.
13 Q. Or less than that because there was some walking time
14 before you got up to her; right?
15 A. Right.
16 Q. Did you have a second interview with Ms. Jackson?
17 A. The second interview with Ms. Jackson was when we went to
18 knock on her front door asking for Mr. Gaines.
19 Q. Okay. That's what I was going to ask you about.
20 So you were going there for the purpose of talking to
21 Mr. John Gaines; correct?
22 A. Correct.
23 Q. And do you recall when that second interview was with
24 Ms. Jackson?
25 A. I believe it was on the 27th of July. So it was maybe,
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1 what, 20 days later.
2 Q. Were you with Agent Cromer again for the second
3 interview?
4 A. I was.
5 Q. Was he there? Okay.
6 So do you recall when you -- did you find out whether
7 Mr. Gaines was there that day?
8 A. Ms. Jackson said that Mr. Gaines was not there or she
9 didn't know where he was, something to the effect. That she
10 doesn't know -- you know, she's not his babysitter, I think
11 she used.
12 Q. Did you have some reason to believe that John Gaines had
13 been living there?
14 A. We had seen a vehicle that was registered to him that
15 was, I believe, outside the residence.
16 Q. Do you recall finding out that actually Mr. Gaines
17 occasionally spent time overnight at that residence?
18 A. I think we knew that that was a possibility.
19 Q. So at least at that point you knew that he probably spent
20 some time at Ms. Jackson's residence; correct?
21 A. Yes.
22 Q. Okay. Now, we had previously introduced into evidence I
23 think Government's Exhibit Number -- I think it was 1700. The
24 divorce petition.
25 Do you recall that?
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1 A. Yes.
2 Q. And I think that there was a separation date at some
3 point. Do you recall when they might have been separated,
4 when that petition was filed?
5 A. Yeah. It was November something. I don't remember the
6 exact date, but November of 2019.
7 Q. Okay.
8 A. Is that correct?
9 Q. November 26th, that sound about right? Somewhere around
10 there?
11 A. Yeah.
12 Q. Okay. All right. Let me move you over to something
13 else, a different topic right now.
14 MR. MARSHALL: Ms. Holland, if you could possibly
15 bring up Government's Exhibit 1116.
16 BY MR. MARSHALL:
17 Q. Do you recall this exhibit being introduced into
18 evidence, Agent Stites?
19 A. Yes, I do.
20 Q. What is this record? If you can tell the jury again
21 about what this is.
22 A. This is a listing of the -- I believe the Wells Fargo --
23 this is the Wells Fargo bank account transactions or activity
24 with the addresses and the dates.
25 Q. So is there anything important about the IP address in
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1 this exhibit that you had pointed out during your testimony?
2 A. That the IP address had come back to Ms. Jackson's
3 residence.
4 Q. You had established that through a separate request, I
5 think, through Comcast; right? To find out who --
6 A. (Nods head.)
7 Q. Okay.
8 And so the IP address, do you know which one of those
9 belongs to Ms. Jackson?
10 A. It is the 76.105.87.198.
11 Q. And over to the right, the second from the -- from the
12 very right side, those columns, the second column from the
13 right, I think it says, what is that, SID. Do you know what
14 that means? Do you have any idea?
15 A. I don't know. I just -- I recognized it as a city name
16 that's in that column. I don't know what SID stands for.
17 Q. And it has Stone Mountain down there; is that correct?
18 For most -- I guess that's the location for all these --
19 A. Yes.
20 Q. -- IP addresses?
21 A. Yes.
22 Q. Is there anything here that -- well, you already know
23 from the other thing that this IP address comes from
24 Ms. Jackson's residence or not?
25 A. Yes.
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1 Q. The address?
2 A. The IP address comes back to her residence.
3 Q. Okay. And are these logins or -- what are these entries
4 here? If this is interaction with Wells Fargo, what do these
5 dates on the very left-hand side, what do they signify?
6 A. The date that the access -- a date of access.
7 Q. And, again, you just answered a couple questions ago from
8 me a little bit -- and these -- well, let me back up a little
9 bit.
10 The dates on the left, are they generally -- what months
11 are showing there that you can tell?
12 A. Those are May and June.
13 Q. Primarily May and June, would that be correct?
14 A. Yes.
15 Q. And that's 2020?
16 A. Correct.
17 Q. And that's a month or two before you made your visit with
18 Ms. Jackson; correct?
19 A. Correct.
20 Q. And you just testified just a little while ago that you
21 had information that Mr. Gaines was staying at that residence
22 at least occasionally; correct?
23 A. Yes. We figured at least occasionally.
24 Q. All right. So at least from this record, especially if
25 you know that Mr. Gaines might be living at that residence for
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1 some time, you don't know who specifically accessed the Wells
2 Fargo account at all from that address at that time, do you?
3 A. Correct.
4 Q. It could be Mr. Gaines; correct?
5 A. Correct.
6 Q. Or anybody else there at that location?
7 A. Yes.
8 Q. I'd like to go over to Government's Exhibit 1150. Turn
9 over a little bit to -- this is a -- well, we'll get that back
10 up first.
11 Do you recognize this exhibit?
12 A. Yes, I do.
13 Q. This was previously admitted earlier. What is this
14 exhibit again?
15 A. This is the Bank of America signature card for Roadrunner
16 Automotive Group, LLC.
17 Q. Thank you.
18 MR. MARSHALL: And, Ms. Holland, can you go to the
19 next page. I think this is a two-page document.
20 Thank you.
21 BY MR. MARSHALL:
22 Q. Is this another signature card for Bank of America?
23 A. That's the original signature card.
24 Q. Okay. That's the original one, you say. So down at the
25 bottom, whose name is there?
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1 A. Carla Jackson.
2 Q. And there's her signature to the right?
3 A. Yes.
4 Q. What's the date of this original signature card?
5 A. 12/30 of 2019.
6 MR. MARSHALL: Ms. Holland, can you go to the first
7 page again, please. Thank you.
8 BY MR. MARSHALL:
9 Q. And what's the date of this second signature card?
10 A. 6/17 of 2020.
11 Q. And what's different with this card? Who's added?
12 A. John Stacey Gaines.
13 MR. MARSHALL: Ms. Holland, that's fine with that
14 one. Could you please go to Government's Exhibit 1151. If
15 you could go down to the transaction page. I think it's
16 either page -- that's good right there. Thank you.
17 If you could -- if you can't see it all right, if you
18 could maybe pull out the deposit section. Thank you very
19 much.
20 BY MR. MARSHALL:
21 Q. There was testimony earlier that you provided about some
22 of these transactions and deposits on this exhibit.
23 Do you recall that?
24 A. Yes.
25 Q. And I'm going to refer your attention to the dated
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1 transaction of June 5th, 2020.
2 Do you see a deposit amount there?
3 A. I do.
4 Q. And this is made into a Roadrunner account; right?
5 A. Yes.
6 Q. And we just saw the signature card for that Roadrunner
7 account. So we know that Ms. Jackson and Mr. Gaines is
8 associated with this account; correct?
9 A. Mr. Gaines is associated as of 6/17.
10 Q. Well, I'm going to ask you about that in a second too.
11 All right. You don't have any evidence in any e-mails --
12 let's see.
13 Do you have any e-mail communications from Ms. Carla
14 Jackson regarding this deposit that you see here in the amount
15 of $71,144.35?
16 A. Can you restate -- do I have an e-mail?
17 Q. Any e-mails in the record that have been presented at
18 trial that discuss -- where Ms. Jackson is in the e-mail
19 discussing this deposit?
20 A. No.
21 Q. As a sender of an e-mail?
22 A. No.
23 Q. As a recipient of an e-mail?
24 A. No.
25 Q. Or being copied on an e-mail?
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1 A. No.
2 MR. MARSHALL: Could you also go down to the
3 transactions below. Thank you. Pull that all up. Thank you
4 very much.
5 BY MR. MARSHALL:
6 Q. So let's look at these here, these transactions. Who are
7 the majority of these transactions done by?
8 A. A majority of them are associated with John Gaines.
9 Q. John Gaines. In fact, that's all the way down, I guess,
10 till the bottom, which is, what, with the last entry? Would
11 that be correct?
12 A. The last entry, a Geico entry for Carla Jackson.
13 Q. And that's, what, June 17, 2020?
14 A. Yes.
15 Q. Now, you just testified a little while that Mr. Gaines
16 had been added on, I guess -- well, that -- he was added on to
17 the Bank of America account as a -- to be able to participate
18 in the bank transactions; correct?
19 A. Correct.
20 Q. But he had been associated with Roadrunner before that;
21 do you recall?
22 Well, let me ask you this: Do you know if he was a
23 founding organizer or a member of Roadrunner?
24 A. I believe he was on the Secretary of State for Roadrunner
25 Automotive.
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1 Q. Do you know what that year was when it was formed?
2 A. I don't really recall. If you want to show me something
3 to refresh my --
4 MR. MARSHALL: Your Honor, can I approach the
5 witness?
6 THE COURT: Yes. Again, y'all can feel free to move
7 about the courtroom.
8 BY MR. MARSHALL:
9 Q. Agent Stites, I'd like to refresh your recollection with
10 this document here and then I'll ask you a question.
11 A. Okay.
12 Q. Are you able to determine the date when that was formed?
13 A. It says the effective date is 1/24 of 2019.
14 Q. Okay. Thank you very much.
15 So Mr. John Gaines would have been involved with this
16 company from its inception; correct?
17 A. Since -- yeah. Yes.
18 Q. So he didn't just start doing transactions at the dates
19 that we're seeing here in the Bank of America in June of 2020,
20 he had been involved with the company earlier than that?
21 A. He had been involved with the company. He was not a
22 signer on the account.
23 Q. And we don't have a Bank of America official here
24 testifying. We don't really know what the reason is why
25 Mr. Gaines got added that particular day to that account, do
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1 we, the Bank of America account?
2 A. We don't know.
3 MR. MARSHALL: Could we please go to 1166,
4 Ms. Holland. Thank you.
5 BY MR. MARSHALL:
6 Q. Do you recall this exhibit being entered into evidence?
7 A. Yes.
8 MR. MARSHALL: If we could go down to the deposit
9 sections, the transaction sections, and pull that part out,
10 please.
11 BY MR. MARSHALL:
12 Q. Do you remember testifying about these transactions?
13 A. Yes.
14 Q. Okay. And of note there are two deposits there. What
15 are the two big deposits there that you see?
16 A. The 155,252.50, which was the check that was deposited.
17 And then the wire from PNC Bank for 179,985.72.
18 Q. I'm going to come back a little bit and make a big
19 general comment again. In your investigation we presented all
20 these WhatsApp messages that have been entered into the
21 record; correct?
22 A. Correct.
23 Q. All kinds of e-mail messages that we've seen from
24 different parties in this case; correct?
25 A. Yes.
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1 Q. Text messages?
2 A. Yes, some text messages.
3 Q. Have any WhatsApp messages, e-mail messages or text
4 messages had Carla Jackson as one of the parties
5 communicating?
6 A. No.
7 Q. So we're not going to find any kind of e-mails or any
8 kind of communications about why this deposit came in and so
9 forth on June 8th, 2020, in that amount of about $155,000;
10 correct?
11 A. Not e-mail.
12 Q. Same thing with the second deposit, 179 -- almost
13 $180,000, no communications between Carla Jackson and John
14 Gaines, for instance?
15 A. Not between Carla Jackson and John Gaines.
16 Q. Or Carla Jackson and Andre Gaines; correct?
17 A. No.
18 Q. And Andre Gaines is the founder of Gaines Travel &
19 Reservation; right?
20 A. Correct.
21 Q. All right. Down below, I think there's some extra
22 testimony --
23 MR. MARSHALL: Let's go to -- if we could go to
24 Government's Exhibit 1169. Go down to -- yes, that's fine.
25 That's fine.
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1 BY MR. MARSHALL:
2 Q. Do you remember this exhibit?
3 A. Yes.
4 Q. What is this exhibit that you recall? What's this
5 withdrawal receipt?
6 A. This is the withdrawal receipt from Wells Fargo to -- to
7 get the three certified checks.
8 Q. Okay. All right.
9 MR. MARSHALL: Go down -- there's some certified
10 checks in there. If you could go down below where the checks
11 are, there are some images. Let's pull that one up.
12 BY MR. MARSHALL:
13 Q. So after these two deposits have been entered, there is
14 some money taken out and these cashier's checks are obtained;
15 right?
16 A. Correct.
17 Q. And do we know from this document right here who the
18 person was that took this check out?
19 A. Yes. The remitter was Carla Jackson.
20 Q. Who is the payee? Who is this made out to?
21 A. 365 Enterprise, LLC.
22 Q. And who do we know from previous testimony who that
23 company belongs to?
24 A. John Gaines.
25 Q. And have you entered -- is there anything in the record
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1 that shows any e-mail communications from John Gaines to Carla
2 Jackson or Carla Jackson to John Gaines about this check?
3 A. No.
4 Q. Are there any communications from Andre Gaines to Carla
5 Jackson about this check?
6 A. No.
7 MR. MARSHALL: If we can go to the next image,
8 please. It's another check.
9 BY MR. MARSHALL:
10 Q. Here's another one here. This is one of the other
11 cashier's checks taken out that day; correct?
12 A. Yes.
13 Q. Who took this one out?
14 A. Carla Jackson.
15 Q. And that's in the amount of how much?
16 A. $10,000.
17 Q. Okay. Similar to the last amount on the last check?
18 A. Yes.
19 Q. Right?
20 Okay. And down below there's a notation there. What
21 does it say down below? It has something redacted, but what
22 does it have noted there?
23 A. John Gaines auto loan.
24 Q. Okay.
25 A. The account ending in 5813.
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1 Q. And we had additional testimony about payment being on an
2 auto loan related to this; correct?
3 A. Correct.
4 Q. Again, is there anything in the record, any e-mail
5 communications, WhatsApp messages, text messages that you have
6 that show Carla Jackson in contact with John Gaines about this
7 matter?
8 A. No.
9 MR. MARSHALL: If you can go to the next one. Thank
10 you.
11 BY MR. MARSHALL:
12 Q. Who took this cashier's check out?
13 A. Carla Jackson.
14 Q. And who's this -- I should maybe reference this.
15 Who's this payee in this one?
16 A. USAA.
17 Q. And down below there's a notation again. What does that
18 say, handwritten or printed?
19 A. Auto loan number ending 4019.
20 Q. Okay. What's the name there?
21 A. John Gaines.
22 Q. What's the amount of this check?
23 A. $10,000.
24 Q. And, again, same question. Any communications at all
25 between John Gaines that we have in the record here and Carla
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1 Jackson about this check and why it's being taken out?
2 A. No.
3 Q. Okay. Thank you.
4 Let me ask you a little bit more about the -- just
5 generally about your interviews that you do. And I want to
6 ask -- so Ms. Jackson indicated this information about this
7 real estate project that she was involved in; right?
8 A. I think she called it a construction project.
9 Q. During that second visit did you ever ask her -- do you
10 recall asking her any additional -- for any additional
11 information about that project?
12 A. No.
13 Q. You wouldn't have requested it in your grand jury
14 subpoena because you didn't know about it at that time?
15 A. I didn't ask her in the second one because I knew that
16 she was seeking counsel.
17 Q. Did you ask -- do you recall asking her during that one
18 if she had an attorney at that point?
19 A. Yes, I did.
20 Q. Do you know if she had one?
21 A. I believe she said Dwight Thomas was going to be her
22 attorney.
23 Q. Did you ever reach out to Attorney Dwight Thomas to find
24 out if he'd talk to you about that or if his client would talk
25 to you about that?
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1 A. I personally did not.
2 Q. I know there was a question asked during the -- when you
3 spoke with Ms. Jackson on July 7th, 2020, you asked her about
4 Andre Gaines. Remember that?
5 A. Yes.
6 Q. And what do you recall her response was?
7 A. She said that she was referred -- or that he was referred
8 to her, there was a referral, but that she didn't really know
9 him prior to this.
10 Q. Do you recall her saying that she knew of him or
11 something?
12 A. She knew of him. She didn't know him.
13 MR. MARSHALL: Just a minute, Your Honor. One
14 second, Judge.
15 Nothing further, Judge.
16 Thank you, Agent Stites.
17 THE WITNESS: Thank you.
18 THE COURT: Ms. Webster, any questions?
19 MS. WEBSTER: I do. Thank you.
20 CROSS-EXAMINATION
21 BY MS. WEBSTER:
22 Q. Good afternoon, Agent Stites.
23 A. Good afternoon.
24 Q. We've heard a lot about certain people in this case, but
25 there are a lot of other people that were charged in this
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1 indictment as well; is that right?
2 A. Yes.
3 MS. WEBSTER: Could we see Government's Exhibit 3000,
4 please, Ms. Holland.
5 BY MS. WEBSTER:
6 Q. How many people were charged in this case? Do you know
7 off the top of your head?
8 A. 24.
9 Q. So were they each involved in one of these loans?
10 A. Yes.
11 Q. And, in fact, Mr. Foster's actually charged in at least
12 one count with most of them; is that right?
13 A. Yes.
14 Q. So let's go through some of those people.
15 We've heard a lot about Darrell Thomas, but can you just
16 describe his role again?
17 A. Darrell Thomas is sort of the main guy. He was
18 responsible for submitting the fraudulent loans. He recruited
19 individuals to go out and find business owners who would
20 submit information for PPP loans.
21 Q. Okay. You would describe him as the ring leader?
22 A. Yes.
23 Q. And he was the one who was communicating with the
24 recruiters?
25 A. Yes.
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1 Q. And he was the one -- well, was he the one communicating
2 with all of the business owners or were they sometimes
3 communicating through the recruiters?
4 A. Most of the time through the recruiters.
5 Q. Okay. And then Meghan Thomas is also charged. Do you
6 know which of these loans she's charged with?
7 A. I know Bellator, but I don't remember exactly which -- I
8 don't remember which loans she was exactly charged with.
9 Q. What was her role?
10 A. Meghan's role was more of a collector of documents and
11 managing the -- sort of the checklist of items that were
12 collected.
13 Q. Okay.
14 A. And assisting Mr. Thomas with whatever, you know, he
15 asked her to do.
16 Q. And they were married?
17 A. They were married.
18 Q. And Jesika Blakely, what was her role?
19 A. Jesika Blakely played a very similar role, where she was
20 managing the listing of loans and what documents were
21 collected and what still was outstanding and kind of managing
22 the process of collecting the documents.
23 Q. And she -- did she consider herself an employee of
24 Mr. Thomas?
25 A. Yes, she considered herself as part of Bellator.
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1 Q. As part of Bellator.
2 And she had a Bellator Phront Group e-mail address?
3 A. She had an e-mail address.
4 Q. And do you remember which of these loans she was involved
5 with?
6 A. I don't recall which ones she was charged with. If you
7 provide me with something to refresh my memory, I would...
8 Q. It's fine.
9 And then who is Kahlil Green?
10 A. Kahlil Green was the business owner for Impact Creations.
11 Q. Do you know if he had direct communication with Darrell
12 Thomas?
13 A. Yes. Yes, he did.
14 Q. And in this case, right, you subpoenaed a lot of e-mails;
15 is that correct?
16 A. Yes.
17 Q. And that includes Darrell Thomas's e-mail addresses;
18 correct?
19 A. Yes.
20 Q. Okay. So that includes his Bellator Phront Group e-mail
21 address?
22 A. Yes.
23 Q. And a Gmail account; correct?
24 A. Correct.
25 Q. And you didn't subpoena Mr. Foster's e-mail address; is
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1 that right?
2 A. No.
3 Q. Did you subpoena Mr. Green's e-mail address?
4 A. His -- no.
5 Q. Okay.
6 A. Can I ask what e-mail address are you referring to for
7 Mr. Green?
8 Q. I don't have one. I was just wondering if you had
9 subpoenaed any e-mails from Mr. Green.
10 A. No.
11 Q. Okay.
12 And then John Gaines is also charged in this case;
13 correct?
14 A. Correct.
15 Q. And do you -- what was his role?
16 A. John Gaines was a recruiter, sort of a middle person on
17 the Gaines Reservation & Travel loan. And the borrower was
18 Andre Gaines.
19 Q. Say that last part again.
20 A. The borrower was Andre Gaines.
21 Q. Okay. And so was Gaines Reservation & Travel the only
22 loan that -- or the only company that he was responsible for?
23 A. The -- of the ones that got charged.
24 Q. But there are other ones that happened that were not
25 charged; is that right?
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1 A. There were other loans that were in the works, yes.
2 Q. And who was Amanda Christian?
3 A. Amanda Christian is an individual that was in -- sort of
4 a recruiter or sort of a middle person between Darrell and a
5 business owner. And she also had a business of her own.
6 Q. Okay. And what business did she have?
7 A. She had Advertising and Then Some.
8 Q. And that's one of the loans that's charged here; is that
9 right?
10 A. Yes.
11 Q. And was she also responsible for preparing some fake
12 documents?
13 A. I believe so.
14 Q. Okay. And then who is Mr. Charles Petty?
15 A. Charles Petty is a recruiter, sort of a middle person
16 between Darrell and business owner. He was primarily involved
17 in the Transportation Management loan.
18 Q. Did you have -- see any evidence of communication between
19 Mr. Petty and Mr. Foster?
20 A. No, I don't believe so.
21 Q. Who is Jerry Baptiste?
22 A. Jerry Baptiste is an individual that was a middle person
23 between Darrell Thomas and Bern Benoit. In the Transportation
24 Management loan, Mr. Petty and Mr. Baptiste worked together on
25 that loan.
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1 Q. Okay. Was there any evidence of communication between
2 Mr. Baptiste and Mr. Foster?
3 A. I don't recall that there were.
4 Q. You can't recall --
5 A. I don't recall that there were.
6 Q. Okay. Thank you.
7 And Bern Benoit, you just said, was associated with the
8 Transportation Management group?
9 A. Yes.
10 Q. Do you have any evidence of communication with Teldrin
11 Foster and Bern Benoit?
12 A. I don't think so.
13 Q. Who is Denesseria Slaton? Am I saying that name
14 correctly?
15 A. Close. I think she goes by Dee, Dee Slaton.
16 Q. Okay. Who is she?
17 A. Again, she's a recruiter for -- that Darrell used to find
18 borrowers.
19 Q. And do you know which of these loans she's responsible
20 for?
21 A. I think she had her hand in several of them. I don't
22 recall exactly which ones at this point.
23 Q. Okay. And tell me about Ricky Dixon. Who is that?
24 A. Ricky Dixon is a recruiter, but he also had his own
25 business, Arcade Painting. So he was a borrower, and he also
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1 recruited some individuals to submit loans.
2 Q. And do you know who he recruited?
3 A. Edward Lee from Lee Operations. Derek Parker from D.
4 Parker Holdings. Charmaine Redding from All Star Room and
5 Board. ML Exotic Customs, Ryan Whittley. And that might be
6 it.
7 Q. Okay. And Mr. Dixon corresponded quite a bit with
8 Darrell Thomas; is that correct?
9 A. Say that again.
10 Q. Mr. Dixon corresponded quite a bit with Darrell Thomas;
11 is that right?
12 A. There was a decent number of e-mails, communication.
13 Q. There were also messages on Mr. Thomas's phone; is that
14 right? Do you recall those?
15 A. From Mr. Dixon?
16 Q. Uh-huh (affirmative).
17 A. I believe there were some. I don't recall what they
18 were, though.
19 Q. Tell me who Charmaine Redding is.
20 A. Charmaine Redding was the owner of All Star Room and
21 Board or the borrower for All Star Room and Board Services of
22 Michigan.
23 Q. And she was communicating with Ricky Dixon; is that
24 right?
25 A. Yes.
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1 Q. And Darrell Thomas?
2 A. I believe there might have been some e-mails.
3 Q. And who is Derek Parker? His name is on at least one of
4 these accounts; right?
5 A. Yes. He's the borrower for D. Parker Holdings, Inc.
6 Q. And did he communicate with Mr. Thomas or did he only
7 communicate with Mr. Dixon?
8 A. D. Parker -- Derek Parker communicated through Ricky
9 Dixon.
10 Q. So there was no evidence of communication between him and
11 Teldrin Foster?
12 A. Between Derek Parker and Teldrin Foster?
13 Q. Yes.
14 A. I don't believe so.
15 Q. Okay. And who is David Belgrave?
16 A. David Belgrave was the borrower for Continuing Success,
17 Inc.
18 Q. So he's a business owner?
19 A. Yes.
20 Q. And who was he communicating with?
21 A. I believe he was communicating with Amanda Christian.
22 Q. Okay. Was there any evidence of communications directly
23 with Darrell Thomas?
24 A. I don't believe so.
25 Q. Tell me about Charles Hill. Who is that?
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1 A. Charles Hill was -- let me see. Which one was he?
2 Infinite Education Services. He was the borrower for Infinite
3 Education Services, Inc.
4 Q. And who was he communicating with?
5 A. I believe he was Dee Slaton. He was communicating
6 through Dee Slaton.
7 Q. And so did he communicate with Darrell Thomas or it all
8 went through Dee Slaton?
9 A. I don't recall if there were any communications with
10 Darrell Thomas directly.
11 Q. Okay. But the primary communication would have been with
12 Ms. Slaton?
13 A. I believe so.
14 Q. Who is Ryan Whittley?
15 A. Ryan Whittley is the borrower for ML Exotic Customs, Inc.
16 Q. Okay. And who did he communicate with?
17 A. That'd be Ricky Dixon.
18 Q. Okay. And was there any evidence that he was actually
19 communicating with Darrell Thomas?
20 A. I believe he had some communications with Darrell Thomas.
21 Q. Okay.
22 A. And just to note, they're -- at some point, you know, I
23 think Darrell Thomas had stated that he had put some -- or
24 that he had communicated with the borrowers once they got the
25 loans through the recruiters on how to get the money back to
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1 him.
2 Q. I'm sorry, I just want to make sure I understood what you
3 were saying.
4 That once the loans were approved and they received the
5 funds, Darrell Thomas then began communicating --
6 A. Was communicating through the recruiters to dictate -- or
7 direct where the money flow was supposed to go.
8 Q. Okay. So when the loan came in to the borrower's
9 account, it all went into the business owners' accounts; is
10 that right?
11 A. Right.
12 Q. And then Darrell Thomas would tell the recruiters to tell
13 the business owners where to send the money?
14 A. Correct.
15 Q. And was Teldrin Foster involved in that process?
16 A. I don't believe so.
17 Q. Who is Dwan Ashong?
18 A. Dwan Ashong is a -- I guess we'll call her a recruiter,
19 but she also had some of her own loans that she was doing.
20 Q. And do you mean that -- when you say she was doing her
21 own loans, that she was also a business owner or that she was
22 also preparing fraudulent loans outside of Darrell Thomas?
23 A. I think she was doing some stuff outside of Darrell
24 Thomas.
25 Q. Okay.
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1 A. But also had some loans that she was working with Darrell
2 Thomas. And then the one, Bellevie Corporation, her husband,
3 El Hadj Sall, was the borrower for that.
4 Q. So tell me who that is again. Say his name again.
5 A. El Hadj Sall.
6 Q. So he's the owner of Bellevie; is that right?
7 A. Correct.
8 Q. And did he have any communications with Darrell Thomas?
9 A. I don't believe so.
10 Q. And then who is Rick McDuffie?
11 A. He is the borrower for Mickies Auto and Tires, LLC.
12 Q. Okay. And who was he communicating with?
13 A. I believe it was Amanda Christian, but I'm not positive.
14 Q. Was he communicating with Teldrin Foster?
15 A. I don't believe so.
16 Q. So we've seen a lot of communications and e-mails between
17 Teldrin Foster's e-mail addresses and Darrell Thomas's e-mail
18 addresses. And we've also seen the WhatsApps. But we haven't
19 seen any e-mails between Teldrin Foster and any of these other
20 people; is that right?
21 A. That's correct.
22 Q. And we haven't seen any WhatsApp messages between Teldrin
23 Foster and these people that I've mentioned?
24 A. Correct.
25 Q. Okay. So I want to spend some time talking about Darrell
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1 Thomas.
2 You've spent a lot of time investigating this case; is
3 that right?
4 A. Yes.
5 Q. That might be an understatement, I imagine.
6 A. There was a lot of hours put in.
7 Q. And so you spent a lot of time reviewing his
8 communications?
9 A. Whose communications?
10 Q. Darrell Thomas's communications.
11 A. Yes.
12 Q. And that includes his e-mails?
13 A. Correct.
14 Q. And other messages that are on his phone?
15 A. Correct.
16 Q. So that includes WhatsApp messages?
17 A. Yes.
18 Q. And not just with Teldrin Foster; right?
19 A. Yeah.
20 Q. And have you reviewed his Telegram messages?
21 A. Darrell's Telegram messages?
22 Q. Yes.
23 A. No.
24 Q. So you haven't -- are you aware that there are Telegram
25 messages on his phone?
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1 A. I don't recall the Telegram messages.
2 Q. Do you know what Telegram is?
3 A. Yes.
4 Q. Tell us what it is.
5 A. I know it's a messaging platform.
6 Q. Is it sort of like WhatsApp?
7 A. I believe it's similar, yeah.
8 Q. Okay. And what about Signal?
9 A. I believe Signal is another type of messaging platform.
10 Q. And did you review any messages between Darrell Thomas
11 and anyone on -- using Signal?
12 A. No.
13 Q. So you haven't reviewed any messages between Darrell
14 Thomas and Jesika Blakely on Telegram; is that right?
15 A. Correct.
16 Q. Okay. And Bellator Phront Group was Darrell's company;
17 correct?
18 A. Yes.
19 Q. And it was the first company that applied for a PPP loan?
20 A. I believe that's the first one out of this group, yes.
21 Q. Okay. And as we were discussing earlier, when the money
22 came in for loans for other companies, he instructed them what
23 to do with the money?
24 A. Correct.
25 Q. And some of those companies sent funds to the Bellator
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1 Phront Group; is that right?
2 A. Yes.
3 Q. And Darrell Thomas controlled Bellator Phront Group?
4 A. Yes.
5 Q. And during this investigation, you've obtained Georgia
6 Secretary of State records for Bellator Phront Group; is that
7 right?
8 A. Yes.
9 Q. And other companies as well?
10 A. Correct.
11 Q. Can you look in the binder in front of you and turn to
12 Exhibit 1B, please?
13 A. I'm sorry, which one was it?
14 Q. 1B.
15 A. 1B. Okay.
16 Q. Do you recognize these documents?
17 A. It looks like the State of Georgia Secretary -- it's the
18 registration for Bellator Phront Group.
19 Q. Thank you.
20 MS. WEBSTER: Your Honor, we'd move to admit
21 Exhibit 1B under Rule 902.11.
22 MS. CHAIKEN: No objection, Your Honor.
23 MR. MARSHALL: No objection, Judge.
24 THE COURT: It's admitted.
25 MS. WEBSTER: Thank you.
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1 I'm going to use the Elmo here.
2 BY MS. WEBSTER:
3 Q. Can you tell me what this document is?
4 A. Is there a way to turn off the --
5 Q. The thing on the side?
6 A. Yeah.
7 MS. WEBSTER: I don't know where that's coming from.
8 Is it a touch screen?
9 (Organizational pause.)
10 MS. WEBSTER: Okay. All right. Problem solved.
11 Okay. Thank you. Here we go. Okay.
12 BY MS. WEBSTER:
13 Q. Can you tell me what that document is?
14 A. That looks like the articles of incorporation for
15 Bellator Phront Group.
16 Q. Who's listed as the incorporator?
17 A. This one says Meghan Thomas.
18 Q. And that's not Darrell Thomas; correct?
19 A. Correct.
20 Q. Can you tell me what this is?
21 A. It looks like an amended annual registration for Bellator
22 Phront Group.
23 Q. What year is this? It's on the top right corner, filing
24 date.
25 A. Filing date is 9/23/2019.
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1 Q. And you see who is listed as the CEO or CFO, I believe?
2 A. Yes.
3 Q. And that's Darrell Thomas?
4 A. It is.
5 Q. And then Meghan Thomas is listed as the secretary?
6 A. Yes.
7 Q. And then Kevin James is listed as the CEO. Do you know
8 who that is?
9 A. We had heard the name -- we had heard the name Kevin
10 James, but we don't really know who he is.
11 Q. To your knowledge, was he actually a CEO of Bellator
12 Phront Group?
13 A. I don't believe so.
14 Q. Thank you.
15 And then if we're looking at the -- this document, this
16 was also filed in December of -- or this was also filed in
17 2019; is that right?
18 A. Correct.
19 Q. And that's another amended annual registration for
20 Bellator Phront Group; correct?
21 A. Yes.
22 Q. And now where it says officers, Darrell Thomas is still
23 listed as CFO; correct?
24 A. Correct.
25 Q. And Meghan Thomas is still listed as secretary; correct?
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1 A. Yep.
2 Q. But now someone named Brenda Johnson Miller is listed as
3 CEO; is that right?
4 A. Correct.
5 Q. And do you -- I think you testified yesterday about where
6 Darrell Thomas was living during the time of the -- of the PPP
7 loans. Was that the address 7200 Grandview Overlook, Duluth,
8 Georgia?
9 A. That was the address that he was living, yes.
10 Q. Do you know who Brenda Johnson Miller is?
11 A. I believe she's the mother of Dwan Ashong.
12 Q. And is she the CEO of Bellator Phront Group?
13 A. No.
14 Q. Do you know why she was listed here?
15 A. I don't.
16 Q. But through your investigation you learned that she
17 doesn't know Darrell Thomas; is that right?
18 A. Correct.
19 Q. And she's definitely not the CEO of Bellator Phront
20 Group?
21 A. Correct.
22 Q. Are you aware that Bellator Phront Group was dissolved --
23 administratively dissolved by the Georgia Secretary of State
24 in 2021 for failing to register?
25 A. I believe I knew that.
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1 Q. But did you know that it's been reinstated in July of
2 2023?
3 MS. CHAIKEN: Your Honor, objection. Relevance.
4 We're now three years outside the time frame.
5 THE COURT: Ms. Webster?
6 MS. WEBSTER: I think it goes to show that -- there's
7 a set of follow-up questions that's relevant to this that
8 shows that Darrell Thomas is still using other people's names
9 in order to further his -- what I would call his fraud and
10 his --
11 THE COURT: Well, I know earlier you cut off
12 Ms. Chaiken's document --
13 MS. CHAIKEN: August 6th.
14 THE COURT: -- on August 6th of 2020, I think. So
15 wouldn't the same thing apply here?
16 MS. WEBSTER: This document's already been admitted
17 into evidence, Your Honor, without objection.
18 THE COURT: That won't do it. Why don't you answer
19 my question.
20 MS. WEBSTER: Okay. I can move on, Your Honor. It's
21 fine.
22 THE COURT: Very well. It sounds like the question
23 is withdrawn; therefore, I don't need to rule on the
24 objection.
25 Go ahead.
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1 MS. WEBSTER: Thank you.
2 BY MS. WEBSTER:
3 Q. But the name Brenda Miller wasn't just used on the
4 Secretary of State registration; is that right?
5 A. I'm trying to think of where else it was. I don't
6 remember where else it was used.
7 Q. Do you remember seeing the name in e-mails?
8 A. I -- I do recall seeing e-mails with Brenda Miller in
9 them.
10 Q. Okay. If you look at F19 and F19A and B in the binder in
11 front of you.
12 A. You said F19, one-nine?
13 Q. Yes, sir. One-nine, yeah.
14 A. 19A?
15 Q. A and B.
16 A. A and B.
17 Q. Have you reviewed those documents? Are you still working
18 on it?
19 A. Oh, sorry. Didn't know you wanted me to review them.
20 Q. Yes, please.
21 A. Okay.
22 Q. Do these appear to be documents that were received from
23 GoDaddy in response to your subpoena for Darrell Thomas's
24 e-mails?
25 A. Yes.
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1 MS. WEBSTER: Move to admit those pursuant to
2 Rule 902.11.
3 MS. CHAIKEN: Your Honor, we object under Rules 401
4 and 608.
5 THE COURT: May I see a copy of the document?
6 MS. WEBSTER: Yes.
7 THE COURT: All right, Ms. Chaiken, if you can expand
8 on that, please.
9 MS. CHAIKEN: Your Honor, Rule 608 allows impeachment
10 only of a witness who has testified in trial. This exhibit,
11 and a lot of the lines of questionings that have been pursued
12 so far are directed to impeachment of Darrell Thomas through
13 this witness. Darrell Thomas has not testified in this trial
14 and, therefore, Rule 608 does not allow impeachment of him,
15 especially not through another witness. So it's otherwise
16 irrelevant.
17 THE COURT: Well, what I've been given is a document
18 with the -- looks to be a bio of a Ms. Miller.
19 MS. CHAIKEN: Right. I think it's being used to show
20 that there was a fake bio created for a fake CEO of Bellator
21 Phront Group. And we've given leeway on these questions
22 because they really are not relevant to anything, but the only
23 purpose of these documents being admitted is to impeach
24 Darrell Thomas and show that he's engaged in other preparation
25 of fraudulent bios. It's not relevant to any issue in the
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1 case.
2 THE COURT: Well -- so you're saying improper
3 impeachment of someone who hasn't been a witness?
4 MS. CHAIKEN: Correct. Rule 608 only allows
5 impeachment of somebody who is a witness. And the Eleventh
6 Circuit has held the term "witness" refers to someone who
7 testified personally at trial or whose testimony has been
8 otherwise introduced as a substantive legal equivalent of
9 in-person testimony, like through a stipulation as to what
10 they would testify to.
11 THE COURT: All right. Ms. Webster?
12 MS. WEBSTER: Your Honor, I'm not admitting this to
13 call Darrell Thomas a liar. I'm admitting -- or I'm seeking
14 to admit it because I think the evidence will show that he had
15 a pattern and practice of using other people's names when it
16 benefited him. So using other people's names for, maybe,
17 applying for credit, things like that. Putting things in
18 other people's names.
19 And that's entirely relevant to our defense because,
20 obviously, our defense is that he was using Mr. Foster's
21 e-mail addresses and things like that. So I think it directly
22 goes to that. I think it's sort of like MO evidence,
23 basically.
24 THE COURT: Sorry, I didn't catch the last thing you
25 said. Sort of like what?
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1 MS. WEBSTER: MO evidence.
2 THE COURT: Okay. One moment.
3 MS. CHAIKEN: Your Honor, on that basis we'd invoke
4 Rule 404 as well.
5 THE COURT: Give me a minute.
6 I want to hear you, Ms. Chaiken, but I can't hear you
7 and try to process what's already been said at the same time.
8 All right. Go ahead, Ms. Chaiken.
9 MS. CHAIKEN: Your Honor, just based on the
10 explanation Ms. Webster just offered for why they're offering
11 this, we would invoke Rule 404. It sounds like propensity
12 evidence.
13 THE COURT: Ms. Webster?
14 MS. WEBSTER: I'm sorry, I'm not sure what you mean
15 by you invoke 404.
16 MS. CHAIKEN: 404 bars the introduction of propensity
17 evidence to prove that a person acted in conformity with a
18 particular character or trait on a particular occasion. And
19 it sounds like that's exactly what Mr. Foster is --
20 Ms. Webster is trying to do here.
21 MS. WEBSTER: Your Honor, it's not meant for
22 propensity purposes. It's to establish that he -- there was
23 modus -- MO, modus operandi, is a permissible purpose under
24 404. And I think that is what this is going to.
25 I also think it's just relevant to the course of the
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1 investigation. These e-mails, these documents were being sent
2 during and around the time of these charges. They also -- I
3 have another exhibit that's relevant to this and it goes to
4 show there was other stuff going on besides the PPP fraud.
5 And I think all of that is relevant to rebut the government's
6 case.
7 THE COURT: Ms. Chaiken, anything else? It's your
8 objection, I'll give you the last word.
9 MS. CHAIKEN: Still improper impeachment under 608,
10 Your Honor.
11 THE COURT: All right. Overruled. Go ahead.
12 MS. WEBSTER: Thank you, Your Honor.
13 Can I have that copy back?
14 THE COURT: Sure.
15 BY MS. WEBSTER:
16 Q. Okay, Agent Stites. Can you tell us who this e-mail was
17 sent from?
18 A. bpgintakecoordinator@gmail.com.
19 Q. That was labeled as Meghan Thomas; correct?
20 A. Yes.
21 Q. And it was sent to Darrell Thomas; correct?
22 A. Yes.
23 Q. And it says, The requested items are attached; yes?
24 A. Yes.
25 Q. And then what was attached is this document; right? And
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1 this says it's the bio of Brenda J. Miller, a real estate
2 developer and CEO of Bellator Phront Group; correct?
3 A. Yes.
4 Q. And so it says that Ms. Miller leads all divisions of
5 operations, business development and construction as the CEO
6 of Bellator Phront Group, that she served in that capacity
7 since 2017 and had continued to develop and grow in the
8 multifamily industry, and that she brings a level of expertise
9 and knowledge in rebuilding multifamily complexes.
10 Is any of that true to your knowledge?
11 A. I don't have -- no. I don't know. I don't think she's
12 part of Bellator Phront Group after interviewing her.
13 Q. And then when it says that Bellator Phront Group sets the
14 industry standard in model multifamily living, does that seem
15 accurate based on your investigation of Bellator Phront Group?
16 A. No.
17 Q. No; right?
18 A. No.
19 Q. Thank you.
20 I'm showing you what I've marked as Defendant's
21 Exhibit 408.
22 Was this also a document that you received in your
23 response to your subpoena to GoDaddy?
24 A. Yes, I remember seeing this e-mail.
25 Q. You recall seeing it?
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1 A. Yeah, I remember seeing some e-mails from an Andrew
2 Berkovitz.
3 Q. Okay. Thank you.
4 MS. WEBSTER: We'd move to admit Defendant's Exhibit
5 F408, also under Rule 902.11.
6 MS. CHAIKEN: No objection, Your Honor.
7 THE COURT: It's admitted.
8 MS. WEBSTER: Thank you.
9 BY MS. WEBSTER:
10 Q. Can you -- this is a document where there's communication
11 between this individual and allegedly Brenda Miller; correct?
12 It's the same document you have in your hand, if that's easier
13 to read.
14 A. It's cut off on the top, so I just want to make sure I've
15 got the same thing you're looking at.
16 It's from Andrew Berkovitz to
17 info@bellatorphrontgroup.com.
18 Q. Do you see who it's addressed to?
19 A. It says, Hi, Brenda.
20 Q. And it says, Thanks for this application; correct?
21 A. Yes.
22 Q. Okay. And you said that you read this e-mail before. Is
23 that --
24 A. No. I said I've seen some e-mails from this individual.
25 Q. And do you recall that these e-mails generally discuss
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1 some sort of equipment loan?
2 A. I don't recall.
3 Q. You don't recall that? Okay. Thank you.
4 I want to go back to Ricky Dixon for a little while.
5 He -- as I think we mentioned, he had a lot of interactions
6 with Darrell Thomas; is that right?
7 A. He had some interactions with Darrell Thomas, yes.
8 Q. Some? Do you disagree --
9 A. I don't know the number.
10 Q. Okay. But he had more than one interaction with Darrell
11 Thomas.
12 A. Yes. True.
13 Q. And he -- I think you testified earlier that he was
14 involved with the Lee Operations loan; is that correct?
15 A. Yes. He was the recruiter for Edward Lee.
16 Q. And if you turn to Exhibits 20A and 20 -- through 20D,
17 can you take a look at those?
18 Have you reviewed all those pages?
19 A. Yes. Just 20A and B; right?
20 Q. A, B, C and D.
21 A. I didn't hear C and D, sorry.
22 Q. You're fine.
23 A. Yes.
24 Q. Can you tell me what that appears to be?
25 A. It's an e-mail from Darrell Thomas from his Gmail account
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1 to Ricky Dixon to his Hotmail account. And it has a --
2 basically a write-up of -- regarding Lee Operations and, you
3 know, the -- something to do with the PPP loan and...
4 Q. And then what is 20C and D?
5 A. This is an e-mail from Ricky Dixon to Darrell Thomas.
6 And it has a -- has that same verbiage, that same paragraph
7 about Lee Operations. And it's signed Edward Lee, with a
8 signature. And then there's a notary stamp. Then looks like
9 there's some other kind of stamp. I'm not sure what that
10 other stamp is.
11 Q. Okay. And so are these documents that you received in
12 response to a subpoena to Google?
13 A. Yes, we got these through the Google subpoena.
14 Q. Thank you.
15 MS. WEBSTER: I'd move to admit F20A through F20D.
16 MS. CHAIKEN: No objection.
17 THE COURT: Hearing no objection from Mr. Marshall
18 either, they're admitted.
19 MR. MARSHALL: No objection, Judge.
20 BY MS. WEBSTER:
21 Q. So just to be clear, this is -- first, 20A is an e-mail
22 from Darrell Thomas; correct?
23 A. Yes.
24 Q. And it's to Ricky Dixon and it sends an attachment?
25 A. Yes.
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1 Q. And that attachment is an unsigned statement; is that
2 right?
3 A. Yes.
4 Q. And that statement relates to Lee Operations; correct?
5 A. Yes.
6 Q. Okay. And so specifically it says, On May 21st after
7 discussing the loan I obtained for my employees at Lee
8 Operations with my investor Darrell Thomas, we discussed that
9 he had recently set up his payroll through rapid! PayCards for
10 accurate bookkeeping.
11 And it basically discusses this alleged agreement that
12 they had; correct?
13 A. Correct.
14 Q. And then the F20C is the document where Ricky Dixon sends
15 that statement back to Darrell Thomas; is that right?
16 A. Yes.
17 Q. But now the statement is signed and certified; correct?
18 A. I don't know about certified but it's notarized.
19 Q. Notarized, sorry. I used the wrong word there.
20 A. I'm not sure it's certification.
21 Q. And so Ricky Dixon and Darrell Thomas were communicating
22 and coming up with ideas on how to make sure that they could
23 get the funds from the loans that Lee Operations received; is
24 that right?
25 A. Yeah, that appears what they were trying to do.
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1 Q. Are you aware that Darrell Thomas actually sent that
2 statement to Gena Pyfrom-Foster in order to see if she thought
3 that it was okay or acceptable or a good idea?
4 A. Am I aware that Darrell Thomas sent that to her?
5 Q. Yes.
6 A. I don't recall it, but you could refresh my recollection.
7 Yes, this is in the WhatsApp between Darrell and Gena on
8 6/30 of 2020.
9 Q. And so he's asking her basically if she thinks that's
10 okay?
11 A. Yeah.
12 Q. Okay.
13 A. Well, is the one on top after or before? I -- the
14 message basically just has the -- those words. It doesn't ask
15 do you think this is okay or anything.
16 Q. Okay.
17 A. It just has the -- that paragraph. There's no other --
18 Q. Can I see?
19 A. Okay. Okay.
20 Q. So it's asking?
21 A. Yeah. I didn't know about that other message. Sorry.
22 Q. Sure. I wanted to confirm before I told you.
23 A. Okay. I gotcha.
24 Q. So there are communications between Ricky Dixon and
25 Darrell Thomas about these loans that are charged in this
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1 indictment?
2 A. Yes.
3 Q. And that's not just -- that's not the only one, that's
4 just one example; is that right?
5 A. That's not the only what, e-mail?
6 Q. That's not the only communication between Darrell Thomas
7 and Ricky --
8 A. No, I believe there are more e-mails between Ricky Dixon
9 and Darrell Thomas, yes.
10 Q. Okay. And in this case one of the things that you did
11 was you conducted interviews; is that right?
12 A. Yes.
13 Q. And you actually interviewed a lot of the people in this
14 case; is that right?
15 A. Yes.
16 Q. You had what we call sort of proffer sessions with some
17 of them; is that correct?
18 A. Yes.
19 Q. And that's where you have meetings with them?
20 A. It's an interview. It includes the individual that we're
21 interviewing, it has -- their attorney is there, the US
22 Attorney's Office is there and agents involved in the case are
23 there.
24 Q. So those are prearranged ahead of time; is that right?
25 A. Yes.
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1 Q. And those people are represented by counsel?
2 A. Yes.
3 Q. And when you come into a meeting, their attorneys are
4 there?
5 A. Yes.
6 Q. They're there, obviously, the person being interviewed?
7 A. Yes.
8 Q. You're there as the agent?
9 A. Yes.
10 Q. And then there are prosecutors from the US Attorney's
11 Office?
12 A. Correct. And usually other agents that are involved in
13 the case are there as well.
14 Q. Okay. And in this case, one of those interviews was --
15 or one of those proffer sessions was with Ricky Dixon; is that
16 correct?
17 A. Yes.
18 Q. And so you had a meeting with him?
19 A. Yes.
20 Q. And that was -- I believe it was Webex or Zoom or
21 something?
22 A. It was a Webex.
23 Q. Because it was during the pandemic?
24 A. Yes.
25 Q. So his attorney was present?
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1 A. Yes.
2 Q. And he spoke with you pursuant to a proffer letter?
3 A. Yes.
4 Q. And a proffer letter, it sort of sets out -- is a letter
5 that sort of sets out the terms of that interview; is that
6 right?
7 A. Yes.
8 Q. That's not what happened when you interviewed Teldrin
9 Foster; correct?
10 A. Correct.
11 Q. And at that time he did not have a lawyer?
12 A. No.
13 Q. There was no proffer letter setting out the terms of the
14 interview?
15 A. No.
16 Q. You didn't advise him about any -- how the statements
17 could be used against him?
18 A. No.
19 Q. You -- he came in, you just started talking basically; is
20 that correct?
21 A. Pretty much, yes.
22 Q. But back to Ricky Dixon.
23 He came in and he was asked to talk about his involvement
24 in the case; is that right?
25 A. Yes.
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1 Q. And he gave you a version of events?
2 A. Yes.
3 Q. And that version of events was inaccurate?
4 MS. CHAIKEN: Objection, Your Honor, 608.
5 MS. WEBSTER: Your Honor, I'm not trying to impeach
6 Ricky Dixon. I think that he falsely identified Teldrin
7 Foster and that's what it's being admitted for.
8 MS. CHAIKEN: Your Honor, the government hasn't
9 relied on Ricky Dixon in any way to prove its case against
10 Teldrin Foster. So whether or not Ricky Dixon said it was
11 Teldrin Foster or not is completely irrelevant.
12 THE COURT: All right. I was close to taking a break
13 anyway, so why don't we take that comfort break and then we'll
14 come back and discuss this issue and then I'll bring the jury
15 in. I don't think they need to be here for all that anyway.
16 Ladies and gentlemen of the jury, let's take a short
17 comfort break. Your break may be a little bit longer than all
18 of ours. All right? You're reminded of your instructions for
19 breaks. Thank you.
20 (The jury exited the courtroom at 4:40 p.m.)
21 THE COURT: Y'all can be seated. Thank you.
22 It's been a while, so why don't we all take a comfort
23 break first and we'll come back and debate that issue. Thank
24 you.
25 (After a recess at 4:41 p.m., the proceedings
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1 continued at 4:57 p.m. as follows:)
2 THE COURT: Let's put 608 to the side for a second.
3 I know that, Ms. Chaiken, you also made the relevance
4 objection, so -- I guess under 401, I guess even to the extent
5 there's some relevance, 403. Let's talk about that.
6 I guess I -- Ms. Webster, I don't know why we're
7 going down the road of attacking Ricky Dixon if the government
8 isn't using Ricky Dixon to prove their case.
9 MS. WEBSTER: It's not about attacking him per se, or
10 not really attacking him or impeaching him at all. The idea
11 is that not just Ricky Dixon but other people in this case,
12 when they were asked about who they were communicating with,
13 they -- I'm sorry.
14 Can the agent be excused for this part of the
15 conversation since it's the subject of the testimony?
16 THE COURT: Sure. Can you step down, please.
17 (Witness exited the courtroom.)
18 THE COURT: Give me one more moment, Ms. Webster.
19 MS. WEBSTER: Okay.
20 THE COURT: All right. Go ahead, Ms. Webster.
21 MS. WEBSTER: So it wasn't just Ricky Dixon, Your
22 Honor. It was multiple witnesses that were interviewed by the
23 government who were involved in this case who, to my
24 knowledge, had no actual communication with Teldrin Foster.
25 Somehow, when they went in to interview and to proffer, they
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1 lied to the agents and said that they were communicating
2 exclusively with Teldrin Foster and were not communicating
3 with Darrell Thomas. And so we know that's a lie because we
4 know they were communicating with Darrell Thomas.
5 And so -- and the agent actually called -- especially
6 with Ricky Dixon, actually confronted him and said you are
7 lying, like this is not true. You've known Darrell Thomas,
8 you were interacting with Darrell Thomas. And then the
9 proffer sort of ended at that point.
10 And so our defense is that it wasn't actually Teldrin
11 Foster sending the e-mails or in the WhatsApp chats. And so
12 that is -- this evidence goes to there being other efforts to
13 sort of point the finger at Teldrin Foster when they are not
14 true.
15 THE COURT: So what you want to get out through this
16 agent is, you talked with Bob, Bob said I talked to Foster,
17 but that wasn't true. I talked to Susie who said she talked
18 to Foster, but that wasn't true. I talked to Jimbo, Jimbo
19 said he talked to Foster, but that wasn't true, et cetera,
20 et cetera, et cetera. These are the -- where we're going with
21 this and it sounds like a lot of other questions.
22 MS. WEBSTER: I don't think there are a lot of other
23 questions, Your Honor, but there are -- there -- when you say
24 et cetera, et cetera, et cetera, there aren't like ten
25 examples of this. I think there are approximately three
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1 examples of this.
2 And those are basically the questions, that he said
3 Teldrin Foster, he was actually communicating with Darrell
4 Thomas. He did not communicate with Teldrin Foster. He was
5 lying to you about that; right? Those are -- and for Ricky
6 Dixon, he didn't even like -- he called him Taldrid. It was
7 like he didn't even know his real name.
8 So I think it all is -- those are the questions. I
9 think it all goes to the idea that there were efforts to blame
10 Mr. Foster for things that Darrell Thomas was doing.
11 THE COURT: Okay.
12 First off, I guess, how do you -- how are you getting
13 in any of these other statements? Through what rule?
14 MS. WEBSTER: None of them are being offered for the
15 truth of the matter, so they're not hearsay because they're
16 lies, so...
17 THE COURT: Ms. Chaiken, what's your issue with this
18 testimony?
19 MS. CHAIKEN: Your Honor, we're not relying on Ricky
20 Dixon or anybody else implicating Teldrin Foster. We're
21 relying on the evidence itself. I think this is completely
22 irrelevant. It doesn't in any way support that there was some
23 concerted effort to frame Teldrin Foster.
24 I think that the jury would need to understand that
25 these people received target letters telling them they were
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1 going to be charged with federal crimes. Some of them came in
2 for proffers. Some of them had already been charged. They
3 were obviously trying to save themselves by pointing the
4 finger at other people.
5 We did not rely on that in any way. And as
6 Ms. Webster said, Agent Stites confronted Ricky Dixon and
7 said, you're lying. So that's not any part of the
8 government's proof in this case. And unless Ms. Webster is
9 planning to introduce some kind of affirmative evidence that
10 someone was told to lie or to implicate Teldrin Foster, to
11 frame him and that he was not involved, there is just nothing
12 in this case that's consistent with somebody being framed.
13 As the Court knows, there's been 24 people charged.
14 Every single one of them who is not here in this trial has
15 pleaded guilty, has said I was involved. And so the
16 suggestion that Darrell Thomas has an MO of falsely
17 implicating people in things is just not borne out by any
18 evidence and it's incredibly misleading to the jury to suggest
19 that it is.
20 If you look at the evidence that came in about Brenda
21 Miller, Brenda Miller was a name on a piece of paper that
22 Darrell Thomas used. There's no doubt he put a fake name on a
23 piece of paper of someone that was not involved with Bellator.
24 But he did not have hundreds of e-mails with Brenda Miller, he
25 did not have WhatsApp messages with her. There's no
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1 indication at all that he took over her e-mail account or took
2 over her phone and was impersonating her. He just took a name
3 of someone he knew, the mother of one of his co-conspirators,
4 and put her name on a piece of paper. That's not an MO of
5 what's happening here with Teldrin Foster.
6 THE COURT: All right. Thank you.
7 Ms. Webster, I think Ms. Chaiken has an okay
8 relevance argument here, to the extent she's arguing. The
9 relevance of this is pretty slight.
10 However, I see your argument, that there's arguably
11 some slight relevance. So I'm going to give you a little
12 leeway. You know, under 403 and that balance, I think it'll
13 depend on how much of this -- how far you want to go down this
14 road because I think as you -- if you go too far down it, I
15 think you may run afoul of wasting time. And that 403 balance
16 may cut against you eventually.
17 I know that Ms. Chaiken has also mentioned the
18 misleading part. And perhaps that's at play as well.
19 So I'm going to give you a little leeway on these
20 types of questions and we'll see how far you go and whether
21 there's a renewed objection under 403 at any point, depending
22 on how far you decide to go.
23 Let's bring in the jury, please.
24 And let's bring in the witness. Thank you.
25 How much longer do you think you have of cross,
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1 Ms. Webster? I'm trying to just gauge our evening.
2 MS. WEBSTER: I'm not going to finish today.
3 THE COURT: Very well.
4 You can have a seat, sir.
5 (Witness recalled to the witness stand.)
6 THE COURT: Y'all can be seated until the jury comes
7 in.
8 (The jury entered the courtroom at 5:07 p.m.)
9 THE COURT: Y'all can be seated. Thank you.
10 Ms. Webster, go ahead.
11 The objection's overruled.
12 MS. WEBSTER: Thank you, Your Honor.
13 BY MS. WEBSTER:
14 Q. So going back to where we were before we broke, you were
15 interviewing Ricky Dixon; is that correct?
16 A. Yes.
17 Q. And that was in a proffer session via Zoom or Webex?
18 A. Correct.
19 Q. And in that interview he told you that he had not been
20 communicating with Darrell Thomas; is that correct?
21 A. He said that he had not been communicating to him
22 regarding the PPP loan.
23 Q. Right. And, in fact, instead he said that it was Teldrin
24 Foster that he had been communicating with?
25 A. He did.
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1 Q. But he didn't actually say Teldrin. Does this sound
2 familiar?
3 A. Yeah. I think he said Taldrin.
4 Q. Taldrid?
5 A. Taldrid.
6 Q. Like T-A-L-D-R-I-D?
7 A. Something like that. Yeah, it was a little bit off.
8 Q. So he didn't actually affirmatively say Teldrin?
9 A. Correct.
10 Q. And, in fact, he lied or misstated what he had been doing
11 so much that you had to confront him on it; is that right?
12 A. Yes.
13 Q. And you had to say, we know that you're lying about this;
14 is that right?
15 A. Yes.
16 Q. And then at that point he had to take a break in the
17 interview?
18 A. Yes.
19 Q. And took a moment to speak with his lawyer?
20 A. Yes.
21 Q. And then that was the end of the interview; correct?
22 A. Correct.
23 Q. But Ricky Dixon wasn't the only one who denied
24 communicating with Darrell Thomas; is that right?
25 A. I'm not sure who you're referring to, but...
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1 Q. Okay. Charmaine Redding also came in for an interview;
2 is that right?
3 A. Yes.
4 Q. Okay. And she also said that she had not been
5 communicating with Darrell Thomas about the PPP fraud; is that
6 correct?
7 A. I -- I would have to relisten to that to confirm.
8 Q. Okay. Do you recall that she said that she did talk to
9 Teldrin Foster?
10 A. Again, I would have to listen to Charmaine's interview
11 again.
12 Q. Okay. Let me -- I'm going to circle back to that.
13 And so you are the case agent, as we said, in this case;
14 correct?
15 A. Yes.
16 Q. Okay. So you're responsible for the overarching
17 investigation?
18 A. Correct.
19 Q. And some people are not located in Atlanta; is that
20 right?
21 A. Correct.
22 Q. So, for example, Amanda Christian lives in South
23 Carolina?
24 A. Yes.
25 Q. Okay. And when her loan -- the PPP funds were deposited
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1 into her account, the Secret Service went to interview her; is
2 that right?
3 A. Yes.
4 Q. And in that interview she denied knowing that it was
5 fraudulent; is that right?
6 A. Yes.
7 Q. And then she said that she had received telephone calls
8 from an individual with the last name of Foster; is that
9 right?
10 A. Again, I'd have to probably relisten to confirm that.
11 Q. Would seeing the report from that interview help you
12 refresh your recollection?
13 A. Sure. This is the Secret Service interview?
14 Q. Yes. In this paragraph.
15 A. She references Foster FNU, so first name unknown.
16 Q. So she says that someone from this CDC SBF -- is that
17 the small business --
18 A. It just says --
19 MS. CHAIKEN: Your Honor. Your Honor.
20 I object to this. He's reading from a report that he
21 was -- of an interview he was not present for and a report he
22 did not write and an interview he has no firsthand knowledge
23 of.
24 THE COURT: Ms. Webster?
25 MS. WEBSTER: He -- well, one, you can refresh
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1 someone's recollection with anything. He doesn't have to have
2 been part of the initial interview, but he testified that he
3 was the case agent and he's responsible for the entire
4 investigation. So I'm happy for him to put the report down
5 and testify about if his recollection was refreshed.
6 MS. CHAIKEN: Your Honor, you can't refresh someone's
7 recollection about something they never knew in the first
8 place. He read the report, but he was not there for the
9 interview, so he doesn't know what was said.
10 THE COURT: Ms. Webster?
11 MS. WEBSTER: I think the rules are pretty clear that
12 you can refresh recollection with anything and if -- and so he
13 knows what's in the report.
14 THE COURT: You can. I think the issue is if he ever
15 had the information in his mind at any point. So let's
16 establish that and then you can --
17 MS. WEBSTER: Okay.
18 BY MS. WEBSTER:
19 Q. Agent Stites, did you previously during your
20 investigation read the report about the interview with Amanda
21 Christian?
22 A. I believe I've seen this report. I got it from the
23 Secret Service agent that interviewed Ms. Christian.
24 Q. And that was part of your investigation in this case;
25 correct?
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1 A. Yeah.
2 Q. Right? You received it as part of your duties as the
3 case agent?
4 A. Yes.
5 Q. And so would seeing -- does seeing it now refresh your
6 recollection about the contents of it?
7 A. It does.
8 MS. CHAIKEN: Your Honor, the report is hearsay of a
9 different agent who is not here. And refreshing recollection
10 is about refreshing a witness's recollection about something
11 they did or something they knew, not about something they
12 read. Otherwise you could just put any document before a
13 witness and refresh their recollection about what that
14 document says.
15 THE COURT: Ms. Webster?
16 MS. WEBSTER: Again, it's not being offered for the
17 truth of the matter, Your Honor. It's -- because she's
18 clearly, I think, lying about basically everything in there,
19 so it's not hearsay, it's not being offered for that.
20 Again, this was -- he's the case agent who
21 investigated the entirety of the case. So this is part of his
22 investigation, part of his efforts.
23 THE COURT: All right. This is seeming awfully
24 messy, folks.
25 Ladies and gentlemen of the jury, why don't you-all
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1 have a great evening and we'll see you tomorrow at 9:00. And
2 perhaps by then I will have waded through this and figured it
3 out. Okay?
4 Have a great evening. See you at 9:00.
5 (The jury exited the courtroom at 5:14 p.m.)
6 THE COURT: Y'all can have a seat. Thank you.
7 Give me a moment.
8 I guess the issue is, you know, how far does the
9 fact that --
10 And, sir, if you could step outside the courtroom,
11 please.
12 (Witness exited the courtroom.)
13 THE COURT: I feel like we're in a bit of a bizarre
14 scenario. I'm just trying to break down where we are.
15 I don't know that I've seen this happen before.
16 That's not to say it's wrong and you can't do it, it's just I
17 haven't seen this before. So I just want everyone to break it
18 down for me and we can think about the actual Rules of
19 Evidence.
20 We have the case agent on the stand; right?
21 MS. WEBSTER: Yes.
22 THE COURT: Knows a lot about the case.
23 MS. WEBSTER: Yes.
24 THE COURT: Didn't do everything on the case, but did
25 some stuff on the case and read a lot of other stuff about the
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1 case; right?
2 MS. WEBSTER: Yes.
3 THE COURT: Agree, Ms. Chaiken?
4 MS. CHAIKEN: Yes, Your Honor.
5 THE COURT: All right. And you want to ask him
6 questions about a lot of different things?
7 MS. WEBSTER: Many different things.
8 THE COURT: Okay. I'm going to ask some questions
9 right now, Ms. Webster, and then I'll let you make your
10 argument, okay?
11 MS. WEBSTER: Okay.
12 THE COURT: Thank you.
13 And what you want to do is ask him some questions
14 about Amanda Christian, who was part of this investigation;
15 right?
16 MS. WEBSTER: Yes. And someone that he was
17 charged -- Mr. Foster was charged with conspiring with, I
18 believe.
19 THE COURT: So far, so good.
20 And, Ms. Chaiken, it seemed like you were fine with
21 questions about Amanda Christian until she wanted to refresh
22 his recollection about Amanda Christian; right?
23 MS. CHAIKEN: Yes, Your Honor.
24 THE COURT: Okay. And you didn't want her to be
25 able -- you didn't want her to be able to provide the agent a
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1 copy of the interview transcript to refresh his recollection?
2 MS. CHAIKEN: Well, Your Honor, it's not an interview
3 transcript. It's a report of an interview that was done by an
4 agent from a different agency who was not involved in this
5 investigation.
6 THE COURT: Okay. Whether it's that or whether it's
7 a telephone book, does it matter what she wants to refresh his
8 recollection with?
9 MS. CHAIKEN: It matters because you can only refresh
10 a witness's recollection about something they once had a
11 recollection about. And so I --
12 THE COURT: And I think she established that he would
13 have known this at one point.
14 MS. CHAIKEN: He would have read it, but he
15 doesn't -- when you refresh a witness's recollection,
16 generally the witness was at an interview and wrote a report
17 and then you ask the agent, you know, did the witness say X,
18 and the agent says, I don't remember exactly. And then they
19 look at a copy of their report that they wrote and that
20 reminds them that in the interview the witness said X.
21 But, here, the agent doesn't know that because he
22 wasn't at the interview. He has no idea what was said because
23 he didn't write the report. All he did was get a copy of the
24 report and read it.
25 And so if you could refresh an agent's recollection
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1 with everything he read in the course of his investigation,
2 you could just present your entire case through reports,
3 hearsay reports from third parties that the agent has no
4 personal knowledge of.
5 THE COURT: Do you have something that shows me you
6 can't do that?
7 MS. CHAIKEN: Not right in this moment. I agree that
8 you can refresh a witness's recollection with anything, but I
9 don't think that she's established that it refreshed his
10 recollection about what was said in the interview. All she's
11 done is refreshed his recollection about what's in the report.
12 THE COURT: Well, that sounds just like an issue with
13 semantics then and how the question's phrased.
14 MS. CHAIKEN: The report is hearsay. She is offering
15 it for the truth of what the report says, which is Amanda
16 Christian said she had calls with Foster, or whatever it is.
17 So that's the whole point, is that --
18 THE COURT: That seems to make sense to me,
19 Ms. Webster. When you're going that far and trying to get
20 that statement in, that does seem to be different.
21 MS. WEBSTER: I'm not --
22 THE COURT: And I know you say, oh, I'm not offering
23 it for the truth of the matter asserted, but what are you
24 offering it for, if not?
25 MS. WEBSTER: I'm not offering the --
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1 THE COURT: And I'll let you know, I don't -- I'm not
2 persuaded by Ms. Chaiken's argument about you can't use this,
3 that or the other to refresh somebody's recollection if it
4 refreshes it. But I do think her argument about hearsay makes
5 sense. And I'm just not understanding why -- if you're just
6 having him read what she said in an interview and then spill
7 it out to the jury, that does seem like for the truth of the
8 matter asserted.
9 MS. WEBSTER: So, Your Honor, we're not -- I think
10 there's potentially two levels of hearsay. We're not trying
11 to get in that the Secret Service agent said anything. We're
12 just trying to get out that Amanda Christian made the false
13 statement. And so that statement, I think, is what is not
14 being offered for the truth of the matter. And so I think
15 that it's admissible.
16 And I would just tell the Court, I'm not -- that's
17 basically the last question I have for him, is just to say,
18 that's what she said, she identified Mr. Foster, which I think
19 he's already testified to. And then to say there's no
20 indication that that's actually true what happened. That's
21 it. That's the entirety of the questioning about that.
22 THE COURT: Well, you asked, Sure, this is a Secret
23 Service interview. Yes, in this paragraph. She references
24 Foster, first name unknown. So she says that someone from the
25 CDC SBF -- is that the small business -- is that -- that seems
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1 like a different question than what you just said you were
2 going to ask.
3 MS. WEBSTER: I'm sorry. Say it again.
4 THE COURT: It looks to me like you're just going
5 through her testimony and have him say did she say this, did
6 she say this.
7 MS. WEBSTER: But what she's saying is not being
8 offered for the truth of the matter because it's not true.
9 Because the idea that someone named Foster from CDC SBF called
10 her and that's when she knew that it was a lie, is not true.
11 So it can't be offered for the truth of the matter. And,
12 therefore, it's not hearsay.
13 MS. CHAIKEN: Your Honor, you can't get to that
14 second level of what she said and what that is offered for
15 without first getting to the first part, which is this is a
16 Secret Service agent who is saying Amanda Christian said X.
17 And that is hearsay.
18 We don't know if that is true or not, we weren't
19 there. Nobody was there. And you can't get to what Amanda
20 Christian said. They should call the Secret Service agent if
21 they want to establish what Amanda Christian said, but she's
22 having our agent read a different agent's report in order to
23 prove what was said.
24 I agree that the underlying -- if she actually said
25 it is not true and would -- well, I don't know if it's not
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1 true, but it's fine that they're not offering it for the
2 truth.
3 But the fact that it was said in and of itself is
4 hearsay because it's coming from an out-of-court declarant's
5 report.
6 MS. WEBSTER: When she's in -- sorry.
7 When I was offering, I was not asking him, And did
8 the Secret Service agent tell you that she said this? I said
9 she was interviewed by the Secret Service and then she said
10 this; right? So I'm not offering that middle level or that --
11 THE COURT: You've lost me, Ms. Webster. I mean, the
12 question was, So she says that someone from the CDC SBF -- is
13 that the small business -- it just says -- and so he's -- you
14 know, at that point he's reading from the report what the
15 agent asked and what she said, which Ms. Chaiken has said,
16 well, it's -- at least what the agent said someone else said
17 is hearsay.
18 And, you know, perhaps if you want her answer to come
19 in and that's not offered for the truth, Ms. Chaiken said
20 fine, but at least what the Secret Service agent asked is
21 hearsay.
22 MS. WEBSTER: But what the -- I didn't offer anything
23 about what the Secret Service asked. When I referred to the
24 CDC SBF, that is the bank and who she --
25 THE COURT: Why don't you give me the exhibit.
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1 MS. WEBSTER: Yes.
2 THE COURT: And we can go line by line what questions
3 you're going to ask and why you're going to ask them. And
4 I'll let Ms. Chaiken object.
5 The only -- the only question that's currently
6 objected to is, So she says that someone from the CDC SBF --
7 is that the small business.
8 So hand me the document that says that and we'll
9 figure it out.
10 MS. WEBSTER: Your Honor, it's two pages, but the
11 relevant part is just this top paragraph on this page.
12 THE COURT: Well, for now, I'm guessing. We're going
13 to have this conversation, then you're going to ask the next
14 question. So give me a moment to read this.
15 Which page is the first page of this two-page
16 document?
17 MS. WEBSTER: The complete one is the first page that
18 goes all the way down. And then the second page only goes
19 part of the way down.
20 THE COURT: And this is a report of investigation,
21 just paragraphs, notes from some agent that wrote them at some
22 point?
23 MS. WEBSTER: It was produced to us in discovery as a
24 document from the Secret Service. I recognize it's not on the
25 form, but that's how it was produced to us in discovery.
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1 THE COURT: All right. I've now read through this.
2 Point me to -- so she says that someone from the CDC SBF -- is
3 that the small business -- where in here exactly is that?
4 MS. WEBSTER: It's the first paragraph on the second
5 page, Your Honor.
6 THE COURT: I don't see the SBF part.
7 MS. WEBSTER: Or -- I'm sorry, I guess I'm -- it's
8 CDC Finance.
9 THE COURT: All right. So what question are you
10 going to ask? So she says that someone from this CDC SBF, CDC
11 Finance, is that the small business -- go ahead with what your
12 question was going to be before Ms. Chaiken objected.
13 MS. WEBSTER: It was going to be, she said that she
14 received a call from CDC Finance, that that person had the
15 last name of Foster, and that's when she figured out that it
16 was a fraud allegedly.
17 THE COURT: I don't see that in this document.
18 MS. WEBSTER: Christian stated that at this point she
19 began to suspect that the loan was a part of a scam.
20 It's the last -- the entirety of the first paragraph;
21 right. That's it.
22 THE COURT: All right. And, Ms. Chaiken, your
23 objection to her asking Agent Stites, was this what she said,
24 is what?
25 MS. CHAIKEN: Your Honor, it's just pure hearsay.
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1 The agent would just be reading off what another agent said
2 that Amanda Christian said. There's no other basis for our
3 agent to know what Amanda Christian said in that interview
4 other than somebody else saying it in a report.
5 THE COURT: All right. So you're -- where you're
6 going is not the underlying Amanda Christian statement.
7 You're conceding, okay, that might not be offered for the
8 truth. But this is saying what somebody else said about what
9 Amanda Christian said; correct?
10 MS. CHAIKEN: Right. Right. Because they are
11 offering the agent's statement to prove the truth that this is
12 what Amanda Christian said. You can't get to what Amanda --
13 THE COURT: Very well.
14 Ms. Webster, how do you get around that? That seems
15 to be a fair argument on Ms. Chaiken's point.
16 And I'm sorry it took me 15 minutes to understand
17 what you were saying, but that does seem -- you've got -- I
18 don't know if double hearsay is the correct way to say it, but
19 you've got one rung there that does seem like hearsay. I get
20 that under the rung below that, you're saying, well, that's
21 not offered for the truth, but it's still hearsay of this
22 other agent.
23 So I don't know who wrote this. Maybe we bring him
24 in and you might not have a problem, but I think you've got a
25 problem right now if you want to get this in through Agent
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1 Stites.
2 MS. WEBSTER: Because my arguments are a couple. One
3 is that I'm not offering -- I'm not going to ask the agent,
4 another agent told you this; correct? No. I just want to ask
5 him if this is what was said.
6 So the hearsay layer that the government is worried
7 about is not being offered into evidence. That's one.
8 THE COURT: Well, of course it is.
9 MS. WEBSTER: What do you mean?
10 THE COURT: Did you just say that the hearsay the
11 government's not (sic) worried about isn't being offered into
12 evidence? You're doing exactly that.
13 MS. WEBSTER: The hearsay level that the
14 government -- because I'm not going to introduce a statement
15 from the agent saying another agent interviewed her and then
16 she said, right?
17 THE COURT: So you'd like to just skip that level and
18 pretend it doesn't exist?
19 MS. WEBSTER: Yes.
20 THE COURT: Okay. I'm not going to let you do that.
21 MS. WEBSTER: Okay.
22 THE COURT: So objection sustained on that grounds.
23 MS. WEBSTER: Okay. Can I -- but let me make a
24 couple different arguments.
25 First of all, it's relevant to the entirety of the --
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1 or to the course of the investigation, which I think we
2 have --
3 THE COURT: I'm with you on relevance. You don't
4 have to argue relevance.
5 MS. WEBSTER: Okay.
6 THE COURT: What you do have to argue is the hearsay,
7 which I just sustained.
8 MS. WEBSTER: Okay. Can I have one second?
9 THE COURT: Yes.
10 MS. WEBSTER: Your Honor, it is not -- that middle
11 level of hearsay I think is not actually being offered for the
12 truth of the matter either. It's actually being offered to
13 show the effect on the investigation, which is something that
14 the government uses all the time to get in what would
15 otherwise be hearsay evidence because this woman, Amanda
16 Christian, ended up being charged in a -- the same count with
17 Teldrin Foster about this crime. And so -- or about this loan
18 that she's referring to; right? And so I'm entitled to ask
19 him about that statement and the effect that it had on his
20 investigation.
21 THE COURT: Ms. Chaiken?
22 MS. CHAIKEN: Your Honor, this is just an attempt to
23 end run here. Just to be clear, this interview was not
24 conducted at Agent Stites's direction. This was a separate
25 investigation that was being conducted by the Secret Service.
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1 When we -- when we did our investigation, we found
2 out that the Secret Service had a separate investigation that
3 they had closed into Amanda Christian. We got the documents
4 because we have an obligation to turn over a defendant's
5 statement. And Amanda Christian was a defendant, and so we
6 got this and we turned it over.
7 But the defense doesn't have any evidence that we
8 charged Teldrin Foster because Amanda Christian identified a
9 CDC Finance employee as first name unknown Foster. She can't
10 show that this did have any impact on the investigation or
11 that Agent Stites in some way decided Teldrin Foster was
12 involved because of this statement by Amanda Christian.
13 She hasn't laid a foundation for that at all. And
14 saying "effect on the investigation" is just an attempt to end
15 run the fact that she can't get in the fact that this
16 statement was made.
17 THE COURT: All right. Yeah.
18 I'm happy to see if you can lay that foundation about
19 the effect on the investigation, but, otherwise, I think
20 Ms. Chaiken's -- that layer of hearsay objection is well
21 taken. And it's sustained but without prejudice to lay the
22 foundation for the effect on the investigation.
23 MS. WEBSTER: Thank you.
24 And just to be clear, we would argue a lack of the
25 effect on the investigation is also relevant.
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1 THE COURT: Okay.
2 MS. WEBSTER: Thank you, Your Honor.
3 THE COURT: Very well.
4 All right. Anything else that we can anticipate
5 discussing to save us some time? I mean, I would hate to come
6 back at 9:00 and then five minutes later after the jury comes
7 back and we get through this issue, there's another big issue
8 that's going to take us a long time to debate.
9 So anything coming down the pipe?
10 MS. WEBSTER: I am a little concerned about timing
11 for tomorrow, so maybe we should take that up. So I still
12 have a fair amount to go through with Agent Stites. The
13 government has -- did you say six -- six more witnesses that
14 it needs to go through and maybe get them all done tomorrow?
15 Right. But they're supposed to be short, I think. And I'm
16 just talking for them.
17 But then we also need to get to Persinger because of
18 his conflict. And so that's sort of the issue.
19 THE COURT: Well, I thought we already agreed that
20 Persinger, at some point, you would call him and it would be
21 out of order.
22 MS. WEBSTER: I think that that's right, Your Honor,
23 but we're just -- I think we're worried about me being able to
24 finish with Agent Stites, get all the witnesses that have to
25 go tomorrow, and then get to Persinger before the end of the
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1 day.
2 THE COURT: I'm missing something. I mean, if that's
3 the problem, do Persinger earlier in the day.
4 MS. CHAIKEN: Well, Your Honor, that's the problem.
5 We have a witness who needs to be done by 3:00 tomorrow. And
6 then we have five other witnesses who are short, like
7 Ms. Liddiard, the bank witnesses, who will, you know, each be
8 five minutes. But they have been here since Wednesday.
9 They're all here from out of town, mostly from the west coast,
10 and they also need to be done tomorrow. We can't keep them
11 here over the weekend. We can't bring them back next week.
12 And so we're just worried about running out of time, because
13 all of our --
14 THE COURT: This seems like -- these seem like
15 problems we can handle. So let's do this.
16 What's our estimate for how long, Ms. Webster, you
17 need with Mr. Persinger?
18 MS. WEBSTER: With Mr. Persinger, I think we -- on
19 direct, an hour, an hour and a half. An hour and a half might
20 be a little extra.
21 THE COURT: What's your anticipated cross of
22 Mr. Persinger? Or is it Dr. Persinger?
23 MS. CHAIKEN: Probably about 45 minutes, Your Honor.
24 MR. MARSHALL: Your Honor, I have my own mini
25 scheduling issue. So I'm assuming that we would not get to my
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1 part of the case and my witness until at least Monday? Is
2 that fair?
3 MS. CHAIKEN: I think so.
4 MR. MARSHALL: Think?
5 MS. CHAIKEN: Yeah, I don't think -- we're not going
6 to get to him tomorrow.
7 MR. MARSHALL: Okay. Because I've got to arrange --
8 I have one witness, so...
9 THE COURT: All right. So Persinger will last about
10 two hours and 15 minutes, give or take. You have five or six
11 short witnesses.
12 MS. CHAIKEN: We have five bank witnesses who we
13 anticipate, you know, assuming that there's no cross, as there
14 wasn't for Ms. Liddiard, we'd estimate, you know, 45 minutes
15 tops for those together, collectively. 30, 45 minutes.
16 THE COURT: So far I've got a total of three hours
17 for Persinger and those five witnesses.
18 MS. CHAIKEN: And then we've got one more that our --
19 the cell site analyst, who our examination would probably be
20 30 minutes, 45 minutes.
21 THE COURT: And how long does the defense counsel
22 believe their cross of these five bank experts and this one
23 other cell person will be?
24 MS. WEBSTER: I don't anticipate having any cross of
25 the bank witnesses, but I anticipate that the cross for the
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1 cell site expert will be approximately an hour.
2 MR. MARSHALL: I don't anticipate any on that
3 witness, Judge.
4 THE COURT: All right. Persinger, two hours and
5 15 minutes. The five bank witnesses, 45 minutes. That's a
6 total of three hours.
7 Cell tower person, 30 to 45, plus one. Let's call it
8 an hour and 45 minutes. That's a total of three, plus hour 45
9 is four hours and 45 minutes, which we should be able to do;
10 right?
11 I must be missing something.
12 MS. WEBSTER: My finishing the cross of Agent Stites.
13 THE COURT: Oh, that's where we might have to give.
14 So I guess you get to decide. Do you want to finish
15 crossing Agent Stites tomorrow morning and risk not getting
16 through Persinger? Or do you want to pause with Agent Stites,
17 do all these bank witnesses and the cell witness and
18 Persinger, and then come back to Stites at the end of the day
19 if we have time?
20 MS. WEBSTER: That is what I suggested, but there's
21 an issue with the government, because while Agent Stites is on
22 the stand, they cannot talk to him. And he's their case
23 agent.
24 MS. CHAIKEN: Your Honor, Agent Stites is our agent.
25 We haven't been able to speak to him since he started
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1 testifying yesterday. And if he doesn't finish tomorrow, we
2 won't be able to talk to him over the weekend and we'll be
3 preparing for the defense case, we'll be preparing for
4 closings, and that, you know, is going to severely limit our
5 ability to work through things. He's an integral part of our
6 team.
7 THE COURT: All right. Here's what we'll do.
8 Ms. Webster can finish her cross-examination of
9 Mr. Stites, at which point we will then hear from the five
10 bank witnesses. Then we will hear from Mr. Persinger.
11 And then if we have time, we'll hear from the cell
12 phone person. It may be that one cell phone person will have
13 to come back.
14 MS. CHAIKEN: Your Honor, he's on leave next week.
15 He's out of town next week, the cell site expert is.
16 THE COURT: Who is the cell site expert?
17 MS. CHAIKEN: His name is Jay Berni.
18 THE COURT: Is he a government employee?
19 MS. CHAIKEN: He's an FBI agent.
20 THE COURT: Okay.
21 MS. WEBSTER: Your Honor, can we propose a slightly
22 different solution? Which is that we agree that the
23 government can speak with Agent Stites over the weekend so
24 long as it's not about his testimony? Would that solve the
25 problem?
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1 MS. CHAIKEN: Your Honor, the time we've estimated
2 still leaves about three hours for tomorrow morning for the
3 cross of Agent Stites. Is that -- do we really think you're
4 going to need longer than that to finish crossing him?
5 MS. WEBSTER: I'm sorry, one second.
6 Alternatively, why can't we do the bank witnesses,
7 the cell site expert, let us do Persinger, and we can put
8 Agent Stites at the end of the day and hopefully it'll be
9 done.
10 THE COURT: But if he's not?
11 MS. WEBSTER: But if it's not, then, again, we agree
12 that they can talk to him over the weekend.
13 THE COURT: About anything and everything?
14 MS. WEBSTER: Except for what he's testified to,
15 yeah.
16 MS. CHAIKEN: Your Honor, he's testified about
17 basically the whole case. When we're talking through closing
18 and what we're going to say and what the defenses are and what
19 the responses are to that, that's obviously going to implicate
20 things he's testified about. I don't think that's a line we
21 can really draw.
22 THE COURT: I agree. I'm not going to ask the
23 government -- I mean, this is, from what I've seen, their most
24 important witness, who is kind of helping them with the entire
25 case. So I'm not willing to accommodate your witness issue --
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1 MS. WEBSTER: Sure.
2 THE COURT: -- stymie the government, so --
3 MS. WEBSTER: We'll agree they can talk to him.
4 THE COURT: -- absent the defense -- both defendants
5 saying, yes, if we don't finish Stites tomorrow, the
6 government can talk with Stites about anything and everything,
7 what I'm going to do is have Stites go first, followed by the
8 five bank witnesses, followed by the cell phone expert,
9 followed by Persinger, if and when we get to him.
10 But I don't think it's -- you know, the government's
11 already saying, fine, we can interrupt our case to have your
12 expert witness, but, you know, to do that, to then bind them
13 out of talking to their agent over the weekend, when I would
14 assume everybody's going to be working pretty hard on this
15 case, that's not an acceptable solution.
16 MS. WEBSTER: Okay. We'll agree to it, Your Honor.
17 MR. MARSHALL: Yeah. And we'd have no objection to
18 it.
19 THE COURT: All right. Very well.
20 So just so we're clear then, before we begin
21 tomorrow, if we don't get back to Stites and finish Stites
22 tomorrow, the government's not going to be prohibited from
23 speaking to him about anything and everything.
24 Is that correct, Ms. Webster?
25 MS. WEBSTER: That's correct.
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1 THE COURT: Is that correct, Mr. Marshall?
2 MR. MARSHALL: Yes.
3 THE COURT: All right. Very well then.
4 In that case, it would seem prudent to tie up this
5 last little line of questioning with Agent Stites, and then to
6 pause him and do everyone else and then go back to him at the
7 end of the day to the extent we have time left.
8 Does everyone agree?
9 MS. WEBSTER: Yes.
10 MS. CHAIKEN: Sure, yes.
11 MR. MARSHALL: I'm fine with that, Judge.
12 Judge, can I add one more thing when you get to the
13 next thing?
14 Can I ask, Ms. Webster, how many -- other than
15 Mr. Persinger, how many other witnesses you have and how long
16 it might take?
17 MS. WEBSTER: Sorry, my mind has just gone totally
18 blank.
19 MR. MARSHALL: That's okay.
20 MS. WEBSTER: I think we have -- we're not entirely
21 sure. I think it might be three, but I'm not positive.
22 THE COURT: And that was the first part of
23 Mr. Marshall's questions.
24 MR. MARSHALL: And then about how long?
25 MS. WEBSTER: How long they will take?
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1 MR. MARSHALL: Yeah.
2 MS. WEBSTER: One of them is our investigator, who
3 could take -- and we're going to admit various records through
4 her. So that one could take, you know, a few hours or an
5 hour, maybe two.
6 And then the other two I think should be fairly
7 short.
8 THE COURT: Okay.
9 MR. MARSHALL: Okay.
10 THE COURT: All right. Anything else for this
11 evening, Counsel?
12 MR. MARSHALL: No, Judge. At some point, when we get
13 to my part and my witnesses, we'll have to advise my client of
14 her right to testify if she wants to and all that. We might
15 still call her.
16 THE COURT: Certainly. I'll do that as to both
17 defendants when we get there.
18 All right. Anything else?
19 MS. CHAIKEN: Yes, Your Honor.
20 We had raised this in some of our pretrial briefing
21 and at the pretrial conference. I do think at this point that
22 the defense has opened the door to admission of the
23 co-defendants' guilty pleas. First of all, by asking about
24 how many people were charged and going through the fact that
25 they were charged and not tying up that loop of what happened
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1 with those charges, but also by suggesting to the jury that
2 Darrell Thomas falsely implicated people, and none of those
3 people who were charged were falsely implicated.
4 And I think that this is exactly what we predicted
5 was going to happen and the argument that was going to be
6 made. And I think the door's been opened to that and we
7 should be able to put that in on redirect.
8 MS. WEBSTER: Your Honor, I just have litigated this
9 issue in the Eleventh Circuit recently. I think that the law
10 is very clear that you can't admit -- it's a confrontation
11 clause issue. And so the law is very clear that you can't
12 admit co-defendants' guilty pleas without having them come and
13 testify.
14 And I think I cited two cases in the response to the
15 government's motion in limine, and I think they're named
16 Griffin and Easley, something like that, and I can provide
17 those to the Court, but I think the law is pretty clear on
18 that.
19 We are not -- we have not suggested that any of the
20 co-defendants have been falsely charged. If the government
21 has a guilty plea from Brenda Miller, I guess that would be
22 relevant potentially, but I don't think that's what has
23 happened here. So I don't think that we have opened the door
24 to that.
25 And I don't think that it's admissible. I think the
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1 law is very clear, that co-defendants' guilty pleas are not
2 admissible unless they come and testify.
3 THE COURT: Mr. Marshall, anything to add?
4 MR. MARSHALL: No, Your Honor. It's not directed
5 towards me, I don't believe. Is that correct, Ms. Chaiken?
6 MS. CHAIKEN: Well, it would be evidence that would
7 come in at the trial that the jury would hear as to everyone.
8 MR. MARSHALL: Well, what would you actually be
9 trying to introduce?
10 MS. CHAIKEN: We would be introducing that all of the
11 list of people that Ms. Webster went through for each one and
12 asked if they were charged and asked if they communicated with
13 Darrell Thomas and in some way implied, I think, that they
14 were not really involved, they didn't talk to Darrell Thomas,
15 but they were charged, that they pleaded guilty and admitted
16 that they were involved.
17 MS. WEBSTER: That was -- I'm sorry.
18 THE COURT: That was a response to Mr. Marshall's
19 question, so I'll let Mr. Marshall speak and then I'll hear
20 from you, Ms. Webster.
21 MR. MARSHALL: I really don't have a dog in that
22 fight, but I'll just object based -- I'll follow co-counsel's
23 arguments, Judge.
24 THE COURT: I'll have to look back at that. Yeah.
25 It seems that we are somewhere different than we were at the
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1 pretrial conference, given some of the questions that were
2 asked. So I don't know -- I don't know where that shakes out.
3 I'll take a look.
4 MS. CHAIKEN: Your Honor, I would just note that we
5 had filed a motion in limine to preclude reference to charging
6 decisions and to who was charged and who was not charged,
7 precisely because who was not charged and was not charged is
8 not generally relevant to the jury's consideration. The
9 questions could have been asked as who was the owner, what did
10 you determine about the owner's involvement, without putting
11 before the jury that they were charged.
12 But it was the defense that chose to go into that,
13 despite the case law that charging decisions really are not
14 relevant, and I think that the jury may be left with a
15 misimpression based on the nature of the questions about
16 people's interactions with Darrell Thomas directly tied to
17 whether they were charged. Who was this person, did they
18 communicate with Darrell Thomas, I think implies to the jury,
19 oh, here's another person that didn't communicate with Darrell
20 Thomas and was charged with a crime.
21 MS. WEBSTER: Your Honor, there were -- first of all,
22 these people are charged in the same indictment. They're
23 charged in the same counts as Mr. Foster, so the government's
24 case, when they are saying, like, look at these communications
25 between these two people, it doesn't address other people that
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1 he's charged with conspiring with. And so I'm entitled to ask
2 the agent about their role.
3 It was not -- the point of that line of questioning,
4 of did they communicate with Darrell Thomas or not was to lead
5 to the questions where Ricky Dixon was falsely identifying
6 Mr. Foster. That is the whole point. That was the setup for
7 those questions, is to say these people -- some of them were
8 communicating directly with Darrell Thomas, some of them
9 weren't. But Ricky Dixon absolutely was. Amanda Christian --
10 Charmaine Redding also was and was not communicating with
11 Teldrin Foster.
12 THE COURT: Right. Didn't you ask about the charge?
13 MS. WEBSTER: I said they were charged in this case.
14 And is the jury not going to get a copy of the indictment that
15 has them charged?
16 I think there's a limiting instruction that says, you
17 know, you don't consider anyone else's guilt or -- like
18 what -- how they answer their charges is left for another day,
19 basically, and you're only considering whether or not Teldrin
20 Foster and Ms. Jackson are guilty.
21 But the idea that just because I said other people
22 were charged in this case means that their guilty pleas get to
23 come in without them testifying violates a number of
24 Constitutional rights, his confrontation clause rights, due
25 process rights.
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1 THE COURT: I asked for Ms. Chaiken, Ms. Webster.
2 MS. CHAIKEN: Your Honor, first of all, I think it
3 was put before the jury that other people in this case pleaded
4 guilty and not by us earlier in the case. So I think the door
5 has been opened to that in any event.
6 But Ms. Webster said, in the presence of the jury,
7 several times that Mr. Foster's defense is that Darrell
8 Thomas's MO is to use other people's names and suggesting that
9 he falsely implicates people. And I think the brief they
10 filed pretrial said that that was their defense. That he, at
11 least in part, falsely implicates people or falsely inculpates
12 people.
13 And I think telling the jury that all of these people
14 have been charged, trying to distance them from Darrell
15 Thomas, and in some way suggesting to the jury that, you know,
16 this is all a big conspiracy against people who don't know
17 Darrell and don't talk to Darrell, I think leaves the
18 impression that Darrell Thomas may have falsely inculpated
19 other people. And that is not true.
20 There is nobody who has been charged in this case who
21 has not admitted their guilt, other than the people who are
22 here on trial and Mr. Baptiste. We're certainly happy for the
23 Court to give a limiting instruction that the jurors should
24 not rely on anybody else's guilt to determine Mr. Foster or
25 Ms. Jackson's guilt. We are not offering it for that purpose.
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1 We certainly agree that the jury should not consider it for
2 that purpose.
3 But guilty pleas are permitted to be considered for
4 other purposes. And here it's to rebut the defense that
5 Darrell Thomas has an MO of falsely implicating people.
6 THE COURT: All right. One moment.
7 All right. Anything else from either side on this
8 for right now?
9 MR. MARSHALL: I would just say, Judge, from my
10 side -- well, when you get to me, Your Honor.
11 THE COURT: Go ahead.
12 MR. MARSHALL: If there is any ruling that admits any
13 of these plea agreements, obviously, if they're standard plea
14 agreements, I'm not assuming any of them make any reference to
15 my client in any way. So I'd object if there was any kind of
16 reference like that. So I think I'm in a different position
17 from Mr. Foster's counsel, but I will -- I just object on that
18 additional ground.
19 MS. CHAIKEN: Just to be clear, Your Honor, we're not
20 seeking to introduce any actual plea agreements, just the fact
21 there was a guilty plea.
22 THE COURT: Anything else, Ms. Webster?
23 MS. WEBSTER: Your Honor, I would like to be able to
24 provide you with the citations to the cases if you're inclined
25 to grant the government's motion.
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1 THE COURT: All right. I think I'd like more than
2 that. I think this would -- I want to be very cautious.
3 Ms. Chaiken, I'm not sure you're not right, you might
4 be, but I want to be very cautious if I take that step and
5 admit what you want me to admit. Therefore, I'd like a motion
6 from the government, a response and a reply. So perhaps by
7 tomorrow morning you could put together a motion of what you
8 want to do and why. And then it might be that we get to --
9 over the weekend I get some response briefs and I'll let y'all
10 know on Monday when it's looking like the government's case
11 will still be open at this point.
12 All right. Okay. Thanks, everyone. Have a good
13 evening. See you at 9:00.
14 (After a recess at 5:57 p.m., proceedings were
15 continued on February 9, 2024, as follows:)
16 - - - - -
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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 7th Day of February, 2024.
10
11
12
13
14 ________________________________
15 PENNY PRITTY COUDRIET, RMR, CRR
OFFICIAL COURT REPORTER
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$ 1:40 [1] - 171:11 2332 [2] - 168:1, 184:9
1:45 [1] - 163:20 2333 [1] - 185:15
$10,000 [2] - 235:16, 236:23 1B [4] - 252:12, 252:14, 252:15, 252:21 2333A [1] - 185:16
$10,560 [3] - 195:3, 195:20, 196:12 1ST [2] - 196:4, 206:21 2336 [1] - 177:6
$155,000 [1] - 233:9 2348 [4] - 170:1, 170:9, 189:2, 189:5
$180,000 [1] - 233:13
$34,000 [1] - 197:10
2 2350 [2] - 190:15, 190:20
23RD [2] - 185:20, 185:23
$34,500 [1] - 193:8 2 [7] - 168:1, 178:25, 191:9, 193:3,
24 [2] - 239:8, 275:13
$60,000 [1] - 192:14 193:16, 204:18, 207:9
2413A [2] - 165:6, 165:12
$71,144.35 [1] - 229:15 20 [2] - 223:1, 264:16
2431 [2] - 164:13, 164:15
$8,000 [1] - 203:3 2017 [2] - 167:14, 262:7
2431B [2] - 165:7, 165:9
$9,810 [1] - 196:7 2019 [18] - 166:25, 168:22, 172:23,
2431C [1] - 164:20
175:8, 175:9, 176:20, 176:22, 176:23,
2436 [2] - 165:22, 165:25
178:14, 180:8, 184:1, 214:21, 214:22,
0 2441 [2] - 172:10, 172:12
214:23, 224:6, 228:5, 231:13, 254:17
05/21 [1] - 198:16 2441A [1] - 172:16
2020 [69] - 164:17, 166:2, 166:15,
2445 [1] - 167:15
166:20, 166:21, 166:22, 167:9,
1 168:19, 170:18, 171:11, 172:14, 2445D [4] - 173:10, 173:15, 181:15,
173:7, 173:25, 175:5, 175:8, 175:9, 181:21
1 [2] - 162:3, 204:18 2445G [1] - 167:16
175:24, 177:15, 178:1, 178:8, 178:16,
1,380.41 [1] - 198:9 2447 [3] - 173:3, 173:5, 173:12
178:17, 178:19, 178:20, 179:13,
1/24 [1] - 231:13 2447A [1] - 173:9
179:25, 180:20, 181:10, 182:10,
10/21/2019 [1] - 177:2 2464 [1] - 179:20
183:17, 184:8, 184:13, 184:21,
10TH [3] - 193:20, 195:14, 195:18 2464B [1] - 180:5
185:20, 185:23, 186:8, 186:22, 188:7,
1116 [1] - 224:15 2467 [2] - 181:6, 181:8
189:14, 192:13, 193:20, 195:14,
1146 [1] - 197:17 2467A [4] - 181:16, 181:18, 182:21,
195:18, 195:24, 196:5, 198:4, 198:9,
1150 [1] - 227:8 182:23
198:22, 202:22, 202:23, 202:24,
1151 [1] - 228:14 2471 [2] - 184:17, 184:19
203:2, 204:14, 204:15, 206:21,
1166 [1] - 232:3 2471A [1] - 184:25
206:24, 207:13, 218:20, 226:15,
1169 [1] - 233:24 228:10, 229:1, 230:13, 231:19, 233:9, 2472 [2] - 175:20, 175:22
11:11 [1] - 188:7 238:3, 256:14, 267:8 2472A [1] - 176:3
11:12 [1] - 172:14 2021 [1] - 255:24 2472B [2] - 176:4, 176:12
11:45 [1] - 163:9 2023 [1] - 256:2 2474 [4] - 169:22, 169:23, 171:7, 171:9
11TH [1] - 193:20 2024 [3] - 160:11, 311:15, 312:9 2474A [1] - 171:17
12 [2] - 220:16, 220:17 20A [3] - 264:16, 264:19, 265:21 2475 [2] - 186:18, 186:20
12/30 [1] - 228:5 20C [1] - 265:4 2475A [2] - 186:23, 186:24
12:08 [1] - 186:8 20D [1] - 264:16 2477 [2] - 178:3, 178:6
12:51 [1] - 173:7 20TH [2] - 198:22, 202:23 2477A [1] - 178:4
12:55 [1] - 181:10 2116 [2] - 213:15, 214:3 2479 [2] - 188:3, 188:5
12:58 [1] - 168:19 21ST [1] - 266:6 2479A [1] - 188:9
12TH [1] - 173:25 2222 [1] - 214:3 24TH [2] - 178:17, 196:10
13 [2] - 220:17, 222:10 2250G [2] - 192:15, 192:17 2508 [1] - 182:7
14 [1] - 188:18 2250H [2] - 196:20, 196:21 2508H [2] - 182:20, 183:1
14TH [2] - 183:17, 184:8 2250I [2] - 196:23 2511 [3] - 183:13, 183:15, 184:5
15 [5] - 175:5, 210:1, 292:16, 298:10, 2250Q [2] - 208:23, 208:24 2511E [1] - 183:22
299:5 2250T [2] - 207:23, 207:24 2512 [2] - 175:1, 175:3
155,252.50 [1] - 232:16 2250U [2] - 208:10, 208:11 2512D [1] - 175:10
15TH [2] - 184:13, 184:15 2250W [3] - 196:23, 197:2, 197:3 2512E [1] - 175:10
16TH [3] - 175:24, 179:13, 184:21 22ND [5] - 166:25, 198:4, 198:7, 198:9, 2513 [2] - 168:15, 169:25
17 [1] - 230:13 198:12 2513C [1] - 168:23
1700 [1] - 223:23 2300 [2] - 189:4, 189:7 2513F [1] - 169:13
179 [1] - 233:12 2318 [1] - 167:4 2514 [2] - 186:4, 186:6
179,985.72 [1] - 232:17 2318A [1] - 167:5 2514G [1] - 186:12
17TH [1] - 179:25 2322 [2] - 173:22, 178:25 2516 [2] - 187:14, 187:16
1920 [1] - 180:21 2324 [1] - 179:9 2516E [1] - 187:22
19A [1] - 257:14 2324A [1] - 179:10 25TH [2] - 168:19, 189:14
1:13 [1] - 166:2 2327 [2] - 198:17, 198:18 26 [2] - 204:18, 206:3
1:20-CR-00296-JPB [1] - 160:5 2327A [1] - 198:18 26-PAGE [1] - 204:12
1:25 [1] - 178:8 2329 [1] - 180:13 26TH [5] - 171:11, 178:1, 186:8, 186:22,
1:31 [1] - 163:1 2329A [1] - 180:13 224:9
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27 [1] - 164:17 5TH [2] - 167:9, 229:1 173:7, 175:24, 178:8, 179:25, 181:10,
27TH [2] - 178:8, 222:25 184:21, 186:8, 186:22
2871 [1] - 193:3 6 A1 [1] - 213:8
2872 [1] - 193:16 ABILITY [1] - 300:5
6 [1] - 197:17
2879 [1] - 192:18 ABLE [11] - 199:8, 230:17, 231:12,
6/11 [1] - 195:24
28TH [1] - 166:2 284:25, 296:23, 299:9, 299:25, 300:2,
6/11/2020 [1] - 195:3
2940 [2] - 194:5, 195:6 305:7, 310:23
6/16/2020 [1] - 168:8
2941 [1] - 195:15 ABSENT [1] - 302:4
6/17 [2] - 228:10, 229:9
2942 [1] - 196:2 ABSOLUTELY [1] - 308:9
6/25 [1] - 170:18
2943 [3] - 194:5, 194:21, 194:25 ACCEPTABLE [2] - 267:3, 302:15
6/26/2020 [1] - 177:25
2950 [1] - 199:25 ACCESS [7] - 205:21, 205:24, 205:25,
6/27/2020 [1] - 177:24
2954 [2] - 199:25, 201:7 212:9, 212:10, 226:6
6/30 [1] - 267:8
29TH [1] - 167:14 ACCESSED [1] - 227:1
608 [7] - 258:4, 258:9, 258:14, 259:4,
2ND [2] - 202:22, 202:24 ACCOMMODATE [1] - 301:25
261:9, 271:4, 272:2
ACCOUNT [82] - 164:16, 164:18,
66 [1] - 166:16
3 164:19, 166:1, 166:4, 168:18, 169:15,
6TH [7] - 172:14, 204:15, 205:11, 206:5, 170:19, 171:10, 171:15, 171:21,
3 [6] - 160:6, 172:23, 193:10, 195:15, 206:6, 256:13, 256:14 172:3, 172:4, 172:13, 175:4, 178:7,
196:2, 204:18 178:19, 179:22, 180:20, 180:22,
30 [3] - 298:15, 298:20, 299:7 7 181:9, 182:15, 182:24, 183:8, 183:9,
3000 [1] - 239:3 183:16, 185:4, 185:8, 185:10, 186:21,
7 [1] - 160:11
3005 [3] - 203:14, 204:2, 206:16 187:8, 187:17, 188:6, 188:23, 188:24,
7200 [1] - 255:7
3015 [4] - 202:1, 202:2, 202:10, 202:16 193:13, 193:19, 193:22, 194:2, 195:9,
76.105.87.198 [1] - 225:10
30TH [1] - 188:7 195:11, 195:13, 195:18, 195:21,
7:38 [1] - 186:22
31ST [2] - 176:21, 196:5 195:25, 196:4, 196:8, 197:8, 197:11,
7:39 [1] - 182:10
365 [1] - 234:21 197:14, 199:7, 199:9, 199:22, 200:7,
7TH [3] - 218:20, 238:3, 312:9
388 [2] - 189:4, 189:7 200:12, 200:14, 200:25, 201:1, 201:4,
3:00 [1] - 297:5 205:21, 206:1, 206:25, 224:23, 227:2,
3:03 [1] - 215:14
8 229:4, 229:7, 229:8, 230:17, 231:22,
3:19 [1] - 215:15 8:02 [2] - 183:17, 184:8 231:25, 232:1, 235:25, 241:23, 248:9,
3:20 [1] - 215:23 8:05 [2] - 178:1, 178:2 264:25, 265:1, 276:1, 280:1
3:24 [1] - 179:25 8:28 [1] - 184:15 ACCOUNTING [1] - 195:4
3:29 [1] - 164:17 8TH [3] - 173:7, 182:10, 233:9 ACCOUNTS [2] - 246:4, 248:9
ACCURATE [2] - 262:15, 266:10
4 9 ACTED [1] - 260:17
ACTIVITIES [1] - 221:18
4 [3] - 172:23, 204:18, 206:3 9 [1] - 311:15
ACTIVITY [1] - 224:23
401 [2] - 258:3, 272:4 9/23/2019 [1] - 253:25
ACTUAL [3] - 272:24, 283:18, 310:20
4019 [1] - 236:19 90 [1] - 1:5
ADD [2] - 303:12, 306:3
403 [4] - 272:5, 276:12, 276:15, 276:21 902.11 [5] - 194:6, 200:1, 252:21, 258:2,
ADDED [4] - 228:11, 230:16, 231:25
404 [5] - 260:4, 260:11, 260:15, 260:16, 263:5
ADDITIONAL [5] - 174:8, 236:1, 237:10,
260:24 940 [6] - 165:9, 165:12, 211:16, 211:19,
310:18
408 [1] - 262:21 212:20, 213:11
ADDRESS [20] - 165:19, 179:17,
45 [9] - 297:23, 298:14, 298:15, 298:20, 940S [1] - 213:9
201:20, 201:21, 224:25, 225:2, 225:8,
299:5, 299:7, 299:8, 299:9 941 [15] - 166:15, 168:5, 168:13, 169:17,
225:23, 226:1, 226:2, 227:2, 241:2,
4:14 [1] - 184:21 175:18, 176:14, 178:14, 178:20,
241:3, 241:21, 241:25, 242:3, 242:6,
4:40 [1] - 271:20 184:1, 186:16, 187:3, 211:8, 212:21,
255:7, 255:9, 307:25
4:41 [1] - 271:25 213:11, 214:5
ADDRESSED [1] - 263:18
4:57 [1] - 272:1 941S [21] - 164:23, 164:25, 168:22,
ADDRESSES [6] - 224:24, 225:20,
4TH [2] - 181:10, 181:19 169:15, 171:23, 172:23, 175:8, 180:8,
241:17, 249:17, 249:18, 259:21
180:10, 185:6, 185:8, 186:9, 186:14,
ADMINISTRATIVELY [1] - 255:23
5 187:20, 187:24, 188:14, 188:16,
ADMISSIBLE [3] - 287:15, 305:25,
213:9, 214:18, 214:21
5/21 [1] - 198:16 306:2
959,946.42 [1] - 166:17
50 [1] - 192:14 ADMISSION [1] - 304:22
9:00 [4] - 283:1, 283:4, 296:6, 311:13
51 [3] - 201:7, 201:10, 201:16 ADMIT [20] - 170:1, 190:14, 194:4,
9:20 [1] - 175:5
5813 [1] - 235:25 196:22, 196:23, 199:24, 202:9,
9:40 [1] - 219:1
5:07 [1] - 277:8 203:20, 204:1, 205:17, 252:20, 258:1,
5:14 [1] - 283:5 259:14, 263:4, 265:15, 304:3, 305:10,
A 305:12, 311:5
5:37 [1] - 175:24
5:57 [1] - 311:14 A.M [12] - 163:9, 166:2, 168:19, 171:11, ADMITS [1] - 310:12
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ADMITTED [18] - 170:7, 190:18, 194:9, 288:16, 288:19, 288:21, 292:2, 292:3, ASSISTANT [1] - 160:16
194:12, 194:14, 197:1, 200:4, 202:15, 292:6, 292:9, 292:12, 294:15, 295:3, ASSISTING [1] - 240:14
227:13, 252:24, 256:16, 258:23, 295:5, 295:8, 295:12, 308:9 ASSOCIATED [10] - 199:22, 201:15,
263:7, 265:18, 271:7, 306:15, 309:21 AMENABLE [1] - 163:11 202:7, 221:19, 229:8, 229:9, 230:8,
ADMITTING [2] - 259:12, 259:13 AMENDED [2] - 253:21, 254:19 230:20, 244:7
ADVERTISING [12] - 172:6, 172:15, AMERICA [1] - 160:4 ASSUME [1] - 302:14
172:24, 173:8, 173:13, 174:23, 175:6, AMERICA [8] - 180:19, 194:2, 227:15, ASSUMING [4] - 215:16, 297:25,
177:15, 178:9, 178:14, 213:5, 243:7 227:22, 230:17, 231:19, 231:23, 232:1 298:13, 310:14
ADVISE [2] - 270:16, 304:13 AMOUNT [8] - 169:3, 229:2, 229:14, AT [1] - 163:1
AFFIDAVIT [1] - 216:24 233:9, 235:15, 235:17, 236:22, 296:12 ATLANTA [1] - 279:19
AFFIRMATIVE) [1] - 245:16 AN [1] - 1:2 ATLANTA [3] - 160:2, 160:25, 163:1
AFFIRMATIVELY [1] - 278:8 ANALYSIS [2] - 217:4, 219:14 ATTACH [4] - 168:20, 175:7, 186:9,
AFORESAID [1] - 312:8 ANALYSIS [1] - 213:7 187:20
AFOUL [1] - 276:15 ANALYST [1] - 298:19 ATTACHED [9] - 164:23, 168:21,
AFTER [1] - 1:7 ANALYZE [3] - 203:8, 207:3, 217:25 173:12, 175:12, 176:6, 186:14,
AFTERNOON [6] - 210:5, 210:6, 216:6, AND [3] - 1:4, 1:7, 160:6 187:24, 261:23, 261:25
216:7, 238:22, 238:23 AND.. [1] - 265:3 ATTACHED [1] - 1:6
AGENCY [1] - 285:4 ANDRE [7] - 222:5, 233:16, 233:18, ATTACHING [1] - 1:9
AGENT [29] - 163:10, 164:6, 203:13, 235:4, 238:4, 242:18, 242:20 ATTACHMENT [5] - 166:12, 178:13,
209:18, 209:20, 215:18, 216:6, ANDREW [2] - 263:1, 263:16 198:24, 265:24, 266:1
218:22, 223:2, 224:18, 238:16, ANN [1] - 160:18 ATTACHMENTS [9] - 171:20, 172:19,
238:22, 261:16, 275:6, 291:23, ANNUAL [3] - 211:19, 253:21, 254:19 172:22, 175:12, 180:7, 183:24, 185:3,
292:25, 294:24, 295:11, 296:12, ANSWER [3] - 256:18, 289:18, 308:18 187:1, 188:12
296:24, 299:12, 299:15, 299:16, ANSWERED [2] - 220:11, 226:7 ATTACKING [3] - 272:7, 272:9, 272:10
299:21, 299:24, 300:23, 301:3, 301:8, ANTICIPATE [6] - 163:8, 296:4, 298:13, ATTEMPT [3] - 219:16, 294:22, 295:14
303:5 298:24, 298:25, 299:2 ATTENTION [1] - 228:25
AGENT [47] - 203:8, 203:12, 207:3, ANTICIPATED [1] - 297:21 ATTORNEY [4] - 237:18, 237:22,
218:23, 220:5, 220:7, 231:9, 269:8, ANY [1] - 1:9 268:21, 269:25
272:14, 273:5, 273:16, 279:13, 281:3, ANYWAY [2] - 271:13, 271:15 ATTORNEY [1] - 237:23
281:19, 281:23, 282:3, 282:9, 282:20, APP [4] - 193:14, 193:25, 198:5, 198:8 ATTORNEY'S [2] - 268:22, 269:10
283:20, 284:25, 285:4, 285:17, APPEAR [1] - 257:22 ATTORNEYS [2] - 209:14, 269:3
285:18, 285:21, 286:3, 287:11, APPEARANCES [1] - 160:13 ATTORNEYS [1] - 160:16
288:16, 288:20, 288:22, 289:8, APPEARED [1] - 220:10 AUGUST [7] - 204:14, 204:15, 205:11,
289:15, 289:16, 289:20, 290:21, APPLICATION [3] - 185:21, 216:24, 206:5, 206:6, 256:13, 256:14
292:1, 292:3, 292:22, 293:3, 293:4, 263:20 AUTHENTICATED [2] - 170:2, 190:15
293:15, 299:23, 299:24, 300:19, AUTHORIZATIONS [1] - 218:11
APPLICATIONS [2] - 200:20, 200:21
302:13, 308:2 AUTO [3] - 235:23, 236:2, 236:19
APPLIED [1] - 251:19
AGENT'S [3] - 285:25, 288:22, 292:11 AUTO [5] - 187:11, 187:18, 188:19,
APPLY [1] - 256:15
AGENTS [3] - 268:22, 269:12, 273:1 213:6, 249:11
APPLYING [1] - 259:17
AGO [2] - 226:7, 226:20 AUTOMOTIVE [3] - 213:6, 227:16,
APPROACH [1] - 231:4
AGREE [11] - 220:6, 284:3, 286:7, 230:25
APPROVED [2] - 216:25, 248:4
288:24, 300:22, 301:11, 301:22, AWARE [4] - 250:24, 255:22, 267:1,
APRIL [4] - 164:17, 166:2, 166:25,
302:3, 302:16, 303:8, 310:1 267:4
192:13
AGREED [1] - 296:19 AWFULLY [1] - 282:23
ARCADE [2] - 213:1, 244:25
AGREEMENT [2] - 199:15, 266:11
ARE [1] - 1:8
AGREEMENTS [3] - 310:13, 310:14,
310:20
ARGUABLY [1] - 276:10 B
ARGUE [3] - 294:4, 294:6, 295:24 BABASIJIBOMI [1] - 160:15
AHEAD [10] - 206:7, 210:2, 256:25,
ARGUING [1] - 276:8 BABYSITTER [1] - 223:10
260:8, 261:11, 268:24, 272:20,
ARGUMENT [9] - 204:25, 205:22, 276:8, BALANCE [2] - 276:12, 276:15
277:10, 291:11, 310:11
276:10, 284:10, 287:2, 287:4, 292:15,
ALABAMA [1] - 220:24 BANK [9] - 180:19, 194:2, 227:15,
305:5
ALLEGED [1] - 266:11 227:22, 230:17, 231:19, 231:23,
ARGUMENTS [3] - 293:2, 293:24,
ALLEGEDLY [2] - 263:11, 291:16 232:1, 232:17
306:23
ALLOW [1] - 258:14 BANK [22] - 180:19, 180:22, 180:24,
ARRANGE [1] - 298:7
ALLOWS [3] - 199:6, 258:9, 259:4 193:5, 194:1, 194:2, 195:17, 196:4,
ARRESTED [1] - 204:15 197:19, 224:23, 230:18, 289:24,
ALMOST [2] - 216:22, 233:12
ARTICLES [1] - 253:14 297:7, 298:12, 298:22, 298:25, 299:5,
ALTERNATIVELY [1] - 301:6
ASHONG [3] - 248:17, 248:18, 255:11 299:17, 300:10, 301:6, 302:8
AMANDA [26] - 243:2, 243:3, 246:21,
ASSERTED [2] - 286:23, 287:8 BAPTISTE [5] - 243:21, 243:22, 243:24,
249:13, 279:22, 281:20, 284:14,
ASSIGNED [1] - 202:7 244:2, 309:22
284:21, 284:22, 286:15, 287:12,
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BARBER [1] - 213:8 BLANK [1] - 303:18 193:18, 194:24, 195:7, 195:16, 196:3,
BARS [1] - 260:16 BLOW [2] - 176:11, 177:7 197:4, 197:18, 198:10, 198:20, 200:5,
BASED [8] - 191:22, 192:3, 192:7, BOARD [4] - 213:4, 245:5, 245:21 201:9, 202:17, 203:22, 206:17,
200:6, 260:9, 262:15, 306:22, 307:15 BOB [2] - 273:16 207:11, 207:25, 208:12, 210:16,
BASIS [2] - 260:3, 292:2 BOOK [1] - 285:7 213:16, 214:4, 214:14, 216:5, 224:16,
BE [2] - 1:3, 1:4 BOOKKEEPING [1] - 266:10 227:21, 228:8, 228:20, 230:5, 231:8,
BECOME [1] - 211:5 BORNE [1] - 275:17 232:5, 232:11, 234:1, 234:12, 235:9,
BEFORE [1] - 160:10 BORROWER [10] - 242:17, 242:20, 236:11, 238:21, 239:5, 253:2, 253:12,
BEGAN [3] - 191:24, 248:5, 291:19 244:25, 245:21, 246:5, 246:16, 247:2, 257:2, 261:15, 263:9, 265:20, 277:13,
BEGIN [1] - 302:20 247:15, 249:3, 249:11 281:18
BEGUN [1] - 168:9 BORROWER'S [1] - 248:8
BEHALF [3] - 160:14, 160:17, 160:20 BORROWERS [2] - 244:18, 247:24 C
BELGRAVE [2] - 246:15, 246:16 BORROWING [1] - 185:21 CAFETERIA [1] - 164:1
BELLATOR [39] - 165:12, 167:24, BOTTOM [7] - 174:24, 179:4, 180:15, CANDACE [2] - 170:2, 190:15
192:21, 195:2, 195:20, 196:16, 202:22, 227:25, 230:10 CANNOT [1] - 299:22
199:17, 199:22, 200:14, 201:2, BOULEE [1] - 160:10 CAPACITY [1] - 262:6
201:13, 208:14, 208:20, 213:1, 214:6, BPGINTAKECOORDINATOR@GMAIL CAPITALIZATION [1] - 190:6
240:7, 240:25, 241:1, 241:2, 241:20, .COM [1] - 261:18 CARD [16] - 174:6, 195:8, 199:1, 199:6,
251:16, 251:25, 252:3, 252:6, 252:18, BREAK [10] - 209:17, 215:12, 271:12, 201:18, 202:24, 202:25, 203:2, 208:7,
253:15, 253:21, 254:11, 254:20, 271:13, 271:17, 271:23, 278:16, 227:15, 227:22, 227:23, 228:4, 228:9,
255:12, 255:19, 255:22, 258:20, 283:14, 283:17 228:11, 229:6
262:2, 262:6, 262:12, 262:13, 262:15, BREAKS [1] - 271:19 CARDS [7] - 199:8, 199:10, 199:12,
275:23 BRENDA [11] - 255:2, 255:10, 257:3, 200:11, 200:15, 201:3, 201:12
BELLATOR'S [2] - 200:7, 200:24 257:8, 262:1, 263:11, 263:19, 275:20, CAREER [1] - 220:3
BELLEVIE [6] - 185:13, 185:22, 186:10, 275:21, 275:24, 305:21 CARLA [2] - 160:6, 160:20
213:5, 249:2, 249:6 BRIEF [2] - 163:8, 309:9 CARLA [15] - 228:1, 229:13, 230:12,
BELONGS [2] - 225:9, 234:23 BRIEFING [1] - 304:20 233:4, 233:13, 233:15, 233:16,
BELOW [9] - 174:8, 201:19, 230:3, BRIEFS [1] - 311:9 234:19, 235:1, 235:2, 235:4, 235:14,
233:21, 234:10, 235:20, 235:21, BRING [7] - 163:2, 224:15, 271:14, 236:6, 236:13, 236:25
236:17, 292:20 276:23, 276:24, 292:23, 297:11 CAROLINA [1] - 279:23
BENEFITED [1] - 259:16 BRINGS [1] - 262:8 CASE [59] - 216:11, 216:14, 216:20,
BENOIT [3] - 243:23, 244:7, 244:11 BROKE [1] - 277:14 217:2, 217:7, 217:15, 217:20, 217:23,
BERKOVITZ [2] - 263:2, 263:16 BUNCH [1] - 222:4 218:17, 232:24, 238:24, 239:6,
BERN [3] - 243:23, 244:7, 244:11 BUSINESS [34] - 172:7, 174:4, 174:5, 241:14, 242:12, 250:2, 259:1, 261:6,
BERNI [3] - 203:13, 300:17 178:23, 179:16, 182:3, 182:4, 197:22, 268:10, 268:14, 268:22, 269:13,
BEST [3] - 219:19, 219:23, 219:24 198:1, 199:16, 200:12, 200:20, 269:14, 270:24, 271:9, 272:8, 272:11,
BETWEEN [35] - 181:1, 188:20, 189:8, 212:12, 213:25, 214:5, 239:19, 240:2, 272:23, 275:8, 275:12, 279:13, 281:3,
189:11, 189:23, 190:1, 190:8, 190:22, 241:10, 243:5, 243:6, 243:16, 244:25, 281:24, 282:3, 282:20, 282:21,
192:7, 192:14, 199:15, 203:18, 246:18, 248:9, 248:13, 248:21, 262:5, 283:20, 283:22, 283:24, 283:25,
206:19, 207:17, 233:13, 233:15, 280:17, 287:25, 289:13, 290:7, 291:3, 284:1, 286:2, 298:1, 299:22, 300:3,
236:25, 243:4, 243:16, 243:18, 291:11 301:17, 301:25, 302:11, 302:15,
243:23, 244:1, 246:10, 246:12, BUSINESSES [15] - 165:3, 167:19, 303:4, 307:13, 307:24, 308:13,
249:16, 249:19, 249:22, 251:10, 174:7, 174:9, 174:14, 174:18, 179:2, 308:22, 309:3, 309:4, 309:20, 311:10,
251:13, 263:11, 267:7, 267:24, 268:6, 181:4, 188:18, 198:2, 200:22, 212:21, 312:8
268:8, 307:25 212:23, 212:24, 214:16 CASES [2] - 305:14, 310:24
BIG [5] - 184:10, 232:15, 232:18, 296:7, BUT.. [1] - 278:25 CASH [2] - 193:14, 193:25
309:16 BY [107] - 1:4, 1:6, 160:23, 164:5, CASH [4] - 193:14, 193:25, 198:5, 198:8
BILL [1] - 174:6 164:14, 164:22, 165:8, 165:24, CASHIER'S [3] - 234:14, 235:11, 236:12
BIND [1] - 302:12 166:11, 167:7, 167:17, 168:2, 168:16, CATCH [1] - 259:24
BINDER [4] - 201:23, 203:14, 252:11, 168:24, 169:14, 170:10, 171:3, 171:8, CAUTIOUS [2] - 311:2, 311:4
257:10 171:19, 172:11, 172:18, 173:4, CDC [12] - 280:16, 287:25, 288:9,
BIO [3] - 258:18, 258:20, 262:1 173:11, 173:23, 174:13, 174:22, 289:12, 289:24, 290:6, 291:2, 291:8,
BIOS [1] - 258:25 175:2, 175:11, 175:21, 176:5, 176:13, 291:10, 291:14, 295:9
BIT [16] - 174:21, 179:5, 193:14, 193:15, 177:8, 178:5, 179:1, 179:11, 179:21, CELL [18] - 203:5, 203:6, 203:8, 203:9,
216:8, 218:19, 226:8, 226:9, 227:9, 180:6, 180:14, 181:7, 181:17, 182:8, 207:3, 217:12, 218:2, 298:19, 298:23,
232:18, 237:4, 245:7, 245:10, 271:17, 182:22, 183:14, 183:23, 184:6, 299:1, 299:7, 299:17, 300:11, 300:12,
278:7, 283:13 184:11, 184:18, 185:2, 185:18, 186:5, 300:15, 300:16, 301:7, 302:8
BIZARRE [1] - 283:13 186:13, 186:19, 186:25, 187:15, CEO [9] - 254:1, 254:7, 254:11, 255:3,
BLAKELY [3] - 240:18, 240:19, 251:14 187:23, 188:4, 188:11, 189:6, 190:21, 255:12, 255:19, 258:20, 262:2, 262:5
BLAME [1] - 274:9 191:10, 192:19, 193:4, 193:12,
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CERTAIN [2] - 212:21, 238:24 298:12, 298:18, 299:24, 300:14, CLEARLY [1] - 282:18
CERTAINLY [3] - 304:16, 309:22, 310:1 300:17, 300:19, 301:1, 301:16, CLIENT [3] - 237:24, 304:13, 310:15
CERTIFICATION [1] - 266:20 303:10, 304:19, 306:6, 306:10, 307:4, CLOSE [2] - 244:15, 271:12
CERTIFIED [4] - 234:7, 234:9, 266:17, 309:2, 310:19 CLOSED [2] - 204:25, 295:3
266:18 CHAIKEN'S [4] - 256:12, 287:2, 292:15, CLOSING [1] - 301:17
CERTIFY [1] - 312:6 295:20 CLOSINGS [1] - 300:4
CERTIFYING [1] - 211:3 CHALLENGE [1] - 205:16 CM/ECF [2] - 1:3, 1:5
CETERA [6] - 273:19, 273:20, 273:24 CHALLENGING [1] - 205:20 CO [6] - 276:3, 304:23, 305:12, 305:20,
CFO [2] - 254:1, 254:23 CHANGE [5] - 169:3, 169:7, 175:16, 306:1, 306:22
CHAIKEN [22] - 164:2, 204:20, 206:4, 183:4, 183:6 CO-CONSPIRATORS [1] - 276:3
258:7, 260:6, 260:8, 261:7, 272:3, CHANGED [4] - 165:17, 165:18, 172:4, CO-COUNSEL'S [1] - 306:22
274:17, 276:7, 276:17, 284:3, 284:20, 183:10 CO-DEFENDANTS [1] - 305:20
289:15, 289:19, 290:4, 291:12, CHARACTER [1] - 260:18 CO-DEFENDANTS' [3] - 304:23,
291:22, 294:21, 306:5, 309:1, 311:3 CHARGE [1] - 308:12 305:12, 306:1
CHAIKEN [228] - 160:14, 163:4, 163:7, CHARGED [41] - 204:6, 238:25, 239:6, COAST [1] - 297:9
163:17, 164:3, 164:5, 164:12, 164:14, 239:11, 240:5, 240:6, 240:8, 241:6, COLLECTED [2] - 240:12, 240:21
164:20, 164:22, 165:6, 165:8, 165:21, 242:12, 242:23, 242:25, 243:8, COLLECTING [1] - 240:22
165:24, 166:10, 166:11, 167:4, 167:7, 267:25, 275:1, 275:2, 275:13, 284:17, COLLECTIVELY [1] - 298:15
167:15, 167:17, 168:1, 168:2, 168:15, 294:16, 295:8, 304:24, 304:25, 305:3, COLLECTOR [1] - 240:10
168:16, 168:23, 168:24, 169:13, 305:20, 306:12, 306:15, 307:6, 307:7, COLUMN [2] - 225:12, 225:16
169:14, 169:22, 170:8, 170:10, 171:1, 307:11, 307:17, 307:20, 307:22, COLUMNS [1] - 225:12
171:3, 171:7, 171:8, 171:17, 171:19, 307:23, 308:1, 308:13, 308:15, COMCAST [1] - 225:5
172:10, 172:11, 172:16, 172:18, 308:22, 309:14, 309:20 COMFORT [4] - 215:12, 271:13, 271:17,
173:3, 173:4, 173:9, 173:11, 173:22, CHARGES [3] - 261:2, 305:1, 308:18 271:22
173:23, 174:11, 174:13, 174:20, CHARGING [2] - 307:5, 307:13 COMFORTABLE [1] - 220:12
174:22, 175:1, 175:2, 175:10, 175:11, CHARLES [4] - 243:14, 243:15, 246:25, COMING [4] - 253:7, 266:22, 289:4,
175:20, 175:21, 176:3, 176:5, 176:11, 247:1 296:9
176:13, 177:6, 177:8, 178:3, 178:5, CHARMAINE [5] - 245:4, 245:19, COMMENT [1] - 232:19
178:25, 179:1, 179:9, 179:11, 179:20, 245:20, 279:1, 308:10 COMMISSIONER [1] - 211:1
179:21, 180:5, 180:6, 180:13, 180:14, CHARMAINE'S [1] - 279:10 COMMUNICATE [9] - 189:20, 246:6,
181:6, 181:7, 181:15, 181:17, 182:7, CHATS [1] - 273:11 246:7, 247:7, 247:16, 274:4, 307:18,
182:8, 182:20, 182:22, 183:13, CHECK [19] - 174:5, 192:20, 193:8, 307:19, 308:4
183:14, 183:22, 183:23, 184:5, 184:6, 195:2, 195:20, 196:13, 197:5, 197:6, COMMUNICATED [3] - 246:8, 247:24,
184:9, 184:11, 184:17, 184:18, 197:11, 212:20, 232:16, 234:18, 306:12
184:25, 185:2, 185:15, 185:18, 186:4, 235:2, 235:5, 235:8, 235:17, 236:12, COMMUNICATING [35] - 168:10,
186:5, 186:12, 186:13, 186:18, 236:22, 237:1 169:10, 177:18, 181:12, 182:18,
186:19, 186:23, 186:25, 187:14, CHECKLIST [1] - 240:11 189:16, 191:24, 207:12, 233:5,
187:15, 187:22, 187:23, 188:3, 188:4, CHECKS [6] - 199:11, 234:7, 234:10, 239:23, 240:1, 240:3, 245:23, 246:20,
188:9, 188:11, 189:2, 189:4, 189:6, 234:14, 235:11 246:21, 247:4, 247:5, 247:19, 248:5,
190:14, 190:19, 190:21, 191:9, CHOICE [1] - 213:8 248:6, 249:12, 249:14, 266:21,
191:10, 192:15, 192:18, 192:19, CHOSE [2] - 209:16, 307:12 272:12, 273:1, 273:2, 273:4, 274:3,
193:3, 193:4, 193:10, 193:12, 193:16, CHRISTIAN [26] - 243:2, 243:3, 246:21, 277:20, 277:21, 277:24, 278:24,
193:18, 194:4, 194:13, 194:18, 249:13, 279:22, 281:21, 281:23, 279:5, 308:8, 308:10
194:21, 194:24, 195:5, 195:7, 195:15, 284:14, 284:21, 284:22, 286:16, COMMUNICATION [14] - 183:20,
195:16, 196:2, 196:3, 196:19, 196:22, 287:12, 288:16, 288:20, 288:21, 185:24, 190:1, 190:8, 241:11, 243:18,
197:2, 197:4, 197:16, 197:18, 198:6, 292:2, 292:3, 292:6, 292:9, 292:12, 244:1, 244:10, 245:12, 246:10,
198:10, 198:17, 198:20, 199:24, 294:16, 295:3, 295:5, 295:8, 295:12, 247:11, 263:10, 268:6, 272:24
200:5, 201:6, 201:9, 202:9, 202:16, 308:9 COMMUNICATIONS [19] - 188:20,
202:17, 203:20, 203:22, 204:1, CHRISTIAN [1] - 291:18 206:18, 229:13, 233:8, 233:13, 235:1,
204:21, 205:4, 205:12, 206:8, 206:14, CIRCLE [1] - 279:12 235:4, 236:5, 236:24, 246:22, 247:9,
206:16, 206:17, 207:9, 207:11, CIRCLES [1] - 205:11 247:20, 249:8, 249:16, 250:8, 250:9,
207:22, 207:25, 208:10, 208:12,
CIRCUIT [2] - 259:6, 305:9 250:10, 267:24, 307:24
208:23, 208:25, 209:3, 209:5, 209:7,
CITATIONS [1] - 310:24 COMPANIES [11] - 199:6, 200:12,
252:22, 256:3, 256:13, 258:3, 258:9,
CITE [1] - 1:5 213:9, 213:11, 213:13, 214:19,
258:19, 259:4, 260:3, 260:9, 260:16,
CITED [1] - 305:14 214:22, 251:22, 251:25, 252:9
261:9, 263:6, 265:16, 271:4, 271:8,
CITY [1] - 225:15 COMPANY [12] - 173:19, 199:1, 199:6,
274:19, 280:19, 281:6, 282:8, 284:4,
CLAUSE [2] - 305:11, 308:24 199:9, 199:19, 231:16, 231:20,
284:23, 285:2, 285:9, 285:14, 286:7,
CLEAR [12] - 191:7, 214:15, 265:21, 231:21, 234:23, 242:22, 251:16,
286:14, 288:13, 291:25, 292:10,
281:11, 294:23, 295:24, 302:20, 251:19
294:22, 297:4, 297:23, 298:3, 298:5,
305:10, 305:11, 305:17, 306:1, 310:19 COMPLETE [1] - 290:17
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COMPLETELY [2] - 271:11, 274:21 207:5, 214:16, 216:12, 216:13, 282:15, 282:23, 283:6, 283:13,
COMPLEXES [1] - 262:9 216:25, 217:9, 217:13, 217:16, 283:22, 283:24, 284:3, 284:5, 284:8,
COMPUTERS [3] - 217:16, 217:18, 217:18, 217:22, 218:2, 218:5, 218:14, 284:12, 284:19, 284:24, 285:6,
218:7 218:20, 218:21, 218:24, 219:11, 285:12, 286:5, 286:12, 286:18,
CONCEDING [1] - 292:7 220:20, 221:8, 222:1, 222:11, 222:12, 286:22, 287:1, 287:22, 288:4, 289:11,
CONCERNED [1] - 296:10 222:21, 222:22, 223:20, 224:8, 289:25, 290:2, 290:12, 290:20, 291:1,
CONCERTED [1] - 274:23 225:17, 226:13, 226:16, 226:18, 291:6, 291:9, 291:17, 291:22, 292:5,
CONDUCT [1] - 212:16 226:19, 226:22, 227:3, 227:4, 227:5, 292:13, 293:8, 293:10, 293:17,
CONDUCTED [3] - 268:11, 294:24, 229:8, 230:11, 230:18, 230:19, 293:20, 293:22, 294:3, 294:6, 294:9,
294:25 231:16, 232:21, 232:22, 232:24, 294:21, 295:17, 296:1, 296:3, 296:19,
CONFERENCE [2] - 304:21, 307:1 233:10, 233:16, 233:20, 234:16, 297:2, 297:14, 297:21, 298:9, 298:16,
CONFIRM [3] - 267:22, 279:7, 280:10 235:11, 236:2, 236:3, 241:15, 241:18, 298:21, 299:4, 299:13, 300:7, 300:16,
CONFLICT [2] - 163:8, 296:18 241:23, 241:24, 242:13, 242:14, 300:18, 300:20, 301:10, 301:13,
CONFORMITY [1] - 260:17 245:8, 248:14, 249:7, 249:21, 249:24, 301:22, 302:2, 302:4, 302:19, 303:1,
CONFRONT [1] - 278:11 250:13, 250:15, 251:15, 251:17, 303:3, 303:22, 304:8, 304:10, 304:16,
251:24, 252:10, 253:18, 253:19, 306:3, 306:18, 306:24, 308:12, 309:1,
CONFRONTATION [2] - 305:10, 308:24
254:18, 254:20, 254:23, 254:24, 310:6, 310:11, 310:22, 311:1, 312:3,
CONFRONTED [2] - 273:6, 275:6
254:25, 255:4, 255:18, 255:21, 259:4, 312:15
CONSENTS [1] - 163:13
261:19, 261:21, 262:2, 263:11, COURT [5] - 210:23, 210:24, 210:25,
CONSEQUENCES [1] - 208:21
263:20, 264:14, 265:22, 266:4, 220:20, 289:4
CONSIDER [3] - 240:23, 308:17, 310:1
266:12, 266:13, 266:17, 268:17, COURT [5] - 163:11, 275:13, 287:16,
CONSIDERATION [1] - 307:8
269:12, 269:16, 270:9, 270:10, 305:17, 309:23
CONSIDERED [3] - 212:8, 240:25,
270:20, 277:15, 277:18, 277:20, COURTHOUSE [2] - 163:18, 164:1
310:3
278:9, 278:21, 278:22, 279:6, 279:14, COURTROOM [10] - 163:20, 194:23,
CONSIDERING [1] - 308:19
279:18, 279:21, 281:25, 292:9, 215:23, 231:7, 271:20, 272:17, 277:8,
CONSISTENT [2] - 197:13, 275:12
292:18, 293:4, 302:24, 302:25, 303:1, 283:5, 283:10, 283:12
CONSPIRACIES [1] - 204:6 306:5, 312:7 COVERS [1] - 204:4
CONSPIRACY [1] - 309:16 CORRECTED [1] - 178:15 CREATED [2] - 167:24, 258:20
CONSPIRATORS [1] - 276:3 CORRECTLY [1] - 244:14 CREATING [1] - 190:12
CONSPIRING [2] - 284:17, 308:1 CORRESPONDED [2] - 245:7, 245:10 CREATION [1] - 202:25
CONSTITUTIONAL [1] - 308:24 COUDRIET [2] - 160:24, 312:15 CREATIONS [2] - 213:1, 241:10
CONSTRUCTION [2] - 237:8, 262:5 COUNSEL [2] - 209:24, 304:11 CREDIT [1] - 259:17
CONSULTING [5] - 195:3, 195:9, COUNSEL [5] - 163:10, 237:16, 269:1, CRIME [2] - 294:17, 307:20
195:18, 196:16, 197:6 298:21, 310:17 CRIMES [1] - 275:1
CONT'D)................232 [1] - 162:5 COUNSEL'S [1] - 306:22 CROMER [2] - 218:22, 223:2
CONTACT [2] - 179:17, 236:6 COUNT [2] - 239:12, 294:16 CROSS [14] - 163:11, 209:15, 209:20,
CONTENTS [1] - 282:6 COUNTS [1] - 307:23 215:3, 215:17, 276:25, 297:21,
CONTINUE [2] - 192:4, 207:12 COUPLE [6] - 214:18, 216:21, 220:22, 298:13, 298:22, 298:24, 298:25,
CONTINUED [8] - 192:1, 204:23, 205:5, 226:7, 293:2, 293:24 299:12, 300:8, 301:3
205:13, 215:15, 262:7, 272:1, 311:15 COURSE [8] - 199:2, 209:4, 212:1, CROSS [2] - 216:4, 238:20
CONTINUING [3] - 174:16, 213:4, 213:25, 260:25, 286:1, 293:8, 294:1 CROSS-EXAMINATION [4] - 209:20,
246:16 COURT [168] - 1:4, 1:7, 1:10, 160:1, 215:3, 215:17, 300:8
CONTRACTS [1] - 222:2 160:24, 160:25, 163:1, 163:2, 163:5, CROSS-EXAMINATION [2] - 216:4,
CONTROLLED [1] - 252:3 163:16, 163:19, 163:21, 163:23, 238:20
CONVERSATION [4] - 168:3, 196:24, 170:4, 170:7, 190:18, 194:9, 194:11, CROSS-EXAMINE [1] - 209:15
272:15, 290:13 194:14, 194:20, 194:22, 195:1, 197:1, CROSSING [2] - 299:15, 301:4
CONVERSATIONS [1] - 192:25 200:4, 202:15, 204:7, 204:9, 204:17, CRR [2] - 160:24, 312:15
CONVINCED [1] - 206:4 204:20, 204:25, 205:10, 205:19, CURIOUS [1] - 217:23
COOPER [3] - 166:3, 166:6, 166:8 206:2, 206:11, 206:15, 209:2, 209:4, CURRENT [1] - 210:23
COORDINATOR [3] - 210:23, 210:24, 209:9, 209:24, 210:2, 210:5, 210:7, CURSE [1] - 190:11
210:25 210:9, 215:3, 215:7, 215:11, 215:19, CUSTODIAL [1] - 211:2
COPIED [1] - 229:25 215:21, 215:24, 231:6, 238:18, CUSTOM [1] - 184:21
COPIES [1] - 188:16 252:24, 256:5, 256:11, 256:14,
CUSTOMS [6] - 183:12, 183:18, 184:14,
COPY [7] - 206:12, 258:5, 261:13, 256:18, 256:22, 258:5, 258:7, 258:17,
213:5, 245:5, 247:15
285:1, 285:19, 285:23, 308:14 259:2, 259:11, 259:24, 260:2, 260:5,
CUT [3] - 256:11, 263:14, 276:16
CORNER [2] - 185:17, 253:23 260:13, 261:7, 261:11, 261:14, 263:7,
CUTS [1] - 213:8
CORP [1] - 185:22 265:17, 271:12, 271:21, 272:2,
CUTTING [1] - 199:11
CORPORATE [1] - 199:1 272:16, 272:18, 272:20, 273:15,
CORPORATION [2] - 199:16, 249:2 274:11, 274:17, 276:6, 277:3, 277:6,
CORRECT [117] - 185:11, 189:1, 204:19, 277:9, 280:24, 281:10, 281:14,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 160 of 174
318
D DECLARANT'S [1] - 289:4 DIRECTION [1] - 294:24
DEE [5] - 244:15, 247:5, 247:6, 247:8 DIRECTLY [8] - 168:10, 169:10, 191:24,
DAILY [1] - 192:9 DEFENDANT [2] - 160:17, 160:20 246:22, 247:10, 259:21, 307:16, 308:8
DARRELL [154] - 164:17, 165:9, 166:2, DEFENDANT [1] - 295:5 DIRECTOR [1] - 206:9
167:8, 168:5, 168:9, 168:12, 168:19, DEFENDANT'S [2] - 262:20, 263:4 DISAGREE [1] - 264:8
169:10, 170:11, 170:14, 170:24, DEFENDANT'S [1] - 295:4 DISCOVERY [2] - 290:23, 290:25
171:11, 172:14, 173:6, 173:24, 174:2, DISCUSS [3] - 229:18, 263:25, 271:14
DEFENDANTS [3] - 302:4, 304:17,
175:5, 175:23, 176:7, 177:9, 177:17,
305:20 DISCUSSED [2] - 163:10, 266:8
178:8, 178:18, 179:7, 179:12, 179:22,
DEFENDANTS [1] - 160:8 DISCUSSES [1] - 266:11
180:16, 181:2, 181:10, 181:12,
DEFENDANTS' [3] - 304:23, 305:12, DISCUSSING [4] - 229:19, 251:21,
181:18, 182:12, 182:18, 182:24,
306:1 266:7, 296:5
183:2, 183:17, 183:19, 184:12,
DEFENSE [15] - 163:10, 205:16, 209:14, DISCUSSION [2] - 163:22, 215:22
184:20, 185:8, 185:19, 185:23, 186:7,
259:19, 259:20, 273:10, 295:7, DISSOLVED [2] - 255:22, 255:23
186:21, 187:18, 188:7, 188:20, 189:8,
298:21, 300:3, 302:4, 304:22, 307:12, DISTANCE [1] - 309:14
189:11, 189:16, 189:23, 189:24,
309:7, 309:10, 310:4 DISTRIBUTE [2] - 200:8, 200:11
190:4, 190:6, 190:9, 190:22, 191:4,
DEFENSES [1] - 301:18 DISTRIBUTED [1] - 200:15
191:11, 191:19, 191:24, 192:1, 192:8,
DEFINITELY [3] - 194:17, 220:15, DISTRICT [6] - 160:1, 160:1, 160:10,
192:13, 198:4, 198:21, 199:15,
255:19 160:25, 312:3, 312:4
199:19, 204:15, 208:6, 208:17, 217:5,
DELIGHTFUL [1] - 163:25 DIVISION [1] - 160:2
217:20, 239:15, 239:17, 241:11,
DENESSERIA [1] - 244:13 DIVISIONS [1] - 262:4
241:17, 243:4, 243:16, 243:23,
DENIED [2] - 278:23, 280:4 DIVORCE [1] - 223:24
244:17, 245:8, 245:10, 246:1, 246:23,
247:7, 247:10, 247:19, 247:20, DEPOSIT [9] - 193:8, 199:7, 228:18, DIXON [34] - 244:23, 244:24, 245:7,
247:23, 248:5, 248:12, 248:22, 229:2, 229:14, 229:19, 232:8, 233:8, 245:10, 245:15, 245:23, 246:7, 246:9,
248:23, 249:1, 249:8, 249:17, 249:25, 233:12 247:17, 264:4, 265:1, 265:5, 265:24,
250:10, 251:10, 251:13, 252:3, DEPOSITED [5] - 195:20, 195:23, 266:14, 266:21, 267:24, 268:8,
253:18, 254:3, 254:22, 255:6, 255:17, 197:11, 232:16, 279:25 269:15, 270:22, 271:6, 271:9, 271:10,
256:8, 257:23, 258:12, 258:13, DEPOSITS [5] - 200:13, 228:22, 232:14, 272:7, 272:8, 272:11, 272:21, 273:6,
258:24, 259:13, 261:21, 264:6, 264:7, 232:15, 234:13 274:6, 274:20, 275:6, 277:15, 278:23,
264:10, 264:25, 265:5, 265:22, 266:8, DEREK [6] - 179:18, 245:3, 246:3, 308:5, 308:9
266:15, 266:21, 267:1, 267:4, 267:7, 246:8, 246:12 DL [1] - 174:5
267:25, 268:6, 268:9, 273:3, 273:4, DESCRIBE [4] - 190:3, 190:25, 239:16, DOCKET [2] - 1:6, 160:5
273:7, 273:8, 274:3, 274:10, 275:16, 239:21 DOCUMENT [36] - 167:8, 167:11,
275:22, 277:20, 278:24, 279:5, 305:2, DESCRIBING [1] - 191:2 167:12, 169:20, 180:16, 180:18,
306:13, 306:14, 307:16, 307:18, DESCRIPTION [1] - 198:14 182:14, 183:1, 199:14, 204:12,
307:19, 308:4, 308:8, 309:7, 309:14, DESKTOP [2] - 217:16, 218:7 206:12, 213:17, 213:18, 214:1, 214:6,
309:17, 309:18, 310:5 DESPITE [1] - 307:13 214:9, 227:19, 231:10, 234:17, 253:3,
DARRELL'S [2] - 250:21, 251:16 DETAILS [1] - 220:23 253:13, 254:15, 256:12, 258:5,
DATA [1] - 212:5 DETERMINE [5] - 191:23, 199:2, 258:17, 261:25, 262:22, 263:10,
DATE [27] - 166:24, 168:7, 170:17, 231:12, 307:10, 309:24 263:12, 266:14, 282:12, 282:14,
170:19, 177:1, 177:23, 178:16, 182:9, DEVELOP [1] - 262:7 290:8, 290:16, 290:24, 291:17
184:7, 189:14, 195:23, 198:11, DEVELOPER [1] - 262:2 DOCUMENT [1] - 1:10
198:14, 204:11, 204:16, 206:21, DEVELOPMENT [1] - 262:5 DOCUMENT'S [1] - 256:16
224:2, 224:6, 226:6, 228:4, 228:9, DEVICES [7] - 217:10, 217:11, 217:18, DOCUMENTATION [1] - 221:3
231:12, 231:13, 253:24, 253:25 217:25, 218:10, 218:11, 218:13 DOCUMENTS [28] - 165:15, 170:20,
DATED [1] - 228:25 DICTATE [1] - 248:6 172:3, 172:4, 175:15, 179:7, 181:3,
DATES [7] - 203:9, 204:6, 204:10, DIFFERENCE [1] - 190:1 183:9, 185:10, 187:8, 188:24, 188:25,
224:24, 226:5, 226:10, 231:18 DIFFERENT [23] - 169:17, 173:18, 195:1, 213:20, 213:22, 214:16, 221:5,
DAVID [2] - 246:15, 246:16 173:20, 182:2, 182:4, 182:5, 198:14, 240:10, 240:20, 240:22, 243:12,
DAVID [1] - 160:20 200:9, 209:19, 224:13, 228:11, 252:16, 257:17, 257:22, 258:23,
DAYS [2] - 182:14, 223:1 232:24, 282:9, 284:6, 284:7, 285:4, 261:1, 265:11, 295:3
DAYS [1] - 1:5 286:20, 288:1, 288:22, 293:24, DOG [1] - 306:21
DEBATE [2] - 271:23, 296:8 300:22, 306:25, 310:16 DOLLARS [1] - 208:9
DEBIT [2] - 199:8, 199:12 DIFFERENTLY [1] - 191:19 DONE [10] - 217:20, 219:14, 220:2,
DECEMBER [3] - 176:19, 176:21, DIGITAL [1] - 217:18 230:7, 285:3, 286:11, 296:14, 297:5,
254:16 DIRE [1] - 162:4 297:10, 301:9
DECENT [2] - 215:11, 245:12 DIRECT [7] - 163:11, 185:24, 209:14, DOOR [6] - 220:8, 221:9, 222:18,
DECIDE [2] - 276:22, 299:14 221:21, 241:11, 248:7, 297:19 304:22, 305:23, 309:4
DECIDED [1] - 295:11 DIRECT [4] - 162:4, 162:5, 164:4, DOOR'S [1] - 305:6
DECISIONS [2] - 307:6, 307:13 210:15 DOT [1] - 199:16
DIRECTED [3] - 221:18, 258:12, 306:4 DOUBLE [1] - 292:18
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DOUBT [1] - 275:22 EFFORTS [3] - 273:12, 274:9, 282:22 244:10, 246:10, 246:22, 247:18,
DOWN [36] - 166:10, 174:8, 174:11, EIN [4] - 165:19, 167:14, 174:5, 179:19 256:17, 259:14, 259:22, 260:1,
179:4, 180:15, 186:24, 191:9, 193:10, EITHER [6] - 194:14, 217:24, 228:16, 260:12, 260:17, 273:12, 274:21,
201:7, 207:9, 209:22, 215:7, 225:17, 265:18, 294:12, 310:7 275:9, 275:18, 275:20, 293:7, 293:12,
227:24, 228:15, 230:2, 230:9, 232:8, EL [2] - 249:3, 249:5 294:15, 295:7, 306:6
233:21, 233:24, 234:9, 234:10, ELEVENTH [2] - 259:5, 305:9 EXACT [2] - 213:13, 224:6
235:20, 235:21, 236:17, 272:7, ELITE [4] - 197:19, 197:22, 198:4, EXACTLY [9] - 180:12, 240:7, 240:8,
272:16, 276:13, 276:14, 281:4, 200:17 244:22, 260:19, 285:18, 291:3,
283:14, 283:18, 290:18, 290:19, ELMO [1] - 253:1 293:12, 305:4
296:9, 312:7 EMBEDDED [1] - 166:12 EXAMINATION [5] - 162:5, 164:4,
DR [1] - 297:22 EMPLOYEE [5] - 173:20, 173:21, 210:15, 216:4, 238:20
DRAW [1] - 301:21 240:23, 295:9, 300:18 EXAMINATION [6] - 209:14, 209:20,
DUE [1] - 308:24 EMPLOYEES [5] - 166:16, 199:8, 215:3, 215:17, 298:19, 300:8
DULUTH [1] - 255:7 199:11, 212:9, 266:7 EXAMINATION.........................142 [1] -
DULY [1] - 210:12 EMPLOYEES' [2] - 199:12, 211:12 162:4
DURING [19] - 192:5, 199:2, 205:7, EMPLOYER [1] - 211:11 EXAMINATION......................218 [1] -
205:14, 207:6, 207:16, 212:20, 218:5, EMPLOYERS [1] - 211:20 162:4
220:19, 222:7, 225:1, 237:9, 237:17, END [8] - 176:20, 278:21, 294:23, EXAMINE [1] - 209:15
238:2, 252:5, 255:6, 261:2, 269:23, 295:14, 296:25, 299:18, 301:8, 303:7 EXAMINED [1] - 210:13
281:19 ENDED [5] - 166:22, 167:2, 177:4, EXAMPLE [2] - 268:4, 279:22
DURRETT [2] - 160:18, 215:4 273:9, 294:16 EXAMPLES [2] - 273:25, 274:1
DUTIES [1] - 282:2 ENDING [3] - 180:20, 235:25, 236:19 EXCEPT [2] - 173:19, 301:14
DWAN [3] - 248:17, 248:18, 255:11 ENGAGED [1] - 258:24 EXCHANGING [1] - 181:3
DWIGHT [2] - 237:21, 237:23 ENJOYING [1] - 163:25 EXCLUSIVE [5] - 195:3, 195:8, 195:17,
ENTERED [7] - 163:20, 215:23, 232:6, 196:16, 197:6
E 232:20, 234:13, 234:25, 277:8 EXCLUSIVELY [1] - 273:2
ENTERPRISE [1] - 234:21 EXCUSED [3] - 209:23, 215:10, 272:14
E-MAIL [70] - 164:16, 164:23, 166:1,
ENTIRE [3] - 281:3, 286:2, 301:24 EXECUTED [1] - 216:25
166:12, 167:18, 168:18, 168:20,
ENTIRELY [3] - 209:19, 259:19, 303:20 EXECUTIVE [4] - 197:19, 197:22, 198:5,
171:10, 171:15, 171:21, 172:13,
ENTIRETY [4] - 282:21, 287:21, 291:20, 200:17
172:20, 173:6, 173:13, 175:4, 175:7,
293:25 EXHIBIT [15] - 168:17, 174:25, 191:2,
175:13, 175:23, 176:1, 176:7, 177:23,
ENTITLED [2] - 294:18, 308:1 204:4, 224:17, 225:1, 227:11, 227:14,
178:7, 179:22, 181:9, 182:9, 182:14,
ENTRIES [1] - 226:3 228:22, 232:6, 234:2, 234:4, 258:10,
182:15, 182:17, 183:16, 183:24,
ENTRY [3] - 230:10, 230:12 261:3, 289:25
184:7, 184:20, 185:3, 186:7, 186:14,
ENTRY [1] - 1:6 EXHIBIT [28] - 164:13, 165:22, 165:25,
186:21, 187:1, 187:17, 187:24, 188:6,
EQUIPMENT [1] - 264:1 183:15, 192:17, 195:6, 196:20,
188:12, 229:13, 229:16, 229:18,
EQUIVALENT [1] - 259:8 196:21, 197:3, 197:17, 201:7, 202:1,
229:21, 229:23, 229:25, 232:23,
ESPECIALLY [3] - 226:24, 258:15, 202:10, 203:21, 204:2, 207:24,
233:3, 233:11, 235:1, 236:4, 241:2,
273:5 208:11, 208:24, 223:23, 224:15,
241:3, 241:17, 241:20, 241:25, 242:3,
ESQ [6] - 160:14, 160:15, 160:15, 227:8, 228:14, 233:24, 239:3, 252:12,
242:6, 249:17, 259:21, 261:16,
160:18, 160:18, 160:20 252:21, 262:21, 263:4
262:24, 263:22, 264:25, 265:5,
ESTABLISH [3] - 260:22, 281:16, EXHIBITS [4] - 194:5, 199:25, 201:25,
265:21, 268:5, 276:1
288:21 264:16
E-MAILS [21] - 191:23, 229:11, 229:17,
ESTABLISHED [3] - 225:4, 285:12, EXIST [1] - 293:18
233:7, 241:14, 242:9, 245:12, 246:2,
249:16, 249:19, 250:12, 257:7, 257:8, 286:9 EXITED [4] - 271:20, 272:17, 283:5,
257:24, 261:1, 263:1, 263:24, 263:25, ESTATE [6] - 220:24, 221:5, 221:12, 283:12
268:8, 273:11, 275:24 221:23, 237:7, 262:1 EXOTIC [6] - 183:12, 183:18, 184:21,
EARLIEST [1] - 206:21 ESTIMATE [2] - 297:16, 298:14 213:4, 245:5, 247:15
EASIER [1] - 263:12 ESTIMATED [1] - 301:1 EXPAND [1] - 258:7
EASLEY [1] - 305:16 ET [6] - 273:19, 273:20, 273:24 EXPECT [2] - 207:16, 214:8
EDUCATION [12] - 164:7, 165:18, ETA [1] - 184:14 EXPERT [6] - 299:1, 300:15, 300:16,
165:20, 166:16, 167:13, 167:21, EVENING [5] - 277:1, 283:1, 283:4, 301:7, 302:8, 302:12
168:21, 170:20, 171:23, 213:6, 247:2, 304:11, 311:13 EXPERTISE [1] - 262:8
247:3 EVENT [1] - 309:5 EXPERTS [1] - 298:22
EDWARD [3] - 245:3, 264:15, 265:7 EVENTS [2] - 271:1, 271:3 EXPLAIN [2] - 181:3, 210:24
EFFECT [7] - 223:9, 294:13, 294:19, EVENTUALLY [1] - 276:16 EXPLANATION [1] - 260:10
295:14, 295:19, 295:22, 295:25 EVIDENCE [1] - 283:19 EXTENDS [1] - 204:5
EFFECTIVE [1] - 231:13 EVIDENCE [28] - 191:22, 216:9, 223:22, EXTENT [3] - 272:4, 276:8, 303:7
EFFORT [3] - 217:24, 218:13, 274:23 224:18, 229:11, 232:6, 243:18, 244:1, EXTRA [2] - 233:21, 297:20
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281:7, 287:24, 288:15, 290:15, 273:13, 273:16, 273:18, 273:19,
F
290:17, 291:4, 291:20, 293:25, 295:9, 274:3, 274:4, 274:10, 274:20, 274:23,
F19 [2] - 257:10, 257:12 302:7, 303:22, 304:23, 307:21, 309:2 275:10, 276:5, 277:24, 279:9, 280:8,
F19A [1] - 257:10 FIRSTHAND [1] - 280:22 280:15, 284:17, 286:16, 287:18,
F20A [1] - 265:15 FIVE [10] - 296:6, 297:6, 297:8, 298:10, 287:24, 288:9, 291:15, 294:17, 295:8,
F20C [1] - 266:14 298:12, 298:17, 298:22, 299:5, 300:9, 295:9, 295:11, 307:23, 308:6, 308:11,
F20D [1] - 265:15 302:8 308:20, 309:24
F408 [1] - 263:5 FIX [1] - 177:20 FOSTER'S [13] - 164:23, 190:4, 194:2,
FACT [13] - 205:4, 205:20, 211:3, 230:9, FLIGHT [1] - 163:9 203:5, 203:9, 207:3, 207:16, 239:11,
239:11, 277:23, 278:10, 283:9, 289:3, FLOOR [1] - 164:2 241:25, 249:17, 259:20, 309:7, 310:17
295:15, 304:24, 310:20 FLOW [1] - 248:7 FOUNDATION [3] - 295:13, 295:18,
FAILING [1] - 255:24 FNU [1] - 280:15 295:22
FAIR [3] - 292:15, 296:12, 298:2 FOLKS [1] - 282:24 FOUNDER [1] - 233:18
FAIRLY [1] - 304:6 FOLLOW [5] - 172:2, 187:7, 188:23, FOUNDING [1] - 230:23
FAKE [4] - 243:11, 258:20, 275:22 256:7, 306:22 FOUR [4] - 177:24, 182:14, 211:14,
FALSE [1] - 287:12 FOLLOW-UP [1] - 256:7 299:9
FALSELY [11] - 271:6, 275:16, 305:2, FOLLOWED [3] - 302:7, 302:8, 302:9 FOURTH [5] - 176:17, 176:20, 177:15,
305:3, 305:20, 308:5, 309:9, 309:11, FOLLOWING [1] - 193:20 178:14, 180:8
309:18, 310:5 FOLLOWING [1] - 1:2 FRAME [7] - 202:21, 206:24, 207:2,
FAMILIAR [5] - 211:5, 211:8, 211:16, FOLLOWS [4] - 210:13, 215:15, 272:1, 207:6, 256:4, 274:23, 275:11
211:24, 278:2 311:15 FRAMED [1] - 275:12
FAR [9] - 258:12, 276:13, 276:14, FOR [2] - 1:5, 160:1 FRAUD [4] - 256:9, 261:4, 279:5, 291:16
276:20, 276:22, 283:8, 284:19, FOREGOING [1] - 312:6 FRAUDULENT [4] - 239:18, 248:22,
286:19, 298:16 FORM [6] - 166:24, 175:18, 211:11, 258:25, 280:5
FARGO [5] - 224:22, 224:23, 226:4, 211:19, 290:25 FREE [1] - 231:6
227:2, 234:6 FORM [12] - 166:15, 169:15, 171:23, FROM [1] - 1:9
FBI [4] - 218:23, 220:5, 220:7, 300:19 172:23, 178:14, 178:20, 180:8, 185:6, FRONT [8] - 174:5, 191:2, 201:23,
FEBRUARY [1] - 160:11 188:14, 211:8, 211:16, 211:19 220:8, 221:9, 222:18, 252:11, 257:11
FEBRUARY [3] - 180:20, 311:15, 312:9 FORMED [2] - 231:1, 231:12 FULL [3] - 190:5, 190:7, 190:12
FEDERAL [2] - 197:11, 197:13 FORMS [10] - 165:4, 168:5, 168:13, FULL [1] - 1:9
FEDERAL [3] - 164:1, 211:20, 275:1 172:25, 176:6, 176:9, 180:10, 186:16, FUND [1] - 211:20
FEW [6] - 178:10, 184:22, 208:25, 187:3, 212:21 FUNDING [2] - 200:11, 200:13
209:3, 214:16, 304:4 FORTH [3] - 213:14, 217:3, 233:9 FUNDS [6] - 199:7, 200:8, 248:5,
FIGHT [1] - 306:22 FORWARD [2] - 164:18, 166:3 251:25, 266:23, 279:25
FIGURE [1] - 290:9 FOSTER [2] - 160:7, 160:17
FIGURED [3] - 226:23, 283:2, 291:15 FOSTER [144] - 164:16, 164:18, 164:19, G
FILE [3] - 211:20, 212:9, 213:11 165:9, 166:1, 166:3, 166:5, 166:8,
GAINES [45] - 173:16, 181:22, 197:23,
FILED [3] - 1:3, 1:8, 1:10 167:9, 167:24, 168:6, 168:10, 168:14,
200:16, 213:2, 222:5, 222:7, 222:9,
FILED [15] - 211:6, 211:11, 211:14, 168:18, 169:1, 169:4, 169:9, 170:12,
222:18, 222:21, 223:7, 223:8, 223:12,
212:21, 213:12, 213:18, 214:6, 170:22, 171:10, 172:13, 173:6,
223:16, 226:21, 226:25, 227:4,
214:16, 214:21, 214:24, 224:4, 173:25, 174:3, 175:4, 175:23, 177:13,
228:12, 229:7, 229:9, 230:8, 230:9,
254:16, 307:5, 309:10 177:18, 177:20, 178:7, 178:18,
230:15, 231:15, 231:25, 233:14,
FILING [2] - 253:23, 253:25 179:12, 180:16, 181:2, 181:9, 181:12,
233:15, 233:16, 233:18, 234:24,
FILINGS [1] - 213:13 182:17, 183:16, 183:19, 184:12,
235:1, 235:2, 235:4, 235:23, 236:6,
FINALLY [1] - 187:11 184:20, 185:9, 185:19, 185:25,
236:21, 236:25, 238:4, 242:12,
FINANCE [4] - 291:8, 291:11, 291:14, 186:21, 188:6, 188:21, 189:8, 189:11,
242:16, 242:17, 242:18, 242:20,
295:9 189:17, 189:20, 189:21, 189:24,
242:21
FINE [14] - 163:16, 215:19, 215:20, 189:25, 190:9, 190:23, 191:11,
GATHERING [1] - 211:2
228:13, 233:24, 233:25, 241:8, 191:17, 191:20, 191:24, 191:25,
GAUGE [1] - 277:1
256:21, 264:22, 284:20, 289:1, 192:8, 192:12, 192:21, 193:5, 193:19,
GEICO [1] - 230:12
289:20, 302:11, 303:11 195:12, 196:15, 197:5, 198:22,
GENA [31] - 167:24, 168:10, 169:9,
FINGER [2] - 273:13, 275:4 199:15, 201:17, 201:18, 201:20,
170:11, 170:22, 177:18, 177:20,
FINISH [8] - 277:2, 296:24, 299:14, 202:8, 202:19, 203:1, 203:18, 203:19,
181:11, 182:17, 183:19, 185:24,
300:1, 300:8, 301:4, 302:5, 302:21 203:24, 204:22, 205:12, 206:19,
189:11, 189:17, 189:25, 190:4,
FINISHING [1] - 299:12 207:6, 207:7, 207:15, 207:17, 207:19,
190:23, 191:6, 191:11, 191:19,
FIRST [34] - 166:15, 166:19, 170:14, 208:1, 208:13, 208:19, 243:19, 244:2,
191:24, 194:1, 195:12, 201:18,
175:8, 176:12, 204:10, 206:11, 244:11, 246:11, 246:12, 248:15,
203:18, 204:22, 206:19, 207:6,
206:13, 210:12, 215:17, 222:8, 249:14, 249:19, 249:23, 250:18,
207:15, 207:17, 267:2, 267:7
227:10, 228:6, 251:19, 251:20, 260:19, 267:2, 270:9, 271:7, 271:10,
GENERAL [1] - 232:19
265:21, 271:23, 274:12, 280:15, 271:11, 272:24, 273:2, 273:11,
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GENERALLY [6] - 212:17, 226:10, 305:21, 306:1, 306:15, 308:20, 263:6, 271:4, 271:5, 271:8, 272:22,
237:5, 263:25, 285:16, 307:8 308:22, 309:4, 310:3, 310:21 273:23, 274:19, 277:12, 280:19,
GENTLEMEN [6] - 163:24, 194:16, GUY [1] - 239:17 281:6, 282:8, 282:17, 284:4, 284:23,
209:10, 216:3, 271:16, 282:25 285:2, 287:9, 288:13, 290:10, 291:5,
GEORGIA [4] - 252:5, 252:17, 255:8, H 291:25, 294:10, 294:22, 296:2,
255:23 296:22, 297:4, 297:23, 297:24,
H-A-Z-E-L [1] - 210:19
GEORGIA [4] - 160:1, 160:25, 163:1, 299:24, 300:14, 300:21, 301:1,
HADJ [2] - 249:3, 249:5 301:16, 302:16, 304:19, 305:8, 306:4,
312:4
HALF [4] - 176:12, 297:19 307:4, 307:21, 309:2, 310:10, 310:19,
GIVEN [4] - 209:11, 258:17, 258:21,
HAND [7] - 189:24, 189:25, 221:10, 310:23
307:1
226:5, 244:21, 263:12, 290:8 HONORABLE [1] - 160:10
GMAIL [2] - 241:23, 264:25
HANDLE [1] - 297:15 HOPE [1] - 163:24
GODADDY [2] - 257:23, 262:23
HANDWRITTEN [1] - 236:18 HOPEFULLY [1] - 301:8
GOOGLE [2] - 265:12, 265:13
HAPPY [3] - 281:4, 295:18, 309:22 HOTMAIL [1] - 265:1
GOTCHA [1] - 267:23
HARD [2] - 206:12, 302:14 HOUR [7] - 297:19, 299:1, 299:8, 304:5
GOVERNMENT [17] - 164:12, 165:21,
HAS [1] - 1:8 HOURS [11] - 177:25, 178:10, 184:22,
165:25, 183:15, 192:17, 195:5,
HATE [1] - 296:5 250:6, 298:10, 298:16, 299:4, 299:6,
196:19, 196:21, 197:3, 197:16, 201:6,
HAZEL [3] - 210:4, 210:18, 210:19 299:9, 301:2, 304:4
202:1, 202:9, 204:1, 207:24, 208:11,
208:24 HAZEL [1] - 210:11 HOWEVER [1] - 1:8
GOVERNMENT [18] - 174:25, 209:13, HEAD [3] - 168:6, 225:6, 239:7 HUNDRED [1] - 220:4
220:22, 271:8, 272:7, 272:23, 293:6, HEAR [9] - 209:18, 260:6, 264:21, HUNDREDS [1] - 275:24
293:14, 294:14, 296:13, 299:21, 300:9, 300:10, 300:11, 306:7, 306:19 HUNTER [2] - 170:2, 190:15
300:18, 300:23, 301:23, 302:2, 302:6, HEARD [4] - 238:24, 239:15, 254:9 HUSBAND [1] - 249:2
305:20, 311:6 HEARING [1] - 265:17
HEARSAY [23] - 274:15, 282:8, 282:19,
GOVERNMENT [1] - 160:14
286:3, 286:14, 287:4, 287:10, 288:12,
I
GOVERNMENT'S [9] - 261:5, 275:8,
288:17, 289:4, 289:17, 289:21, ICLOUD [33] - 164:16, 164:19, 166:1,
293:11, 302:10, 302:22, 305:15,
291:25, 292:18, 292:19, 292:21, 166:4, 169:5, 171:10, 171:15, 171:21,
307:23, 310:25, 311:10
293:6, 293:10, 293:13, 294:6, 294:11, 172:2, 172:4, 172:13, 173:6, 173:13,
GOVERNMENT'S [10] - 194:5, 199:25,
294:15, 295:20 175:16, 175:23, 176:7, 178:7, 178:19,
201:25, 203:21, 223:23, 224:15,
HELD [1] - 163:1 179:22, 181:9, 181:18, 182:15,
227:8, 228:14, 233:24, 239:3
HELD [1] - 259:6 182:24, 183:8, 184:20, 185:3, 185:9,
GRAND [7] - 219:5, 221:6, 221:10,
HELP [2] - 211:20, 280:11 186:21, 187:1, 187:8, 188:6, 188:12,
221:16, 221:18, 221:22, 237:13
HELPING [1] - 301:24 188:24
GRANDVIEW [1] - 255:7
HEREBY [1] - 312:6 IDEA [7] - 225:14, 267:3, 272:10, 274:9,
GRANT [1] - 310:25
HEREIN [1] - 210:12 285:22, 288:9, 308:21
GREAT [3] - 170:16, 283:1, 283:4
HERSELF [2] - 240:23, 240:25 IDEAS [1] - 266:22
GREEN [3] - 199:16, 241:9, 241:10
HI [1] - 263:19 IDENTICAL [5] - 165:3, 165:15, 165:16,
GREEN [4] - 177:7, 184:10, 242:7,
HIGHLIGHT [1] - 198:6 167:19, 172:3
242:9
HIGHLY [1] - 205:15 IDENTIFIED [3] - 271:6, 287:18, 295:8
GREEN'S [1] - 242:3
HILL [2] - 246:25, 247:1 IDENTIFYING [1] - 308:5
GRIFFIN [1] - 305:16
HIT [1] - 203:9 IDRS [3] - 212:6, 212:7, 212:14
GROUND [1] - 310:18
HOLDINGS [10] - 178:22, 179:16, IMAGE [4] - 179:12, 179:15, 179:16,
GROUNDS [1] - 293:22
179:17, 179:19, 180:9, 180:19, 235:7
GROUP [29] - 165:13, 192:21, 195:3,
182:13, 213:3, 245:4, 246:5 IMAGES [1] - 234:11
196:16, 199:17, 201:13, 213:1, 214:6,
HOLLAND [16] - 167:6, 170:9, 171:2, IMAGINE [1] - 250:5
227:16, 241:2, 241:20, 251:16, 252:1,
174:12, 176:11, 177:7, 192:15, IMPACT [1] - 295:10
252:3, 252:6, 252:18, 253:15, 253:22,
193:11, 207:10, 207:22, 224:14, IMPACT [2] - 213:1, 241:10
254:12, 254:20, 255:12, 255:20,
227:18, 228:6, 228:13, 232:4, 239:4 IMPEACH [2] - 258:23, 271:5
255:22, 258:21, 262:2, 262:6, 262:12,
HOLLAND [1] - 189:3 IMPEACHING [1] - 272:10
262:13, 262:15
HONEST [1] - 220:12 IMPEACHMENT [6] - 258:9, 258:12,
GROUP [2] - 244:8, 251:20
HONOR [83] - 163:4, 164:3, 169:24, 258:14, 259:3, 259:5, 261:9
GROW [1] - 262:7
190:14, 194:4, 194:19, 196:22, IMPERSONATING [1] - 276:2
GUESS [16] - 204:10, 217:2, 218:12,
196:25, 199:24, 202:12, 203:20, IMPLICATE [2] - 275:10, 301:19
219:9, 225:18, 230:9, 230:16, 248:18,
204:1, 204:3, 204:13, 204:21, 205:4, IMPLICATED [2] - 305:2, 305:3
272:4, 272:6, 274:12, 283:8, 291:7,
206:8, 208:25, 209:7, 210:1, 214:12, IMPLICATES [2] - 309:9, 309:11
299:14, 305:21
215:4, 215:9, 215:13, 215:16, 231:4, IMPLICATING [3] - 274:20, 275:17,
GUESSING [1] - 290:12
238:13, 252:20, 252:22, 256:3, 310:5
GUILT [4] - 308:17, 309:21, 309:24,
256:17, 256:20, 258:3, 258:9, 259:12, IMPLIED [1] - 306:13
309:25
260:3, 260:9, 260:21, 261:10, 261:12, IMPLIES [1] - 307:18
GUILTY [11] - 275:15, 304:23, 305:12,
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IMPORTANT [6] - 216:12, 217:13, INTERRUPT [1] - 302:11 IT'LL [2] - 276:12, 301:8
217:16, 218:10, 224:25, 301:24 INTERVIEW [42] - 166:6, 192:12, ITEMS [2] - 240:11, 261:23
IMPRESSION [1] - 309:18 207:20, 216:11, 216:12, 219:22, ITSELF [2] - 274:21, 289:3
IMPROPER [2] - 259:2, 261:9 220:19, 222:8, 222:10, 222:16,
IN [3] - 1:3, 1:4, 163:1 222:17, 222:23, 223:3, 268:20, 270:5, J
IN-PERSON [1] - 259:9 270:14, 272:25, 277:19, 278:17,
J.P [1] - 160:10
INACCURATE [1] - 271:3 278:21, 279:1, 279:10, 280:1, 280:4,
280:11, 280:13, 280:21, 280:22, JACKSON [33] - 202:11, 218:20, 219:9,
INC [10] - 166:16, 167:13, 172:24,
281:2, 281:9, 281:20, 285:1, 285:2, 219:24, 220:10, 220:23, 221:3,
175:25, 182:13, 197:20, 246:5,
285:3, 285:16, 285:20, 285:22, 222:16, 222:17, 222:24, 223:8, 225:9,
246:17, 247:3, 247:15
286:10, 287:6, 287:23, 292:3, 294:23 226:18, 228:1, 229:7, 229:14, 229:18,
INCEPTION [1] - 231:16
INTERVIEWED [10] - 196:17, 208:19, 230:12, 233:4, 233:13, 233:15,
INCLINED [1] - 310:24
233:16, 234:19, 235:2, 235:5, 235:14,
INCLUDE [4] - 165:2, 203:6, 204:5, 218:17, 268:13, 269:6, 270:8, 272:22,
236:6, 236:13, 237:1, 237:6, 238:3,
216:21 281:23, 289:9, 293:15
308:20
INCLUDED [2] - 171:20, 172:19 INTERVIEWING [3] - 262:12, 268:21,
JACKSON [2] - 160:6, 160:20
INCLUDES [5] - 241:17, 241:20, 250:12, 277:15
JACKSON'S [5] - 217:25, 223:20, 225:2,
250:16, 268:20 INTERVIEWS [5] - 218:16, 219:20,
225:24, 309:25
INCLUDING [1] - 205:9 237:5, 268:11, 269:14
JAMES [4] - 203:13, 254:7, 254:10
INCLUSION [1] - 204:14 INTRODUCE [4] - 275:9, 293:14, 306:9,
310:20 JANUARY [1] - 178:17
INCORPORATION [2] - 174:5, 253:14
INTRODUCED [3] - 223:22, 224:17, JAY [1] - 300:17
INCORPORATOR [1] - 253:16
259:8 JERRY [2] - 243:21, 243:22
INCREDIBLY [1] - 275:18
INTRODUCING [1] - 306:10 JESIKA [3] - 240:18, 240:19, 251:14
INCULPATED [1] - 309:18
INTRODUCTION [1] - 260:16 JIMBO [2] - 273:18
INCULPATES [1] - 309:11
INVESTIGATED [1] - 282:21 JOB [2] - 212:2, 212:18
INDICATED [1] - 237:6
INVESTIGATING [1] - 250:2 JOHN [19] - 222:7, 222:9, 222:21,
INDICATING [1] - 194:11
INVESTIGATION [39] - 164:10, 172:8, 223:12, 228:12, 230:8, 230:9, 231:15,
INDICATION [2] - 276:1, 287:20
178:23, 185:13, 187:12, 194:1, 199:2, 233:13, 233:15, 234:24, 235:1, 235:2,
INDICTMENT [4] - 239:1, 268:1, 307:22, 235:23, 236:6, 236:21, 236:25,
308:14 212:20, 216:9, 216:11, 217:12, 218:5,
219:22, 220:3, 232:19, 252:5, 255:16, 242:12, 242:16
INDIVIDUAL [6] - 243:3, 243:22, 263:11, JOHNSON [2] - 255:2, 255:10
263:24, 268:20, 280:8 261:1, 262:15, 279:17, 281:4, 281:20,
281:24, 282:22, 284:14, 285:5, 286:1, JOKE [1] - 194:23
INDIVIDUALS [4] - 200:8, 213:22, JOSEPH [1] - 162:3
239:19, 245:1 290:20, 294:1, 294:13, 294:20,
294:25, 295:1, 295:2, 295:10, 295:14, JUDGE [17] - 163:14, 170:5, 194:8,
INDUSTRY [2] - 262:8, 262:14
295:19, 295:22, 295:25 200:3, 202:11, 204:8, 215:6, 215:20,
INFINITE [15] - 164:7, 164:19, 165:18, 238:14, 238:15, 252:23, 265:19,
INVESTIGATOR [1] - 304:2
165:20, 166:15, 167:13, 167:21, 299:3, 303:11, 304:12, 306:23, 310:9
INVESTOR [1] - 266:8
168:5, 168:13, 168:21, 170:20, JUDGE [1] - 160:10
171:23, 213:5, 247:2 INVOKE [3] - 260:3, 260:11, 260:15
INVOLVED [26] - 164:9, 172:7, 178:23, JUDGE [2] - 216:24, 303:12
INFLOW [1] - 221:19
185:12, 187:12, 191:25, 200:10, JULY [13] - 193:20, 196:4, 196:5,
INFO@BELLATORPHRONTGROUP.
231:15, 231:20, 231:21, 237:7, 239:9, 196:10, 202:23, 203:2, 206:21,
COM [1] - 263:17 206:24, 207:12, 218:20, 222:25,
241:4, 243:16, 248:15, 264:14,
INFORMATION [13] - 165:18, 165:19, 238:3, 256:1
268:22, 269:12, 272:23, 275:11,
174:8, 198:25, 203:6, 212:8, 212:10, JUNE [32] - 168:19, 169:9, 171:11,
275:15, 275:23, 285:4, 295:12,
218:9, 226:21, 237:6, 237:11, 239:20, 175:5, 175:24, 178:1, 178:8, 181:10,
306:14, 306:16
281:15 181:19, 182:10, 183:17, 184:8,
INVOLVEMENT [2] - 270:23, 307:10
INITIAL [1] - 281:2 184:13, 184:15, 184:21, 185:20,
IP [6] - 224:25, 225:2, 225:8, 225:20,
INQUIRY [1] - 167:14 185:23, 186:8, 186:22, 188:7, 189:14,
225:23, 226:2
INSTANCE [3] - 220:24, 221:4, 233:14 193:20, 195:14, 195:18, 202:22,
IRRELEVANT [3] - 258:16, 271:11,
INSTEAD [3] - 199:11, 209:17, 277:23 202:24, 226:12, 226:13, 229:1,
274:22
INSTRUCTED [1] - 251:22 230:13, 231:19, 233:9
IRS [11] - 211:4, 211:5, 211:8, 211:16,
INSTRUCTION [2] - 308:16, 309:23 JURORS [1] - 309:23
211:22, 212:9, 212:12, 213:18,
INSTRUCTIONS [1] - 271:18 JURY [1] - 160:9
213:20, 213:22, 214:6
INTEGRAL [1] - 300:5 JURY [40] - 163:3, 163:20, 163:24,
IS [1] - 1:2
INTEGRATED [1] - 212:5 168:4, 194:16, 209:10, 212:24,
ISSUE [15] - 258:25, 271:14, 271:23,
INTERACTING [1] - 273:8 213:18, 215:23, 219:5, 221:6, 221:10,
274:17, 281:14, 283:8, 286:12, 296:7,
INTERACTION [2] - 226:4, 264:10 221:16, 221:18, 221:22, 224:20,
296:18, 297:25, 299:21, 301:25,
INTERACTIONS [3] - 264:5, 264:7, 237:13, 271:14, 271:16, 271:20,
305:9, 305:11
307:16 274:24, 275:18, 276:23, 277:6, 277:8,
ISSUED [2] - 201:13, 216:15
INTERNAL [3] - 167:12, 210:21, 211:1 282:25, 283:5, 287:7, 296:6, 305:1,
ISSUES [1] - 209:12
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306:7, 307:11, 307:14, 307:18, LEEWAY [3] - 258:21, 276:12, 276:19 LOGINS [1] - 226:3
308:14, 309:3, 309:6, 309:13, 309:15, LEFT [7] - 183:1, 189:7, 226:5, 226:10, LOOK [13] - 203:14, 208:2, 213:9,
310:1 303:7, 307:14, 308:18 214:20, 230:6, 252:11, 257:10,
JURY'S [1] - 307:8 LEFT-HAND [1] - 226:5 264:17, 275:20, 285:19, 306:24,
LEGAL [1] - 259:8 307:3, 307:24
K LEIGH [1] - 160:18 LOOKED [14] - 165:2, 167:18, 171:12,
LESS [1] - 210:1 173:1, 173:15, 178:11, 180:3, 181:21,
KAHLIL [2] - 241:9, 241:10
LESS [1] - 222:13 182:15, 191:22, 192:20, 193:6, 203:5,
KAUSHAL [1] - 160:15
LETTER [6] - 167:13, 174:4, 270:2, 212:25
KEEP [1] - 297:10
270:4, 270:13 LOOKING [9] - 174:2, 174:8, 179:2,
KEVIN [2] - 254:7, 254:9
LETTERS [1] - 274:25 180:11, 198:2, 205:6, 254:15, 263:15,
KIND [12] - 179:5, 193:13, 205:10,
LEVEL [6] - 262:8, 288:14, 289:10, 311:10
217:24, 220:6, 233:7, 233:8, 240:21,
293:13, 293:17, 294:11 LOOKS [6] - 252:17, 253:14, 253:21,
265:9, 275:9, 301:24, 310:15
LEVELS [1] - 287:10 258:18, 265:8, 288:4
KINDS [2] - 193:22, 232:23
LIAR [1] - 259:13 LOOP [1] - 304:25
KNOCK [6] - 170:25, 171:4, 219:25,
LIDDIARD [2] - 297:7, 298:14 LOST [1] - 289:11
220:1, 220:2, 222:18
LIE [3] - 273:3, 275:10, 288:10 LOWER [1] - 179:5
KNOCK-AND-TALK [1] - 219:25
LIED [2] - 273:1, 278:10 LUNCH [1] - 163:25
KNOCK-AND-TALKS [2] - 220:1, 220:2
LIES [1] - 274:16 LYING [5] - 273:7, 274:5, 275:7, 278:13,
KNOWING [1] - 280:4
LIGHT [1] - 205:22 282:18
KNOWLEDGE [6] - 254:11, 262:9,
LIMINE [2] - 305:15, 307:5
262:10, 272:24, 280:22, 286:4
KNOWN [3] - 212:6, 273:7, 285:13
LIMIT [1] - 300:4 M
LIMITING [2] - 308:16, 309:23 MAIL [70] - 164:16, 164:23, 166:1,
KNOWS [3] - 275:13, 281:13, 283:22
LINE [1] - 1:7 166:12, 167:18, 168:18, 168:20,
LINE [10] - 192:23, 195:4, 201:7, 201:10, 171:10, 171:15, 171:21, 172:13,
L 201:16, 290:2, 301:20, 303:5, 308:3 172:20, 173:6, 173:13, 175:4, 175:7,
LABELED [1] - 261:19 LINES [1] - 258:11 175:13, 175:23, 176:1, 176:7, 177:23,
LACK [1] - 295:24 LIST [6] - 174:14, 179:2, 179:4, 179:7, 178:7, 179:22, 181:9, 182:9, 182:14,
LADIES [6] - 163:24, 194:16, 209:10, 212:23, 306:11 182:15, 182:17, 183:16, 183:24,
216:3, 271:16, 282:25 LISTED [14] - 174:9, 177:1, 198:14, 184:7, 184:20, 185:3, 186:7, 186:14,
LAID [1] - 295:13 201:20, 214:16, 214:22, 253:16, 186:21, 187:1, 187:17, 187:24, 188:6,
LANGUAGE [3] - 190:11, 191:1 254:1, 254:5, 254:7, 254:23, 254:25, 188:12, 229:13, 229:16, 229:18,
LAPTOP [2] - 217:4, 217:18 255:2, 255:14 229:21, 229:23, 229:25, 232:23,
LAPTOPS [1] - 218:4 LISTEN [1] - 279:10 233:3, 233:11, 235:1, 236:4, 241:2,
LAST [15] - 202:4, 209:25, 230:10, LISTING [5] - 174:6, 201:12, 202:6, 241:3, 241:17, 241:20, 241:25, 242:3,
230:12, 235:17, 242:19, 259:24, 224:22, 240:20 242:6, 249:17, 259:21, 261:16,
261:8, 280:8, 287:17, 291:15, 291:20, LITIGATED [1] - 305:8 262:24, 263:22, 264:25, 265:5,
298:9, 303:5 LIVES [1] - 279:22 265:21, 268:5, 276:1
LASTED [1] - 222:10 LIVING [5] - 223:13, 226:25, 255:6, MAILS [21] - 191:23, 229:11, 229:17,
LATE [3] - 171:12, 179:13, 184:13 255:9, 262:14 233:7, 241:14, 242:9, 245:12, 246:2,
LAUGHTER [1] - 194:22 LLC [4] - 187:19, 227:16, 234:21, 249:16, 249:19, 250:12, 257:7, 257:8,
LAW [5] - 305:9, 305:11, 305:17, 306:1, 249:11 257:24, 261:1, 263:1, 263:24, 263:25,
307:13 LOAD [1] - 199:12 268:8, 273:11, 275:24
LAWYER [2] - 270:11, 278:19 LOAN [25] - 172:2, 185:12, 187:7, MAIN [2] - 199:9, 239:17
LAY [2] - 295:18, 295:21 187:12, 200:21, 208:17, 208:20, MAJORITY [2] - 230:7, 230:8
LAYER [2] - 293:6, 295:20 235:23, 236:2, 236:19, 242:17, MANAGEMENT [5] - 213:2, 213:7,
LEAD [1] - 308:4 242:22, 243:17, 243:24, 243:25, 243:17, 243:24, 244:8
LEADER [1] - 239:21 248:8, 251:19, 264:1, 264:14, 265:3, MANAGING [3] - 240:11, 240:20,
LEADS [1] - 262:4 266:7, 277:22, 279:25, 291:19, 294:17 240:21
LEARNED [1] - 255:16 LOANS [23] - 164:9, 200:10, 239:9, MARCH [2] - 166:22, 167:14
LEAST [12] - 204:4, 217:20, 223:19, 239:18, 239:20, 240:6, 240:8, 240:20, MARKED [1] - 262:20
226:22, 226:23, 226:24, 239:11, 241:4, 243:1, 243:8, 244:19, 245:1, MARRIED [2] - 240:16, 240:17
246:3, 289:16, 289:20, 298:1, 309:11 247:25, 248:4, 248:19, 248:21, MARSHALL [8] - 170:4, 204:7, 215:17,
LEAVE [1] - 300:14 248:22, 249:1, 251:22, 255:7, 266:23, 216:1, 265:17, 303:1, 306:3, 306:19
LEAVES [2] - 301:2, 309:17 267:25 MARSHALL [57] - 160:20, 163:14,
LEAVING [1] - 163:9 LOCATED [1] - 279:19 170:5, 190:17, 194:8, 194:10, 200:3,
LEE [13] - 194:11, 206:12, 213:3, 245:3, LOCATION [4] - 203:6, 207:3, 225:18, 202:11, 204:8, 215:6, 215:20, 216:2,
264:14, 264:15, 265:2, 265:7, 266:4, 227:6 216:5, 224:14, 224:16, 227:18,
266:7, 266:23 LOCATIONS [1] - 203:9 227:21, 228:6, 228:8, 228:13, 228:20,
LOGIN [1] - 174:4
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230:2, 230:5, 231:4, 231:8, 232:3, 303:16, 303:21, 304:14, 311:3, 311:8 227:18, 227:21, 228:6, 228:8, 228:13,
232:5, 232:8, 232:11, 233:23, 234:1, MILLER [12] - 255:2, 255:10, 257:3, 228:20, 230:2, 230:5, 231:4, 231:8,
234:9, 234:12, 235:7, 235:9, 236:9, 257:8, 258:18, 262:1, 262:4, 263:11, 232:3, 232:5, 232:8, 232:11, 233:23,
236:11, 238:13, 252:23, 265:19, 275:21, 275:24, 305:21 234:1, 234:9, 234:12, 235:7, 235:9,
297:24, 298:4, 298:7, 299:2, 302:17, MIND [2] - 281:15, 303:17 236:9, 236:11, 238:13, 252:23,
303:2, 303:11, 303:19, 303:24, 304:1, MINI [1] - 297:24 265:19, 297:24, 298:4, 298:7, 299:2,
304:9, 304:12, 306:4, 306:8, 306:21, MINUTE [2] - 238:13, 260:5 302:17, 303:2, 303:11, 303:19,
310:9, 310:12 MINUTES [16] - 210:1, 220:17, 222:10, 303:24, 304:1, 304:9, 304:12, 306:4,
MARSHALL'S [2] - 303:23, 306:18 292:16, 296:6, 297:8, 297:23, 298:10, 306:8, 306:21, 310:9, 310:12
MASTER [1] - 212:9 298:14, 298:15, 298:20, 299:5, 299:8, MS [340] - 163:4, 163:7, 163:15, 163:17,
MATTER [10] - 236:7, 274:15, 282:17, 299:9 164:3, 164:5, 164:12, 164:14, 164:20,
285:7, 286:23, 287:8, 287:14, 288:8, MISIMPRESSION [1] - 307:15 164:22, 165:6, 165:8, 165:21, 165:24,
288:11, 294:12 MISLEADING [2] - 275:18, 276:18 166:10, 166:11, 167:4, 167:7, 167:15,
MATTERS [1] - 285:9 MISSING [2] - 297:2, 299:11 167:17, 168:1, 168:2, 168:15, 168:16,
MAY [2] - 1:3, 1:5 MISSPOKE [1] - 198:11 168:23, 168:24, 169:13, 169:14,
MCDUFFIE [1] - 249:10 MISSTATED [1] - 278:10 169:22, 170:3, 170:8, 170:10, 171:1,
MEAN [8] - 217:12, 248:20, 260:14, MISTAKE [1] - 177:9 171:3, 171:7, 171:8, 171:17, 171:19,
289:11, 293:9, 296:5, 297:2, 301:23 ML [7] - 183:12, 183:18, 184:14, 184:21, 172:10, 172:11, 172:16, 172:18,
MEANS [2] - 225:14, 308:22 213:4, 245:5, 247:15 173:3, 173:4, 173:9, 173:11, 173:22,
MEANT [1] - 260:21 MO [7] - 259:22, 260:1, 260:23, 275:16, 173:23, 174:11, 174:13, 174:20,
MEETING [2] - 269:3, 269:18 276:4, 309:8, 310:5 174:22, 175:1, 175:2, 175:10, 175:11,
MEETINGS [1] - 268:19 MOBILE [3] - 203:4, 203:23, 206:22 175:20, 175:21, 176:3, 176:5, 176:11,
MEGHAN [5] - 240:5, 253:17, 254:5, 176:13, 177:6, 177:8, 178:3, 178:5,
MODEL [1] - 262:14
254:25, 261:19 178:25, 179:1, 179:9, 179:11, 179:20,
MODUS [2] - 260:23
MEGHAN'S [1] - 240:10 179:21, 180:5, 180:6, 180:13, 180:14,
MOMENT [10] - 163:5, 194:9, 214:12,
MEMBER [1] - 230:23 181:6, 181:7, 181:15, 181:17, 182:7,
260:2, 272:18, 278:19, 283:7, 286:7,
182:8, 182:20, 182:22, 183:13,
MEMO [2] - 192:23, 195:4 290:14, 310:6
183:14, 183:22, 183:23, 184:5, 184:6,
MEMORY [1] - 241:7 MOMENTS [2] - 208:25, 209:3
184:9, 184:11, 184:17, 184:18,
MENTION [1] - 222:7 MONDAY [2] - 298:1, 311:10
184:25, 185:2, 185:15, 185:18, 186:4,
MENTIONED [6] - 221:2, 221:4, 222:5, MONEY [20] - 192:13, 196:12, 197:8,
186:5, 186:12, 186:13, 186:18,
249:23, 264:5, 276:17 199:9, 200:11, 200:15, 200:22,
186:19, 186:23, 186:25, 187:14,
MESSAGE [24] - 164:18, 166:3, 167:6, 200:24, 203:1, 208:2, 208:8, 208:16,
187:15, 187:22, 187:23, 188:3, 188:4,
168:12, 170:11, 170:15, 171:1, 221:19, 221:20, 234:14, 247:25,
188:9, 188:11, 189:2, 189:3, 189:4,
171:10, 177:7, 177:9, 177:12, 178:10, 248:7, 248:13, 251:21, 251:23
189:6, 190:14, 190:16, 190:19,
180:2, 180:15, 184:10, 184:22, 185:9, MONTH [5] - 180:20, 193:20, 193:23,
190:21, 191:9, 191:10, 192:15,
185:16, 189:13, 191:4, 191:14, 211:13, 226:17
192:18, 192:19, 193:3, 193:4, 193:10,
198:19, 267:14, 267:21 MONTHS [3] - 176:18, 205:6, 226:10
193:12, 193:16, 193:18, 194:4, 194:7,
MESSAGED [3] - 177:21, 189:18, MOORE [11] - 160:15, 210:1, 210:4,
194:13, 194:18, 194:21, 194:24,
189:21 210:16, 213:15, 213:16, 214:3, 214:4, 195:5, 195:7, 195:15, 195:16, 196:2,
MESSAGES [34] - 168:7, 170:17, 214:12, 214:14, 214:25 196:3, 196:19, 196:22, 196:25, 197:2,
171:12, 173:24, 181:1, 189:11, MORNING [7] - 163:9, 170:16, 209:11, 197:4, 197:16, 197:18, 198:6, 198:10,
189:13, 189:23, 190:4, 190:10, 219:1, 299:15, 301:2, 311:7 198:17, 198:20, 199:24, 200:2, 200:5,
190:22, 191:23, 192:7, 217:3, 232:20, MOST [6] - 212:8, 212:17, 225:18, 201:6, 201:9, 202:9, 202:12, 202:16,
232:23, 233:1, 233:2, 233:3, 233:4, 239:12, 240:4, 301:23 202:17, 203:20, 203:22, 204:1, 204:3,
236:5, 245:13, 249:22, 250:14, MOSTLY [2] - 217:4, 297:9 204:13, 204:19, 204:21, 205:4,
250:16, 250:20, 250:21, 250:25, MOTHER [2] - 255:11, 276:3 205:12, 205:20, 206:8, 206:14,
251:1, 251:10, 251:13, 275:25 MOTION [5] - 305:15, 307:5, 310:25, 206:16, 206:17, 207:9, 207:11,
MESSAGING [3] - 190:13, 251:5, 251:9 311:5, 311:7 207:22, 207:25, 208:10, 208:12,
MESSY [1] - 282:24 MOTIVE [1] - 208:16 208:23, 208:25, 209:3, 209:5, 209:7,
METABANK [2] - 199:21, 200:6 MOUNTAIN [1] - 225:17 215:4, 215:13, 215:16, 238:19,
METHOD [1] - 219:19 MOVE [17] - 164:6, 170:1, 172:6, 238:21, 239:3, 239:5, 252:20, 252:22,
MICHIGAN [2] - 213:4, 245:22 190:14, 194:4, 196:23, 199:24, 202:9, 252:25, 253:2, 253:7, 253:10, 253:12,
MICKIES [6] - 187:11, 187:18, 188:8, 203:20, 204:1, 224:12, 231:6, 252:20, 256:3, 256:6, 256:13, 256:16, 256:20,
188:19, 213:6, 249:11 256:20, 258:1, 263:4, 265:15 257:1, 257:2, 258:1, 258:3, 258:6,
MIDDLE [9] - 174:16, 176:24, 179:6, MOVED [1] - 196:22 258:9, 258:19, 259:4, 259:12, 260:1,
242:16, 243:4, 243:15, 243:22, MR [66] - 163:14, 170:5, 190:17, 194:8, 260:3, 260:9, 260:14, 260:16, 260:21,
289:10, 294:10 194:10, 200:3, 202:11, 204:8, 210:1, 261:9, 261:12, 261:15, 263:4, 263:6,
MIGHT [17] - 213:12, 214:18, 218:9, 210:4, 210:16, 213:15, 213:16, 214:3, 263:8, 263:9, 265:15, 265:16, 265:20,
224:3, 226:25, 245:5, 246:2, 250:5, 214:4, 214:12, 214:14, 214:25, 215:6, 271:4, 271:5, 271:8, 272:9, 272:19,
292:7, 292:24, 297:19, 299:13, 215:20, 216:2, 216:5, 224:14, 224:16, 272:21, 273:22, 274:14, 274:19,
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277:2, 277:12, 277:13, 280:19, NOTARIZED [2] - 266:18, 266:19 ON [3] - 160:14, 160:17, 160:20
280:25, 281:6, 281:11, 281:17, NOTARY [1] - 265:8 ONCE [4] - 200:13, 247:24, 248:4,
281:18, 282:8, 282:16, 283:21, NOTATION [2] - 235:20, 236:17 285:10
283:23, 284:2, 284:4, 284:7, 284:11, NOTE [3] - 232:14, 247:22, 307:4 ONE [79] - 163:5, 164:9, 169:15, 174:18,
284:16, 284:23, 285:2, 285:9, 285:14, NOTED [1] - 235:22 181:11, 183:24, 186:14, 187:24,
286:7, 286:14, 286:21, 286:25, 287:9, NOTES [1] - 290:21 188:19, 189:24, 194:9, 202:4, 202:12,
288:3, 288:7, 288:13, 289:6, 289:22, NOTHING [3] - 214:25, 238:15, 275:11 205:17, 207:15, 209:11, 213:12,
290:1, 290:10, 290:17, 290:23, 291:4, NOTICE [1] - 189:25 214:12, 217:6, 225:8, 227:24, 228:14,
291:7, 291:13, 291:18, 291:25, NOVEMBER [4] - 176:19, 224:5, 224:6, 233:4, 234:11, 235:10, 235:13, 236:9,
292:10, 293:2, 293:9, 293:13, 293:19, 224:9 236:15, 237:15, 237:17, 237:20,
293:21, 293:23, 294:5, 294:8, 294:10, NUMBER [1] - 223:23 238:13, 239:9, 239:12, 239:23, 240:1,
294:22, 295:23, 296:2, 296:10, NUMBER [2] - 1:6, 1:7 242:8, 243:8, 246:3, 247:1, 249:2,
296:22, 297:4, 297:18, 297:23, 298:3, NUMBER [10] - 165:19, 167:14, 179:18, 251:20, 252:13, 253:17, 257:12,
298:5, 298:12, 298:18, 298:24, 180:20, 201:16, 219:12, 236:19, 257:13, 260:2, 264:10, 267:13, 268:3,
299:12, 299:20, 299:24, 300:14, 245:12, 264:9, 308:23 268:4, 268:10, 269:14, 269:15,
300:17, 300:19, 300:21, 301:1, 301:5, NUMBERS [12] - 165:2, 165:15, 169:17, 272:18, 275:14, 276:3, 278:23,
301:11, 301:14, 301:16, 302:1, 302:3, 169:18, 172:25, 173:1, 175:15, 280:25, 285:13, 290:17, 292:19,
302:16, 302:25, 303:9, 303:10, 180:10, 181:24, 181:25, 182:5, 183:4 293:2, 293:7, 294:8, 298:8, 298:18,
303:17, 303:20, 303:25, 304:2, 298:22, 299:7, 300:12, 301:5, 303:12,
NUMEROUS [1] - 200:8
304:19, 305:8, 306:6, 306:10, 306:17, 304:2, 304:4, 306:11, 310:6
307:4, 307:21, 308:13, 309:2, 310:19, ONE-NINE [2] - 257:12, 257:13
310:23
O ONES [5] - 180:12, 241:6, 242:23,
MULTIFAMILY [3] - 262:8, 262:9, OBJECT [12] - 204:3, 204:11, 204:13, 242:24, 244:22
262:14 204:16, 204:17, 204:18, 258:3, ONLY [2] - 1:3, 1:7
MULTIPLE [1] - 272:22 280:20, 290:4, 306:22, 310:15, 310:17 OPEN [1] - 311:11
MUST [1] - 299:11 OBJECTED [2] - 290:6, 291:12 OPEN [1] - 163:1
OBJECTION [31] - 170:3, 170:6, 190:16, OPENED [6] - 195:13, 195:25, 304:22,
N 190:17, 194:7, 194:8, 194:10, 196:25, 305:6, 305:23, 309:5
200:2, 200:3, 202:11, 202:14, 204:8, OPERANDI [1] - 260:23
NAME [37] - 172:7, 173:19, 174:4, 206:2, 252:22, 252:23, 256:3, 256:17, OPERATIONS [1] - 262:5
179:16, 179:17, 182:3, 182:4, 195:11, 256:24, 261:8, 263:6, 265:16, 265:17,
201:1, 201:12, 201:15, 201:18, OPERATIONS [8] - 213:3, 245:3,
265:19, 271:4, 272:4, 276:21, 291:23, 264:14, 265:2, 265:7, 266:4, 266:8,
210:17, 210:18, 212:4, 212:5, 225:15, 293:22, 295:20, 302:17
227:25, 236:20, 244:13, 246:3, 249:4, 266:23
OBJECTION'S [1] - 277:11 OPINION [1] - 220:10
254:9, 257:3, 257:7, 274:7, 275:21,
OBLIGATION [1] - 295:4 OPPORTUNITY [1] - 209:15
275:22, 276:2, 276:4, 280:8, 280:15,
OBTAINED [5] - 216:14, 218:10, 234:14, OR [1] - 1:9
287:24, 291:15, 295:9, 300:17
252:5, 266:7 ORDER [5] - 209:11, 256:9, 267:2,
NAMED [3] - 255:2, 288:9, 305:15
OBVIOUSLY [5] - 259:20, 269:6, 275:3, 288:22, 296:21
NAMES [14] - 169:7, 173:20, 173:21,
301:19, 310:13 ORGANIZATIONAL [1] - 253:9
182:1, 182:2, 182:5, 183:6, 200:9,
OCCASION [1] - 260:18 ORGANIZER [1] - 230:23
256:8, 259:15, 259:16, 259:18, 309:8
OCCASIONALLY [5] - 216:17, 216:18, ORIGINAL [3] - 227:23, 227:24, 228:4
NATURE [1] - 307:15
223:17, 226:22, 226:23 OTHERWISE [5] - 258:15, 259:8,
NAVY [2] - 197:11, 197:13
OCTOBER [1] - 176:19 282:12, 294:15, 295:19
NEARLY [1] - 192:4
OF [10] - 1:2, 1:5, 1:6, 160:1, 160:4, OUT-OF-COURT [1] - 289:4
NEED [9] - 178:19, 205:17, 256:23,
160:9, 160:14, 160:17, 160:20, 312:4 OUTSIDE [6] - 204:14, 223:15, 248:22,
271:15, 274:24, 296:17, 297:10,
OFF-THE-RECORD [2] - 163:22, 215:22 248:23, 256:4, 283:10
297:17, 301:4
OFFER [1] - 289:22 OUTSTANDING [1] - 240:21
NEEDED [1] - 174:7
OFFERED [15] - 260:10, 274:14, 282:16, OVERALL [1] - 216:10
NEEDS [2] - 296:14, 297:5
282:19, 287:14, 288:8, 288:11, OVERARCHING [1] - 279:16
NEVER [1] - 281:7
288:14, 289:19, 292:7, 292:21, 293:7, OVERLOOK [1] - 255:7
NEXT [9] - 209:24, 227:19, 235:7, 236:9,
293:11, 294:11, 294:12
290:13, 297:11, 300:14, 300:15, OVERNIGHT [1] - 223:17
OFFERING [11] - 260:10, 286:14,
303:13 OVERRULED [2] - 261:11, 277:11
286:22, 286:24, 286:25, 289:1, 289:7,
NIGHT [3] - 171:12, 179:13, 184:13 OVERVIEW [1] - 216:8
289:10, 292:11, 293:3, 309:25
NINE [2] - 257:12, 257:13 OWN [10] - 204:23, 204:24, 205:2,
OFFICE [2] - 192:24, 193:1
NO [1] - 160:5 205:8, 205:9, 243:5, 244:24, 248:19,
OFFICE [3] - 213:8, 268:22, 269:11
NOBODY [3] - 194:23, 288:19, 309:20 248:21, 297:24
OFFICERS [1] - 254:22
NONE [2] - 274:14, 305:2 OWNER [8] - 241:10, 243:5, 243:16,
OFFICIAL [1] - 231:23
NORMALLY [3] - 209:13, 219:5, 219:19 245:20, 246:18, 248:21, 249:6, 307:9
OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 160:24,
NORTHERN [2] - 160:1, 312:4 OWNER'S [1] - 307:10
312:15
OWNERS [3] - 239:19, 240:2, 248:13
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OWNERS' [2] - 200:12, 248:9 200:22, 201:12, 203:1, 266:9 PLAYED [2] - 220:20, 240:19
PAYROLL [1] - 195:4 PLEA [5] - 305:21, 310:13, 310:20,
P PDF [1] - 1:2 310:21
PENNY [2] - 160:24, 312:15 PLEADED [3] - 275:15, 306:15, 309:3
P.M [18] - 163:20, 164:17, 172:14,
PEOPLE [35] - 200:10, 208:3, 220:6, PLEAS [5] - 304:23, 305:12, 306:1,
175:5, 182:10, 183:17, 184:8, 184:15,
238:24, 238:25, 239:6, 239:14, 308:22, 310:3
188:7, 215:14, 215:15, 215:23,
249:20, 249:23, 268:13, 269:1, PLUS [3] - 220:4, 299:7, 299:8
271:20, 271:25, 272:1, 277:8, 283:5,
272:11, 274:25, 275:4, 275:13, PM [2] - 160:6, 163:1
311:14
275:17, 279:19, 304:24, 305:2, 305:3, PNC [1] - 232:17
PAGE [1] - 1:7
306:11, 307:22, 307:25, 308:7, POINT [30] - 168:9, 177:17, 185:23,
PAGE [27] - 162:2, 168:1, 174:2, 176:24,
308:21, 309:3, 309:9, 309:11, 309:12, 190:13, 222:8, 222:9, 223:19, 224:3,
178:25, 189:4, 189:7, 191:9, 193:3,
309:13, 309:16, 309:19, 309:21, 310:5 237:18, 244:22, 247:22, 273:9,
193:10, 193:16, 195:15, 196:2,
PEOPLE'S [6] - 256:8, 259:15, 259:16, 273:13, 276:21, 278:16, 281:15,
197:17, 207:9, 227:19, 228:7, 228:15,
259:18, 307:16, 309:8 285:13, 286:17, 289:14, 290:22,
228:16, 290:11, 290:15, 290:17,
PER [1] - 272:9 291:2, 291:18, 292:15, 296:20, 300:9,
290:18, 291:5
PERHAPS [4] - 276:18, 283:2, 289:18, 304:12, 304:21, 308:3, 308:6, 311:11
PAGES [8] - 204:18, 205:18, 206:3,
311:6 POINTED [1] - 225:1
206:9, 264:18, 290:10, 312:6
PERIOD [12] - 192:5, 204:5, 204:24, POINTING [1] - 275:3
PAINTING [2] - 213:1, 244:25
205:1, 205:3, 205:6, 205:7, 205:14, PORTION [1] - 196:12
PANDEMIC [1] - 269:23
205:15, 205:23, 207:16, 218:5 PORTION [1] - 1:5
PAPER [4] - 208:2, 275:21, 275:23,
PERIOD [1] - 1:5 POSITION [1] - 310:16
276:4
PERMISSIBLE [1] - 260:23 POSITIVE [2] - 249:13, 303:21
PARAGRAPH [7] - 265:6, 267:17,
PERMITTED [1] - 310:3 POSSESSION [4] - 204:22, 204:23,
280:14, 287:23, 290:11, 291:4, 291:20
PERSINGER [17] - 296:17, 296:20, 211:4, 219:6
PARAGRAPHS [1] - 290:21
296:25, 297:3, 297:17, 297:18, POSSIBILITY [1] - 223:18
PARKER [18] - 178:22, 179:4, 179:16,
297:22, 298:9, 298:17, 299:4, 299:16, POSSIBLY [1] - 224:14
179:17, 179:18, 179:19, 180:9,
299:18, 300:10, 301:7, 302:9, 303:15 POSTED [1] - 198:12
180:19, 182:13, 213:3, 245:3, 245:4,
PERSON [19] - 205:21, 205:24, 205:25, POTENTIALLY [2] - 287:10, 305:22
246:3, 246:5, 246:8, 246:12
219:22, 234:18, 242:16, 243:4, PPP [15] - 164:9, 181:4, 192:10, 200:10,
PART [28] - 204:4, 212:11, 212:18,
243:15, 243:22, 259:9, 260:17, 269:6, 200:13, 200:20, 208:17, 239:20,
221:5, 232:9, 240:25, 241:1, 242:19,
291:14, 298:23, 299:7, 300:12, 251:19, 255:6, 261:4, 265:3, 277:22,
262:12, 272:14, 275:7, 276:18, 281:2,
307:17, 307:19 279:5, 279:25
281:24, 282:2, 282:21, 282:22,
PERSONAL [1] - 286:4 PRACTICE [1] - 259:15
284:14, 288:15, 290:11, 290:19,
PERSONALLY [2] - 238:1, 259:7 PREARRANGED [1] - 268:24
291:6, 291:19, 298:1, 300:5, 303:22,
PERSUADED [1] - 287:2 PRECISELY [1] - 307:7
304:13, 309:11
PETITION [2] - 223:24, 224:4 PRECLUDE [1] - 307:5
PARTIAL [1] - 1:9
PETTY [4] - 243:14, 243:15, 243:19, PREDICTED [1] - 305:4
PARTICIPATE [1] - 230:17
243:24 PREJUDICE [1] - 295:21
PARTICULAR [3] - 231:25, 260:18
PHONE [25] - 179:18, 192:3, 192:4, PREMIER [1] - 213:8
PARTIES [3] - 232:24, 233:4, 286:3
203:5, 203:9, 204:23, 204:24, 205:13, PREPAID [2] - 199:1, 199:8
PAST [1] - 204:6
205:16, 205:17, 206:5, 206:18, 207:4, PREPARATION [1] - 258:24
PATTERN [5] - 172:2, 183:8, 187:7,
207:16, 217:5, 218:2, 219:12, 245:13, PREPARED [2] - 165:12, 183:9
188:23, 259:15
250:14, 250:25, 276:2, 300:12, 302:8 PREPARING [4] - 243:11, 248:22, 300:3
PAUSE [3] - 253:9, 299:16, 303:6
PHONES [7] - 205:2, 205:5, 205:8, PRESENCE [1] - 309:6
PAUSE [2] - 209:6, 214:13
205:9, 217:10, 217:11, 217:13 PRESENT [4] - 216:24, 269:25, 280:21,
PAYCARD [17] - 198:25, 199:3, 199:16,
PHRASE [1] - 220:1 286:2
199:21, 200:7, 200:14, 200:22,
PHRASED [1] - 286:13 PRESENTED [2] - 229:17, 232:19
200:24, 201:1, 201:15, 202:6, 202:7,
PHRONT [28] - 165:12, 192:21, 195:2, PRESERVED [1] - 212:11
202:19, 206:25, 207:19, 208:1, 208:5
196:16, 199:17, 201:13, 213:1, 214:6, PRETEND [1] - 293:18
PAYCARDS [2] - 201:14, 266:9
241:2, 241:20, 251:16, 252:1, 252:3,
PAYCHECK [1] - 185:21 PRETRIAL [4] - 304:20, 304:21, 307:1,
252:6, 252:18, 253:15, 253:22,
PAYCHECKS [1] - 211:13 309:10
254:12, 254:20, 255:12, 255:19,
PAYEE [2] - 234:20, 236:15 PRETTY [7] - 191:5, 220:12, 270:21,
255:22, 258:21, 262:2, 262:6, 262:12,
PAYMENT [6] - 196:15, 197:23, 198:5, 276:9, 281:11, 302:14, 305:17
262:13, 262:15
198:7, 198:8, 236:1 PREVIOUS [1] - 234:22
PIECE [3] - 275:21, 275:23, 276:4
PAYMENTS [4] - 193:15, 198:1, 200:17 PREVIOUSLY [9] - 169:4, 169:18,
PIPE [1] - 296:9
PAYROLL [22] - 167:19, 168:21, 168:25, 170:2, 175:16, 196:22, 213:17,
PLACE [2] - 196:24, 281:8
169:3, 173:12, 173:15, 175:9, 181:21, 223:22, 227:13, 281:19
PLANNING [1] - 275:9
182:23, 183:1, 186:9, 187:20, 197:23, PRIMARILY [3] - 200:9, 226:13, 243:16
PLATFORM [2] - 251:5, 251:9
198:1, 199:1, 199:6, 199:10, 200:18, PRIMARY [1] - 247:11
PLAY [1] - 276:18
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PRINTED [1] - 236:18 PURPORTEDLY [1] - 214:5 266:9
PRITTY [2] - 160:24, 312:15 PURPOSE [5] - 222:20, 258:23, 260:23, RAPID! [1] - 199:1
PROBLEM [7] - 163:19, 253:10, 292:24, 309:25, 310:2 RE [1] - 168:13
292:25, 297:3, 297:4, 300:25 PURPOSES [4] - 199:10, 219:8, 260:22, RE-SENT [1] - 168:13
PROBLEMS [1] - 297:15 310:4 REACH [1] - 237:23
PROCEEDINGS [6] - 209:6, 214:13, PURSUANT [5] - 194:5, 196:24, 199:25, READ [14] - 168:3, 263:13, 263:22,
215:14, 271:25, 311:14, 312:7 258:1, 270:2 281:8, 281:20, 282:12, 283:25,
PROCEEDINGS [2] - 160:9, 163:1 PURSUED [1] - 258:11 285:14, 285:24, 286:1, 287:6, 288:22,
PROCESS [4] - 240:22, 248:15, 260:7, PUT [14] - 173:9, 177:15, 216:9, 247:23, 290:14, 291:1
308:25 250:6, 272:2, 275:22, 276:4, 281:4, READING [3] - 280:20, 289:14, 292:1
PROCESSED [2] - 217:10, 217:11 282:12, 301:7, 305:7, 309:3, 311:7 REAL [10] - 169:25, 180:24, 201:21,
PRODUCED [2] - 290:23, 290:25 PUTTING [3] - 163:10, 259:17, 307:10 220:24, 221:5, 221:12, 221:23, 237:7,
PROFFER [8] - 268:16, 269:15, 270:2, PYFROM [33] - 167:24, 168:10, 169:9, 262:1, 274:7
270:4, 270:13, 272:25, 273:9, 277:17 170:12, 170:22, 177:18, 177:20, REALLY [12] - 190:11, 231:2, 231:24,
PROFFERS [1] - 275:2 181:12, 182:17, 183:19, 185:25, 238:8, 254:10, 258:22, 272:10, 301:3,
PROGRAM [3] - 181:4, 192:10, 198:25 189:11, 189:17, 189:25, 190:4, 301:21, 306:14, 306:21, 307:13
PROGRAM [1] - 185:21 190:23, 191:11, 191:20, 191:24, REASON [2] - 223:12, 231:24
PROHIBITED [1] - 1:9 194:2, 195:3, 195:8, 195:12, 195:17, REBUILDING [1] - 262:9
PROHIBITED [1] - 302:22 196:16, 197:6, 203:19, 204:22, REBUT [2] - 261:5, 310:4
PROJECT [6] - 220:24, 221:5, 221:12, 206:19, 207:7, 207:15, 207:17, 267:2 RECALLED [1] - 277:5
237:7, 237:8, 237:11 PYFROM-FOSTER [26] - 167:24, RECEIPT [2] - 234:5, 234:6
PROJECTS [1] - 221:23 168:10, 169:9, 170:12, 170:22, RECEIVED [11] - 167:1, 177:3, 248:4,
PROOF [1] - 275:8 177:18, 177:20, 181:12, 182:17, 257:22, 262:22, 265:11, 266:23,
PROPENSITY [3] - 260:11, 260:16, 183:19, 185:25, 189:11, 189:17, 274:25, 280:7, 282:2, 291:14
260:22 189:25, 190:23, 191:11, 191:20, RECENTLY [2] - 266:9, 305:9
PROPOSAL [2] - 221:4, 222:1 191:24, 195:12, 203:19, 204:22, RECESS [3] - 215:14, 271:25, 311:14
PROPOSE [1] - 300:21 206:19, 207:7, 207:15, 207:17, 267:2 RECIPIENT [1] - 229:23
PROSECUTOR [2] - 220:22, 221:2 PYFROM-FOSTER'S [2] - 190:4, 194:2 RECOGNIZE [6] - 202:1, 202:5, 203:15,
PROSECUTORS [1] - 269:10 227:11, 252:16, 290:24
PROTECTION [1] - 185:21 Q RECOGNIZED [1] - 225:15
PROVE [5] - 260:17, 271:9, 272:8, QUARTER [18] - 166:15, 166:18, RECOLLECTION [22] - 231:9, 267:6,
288:23, 292:11 166:19, 167:1, 172:23, 175:8, 176:14, 280:12, 281:1, 281:5, 281:7, 281:12,
PROVIDE [5] - 220:23, 241:7, 284:25, 176:16, 176:17, 176:20, 177:3, 282:6, 282:9, 282:10, 282:13, 284:22,
305:16, 310:24 177:15, 178:14, 180:8, 180:9, 211:15 285:1, 285:8, 285:10, 285:11, 285:15,
PROVIDED [2] - 221:3, 228:21 QUARTERLY [1] - 211:11 285:25, 286:8, 286:10, 286:11, 287:3
PROVIDING [1] - 167:14 QUESTION'S [1] - 286:13 RECORD [14] - 163:21, 163:22, 194:22,
PRUDENT [1] - 303:4 QUESTIONING [3] - 287:21, 303:5, 210:17, 215:21, 215:22, 216:10,
PUBLIC [1] - 212:12 308:3 224:20, 226:24, 229:17, 232:21,
PUBLISH [45] - 164:12, 164:20, 165:6, 234:25, 236:4, 236:25
QUESTIONINGS [1] - 258:11
165:21, 167:4, 168:1, 168:15, 168:23, RECORDED [1] - 160:23
QUESTIONS [25] - 209:7, 215:4, 215:6,
169:13, 170:9, 171:7, 171:17, 172:10, RECORDING [1] - 220:20
220:23, 222:4, 226:7, 238:18, 256:7,
172:16, 173:22, 176:3, 178:3, 178:25, 258:21, 273:21, 273:23, 274:2, 274:8, RECORDKEEPING [1] - 211:22
179:9, 183:13, 184:17, 184:25, 276:20, 284:6, 284:8, 284:13, 284:21, RECORDS [18] - 180:22, 194:1, 199:21,
185:15, 186:12, 186:23, 187:14, 290:2, 303:23, 307:1, 307:9, 307:15, 200:6, 203:4, 203:18, 203:23, 206:22,
189:4, 190:20, 192:15, 194:21, 195:5, 308:5, 308:7 211:2, 211:3, 212:11, 216:14, 216:22,
196:19, 197:2, 197:16, 198:18, 201:6, QUICK [1] - 169:25 221:15, 221:16, 221:23, 252:6, 304:3
202:16, 206:9, 206:11, 206:16, QUICKBOOKS [1] - 174:4 RECRUITED [3] - 239:18, 245:1, 245:2
207:22, 208:10, 208:23, 213:15, 214:3 QUITE [2] - 245:7, 245:10 RECRUITER [7] - 242:16, 243:4,
PUBLISHED [6] - 192:17, 196:21, 243:15, 244:17, 244:24, 248:18,
197:3, 207:24, 208:11, 208:24 264:15
R RECRUITERS [6] - 239:24, 240:3,
PULL [13] - 165:22, 167:5, 171:1,
184:10, 185:16, 198:6, 198:18, 201:7, RADAR [1] - 222:8 240:4, 247:25, 248:6, 248:12
204:9, 228:18, 230:3, 232:9, 234:11 RAISED [1] - 304:20 REDACTED [1] - 235:21
PULLING [1] - 170:5 RAN [1] - 212:14 REDDING [5] - 245:4, 245:19, 245:20,
PUNCTUATING [1] - 190:11 RANGE [1] - 204:11 279:1, 308:10
PUNCTUATION [3] - 190:6, 191:6, RANGES [1] - 204:11 REDIRECT [1] - 305:7
191:8 RAPID [18] - 198:25, 199:3, 199:16, REFER [1] - 228:25
PURCHASES [1] - 193:24 199:21, 200:7, 200:14, 200:22, REFERENCE [4] - 236:14, 307:5,
PURCHASING [1] - 193:15 200:24, 201:1, 201:14, 202:6, 202:7, 310:14, 310:16
PURE [1] - 291:25 202:19, 206:25, 207:19, 208:1, 208:5, REFERENCED [1] - 188:20
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REFERENCES [2] - 280:15, 287:23 REQUESTED [2] - 237:13, 261:23 RYAN [3] - 245:5, 247:14, 247:15
REFERENCING [1] - 1:7 REQUESTING [1] - 221:23
REFERRAL [1] - 238:8 RESEND [1] - 168:5 S
REFERRED [3] - 238:7, 289:23 RESERVATION [8] - 173:16, 181:22,
S-A-L-V-A-T-O-R-E [1] - 210:18
REFERRING [3] - 242:6, 278:25, 294:18 197:23, 200:16, 213:2, 233:19,
SALL [2] - 249:3, 249:5
REFERS [1] - 259:6 242:17, 242:21
SALVATORE [2] - 210:4, 210:18
REFLECT [2] - 194:22, 196:7 RESIDENCE [8] - 223:15, 223:17,
SALVATORE [1] - 210:11
REFRESH [18] - 231:3, 231:9, 241:7, 223:20, 225:3, 225:24, 226:2, 226:21,
SAMIR [1] - 160:15
267:6, 280:12, 280:25, 281:6, 281:12, 226:25
SARALIENE [1] - 160:18
282:5, 282:13, 284:21, 285:1, 285:7, RESOURCE [1] - 213:7
SAVE [2] - 275:3, 296:5
285:9, 285:15, 285:25, 286:8, 287:3 RESPONDING [1] - 191:7
SAW [6] - 184:23, 190:25, 197:13,
REFRESHED [3] - 281:5, 286:9, 286:11 RESPONSE [11] - 191:6, 221:6, 221:21,
200:17, 218:19, 229:6
REFRESHES [1] - 287:4 238:6, 257:23, 262:23, 265:12,
SBF [9] - 280:16, 287:25, 288:9, 289:12,
REFRESHING [2] - 282:9, 282:10 305:14, 306:18, 311:6, 311:9
289:24, 290:6, 291:2, 291:6, 291:10
REGARDING [4] - 198:25, 229:14, RESPONSES [2] - 190:7, 301:19
SCAM [1] - 291:19
265:2, 277:22 RESPONSIBLE [6] - 239:18, 242:22,
SCENARIO [1] - 283:14
REGISTER [1] - 255:24 243:11, 244:19, 279:16, 281:3
SCHEDULING [3] - 163:8, 209:12,
REGISTERED [1] - 223:14 REST [1] - 205:18
297:25
REGISTRATION [4] - 252:18, 253:21, RESTATE [1] - 229:16
SCREEN [1] - 253:8
254:19, 257:4 RESTRICTED [1] - 1:4
SCROLL [5] - 166:10, 174:11, 186:24,
REGULAR [2] - 212:1, 212:18 RETAIL [1] - 193:24
193:10, 201:7
REGULARLY [3] - 207:7, 207:12, RETRIEVAL [1] - 212:5
SE [1] - 272:9
212:11 RETURNS [1] - 214:24
SEARCH [5] - 216:17, 216:21, 216:23,
REINSTATED [1] - 256:1 REVENUE [3] - 167:12, 210:21, 211:1
216:25, 217:24
RELATED [3] - 181:3, 221:5, 236:2 REVIEW [8] - 181:1, 191:22, 192:3,
SEARCHES [2] - 212:14, 212:16
RELATES [1] - 266:4 192:7, 200:6, 201:25, 251:10, 257:19
SEAT [2] - 277:4, 283:6
RELEVANCE [12] - 204:3, 205:1, REVIEWED [5] - 189:23, 250:20,
SEATED [6] - 163:2, 163:23, 215:24,
205:23, 206:6, 256:3, 272:3, 272:5, 251:13, 257:17, 264:18
271:21, 277:6, 277:9
276:8, 276:9, 276:11, 294:3, 294:4 REVIEWING [1] - 250:7
SECOND [20] - 167:5, 202:12, 222:16,
RELEVANT [21] - 204:21, 204:24, 205:1, RICK [1] - 249:10
222:17, 222:23, 223:2, 225:11,
205:2, 205:7, 205:11, 205:15, 205:23, RICKY [31] - 244:23, 244:24, 245:23,
225:12, 228:9, 229:10, 233:12, 237:9,
256:7, 258:22, 258:25, 259:19, 246:8, 247:17, 264:4, 265:1, 265:5,
237:15, 238:14, 272:2, 288:14,
260:25, 261:3, 261:5, 290:11, 293:25, 265:24, 266:14, 266:21, 267:24,
290:18, 291:4, 294:8, 301:5
295:25, 305:22, 307:8, 307:14 268:7, 268:8, 269:15, 270:22, 271:6,
SECRET [14] - 280:1, 280:13, 281:23,
RELIED [1] - 271:9 271:9, 271:10, 272:7, 272:8, 272:11,
287:11, 287:22, 288:16, 288:20,
RELISTEN [2] - 279:7, 280:10 272:21, 273:6, 274:5, 274:19, 275:6,
289:8, 289:9, 289:20, 289:23, 290:24,
RELY [2] - 275:5, 309:24 277:15, 278:23, 308:5, 308:9
294:25, 295:2
RELYING [2] - 274:19, 274:21 RIGHTS [3] - 308:24, 308:25
SECRETARY [5] - 230:24, 252:6,
REMEMBER [15] - 220:25, 221:7, 221:8, RING [1] - 239:21
252:17, 255:23, 257:4
224:5, 232:12, 234:2, 238:4, 240:7, RISK [1] - 299:15
SECRETARY [2] - 254:5, 254:25
240:8, 241:4, 257:6, 257:7, 262:24, RMR [2] - 160:24, 312:15
SECTION [1] - 228:18
263:1, 285:18 ROAD [2] - 272:7, 276:14
SECTIONS [2] - 232:9
REMINDED [1] - 271:18 ROAD [2] - 192:24, 193:1
SEE [32] - 168:22, 174:16, 174:23,
REMINDS [1] - 285:20 ROADRUNNER [7] - 213:6, 227:15,
176:24, 181:2, 188:19, 191:16,
REMITTER [1] - 234:19 229:4, 229:6, 230:20, 230:23, 230:24
192:25, 193:8, 199:14, 201:10,
RENEWED [1] - 276:21 ROLE [8] - 211:1, 239:16, 240:9,
228:17, 229:2, 229:12, 229:14,
REPLIED [1] - 168:6 240:10, 240:18, 240:19, 242:15, 308:2
232:15, 239:3, 243:18, 247:1, 254:1,
REPLY [1] - 311:6 ROOM [4] - 213:3, 245:4, 245:20,
258:5, 263:18, 267:2, 267:18, 276:10,
REPORT [22] - 280:11, 280:20, 280:21, 245:21
276:20, 283:1, 283:4, 291:6, 291:17,
281:4, 281:8, 281:13, 281:20, 281:22, ROSWELL [2] - 192:24, 193:1
295:18, 311:13
282:8, 285:3, 285:16, 285:19, 285:23, RULE [10] - 194:6, 200:1, 252:21, 258:2,
SEEING [9] - 231:19, 257:7, 257:8,
285:24, 286:11, 286:14, 286:15, 258:9, 258:14, 259:4, 260:4, 260:11,
262:24, 262:25, 263:1, 280:11, 282:5
288:22, 289:5, 289:14, 290:20, 292:4 263:5
SEEKING [3] - 237:16, 259:13, 310:20
REPORTER [4] - 1:4, 1:8, 160:24, RULE [2] - 256:23, 274:13
SEEM [8] - 220:11, 262:14, 286:20,
312:15 RULES [2] - 258:3, 283:18
287:7, 292:17, 292:19, 297:14, 303:4
REPORTS [4] - 168:21, 175:9, 286:2, RULES [1] - 281:11
SEEMING [1] - 282:23
286:3 RULING [1] - 310:12
SEIZED [1] - 217:11
REPRESENT [1] - 210:25 RUN [3] - 276:15, 294:23, 295:15
SEMANTICS [1] - 286:13
REPRESENTED [2] - 196:12, 269:1 RUNG [2] - 292:19, 292:20
SEND [9] - 168:12, 174:2, 179:7,
REQUEST [2] - 221:16, 225:4 RUNNING [1] - 297:12
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179:12, 180:16, 185:19, 200:22, SHOWS [6] - 166:16, 205:12, 220:7, 221:21, 227:1, 266:6
213:22, 248:13 235:1, 256:8, 286:5 SPELL [1] - 210:17
SENDER [1] - 229:21 SIC [2] - 222:4, 293:11 SPEND [2] - 220:15, 249:25
SENDING [2] - 174:4, 273:11 SID [2] - 225:13, 225:16 SPENT [6] - 203:1, 220:16, 223:17,
SENDS [2] - 265:24, 266:14 SIDE [24] - 164:21, 165:7, 167:5, 223:19, 250:2, 250:7
SENSE [2] - 286:18, 287:5 172:17, 173:9, 173:10, 181:15, SPILL [1] - 287:6
SENT [31] - 165:9, 167:8, 168:13, 182:20, 189:5, 189:7, 189:10, 225:12, SPREADSHEET [8] - 167:21, 167:23,
168:25, 169:4, 169:15, 169:18, 226:5, 253:5, 272:2, 310:7, 310:10 168:25, 169:4, 173:12, 173:15,
170:19, 172:3, 175:16, 176:1, 178:19, SIGNAL [3] - 251:8, 251:9, 251:11 181:21, 182:23
179:25, 181:18, 182:24, 183:2, 185:8, SIGNATURE [9] - 195:8, 227:15, SPREADSHEETS [3] - 167:19, 186:9,
185:10, 186:2, 187:8, 188:24, 198:21, 227:22, 227:23, 228:2, 228:4, 228:9, 187:20
199:15, 251:25, 261:1, 261:17, 229:6, 265:8 STACEY [1] - 228:12
261:21, 267:1, 267:4 SIGNED [2] - 265:7, 266:17 STAMP [14] - 166:24, 176:24, 177:1,
SENTENCE [1] - 190:8 SIGNER [1] - 231:22 177:10, 177:16, 177:20, 178:15,
SENTENCE-TYPE [1] - 190:8 SIGNIFY [1] - 226:5 178:16, 178:19, 178:20, 213:20,
SENTENCES [4] - 190:5, 190:12, 191:5, SIMILAR [5] - 220:3, 221:3, 235:17, 265:8, 265:9, 265:10
191:7 240:19, 251:7 STAMP'S [1] - 178:17
SEPARATE [3] - 225:4, 294:24, 295:2 SINGLE [2] - 201:1, 275:14 STAMPED [19] - 164:25, 167:1, 169:20,
SEPARATED [1] - 224:3 SITE [8] - 203:6, 203:8, 207:3, 298:19, 172:4, 175:18, 176:9, 177:3, 184:3,
SEPARATELY [1] - 205:9 299:1, 300:15, 300:16, 301:7 185:6, 185:10, 186:16, 187:5, 187:8,
SEPARATION [1] - 224:2 SITUATION [1] - 219:21 188:1, 188:16, 188:25, 213:23, 214:1,
SERIES [2] - 173:24, 212:23 SIX [3] - 296:13, 298:10 214:9
SERIOUS [1] - 194:23 SKIP [1] - 293:17 STAMPS [4] - 166:17, 170:25, 171:4,
SERVE [2] - 219:10, 219:25 SLATON [6] - 244:13, 244:15, 247:5, 171:25
SERVED [1] - 262:6 247:6, 247:8, 247:12 STAND [4] - 209:23, 277:5, 283:20,
SERVICE [17] - 167:12, 210:21, 211:1, SLIGHT [2] - 276:9, 276:11 299:22
280:1, 280:13, 281:23, 287:11, SLIGHTLY [1] - 300:21 STANDARD [2] - 262:14, 310:13
287:23, 288:16, 288:20, 289:8, 289:9, SMALL [6] - 280:17, 287:25, 289:13, STANDS [1] - 225:16
289:20, 289:23, 290:24, 294:25, 295:2 290:7, 291:3, 291:11 STAR [4] - 213:3, 245:4, 245:20, 245:21
SERVICES [17] - 164:7, 165:19, 165:20, SMH [1] - 168:6 START [1] - 231:18
166:16, 167:13, 168:22, 171:23, SNEAK [1] - 194:18 STARTED [6] - 169:10, 181:12, 182:17,
197:19, 197:22, 198:5, 200:17, 213:3, SO.. [2] - 274:16, 298:8 202:22, 270:19, 299:25
213:4, 213:7, 245:21, 247:2, 247:3 SOLUTION [2] - 300:22, 302:15 STARTING [1] - 195:18
SERVICES [1] - 195:4 SOLVE [1] - 300:24 STATE [1] - 210:17
SESSION [1] - 160:6 SOLVED [1] - 253:10 STATE [5] - 230:24, 252:6, 252:17,
SESSION [1] - 277:17 SOMEONE [16] - 209:14, 255:2, 259:3, 255:23, 257:4
SESSIONS [2] - 268:16, 269:15 259:6, 275:10, 275:23, 276:3, 280:16, STATEMENT [23] - 180:19, 180:24,
SET [6] - 172:25, 199:6, 199:7, 206:22, 284:16, 287:24, 288:9, 289:12, 193:5, 193:19, 195:17, 196:4, 197:19,
256:7, 266:9 289:16, 290:6, 291:2, 291:10 220:6, 266:1, 266:4, 266:15, 266:17,
SETS [3] - 262:13, 270:4, 270:5 SOMETIMES [1] - 240:2 267:2, 286:20, 287:13, 292:6, 292:11,
SETTING [1] - 270:13 SOMEWHERE [3] - 220:13, 224:9, 293:14, 294:19, 295:5, 295:12, 295:16
SETUP [1] - 308:6 306:25 STATEMENTS [2] - 270:16, 274:13
SEVERAL [4] - 175:8, 205:5, 244:21, SOON [1] - 163:18 STATES [6] - 160:1, 160:4, 160:10,
309:7 SORRY [22] - 169:23, 176:16, 194:10, 160:16, 160:25, 312:3
SEVERELY [1] - 300:4 202:13, 209:2, 214:3, 248:2, 252:13, STATES [1] - 210:4
SHAKES [1] - 307:2 257:19, 259:24, 260:14, 264:21, STAYED [1] - 191:25
SHAKING [1] - 168:6 266:19, 267:21, 272:13, 288:3, 289:6, STAYING [1] - 226:21
SHOCKED [1] - 220:7 291:7, 292:16, 301:5, 303:17, 306:17 STENOGRAPHICALLY [1] - 160:23
SHOP [1] - 213:8 SORT [19] - 190:9, 190:13, 193:24, STEP [5] - 209:22, 215:7, 272:16,
SHORT [7] - 190:10, 215:12, 271:16, 239:17, 240:11, 242:16, 243:3, 243:4, 283:10, 311:4
296:15, 297:6, 298:11, 304:7 243:15, 251:6, 259:22, 259:25, 264:1, STICKER [1] - 174:25
SHORTENED [3] - 190:10, 190:13, 268:16, 270:4, 270:5, 273:9, 273:13, STILL [12] - 201:23, 240:21, 254:22,
191:8 296:18 254:25, 256:8, 257:17, 261:9, 292:21,
SHORTLY [1] - 180:2 SOUND [2] - 224:9, 278:1 296:11, 301:2, 304:15, 311:11
SHOW [10] - 219:19, 231:2, 236:6, SOUNDS [6] - 170:16, 256:22, 260:11, STIPULATION [1] - 259:9
256:6, 258:19, 258:24, 259:14, 261:4, 260:19, 273:21, 286:12 STITES [32] - 164:6, 209:20, 215:18,
294:13, 295:10 SOUTH [1] - 279:22 216:6, 224:18, 231:9, 238:16, 238:22,
SHOWING [6] - 204:21, 205:7, 205:15, SPEAKING [1] - 302:23 261:16, 275:6, 281:19, 291:23, 293:1,
219:15, 226:11, 262:20 SPECIAL [2] - 209:18, 209:20 295:11, 296:12, 296:24, 299:12,
SHOWN [2] - 213:17, 221:9 SPECIFICALLY [5] - 214:21, 214:23, 299:15, 299:16, 299:18, 299:21,
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330
299:24, 300:9, 300:23, 301:3, 301:8, TARGET [1] - 274:25 THANKING [1] - 167:13
302:5, 302:6, 302:7, 302:21, 303:5 TASKED [1] - 211:2 THAT'D [1] - 247:17
STITES [1] - 162:3 TAX [3] - 211:20, 214:16, 214:23 THE [179] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10,
STITES'S [3] - 163:11, 209:18, 294:24 TAXES [1] - 211:6 160:1, 160:10, 160:14, 160:17,
STONE [1] - 225:17 TAXPAYER [4] - 212:8, 213:25, 214:8, 160:20, 163:2, 163:5, 163:16, 163:19,
STORED [1] - 212:7 214:9 163:21, 163:23, 170:4, 170:7, 190:18,
STORES [1] - 193:24 TAXPAYERS [1] - 212:10 194:9, 194:11, 194:14, 194:20,
STRING [3] - 189:7, 189:10, 190:22 TEAM [1] - 300:6 194:22, 195:1, 195:2, 197:1, 198:8,
STRINGS [1] - 189:13 TECHNIQUE [1] - 218:19 200:4, 202:15, 204:7, 204:9, 204:17,
STRUCTURE [1] - 190:8 TECHNOLOGY [1] - 213:7 204:20, 204:25, 205:10, 205:19,
STUFF [5] - 190:11, 248:23, 261:4, TELDRIN [106] - 164:16, 164:18, 164:19, 206:2, 206:11, 206:15, 209:2, 209:4,
283:25 165:9, 166:1, 166:3, 166:5, 166:8, 209:9, 209:24, 210:2, 210:5, 210:6,
STYLES [1] - 190:1 167:8, 168:6, 168:14, 168:18, 168:25, 210:7, 210:8, 210:9, 215:2, 215:3,
STYMIE [1] - 302:2 169:4, 171:10, 172:13, 173:6, 173:25, 215:7, 215:9, 215:11, 215:19, 215:21,
SUBJECT [11] - 164:19, 172:14, 173:7, 174:3, 175:4, 175:16, 175:23, 177:13, 215:24, 231:6, 238:17, 238:18,
175:5, 175:24, 178:8, 182:12, 183:18, 178:7, 178:18, 179:12, 180:16, 181:2, 252:24, 256:5, 256:11, 256:14,
187:18, 188:7, 272:15 181:9, 181:18, 182:24, 183:2, 183:16, 256:18, 256:22, 258:5, 258:7, 258:17,
SUBJECT [1] - 184:21 184:12, 184:20, 185:9, 185:19, 259:2, 259:11, 259:24, 260:2, 260:5,
SUBMIT [2] - 239:20, 245:1 186:21, 188:6, 188:21, 189:8, 189:20, 260:13, 261:7, 261:11, 261:14, 263:7,
SUBMITTED [2] - 165:3, 200:21 189:21, 189:24, 191:17, 191:20, 265:17, 271:12, 271:21, 272:2,
SUBMITTING [1] - 239:18 191:25, 192:8, 192:12, 192:20, 193:5, 272:16, 272:18, 272:20, 273:15,
193:19, 196:15, 198:9, 198:21, 274:11, 274:17, 276:6, 277:3, 277:6,
SUBPOENA [15] - 219:6, 219:10,
199:15, 201:17, 201:20, 202:8, 277:9, 280:24, 281:10, 281:14,
219:25, 221:6, 221:10, 221:16,
202:18, 203:1, 203:4, 203:9, 203:18, 282:15, 282:23, 283:6, 283:13,
221:18, 221:22, 237:14, 241:25,
203:23, 204:22, 205:12, 206:19, 283:22, 283:24, 284:3, 284:5, 284:8,
242:3, 257:23, 262:23, 265:12, 265:13
207:3, 207:6, 207:15, 207:17, 207:19, 284:12, 284:19, 284:24, 285:6,
SUBPOENAED [2] - 241:14, 242:9
208:19, 244:10, 246:11, 246:12, 285:12, 286:5, 286:12, 286:18,
SUBPOENAS [1] - 216:15
248:15, 249:14, 249:17, 249:19, 286:22, 287:1, 287:22, 288:4, 289:11,
SUBSTANTIVE [1] - 259:8
249:22, 250:18, 270:8, 271:6, 271:10, 289:25, 290:2, 290:12, 290:20, 291:1,
SUCCESS [3] - 174:16, 213:4, 246:16
271:11, 272:24, 273:2, 273:10, 291:6, 291:9, 291:17, 291:22, 292:5,
SUGGEST [1] - 275:18
273:13, 274:3, 274:4, 274:20, 274:23, 292:13, 293:8, 293:10, 293:17,
SUGGESTED [2] - 299:20, 305:19
275:10, 276:5, 277:23, 278:1, 278:8, 293:20, 293:22, 294:3, 294:6, 294:9,
SUGGESTING [3] - 305:1, 309:8,
279:9, 294:17, 295:8, 295:11, 308:11, 294:21, 295:17, 296:1, 296:3, 296:19,
309:15
308:19 297:2, 297:14, 297:21, 298:9, 298:16,
SUGGESTION [1] - 275:16
TELDRIN [2] - 160:7, 160:17 298:21, 299:4, 299:13, 300:7, 300:16,
SUMMARIZED [1] - 206:24 300:18, 300:20, 301:10, 301:13,
TELDRIN_FOSTER@YAHOO [3] -
SUMMARY [2] - 202:18, 206:18 301:22, 302:2, 302:4, 302:19, 303:1,
182:12, 186:7, 187:17
SUPPLY [1] - 213:8 303:3, 303:22, 304:8, 304:10, 304:16,
TELDRINFOSTER@ICLOUD [1] -
SUPPORT [1] - 274:22 306:3, 306:18, 306:24, 308:12, 309:1,
169:18
SUPPOSED [2] - 248:7, 296:15 310:6, 310:11, 310:22, 311:1
TELEGRAM [6] - 250:20, 250:21,
SUPPOSEDLY [1] - 214:9 THEMSELVES [1] - 275:3
250:24, 251:1, 251:2, 251:14
SURPRISED [2] - 220:7, 220:11 THEREFORE [4] - 256:23, 258:14,
TELEPHONE [2] - 280:7, 285:7
SUSIE [1] - 273:17 288:12, 311:5
TEMPLATE [1] - 167:23
SUSPECT [1] - 291:19 THINKS [1] - 267:9
TEN [2] - 216:22, 273:24
SUSTAIN [1] - 206:2 THIRD [2] - 180:8, 286:3
TERM [1] - 259:6
SUSTAINED [3] - 293:22, 294:7, 295:21 THOMAS [148] - 164:17, 165:10, 166:2,
TERMS [2] - 270:5, 270:13
SWORN [1] - 210:12 167:8, 168:5, 168:9, 168:12, 168:19,
TESTIFIED [13] - 210:13, 226:20,
SYSTEM [9] - 211:21, 211:22, 212:1, 169:10, 170:11, 170:14, 170:24,
230:15, 255:5, 258:10, 258:13, 259:7,
212:4, 212:5, 212:6, 212:7, 212:14, 171:11, 172:14, 173:7, 173:24, 174:2,
264:13, 281:2, 287:19, 301:14,
212:16 175:5, 175:24, 176:7, 177:9, 177:17,
301:16, 301:20
SYSTEM [2] - 212:6, 213:7 178:8, 178:18, 179:7, 179:12, 179:23,
TESTIFY [5] - 259:10, 281:5, 304:14,
305:13, 306:2 180:16, 181:2, 181:10, 181:12,
T TESTIFYING [5] - 211:3, 231:24,
181:18, 182:12, 182:18, 182:24,
183:2, 183:17, 183:19, 184:12,
T-MOBILE [3] - 203:4, 203:23, 206:22 232:12, 300:1, 308:23
184:20, 185:8, 185:19, 185:24, 186:8,
TAL [1] - 160:14 TESTIMONY [13] - 163:7, 209:18, 225:1,
186:22, 187:18, 188:7, 188:21, 189:8,
TALDRID [2] - 278:4, 278:5 228:21, 233:22, 234:22, 236:1, 259:7,
189:11, 189:16, 189:24, 190:4, 190:9,
TALDRID [1] - 274:6 259:9, 272:15, 274:18, 288:5, 300:24
190:22, 191:11, 191:19, 191:25,
TALDRID [1] - 278:6 TEXT [7] - 184:12, 190:10, 190:22,
192:1, 192:8, 192:13, 198:4, 198:21,
TALDRIN [1] - 278:3 233:1, 233:2, 233:3, 236:5
199:15, 204:15, 208:6, 217:21,
TALKS [2] - 220:1, 220:2 TEXTS [2] - 206:19, 207:8
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 173 of 174
331
237:21, 237:23, 239:15, 239:17, TRANSACTIONS [15] - 193:13, 193:22, UNKNOWN [3] - 280:15, 287:24, 295:9
240:5, 240:14, 240:24, 241:12, 202:6, 202:18, 202:21, 203:10, UNLESS [2] - 275:8, 306:2
243:23, 245:8, 245:10, 246:1, 246:6, 206:25, 224:23, 228:22, 230:3, 230:6, UNSIGNED [1] - 266:1
246:23, 247:7, 247:10, 247:19, 230:7, 230:18, 231:18, 232:12 UP [29] - 163:10, 170:5, 174:20, 176:11,
247:20, 247:23, 248:5, 248:12, TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9, 177:7, 199:7, 199:12, 204:9, 209:20,
248:22, 248:24, 249:2, 249:8, 250:1, 160:9 213:9, 219:15, 219:19, 220:7, 221:9,
251:10, 251:14, 252:3, 253:17, TRANSCRIPT [3] - 285:1, 285:3, 312:7 222:14, 224:15, 226:8, 227:10, 230:3,
253:18, 254:3, 254:5, 254:22, 254:25, TRANSCRIPTS [1] - 1:3 234:11, 256:7, 265:2, 266:9, 266:22,
255:6, 255:17, 256:8, 258:12, 258:13, TRANSFER [1] - 199:9 294:16, 296:11, 303:4, 304:25
258:24, 259:13, 261:19, 261:21, TRANSFERS [2] - 193:25, 200:14 US [2] - 268:21, 269:10
264:6, 264:7, 264:11, 264:25, 265:5, TRANSPORTATION [4] - 213:2, 243:17, USAA [1] - 236:16
265:22, 266:8, 266:15, 266:21, 267:1, 243:23, 244:8 USES [1] - 294:14
267:4, 267:25, 268:6, 268:9, 273:3, TRAVEL [8] - 173:16, 181:22, 197:24, UTILITY [1] - 174:6
273:4, 273:7, 273:8, 274:4, 274:10, 200:17, 213:2, 233:18, 242:17, 242:21 UTWUAN [3] - 166:3, 166:5, 166:8
275:16, 275:22, 277:20, 278:24, TRIAL [1] - 206:9
279:5, 305:2, 306:13, 306:14, 307:16,
307:18, 307:20, 308:4, 308:8, 309:15,
TRIAL [7] - 229:18, 258:10, 258:13, V
259:7, 275:14, 306:7, 309:22
309:18, 310:5 VARIOUS [5] - 167:19, 179:7, 200:12,
TRIAL [1] - 160:9
THOMAS'S [10] - 190:7, 191:4, 199:19, 201:3, 304:3
TROUBLE [1] - 191:12
217:5, 241:17, 245:13, 249:17, VEHICLE [1] - 223:14
TRUE [15] - 262:10, 264:12, 273:7,
250:10, 257:23, 309:8 VERBIAGE [1] - 265:6
273:14, 273:17, 273:18, 273:19,
THOUSAND [1] - 208:9 VERBOSE [1] - 190:5
287:20, 288:8, 288:10, 288:18,
THREE [11] - 170:23, 206:11, 206:13, VERSION [5] - 206:8, 214:1, 214:9,
288:25, 289:1, 309:19, 312:6
234:7, 256:4, 273:25, 298:16, 299:6, 271:1, 271:3
TRUTH [14] - 274:15, 282:17, 286:15,
299:8, 301:2, 303:21 VIA [8] - 168:10, 169:10, 177:18,
286:23, 287:7, 287:14, 288:8, 288:11,
THROUGHOUT [1] - 207:12 181:12, 182:18, 185:24, 191:25,
289:2, 289:19, 292:8, 292:11, 292:21,
TIE [1] - 303:4 277:17
294:12
TIED [2] - 201:3, 307:16 VIEW [1] - 216:10
TRY [4] - 208:16, 217:23, 217:24, 260:7
TIMING [1] - 296:10 VIOLATES [1] - 308:23
TRYING [13] - 194:18, 257:5, 260:20,
TIRE [4] - 187:11, 187:18, 188:19, 213:6 VISIT [2] - 226:17, 237:9
266:25, 271:5, 275:3, 277:1, 283:14,
TIRES [1] - 249:11 286:19, 287:10, 287:12, 306:9, 309:14 VOIDED [1] - 174:5
TITLE [2] - 210:22, 210:23 TURN [5] - 227:8, 252:11, 253:4, VOIR [1] - 162:4
TO [2] - 1:5, 1:9 264:16, 295:4 VOLUME [1] - 160:6
TO-THE-POINT [1] - 190:13 TURNED [1] - 295:6 VS [1] - 160:5
TODAY [1] - 277:2 TWICE [1] - 194:15
TOGETHER [3] - 243:24, 298:15, 311:7 TWO [24] - 171:20, 172:19, 175:12, W
TOMORROW [15] - 163:9, 283:1, 176:6, 187:1, 188:12, 192:9, 213:12, WADED [1] - 283:2
296:11, 296:14, 296:25, 297:5, 219:8, 226:17, 227:19, 232:14, WAGES [1] - 166:17
297:10, 298:6, 299:15, 300:1, 301:2, 232:15, 234:13, 287:10, 290:10, WAITING [2] - 170:25, 171:4
302:5, 302:21, 302:22, 311:7 290:15, 298:10, 299:4, 304:5, 304:6, WALKING [1] - 222:13
TOOK [10] - 197:8, 209:11, 234:18, 305:14, 307:25 WANTS [2] - 285:7, 304:14
235:13, 236:12, 276:1, 276:2, 278:19, TWO-PAGE [2] - 227:19, 290:15 WARRANT [2] - 216:25, 217:24
292:16 TWOFOLD [1] - 219:8 WARRANTS [3] - 216:17, 216:22,
TOP [9] - 176:12, 185:16, 191:14, TYING [1] - 304:25 216:23
198:19, 239:7, 253:23, 263:14, TYPE [4] - 190:8, 217:12, 220:3, 251:9 WASTING [1] - 276:15
267:13, 290:11 TYPES [3] - 221:15, 222:1, 276:20 WEBEX [3] - 269:20, 269:22, 277:17
TOPIC [1] - 224:13 TYPICAL [1] - 213:25 WEBSTER [112] - 160:18, 163:15,
TOPS [1] - 298:15
170:3, 190:16, 194:7, 196:25, 200:2,
TOTAL [4] - 216:22, 298:16, 299:6,
U 202:12, 204:3, 204:13, 204:19,
299:8
UNDER [9] - 252:21, 258:3, 260:23, 205:20, 215:13, 215:16, 238:19,
TOTALLY [1] - 303:17
261:9, 263:5, 272:4, 276:12, 276:21, 238:21, 239:3, 239:5, 252:20, 252:25,
TOUCH [1] - 253:8
292:20 253:2, 253:7, 253:10, 253:12, 256:6,
TOWARDS [2] - 179:4, 306:5
UNDERLYING [2] - 288:24, 292:6 256:16, 256:20, 257:1, 257:2, 258:1,
TOWER [1] - 299:7 258:6, 259:12, 260:1, 260:14, 260:21,
TOWN [2] - 297:9, 300:15 UNDERSTATEMENT [1] - 250:5
UNDERSTOOD [1] - 248:2 261:12, 261:15, 263:4, 263:8, 263:9,
TRADITIONAL [1] - 190:9 265:15, 265:20, 271:5, 272:9, 272:19,
TRAIL [1] - 208:2 UNEMPLOYMENT [1] - 211:20
272:21, 273:22, 274:14, 277:2,
TRAIT [1] - 260:18 UNITED [6] - 160:1, 160:4, 160:10,
277:12, 277:13, 280:25, 281:11,
TRANSACTION [5] - 198:15, 202:24, 160:16, 160:25, 312:3
281:17, 281:18, 282:16, 283:21,
228:15, 229:1, 232:9 UNITED [1] - 210:4
283:23, 284:2, 284:7, 284:11, 284:16,
Case 1:20-cr-00296-JPB-CMS Document 1027 Filed 06/14/24 Page 174 of 174
332
286:21, 286:25, 287:9, 288:3, 288:7, 210:8, 215:2, 215:9, 238:17
289:6, 289:22, 290:1, 290:10, 290:17, WITNESS'S [4] - 282:10, 285:10,
290:23, 291:4, 291:7, 291:13, 291:18, 285:15, 286:8
293:2, 293:9, 293:13, 293:19, 293:21, WITNESSES [18] - 216:12, 218:17,
293:23, 294:5, 294:8, 294:10, 295:23, 272:22, 296:13, 296:24, 297:6, 297:7,
296:2, 296:10, 296:22, 297:18, 298:11, 298:12, 298:17, 298:25,
298:24, 299:12, 299:20, 300:21, 299:5, 299:17, 300:10, 301:6, 302:8,
301:5, 301:11, 301:14, 302:1, 302:3, 303:15, 304:13
302:16, 302:25, 303:9, 303:17, WOMAN [1] - 294:15
303:20, 303:25, 304:2, 305:8, 306:17, WONDERFUL [1] - 163:25
307:21, 308:13, 310:23 WONDERING [1] - 242:8
WEBSTER [31] - 205:19, 238:18, 256:5, WORD [2] - 261:8, 266:19
259:11, 260:10, 260:13, 260:20, WORDS [5] - 190:10, 190:11, 191:7,
272:6, 272:18, 272:20, 275:6, 275:8, 191:8, 267:14
276:7, 277:1, 277:10, 280:24, 281:10, WORKS [1] - 243:1
282:15, 284:9, 286:19, 289:11, WORRIED [4] - 293:6, 293:11, 296:23,
292:14, 297:16, 300:8, 302:24, 297:12
303:14, 306:11, 306:20, 309:1, 309:6, WOULD.. [1] - 241:7
310:22 WRITE [4] - 216:23, 265:2, 280:22,
WEDNESDAY [1] - 297:8 285:23
WEEK [3] - 297:11, 300:14, 300:15 WRITE-UP [1] - 265:2
WEEKEND [6] - 297:11, 300:2, 300:23, WRITING [1] - 191:5
301:12, 302:13, 311:9 WROTE [4] - 285:16, 285:19, 290:21,
WELCOME [1] - 215:2 292:23
WELLS [5] - 224:22, 224:23, 226:4,
227:1, 234:6
Y
WEST [1] - 297:9
WHATSAPP [33] - 168:10, 168:12, Y'ALL [9] - 163:2, 163:23, 220:18,
169:11, 170:11, 177:18, 178:10, 231:6, 271:21, 277:6, 277:9, 283:6,
180:2, 181:1, 181:13, 182:18, 184:22, 311:9
185:9, 185:24, 188:20, 189:10, YAHOO [16] - 164:18, 168:18, 169:1,
189:23, 191:25, 192:7, 198:21, 169:15, 170:19, 172:3, 175:4, 175:13,
205:21, 205:25, 217:3, 217:5, 232:20, 176:1, 183:2, 183:9, 183:16, 183:24,
233:3, 236:5, 249:22, 250:16, 251:6, 185:8, 187:7, 188:23
267:7, 273:11, 275:25 YEAR [5] - 211:14, 214:22, 214:23,
WHATSAPPED [1] - 178:18 231:1, 253:23
WHATSAPPS [2] - 189:8, 249:18 YEARS [1] - 256:4
WHITTLEY [3] - 245:5, 247:14, 247:15 YESTERDAY [6] - 170:23, 194:12,
WHOLE [3] - 286:17, 301:17, 308:6 197:23, 203:5, 255:5, 300:1
WILL [1] - 1:4 YOU [2] - 1:5, 1:8
WILLING [2] - 220:15, 301:25 YOU-ALL [1] - 282:25
WIRE [1] - 232:17
WITH [1] - 1:10 Z
WITHDRAW [1] - 196:23 ZELLE [2] - 193:15, 193:24
WITHDRAWAL [4] - 193:14, 196:7, ZOOM [2] - 269:20, 277:17
234:5, 234:6
WITHDRAWALS [1] - 193:25
WITHDRAWN [1] - 256:23
WITHHOLDINGS [1] - 211:12
WITNESS [39] - 162:2, 163:7, 209:8,
209:11, 209:15, 209:19, 209:23,
209:25, 210:12, 210:23, 210:24,
210:25, 215:5, 216:1, 231:5, 258:10,
258:13, 258:15, 259:3, 259:5, 259:6,
272:17, 276:24, 277:5, 282:13,
283:12, 285:16, 285:17, 285:20,
297:5, 298:1, 298:8, 299:3, 299:17,
301:24, 301:25, 302:12
WITNESS [2] - 209:23, 215:10
WITNESS [7] - 195:2, 198:8, 210:6,
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