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Transcript of Jury Trial Proceedings, Volume 8 — Jury Charge — Carla Jackson and Teldrin Foster

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Transcript of the Volume 8 (PM Session) jury trial proceedings, the jury charge, 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 14, 2024; it is Document 1032, filed June 14, 2024. The Court instructs the jury on proof beyond a reasonable doubt, the evidence, witness credibility and defendants' statements. It states that the indictment charges 42 separate crimes called counts, that Defendant Foster is charged in Counts 1 through 28, Counts 30 through 41 and Count 59, and that Defendant Jackson is charged in Counts 46 and 47. The instructions then turn to conspiracy, aiding and abetting, bank fraud and wire fraud.

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“Transcript of Jury Trial Proceedings, Volume 8 — Jury Charge — Carla Jackson and Teldrin Foster.” Original at ecf.gand.uscourts.gov, No. 1:20-cr-00296-JPB-CMS, Doc. 1032. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-dixon/2024-02-14-jury-trial-transcript-vol8-dkt-1032/, SHA-256 cfea955dd83fdc643644dbb404e053b93e14891d264eba75dcc1bb320e93ce02.

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Case 1:20-cr-00296-JPB-CMS   Document 1032    Filed 06/14/24   Page 1 of 49




               THE FOLLOWING IS THE PDF OF AN OFFICIAL

TRANSCRIPT.    OFFICIAL TRANSCRIPTS MAY ONLY BE FILED IN CM/ECF

BY THE OFFICIAL COURT REPORTER AND WILL BE RESTRICTED IN

CM/ECF FOR A PERIOD OF 90 DAYS.        YOU MAY CITE TO A PORTION

OF THE ATTACHED TRANSCRIPT BY THE DOCKET ENTRY NUMBER,

REFERENCING PAGE AND LINE NUMBER, ONLY AFTER THE COURT

REPORTER HAS FILED THE OFFICIAL TRANSCRIPT; HOWEVER, YOU ARE

PROHIBITED FROM ATTACHING A FULL OR PARTIAL TRANSCRIPT TO ANY

DOCUMENT FILED WITH THE COURT.




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                                                                              141



 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 8 (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 14, 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    (PROCEEDINGS HELD IN OPEN COURT AT 1:59 PM, ATLANTA, GEORGIA)

 2               (The jury entered the courtroom.)

 3               THE COURT:   Y'all can be seated.

 4               Members of the jury, it's my duty to instruct you

 5   on the rules of law that you must use in deciding this case.

 6   After I've completed these instructions, you'll go to the jury

 7   room and begin your discussions.        What we call your

 8   deliberations.

 9               You must decide whether the government has proved the

10   specific facts necessary to find each defendant guilty beyond

11   a reasonable doubt.

12               Your decision must be based only on the evidence

13   presented during the trial.       You must not be influenced in any

14   way by either sympathy for or prejudice against any defendant

15   or the government.

16               You must follow the law as I explain it, even if you

17   do not agree with the law, and you must follow all of my

18   instructions as a whole.      You must not single out or disregard

19   any of the Court's instructions on the law.

20               The indictment or formal charge against a defendant

21   isn't evidence of guilt.      The law presumes every defendant is

22   innocent.    Each defendant does not have to prove his or her

23   innocence or produce any evidence at all.          A defendant does

24   not have to testify, and if any defendant chose not to

25   testify, you cannot consider that in any way while making your


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 1   decision.     The government must prove guilt beyond a reasonable

 2   doubt.     If it fails to do so, you must find the defendant not

 3   guilty.

 4               The government's burden of proof is heavy, but it

 5   doesn't have to prove a defendant's guilt beyond all possible

 6   doubt.     The government's proof only has to exclude any

 7   reasonable doubt concerning each defendant's guilt.

 8               A reasonable doubt is a real doubt based on your

 9   reason and common sense after you've carefully and impartially

10   considered all the evidence in the case.

11               Proof beyond a reasonable doubt is proof so

12   convincing that you would be willing to rely and act on it

13   without hesitation in the most important of your own affairs.

14   If you're convinced that a defendant has been proved guilty

15   beyond a reasonable doubt, say so.          If you're not convinced,

16   say so.

17               As I said before, you must consider only the evidence

18   that I have admitted in the case.          Evidence includes the

19   testimony of witnesses and the exhibits admitted.                But

20   anything the lawyers say is not evidence and isn't binding on

21   you.

22               You shouldn't assume from anything I've said that I

23   have any opinion about any factual issue in this case.                 Except

24   for my instructions to you on the law, you should disregard

25   anything I may have said during the trial in arriving at your


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 1   own decision about the facts.

 2               Your own recollection and interpretation of the

 3   evidence is what matters.

 4               In considering the evidence, you may use reasoning

 5   and common sense to make deductions and reach conclusions.

 6   You shouldn't be concerned about whether the evidence is

 7   direct or circumstantial.

 8               Direct evidence is the testimony of a person who

 9   asserts that he or she has actual knowledge of a fact, such as

10   an eyewitness.

11               Circumstantial evidence is proof of a chain of facts

12   and circumstances that tend to prove or disprove a fact.

13   There's no legal difference in the weight you may give to

14   either direct or circumstantial evidence.

15               When I say you must consider all the evidence, I

16   don't mean that you must accept all the evidence as true or

17   accurate.    You should decide whether you believe what each

18   witness had to say and how important that testimony was.              In

19   making that decision, you may believe or disbelieve any

20   witness, in whole or in part.       The number of witnesses

21   testifying concerning a particular point doesn't necessarily

22   matter.

23               To decide whether you believe any witness, I suggest

24   that you ask yourself a few questions:

25               Did the witness impress you as one who was telling


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 1   the truth?

 2               Did the witness have any particular reason not to

 3   tell the truth?

 4               Did the witness have a personal interest in the

 5   outcome of the case?

 6               Did the witness seem to have a good memory?

 7               Did the witness have the opportunity and ability to

 8   accurately observe the things he or she testified about?

 9               Did the witness appear to understand the questions

10   clearly and answer them directly?

11               Did the witness's testimony differ from other

12   testimony or other evidence?

13               If the government offers evidence the defendant made

14   a statement or admission to someone, you must decide for

15   yourself:    One, whether the defendant made the statement, and,

16   two, if so, how much weight to give it.          To make these

17   decisions, you must consider all the evidence about the

18   statement, including the circumstances under which it was

19   made.

20               Any such statement is not evidence about any other

21   defendant.

22               You should ask yourself whether there was evidence

23   that a witness testified falsely about an important fact.               And

24   ask whether there was evidence that at some other time a

25   witness said or did something or didn't say or do something


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 1   that was different from the testimony the witness gave during

 2   this trial.

 3             But keep in mind that a simple mistake doesn't mean a

 4   witness wasn't telling the truth as he or she remembers it.

 5   People naturally tend to forget some things or remember them

 6   inaccurately.    So if a witness misstated something, you must

 7   decide whether it was because of an innocent lapse in memory

 8   or an intentional deception.       The significance of your

 9   decision may depend on whether the misstatement is about an

10   important fact or about an unimportant detail.

11             You've been permitted to take notes during the trial,

12   most of you, perhaps all of you, have taken average of that

13   opportunity.

14             You must use your notes only as a memory aid during

15   deliberations.    You must not give your notes priority over

16   your independent recollection of the evidence.           And you must

17   not allow yourself to be unduly influenced by the notes of

18   other jurors.

19             I emphasize that notes are not entitled to any

20   greater weight than your memories or impressions about the

21   testimony.

22             When scientific, technical or other specialized

23   knowledge might be helpful, a person who has special training

24   or experience in that field is allowed to state an opinion

25   about the matter.


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 1               But that doesn't mean you must accept the witness's

 2   opinion.    As with any other witness's testimony, you must

 3   decide for yourself whether to rely upon the opinion.

 4               The indictment charges 42 separate crimes called

 5   counts against some or all of the defendants.           Each count has

 6   a number.    Specifically, Defendant Foster is charged in

 7   Counts 1 through 28, Counts 30 through 41 and Count 59.               And

 8   Defendant Jackson is charged in Counts 46 and 47.              You'll be

 9   given a copy of the indictment to refer to during your

10   deliberations.

11               Some of the counts charge that Defendant Foster

12   knowingly and willfully conspired to commit bank fraud and/or

13   wire fraud.

14               Other counts charge that Defendants Jackson and/or

15   Foster committed what are called substantive offenses,

16   specifically bank fraud, wire fraud, making false statements

17   to a federally insured financial institution and/or money

18   laundering.    I will explain the law governing those

19   substantive offenses -- excuse me -- those substantive

20   offenses in a moment.

21               But first note that the defendants who are charged

22   in conspiracy counts are not charged in those counts with

23   committing a substantive offense.        They are charged with

24   conspiring to commit that offense.

25               I will also give you specific instructions on


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 1   conspiracy.

 2             It's possible to prove a defendant guilty of a crime

 3   even without evidence that the defendant personally performed

 4   every act charged.

 5             Ordinarily, any act a person can do may be done by

 6   directing another person or agent.        Or it may be done by

 7   acting with or under the direction of others.

 8             A defendant aids and abets a person if the defendant

 9   intentionally joins with the person to commit a crime.

10             A defendant is criminally responsible for the acts of

11   another person if the defendant aids and abets the other

12   person.   A defendant is also responsible if the defendant

13   willfully directs or authorizes the acts of an agent, employee

14   or other associate.

15             But finding that a defendant is criminally

16   responsible for the acts of another person requires proof that

17   the defendant intentionally associated with or participated in

18   the crime.    Not just proof that the defendant was simply

19   present at the scene of a crime or knew about it.

20             In other words, you must find beyond a reasonable

21   doubt that the defendant was a willful participant and not

22   merely a knowing spectator.

23             It's a federal crime to carry out or attempt to carry

24   out a scheme to defraud a financial institution, or to get

25   money or property owned or controlled by a financial


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 1   institution by using false pretenses, representations or

 2   promises.

 3               Each defendant can be found guilty of this crime only

 4   if all the following acts are proved beyond a reasonable

 5   doubt:

 6               The defendant knowingly carried out or attempted to

 7   carry out a scheme to defraud a financial institution or to

 8   get money, assets or other property from a financial

 9   institution by using false or fraudulent pretenses,

10   representations or promises about a material fact;

11               The false or fraudulent pretenses, representations or

12   promises were material;

13               The defendant intended to defraud the financial

14   institution;

15               And the federal institution was federally insured.

16               A scheme to defraud includes any plan or course of

17   action intended to deceive or cheat someone out of money or

18   property by using false or fraudulent pretenses,

19   representations or promises relating to a material fact.

20               The statement or representation is false or

21   fraudulent if it is about a material fact that the speaker

22   knows is untrue or makes with reckless indifference as to the

23   truth and makes with intent to defraud.           A statement or

24   representation may be false or fraudulent when it's a half

25   truth or effectively conceals a material fact and it was --


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 1   and is made with the intent to defraud.

 2               A material fact is an important fact that a

 3   reasonable person would use to decide whether to do or not to

 4   do something.      A fact is material if it has the capacity or

 5   natural tendency to influence a person's decision.              It doesn't

 6   matter whether the decisionmaker actually relied on the

 7   statement or knew or should have known the statement was

 8   false.

 9               To act with intent to defraud means to act knowingly

10   and with the specific intent to use false or fraudulent

11   pretenses, representations or promises to cause loss or

12   injury.     Proving intent to deceive a loan without the intent

13   to cause loss or injury is not sufficient to prove intent to

14   defraud.

15               The government doesn't have to prove all the details

16   alleged in the indictment about the precise nature and purpose

17   of the scheme.      It also doesn't have to prove that the alleged

18   scheme actually succeeded in defrauding anyone.             What must be

19   proved beyond a reasonable doubt is that the defendant

20   knowingly attempted or carried out a scheme substantially

21   similar to the one alleged in the indictment.

22               It's a federal crime to use interstate wire, radio or

23   television communications to carry out a scheme to defraud

24   someone else.

25               Each defendant can be found guilty of this crime --


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 1               Counsel, when we were reviewing these, bank fraud and

 2   wire fraud both say "each defendant."           Shouldn't that just say

 3   "a defendant"?

 4               MS. WEBSTER:     That seems right.

 5               THE COURT:    Agreed, Ms. Webster?

 6               MS. WEBSTER:     Yes.

 7               MR. MARSHALL:     Yes, Judge.

 8               THE COURT:    Okay, Mr. Marshall?

 9               MR. MARSHALL:     Yes.

10               THE COURT:    Government?

11               MR. KAUSHAL:     Either way is fine, Your Honor.

12               THE COURT:    Okay.

13               When I was describing the bank fraud, I said "each

14   defendant" can be found, but I should have read "a defendant"

15   can be found.      And here again with wire fraud, I'm going to

16   say it's a federal crime to use interstate wire, radio or

17   television communications to carry out a scheme to defraud

18   someone else.

19               A defendant can be found guilty of this crime only if

20   all the following facts are proved beyond a reasonable doubt.

21               And, Ms. Mueller, if you can change that on page 14

22   and 12 and reprint those two pages.           Thank you.

23               The following facts are proved beyond a reasonable

24   doubt:

25               The defendant knowingly devised or participated in a


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 1   scheme to defraud someone by using false or fraudulent

 2   pretenses, representations or promises;

 3              The false pretenses, representations or promises were

 4   about a material fact;

 5              The defendant acted with the intent to defraud;

 6              And the defendant transmitted or caused to be

 7   transmitted by wire some communication in interstate commerce

 8   to help carry out the scheme to defraud.

 9              A scheme to defraud means any plan or course of

10   action intended to deceive or cheat someone out of money or

11   property by using false or fraudulent pretenses,

12   representations or promises.

13              A statement of representation is false or fraudulent

14   if it's about a material fact the speaker knows is untrue or

15   makes with reckless indifference to the truth and makes with

16   the intent to defraud.       A statement or representation may be

17   false or fraudulent when it is a half-truth, or effectively

18   conceals a material fact and is made with the intent to

19   defraud.

20              A material fact is an important fact that a

21   reasonable person would use to decide whether to do or not do

22   something.    A material fact, it has the capacity or natural

23   tendency to influence a person's decision -- excuse me.

24              A fact is material if it has the capacity or natural

25   tendency to influence a person's decision.          It doesn't matter


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 1   whether the decisionmaker actually relied on the statement or

 2   knew or should have known the statement was false.

 3               To act with intent to defraud means to act knowingly

 4   and with the specific intent to use false or fraudulent

 5   pretenses, representations or promises to cause loss or

 6   injury.     Proving intent to deceive alone, without the intent

 7   to cause loss or injury, is not sufficient to prove intent to

 8   defraud.

 9               The government does not have to prove all the details

10   alleged in the indictment about the precise nature and purpose

11   of the scheme.      It also doesn't have to prove the material --

12   does not have to prove that the material transmitted by

13   interstate wire was itself false or fraudulent; or that using

14   the wire was intended as the specific or exclusive means of

15   carrying out the alleged fraud; or that the defendant

16   personally made the transmission over the wire.             And it

17   doesn't have to prove that the alleged scheme actually

18   succeeded in defrauding anyone.

19               To use interstate wire communications is to act

20   so that something would normally be sent through wire

21   communications in the normal course of business.

22               Each separate use of the interstate wire

23   communications as part of the scheme to defraud is a separate

24   crime.

25               It's a federal crime to knowingly and willfully


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 1   conspire or agree with someone to do something that, if

 2   actually carried out, would result in the crime of bank fraud

 3   or wire fraud.

 4              A conspiracy is an agreement by two or more persons

 5   to commit an unlawful act.       In other words, it is a kind of

 6   partnership for criminal purposes.        Every member of the

 7   conspiracy becomes the agent or partner of every other member.

 8              The government does not have to prove that all the

 9   people named in the indictment were members of the plan or

10   that those who were members made any kind of formal agreement.

11   The heart of a conspiracy is the making of the unlawful plan

12   itself, so the government does not have to prove that the

13   conspirators succeeded in carrying out the plan.

14              Each defendant can be found guilty of this conspiracy

15   offense only if all the following facts are proved beyond a

16   reasonable doubt:

17              Two or more persons in some way or manner agreed to

18   try to accomplish a common and unlawful plan to commit bank

19   fraud or wire fraud as charged in the indictment;

20              And the defendant knew the unlawful purpose of the

21   plan and willfully joined in it.

22              A person may be a conspirator even without knowing

23   all the details of the unlawful plan or the names and

24   identities of all the other alleged conspirators.

25              If the defendant played only a minor role in the plan


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 1   but had a general understanding of the unlawful purpose of the

 2   plan and willfully joined in the plan on at least one

 3   occasion, that's sufficient for you to find the defendant

 4   guilty.

 5              But simply being present at the scene of an event or

 6   merely associating with certain people and discussing common

 7   goals and interests doesn't establish proof of a conspiracy.

 8   Also, a person who doesn't know about a conspiracy but happens

 9   to act in a way that advances some purpose of one doesn't

10   automatically become a conspirator.

11              In this case, some of the conspiracy counts in the

12   indictment allege that a defendant conspired to commit bank

13   fraud and to commit wire fraud.        In other words, in some

14   counts the defendants are charged with conspiring to commit

15   two separate substantive crimes.

16              The government does not have to prove that a

17   defendant willfully conspired to commit both crimes.             It is

18   sufficient if the government proves beyond a reasonable doubt

19   that a defendant willfully conspired to commit one of those

20   crimes.   But to return a verdict of guilty, you must all agree

21   on which of the two crimes the defendant conspired to commit.

22              It's a federal crime to knowingly make a false

23   statement or report to a federally insured financial

24   institution.

25              Each defendant can be found guilty of this crime only


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 1   if all the following facts are proved beyond a reasonable

 2   doubt:

 3               The defendant made a false statement or report;

 4               The defendant did so knowingly and with intent to

 5   influence an action of the institution described in the

 6   indictment regarding an application, advance, commitment or

 7   loan or a change or extension to any of those;

 8               And the deposits of the institution were insured by

 9   the Federal Deposit Insurance Corporation.

10               A statement or report is false if it is untrue and

11   made and the person making it knows it is untrue.

12               The heart of the crime is the attempt to influence

13   the action of the institution by knowingly making a false

14   statement or report.        The government does not have to prove

15   that the institution was actually influenced or misled.

16               It's a federal crime to knowingly engage in certain

17   kinds of financial transactions, commonly known as money

18   laundering.

19               Each defendant can be found guilty of this crime only

20   if all the following facts are proved beyond a reasonable

21   doubt:

22               The defendant knowingly conducted or tried to conduct

23   a financial transaction;

24               The defendant knew that the money or property

25   involved in the transaction were the proceeds of some kind of


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 1   unlawful activity;

 2               Money or property did come from a specified unlawful

 3   activity, specifically wire fraud;

 4               And the defendant knew that the transaction was

 5   designed, in whole or in part, to conceal or disguise the

 6   nature, location, source, ownership or the control of the

 7   proceeds.

 8               One moment.

 9               To conduct a transaction means to start or finish a

10   transaction or participate in a transaction at any point.

11               A transaction means a purchase, sale, loan, promise,

12   gift, transfer, delivery or other disposition of money or

13   property.    A transaction with a financial institution also

14   includes a deposit, withdrawal, transfer between accounts,

15   exchange of currency, loan, extension of credit, use of a safe

16   deposit box or purchase or sale of any stock, bonds,

17   certificate of deposit or other monetary instrument.

18               A financial transaction means a transaction that

19   in any way or to any degree affects interstate or foreign

20   commerce by sending or moving money by wire or other means; or

21   a transaction that in any way or to any degree affects

22   interstate or foreign commerce by involving one or more

23   monetary instruments.        The phrase "monetary instruments"

24   includes coins or currency of any country, Travelers or

25   personal checks, bank checks or money orders, or investment


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 1   securities or negotiable instruments in a form that allows

 2   ownership to transfer on delivery; a transaction involving the

 3   use -- or a transaction involving the use of a financial

 4   institution that is involved in interstate or foreign commerce

 5   or whose activities affect interstate or foreign commerce in

 6   any way or degree.       The phrase "financial institution"

 7   includes a bank insured by the Federal Deposit Insurance

 8   Corporation.

 9               Interstate or foreign commerce means trade and other

10   business activity between people or businesses in at least two

11   states or between people or businesses in the United States

12   and people or businesses outside the United States.

13               To know that the money or property involved in the

14   transaction came from some kind of unlawful activity is to

15   know that the money or property came from an activity that's a

16   felony under state, federal or foreign law.

17               The term "proceeds" means any property derived from

18   or obtained or retained, directly or indirectly, through some

19   form of unlawful activity, including the gross receipts of the

20   activity.

21               The phrase "specified unlawful activity" means wire

22   fraud.

23               To prove the element of concealment, the government

24   must prove that the purpose, not merely the effect, was to

25   conceal or disguise the nature, location, source, ownership or


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 1   control of the proceeds.      Evidence of concealment must be

 2   substantial.    Merely conducting a transaction with money whose

 3   nature has been concealed is not in and of itself a crime.

 4              Where a statute specifies multiple alternative ways

 5   in which an offense may be committed, the indictment may

 6   allege the multiple ways in the conjunctive, that is by using

 7   the word "and."     If only one of the alternatives is proved

 8   beyond a reasonable doubt, that is sufficient for a conviction

 9   so long as you agree unanimously as to that alternative.

10              Good faith is a complete defense to a charge that

11   requires intent to defraud.       A defendant isn't required to

12   prove good faith.     The government must prove intent to defraud

13   beyond a reasonable doubt.

14              An honestly held opinion or an honestly formed belief

15   cannot be fraudulent -- excuse me -- cannot be fraudulent

16   intent, even if the opinion or belief is mistaken.            Similarly,

17   evidence of a mistake in judgment, an error in management or

18   carelessness can't establish fraudulent intent.

19              But an honest belief that a business venture would

20   ultimately succeed doesn't constitute good faith if the

21   defendant intended to deceive others by making representations

22   the defendant knew to be false or fraudulent.

23              You'll see that the indictment charges that a crime

24   was committed on or about a certain date.          The government

25   doesn't have to prove that the crime occurred on an exact


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 1   date.    The government only has to prove beyond a reasonable

 2   doubt that the crime was committed on a date reasonably close

 3   to the date alleged.

 4              The word "knowingly" means that an act was done

 5   voluntarily and intentionally and not because of a mistake or

 6   an accident -- or by accident.

 7              The word "willfully" means that the act was committed

 8   voluntarily and purposely, with the intent to do something the

 9   law forbids; that is, with the bad purpose to disobey or

10   disregard the law.      While a person must have acted with the

11   intent to do something the law forbids before you can find

12   that the person acted willfully, the person need not be aware

13   of the specific law or rule that his or her conduct may be

14   violating.

15              This next instruction applies only to the

16   government's case against Defendant Jackson.           It does not

17   apply to the government's case against Defendant Foster.

18              If a defendant's knowledge of a fact is an essential

19   element of a crime, it's enough that the defendant was aware

20   of a high probability that the fact existed unless the

21   defendant actually believed the fact didn't exist.

22              Deliberate avoidance of positive knowledge, which is

23   the equivalent of knowledge, occurs, for example, if a

24   defendant possesses a package and believes it contains a

25   controlled substance but deliberately avoids learning that it


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 1   contains the controlled substance so he or she can deny

 2   knowledge of the package's contents.

 3              So you may find the defendant -- that a defendant

 4   knew about the possession of a controlled substance if you

 5   determine beyond a reasonable doubt that the defendant

 6   actually knew about the controlled substance or had every

 7   reason to know but deliberately closed his or her eyes.

 8              And I would add, with counsel's permission, for

 9   example.    Hearing no objection.

10              But I must emphasize that negligence, carelessness or

11   foolishness isn't enough to prove that the defendant knew

12   about the possession of the controlled substance, in that

13   example.

14              Each count of the indictment charges a separate crime

15   against one or more of the defendants.         You must consider each

16   crime and the evidence related to it separately.              And you must

17   consider the case of each defendant separately and

18   individually.    If you find a defendant guilty of one crime,

19   that must not affect your verdict for any other crime or any

20   other defendant.

21              I caution you that each defendant is on trial only

22   for the specific crimes charged in the indictment.             You're

23   here to determine from the evidence in this case whether each

24   defendant is guilty or not guilty of those specific crimes.

25              You must never consider punishment in any way to


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 1   decide whether a defendant is guilty.         If you find a defendant

 2   guilty, the punishment is for the judge alone to decide later.

 3              Your verdict, whether guilty or not guilty, must be

 4   unanimous.    In other words, you must all agree.         Your

 5   deliberations are secret and you'll never have to explain your

 6   verdict to anyone.

 7              Each of you must decide the case yourself, but only

 8   after fully considering the evidence with the other jurors.

 9   So you must discuss the case with one another and try to reach

10   an agreement.    While you're discussing the case, don't

11   hesitate to re-examine your own opinion and change your mind

12   if you become convinced that you were wrong.          But don't give

13   up your honest beliefs just because others think differently

14   or because you simply want to get the case over with.

15              Remember that, in a very real way, you're judges,

16   judges of the facts.      Your only interest is to seek the truth

17   from the evidence in this case.

18              One moment.

19              All right.    Before I complete the instructions,

20   either my law clerk or one of the counsel has identified a

21   couple other places where I've said "each defendant" where it

22   should have said "a defendant."

23              When I was describing conspiracy to commit bank fraud

24   and/or wire fraud I said, "each" defendant can be found guilty

25   of this conspiracy offense.       I should have said "a" defendant


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 1   can be found guilty.

 2               Same thing when I was discussing false statement to a

 3   federally insured institution, I said "each" defendant can be

 4   found guilty of this crime.       I should have said "a" defendant

 5   can be found guilty of this crime.

 6               Counsel, does that address those "each" versus "a"

 7   issues that I -- some of which I found as I was reading

 8   through, others of which someone else found as I was reading

 9   through and I didn't see the e-mail until just now?

10               MS. WEBSTER:     Yes, your Honor, I think so.

11               MR. MARSHALL:    Yes, your Honor.

12               MR. KAUSHAL:     Your Honor, since we are making these

13   small edits, page 18, the sentence that says -- that starts

14   with, "In other words," should say "a defendant" is charged,

15   instead of "the defendants" are charged.

16               THE COURT:   Okay.

17               All right.   And pardon us, ladies and gentlemen of

18   the jury.    We went through all of these but missed a few of

19   the things we were supposed to switch around.

20               When you get to the jury room, choose one of your

21   members to act as foreperson.        The foreperson will direct your

22   deliberations and will speak for you in court.

23               A verdict form has been prepared for your

24   convenience.

25               Ms. Lee, can you put the verdict form on the -- I


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 1   always thought it was an Elmo, but I heard somebody call it an

 2   Exhibitron during this trial, which I thought was an even

 3   better way to describe it.       So I might use Exhibitron from now

 4   on.

 5              Can you put the verdict form on the Exhibitron,

 6   Ms. Lee?

 7              COURTROOM DEPUTY CLERK:      Yes.    Which one first?

 8              THE COURT:   Let's start with Mr. Foster's.

 9              All right.   So you're going to have two separate

10   verdict forms, ladies and gentlemen of the jury.                The first

11   one involves Mr. Foster.

12              And for each of the counts listed there, for example,

13   Count 1, as to Count 1 of the indictment charging conspiracy

14   to commit wire fraud as to Bellator Phront Group, Inc., we,

15   the jury, unanimously find defendant, Teldrin Foster, and

16   you'll check either not guilty or guilty.

17              For some of these, for example -- can you go to

18   Count 6 on page 2, Ms. Lee?

19              Some of these will ask you -- and only if you reach a

20   guilty verdict.     If you reach a not guilty verdict, you don't

21   answer the second part of the question.           But if you reach a

22   guilty verdict, you then answer whether or not you find --

23   unanimously find the government proved that the object of the

24   conspiracy was bank fraud, wire fraud or both.

25              And you'll just answer those questions for all the


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 1   counts up to Count 59.       And then you will sign and date -- and

 2   the foreperson will sign and date the verdict form.

 3              With Ms. Jackson's verdict form, which we see here,

 4   you will -- just like with the first count mentioned of

 5   Mr. Foster's verdict form, you will simply decide between the

 6   options listed there, not guilty and guilty.           And then, again,

 7   the foreperson will sign and date the form.

 8              You'll have the verdict form with you in the jury

 9   room.    When you've agreed on your verdict, the foreperson,

10   again, will sign the form and date it and carry it back in to

11   the courtroom.

12              You will have -- in addition to the verdict form, you

13   will have a copy of my instructions.          You will also have the

14   indictment.     And you will have all of the exhibits.

15              Which, Ms. Lee, have you and the various parties

16   worked through those exhibits?        Are those close?

17              COURTROOM DEPUTY CLERK:       They're close.

18              THE COURT:    Okay.    Those will -- we'll get a packet

19   with you including all these materials shortly.

20              I'll also say, by agreement of the parties, you'll

21   see in the indictment there are references to company 1, for

22   example, and bank 1, for example.         And there's a stipulation

23   that the parties agreed to that describe which companies and

24   banks are listed therein.

25              If you wish to communicate with me at any time,


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 1   please write down your message or question and give it to the

 2   court security officer.       He or she will bring it to me and

 3   I'll respond as promptly as possible, either in writing or by

 4   talking to you in the courtroom.         But I caution you not to

 5   tell me how many jurors have voted one way or the other at any

 6   time.

 7              All right.    Jurors 27 and Juror 30, who are you?

 8   I've lost track.

 9              Okay.   Jurors 27 and 30, you are alternate jurors in

10   this case, so you will not go back and deliberate, but I do

11   need you to stand by in case we need you at any point.              Thank

12   you.

13              All right.    So now I'll ask the jury -- or, first

14   off, Counsel, other than all those "each" and "a" issues that

15   I think we fixed, any issues with the charge other than what's

16   been previously objected to?

17              MS. WEBSTER:      Your Honor, I think --

18              MR. KAUSHAL:      No.

19              MS. WEBSTER:      Your Honor, I think I have to renew my

20   objection to the previously decided ones to preserve it for

21   appeal.

22              THE COURT:    All right.     Thank you, Ms. Webster.

23              MR. MARSHALL:     Judge, and I think the Court already

24   said it, subject to previous objections.

25              THE COURT:    I did.


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 1              MR. KAUSHAL:      No objection from the government.

 2              THE COURT:   All right.     Thank you.

 3              Okay.   You can now, please -- 12 of the 14 of you,

 4   please go to the jury room to deliberate and we will be there

 5   shortly with the verdict form, the indictment and the

 6   instructions and the exhibits.        Thank you.

 7              (The jury exited the courtroom to deliberate.)

 8              THE COURT:   Counsel, anything else for now?

 9              MS. WEBSTER:      I do have one issue, Your Honor.

10              THE COURT:   All right.     Let's wait for the jury to go

11   out.

12              Yes, Ms. Webster?

13              Y'all can be seated.

14              MS. WEBSTER:      Thank you, Your Honor.

15              We are requesting that the Court find that there was

16   a constructive amendment or a material variance during the

17   government's closing argument, specifically as the Court is

18   aware, I -- we've litigated a bunch of motions about the

19   conspiracy -- or not a bunch.        We litigated a multiplicitous

20   argument arguing that it should be one conspiracy and not 14.

21   And the government opposed that at every step along the way.

22   And then I believe they stood up in closing and said that it's

23   actually one conspiracy.

24              And so we would move for a -- for the Court to find

25   that there's a material -- or constructive amendment or


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 1   material variance on that basis.

 2              THE COURT:   Yes, Ms. Chaiken.

 3              MS. CHAIKEN:      Your Honor, first of all, this wasn't

 4   raised in any contemporaneous objection, so I don't think it's

 5   been preserved.

 6              But in any event, I don't think anything I said in

 7   closing suggested that there was only one conspiracy.              What I

 8   said is that as to each loan Teldrin Foster conspired with

 9   Darrell Thomas.     And I don't think there was any constructive

10   amendment.

11              The evidence at trial showed the existence of

12   multiple conspiracies because it established that the business

13   owners did not work together with each other, were not

14   connected by any kind of rim.        So I think based on our prior

15   briefing I don't think anything I said in closing changed the

16   propriety of the way that the case was charged.

17              THE COURT:   All right.     One moment.

18              All right.   Ms. Webster, anything else?

19              MS. WEBSTER:      Nothing additional, Your Honor.

20              THE COURT:   All right.     I'm going to deny that

21   motion.

22              All right.   Thanks, everyone.

23              (After a recess at 1:39 p.m., the proceedings

24   continued at 4:31 p.m., as follows:)

25              THE COURT:   Y'all can be seated.       Thank you.


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 1               I wanted to check in and get on the record given the

 2   issues we've been having.        You know, it's pretty typical,

 3   you know, sometimes to tell the jury, okay, begin your

 4   deliberations, we'll -- or go back to the jury room, we'll

 5   have the stack here for you shortly with the verdict form,

 6   instructions, if y'all have consented to send them back and

 7   have agreed to send them back, and then the exhibits.               That

 8   happened here, too.       My impression was that things were about

 9   ready.

10               You know, there was a question from the jury if they

11   could begin deliberations before they got everything.               And I

12   had Ms. Lee check with counsel to get counsel's position on

13   that.     I was told that counsel did not want that to happen,

14   and I was only going to let that happen if everybody agreed.

15   So I said okay, I understand no one wanted that to happen, so

16   I said, tell the jury not to begin deliberations then.

17               Then I got a follow-up message a little bit later

18   saying the documents still weren't ready but could -- was it

19   permissible to let the jury start deliberating.             I was told

20   all counsel was amenable to that.          So I said, fine, let the

21   jury know they can begin deliberating, thinking again we were

22   close to having the stack sent back to them.

23               So, first off, is my understanding of the

24   communications so far, is that accurate, Ms. Chaiken?

25               MS. CHAIKEN:     Yes, your Honor.


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 1              THE COURT:    Ms. Webster?

 2              MS. WEBSTER:      Yes, your Honor.

 3              THE COURT:    Mr. Marshall?

 4              MR. MARSHALL:     Yes, your Honor.

 5              THE COURT:    That unfortunately was probably an hour

 6   and half plus ago.      And I understand -- well, first off, I

 7   understand that a member of the Foster defense team was ill

 8   and so wasn't here, your paralegal, which would explain maybe

 9   why we're having some issues.

10              But bottom line is, you know, I think at this point I

11   need to bring the jury in and say, we're having some trouble

12   with the documents and we're going to pause for the rest of

13   the day and bring you back in in the morning, at which time we

14   will have all the documents ready to go.

15              To me, that seems clearly like what we should do at

16   this point unless, Ms. Webster, you tell me that your

17   documents are minutes away from being ready to go back.

18              MS. WEBSTER:      I don't think I can say that they're

19   minutes away from going back.        Hopefully within half an hour

20   or something, but I -- I'm very sorry, but I don't think I can

21   promise they're minutes away.

22              THE COURT:    Okay.   Would anyone like to be heard on

23   my suggestion, and that is, again, that I release the jury and

24   have them come back in the morning given this issue?

25              MS. CHAIKEN:      No, your Honor.


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 1              MR. MARSHALL:     Your Honor, is there any instruction

 2   we can give them that just reminds them that they don't have

 3   the exhibits yet and not to form any conclusions in the case

 4   or anything related to that until they have all the

 5   evidence --

 6              THE COURT:   Well, we've already told them they could

 7   begin deliberations by consent of everyone, so I'm not going

 8   to try to get into the verbal gymnastics of don't decide

 9   anything or do decide something.        I don't think that would be

10   fair to them given that we've by consent told them they could

11   go ahead and talk about the case and that the documents are on

12   the way.

13              Do you want to be further heard, Mr. Marshall?

14              MR. MARSHALL:     No, that's fine, Your Honor.

15              THE COURT:   So my intent is just to bring the jury in

16   and say, without any attribution as to which party has caused

17   the issue, just to say we're having some issues with the

18   documents unfortunately.       Minutes have turned into hours and

19   I've decided to pause your deliberations until you can come

20   back in the morning with the documents.

21              Is that acceptable to everyone?

22              Ms. Chaiken?

23              MS. CHAIKEN:      Yes, your Honor.

24              THE COURT:   Ms. Webster?

25              MS. WEBSTER:      Yes, your Honor.


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 1              THE COURT:    Mr. Marshall?

 2              MR. MARSHALL:     Yes, Judge.

 3              THE COURT:    Could someone grab the CSO and have him

 4   bring in the jury.      Thank you.

 5              And, Ms. Webster, again, I understand your paralegal

 6   that normally does all this stuff was not here and that makes

 7   sense to me it would become an issue.          It's unfortunate but

 8   it's fine and we're dealing with it and everything's going to

 9   be okay.

10              MS. WEBSTER:      Thank you, Your Honor.      I appreciate

11   that.

12              COURTROOM DEPUTY CLERK:       As to the alternates, do you

13   want me to message them they're not to come in?

14              THE COURT:    Yes, that would be fine.

15              Actually, does everyone consent, the alternates, to

16   release them but tell them they're on standby to potentially

17   need to come back?

18              Ms. Chaiken?

19              MS. CHAIKEN:      That's fine, Your Honor.

20              THE COURT:    Ms. Webster?

21              MS. WEBSTER:      Yes, Your Honor.

22              THE COURT:    Mr. Marshall?

23              MR. MARSHALL:     Yes, Judge.

24              THE COURT:    Actually are they close by?           I want to

25   bring them in and tell them that in person and thank them.


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 1   Thank you.    Just have them come up, please.

 2              Counsel, does everyone also consent to my telling

 3   them once they receive the stack in the morning, they can

 4   restart their deliberations without me coming into -- bringing

 5   them into the courtroom and bringing you all in the courtroom

 6   and telling them that?

 7              MS. CHAIKEN:      Yes, Your Honor.

 8              MS. WEBSTER:      Yes, Your Honor.

 9              MR. MARSHALL:     Yes, Your Honor.

10              And, Your Honor, I believe Mr. Foster's counsel is

11   submitting I think --

12              THE COURT:   I'm sorry, let me interrupt you.           I won't

13   say restart, I'll just say continue.

14              MR. MARSHALL:     Continue, yes.

15              I believe Mr. Foster's counsel has documents that

16   will be submitted on a flash drive.

17              Is that correct, Ms. Webster?

18              MS. WEBSTER:      Yes, Your Honor.    I was going to put

19   that on the record.

20              I think by consent of the parties we have documents

21   that we had admitted into evidence and it turns out that they

22   were not actually all printed, which is part of the issue.

23   And so we had discussed putting them on a flash drive and

24   sending them back that way, so to avoid the time in printing

25   and stickering them and stuff.        And so I think all the parties


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 1   have agreed, so that's what we are planning to do.             I think

 2   we're trying to wrap up that process.

 3               THE COURT:   That's fine.    Do you have a list of

 4   exhibits that's going to apply to?        I guess we should just put

 5   that on the record if you have it or we might need to do that

 6   tomorrow.

 7               MS. WEBSTER:     I think tomorrow.

 8               THE COURT:   All right.    Thank you.

 9               Ready.   Thank you, Officer.

10               (The jury entered the courtroom at 4:43 p.m.)

11               THE COURT:   All right.    You can be seated.

12               Ladies and gentlemen of the jury, so we have had some

13   issues with the exhibits, with the documents.            As you know,

14   this has been a fairly document intensive case with some hard

15   documents, some electronic documents, et cetera.

16               When I sent you back to choose your foreperson, it

17   was my expectation that soon thereafter we would be giving you

18   a stack of the materials.       I thought that was going to be in a

19   few minutes or a couple minutes.        A couple minutes have turned

20   into a couple hours.       It's now 4:45.     I think I sent you back

21   at 2:30-something or so.

22               A little while after I sent you back, it was

23   confirmed after discussions with the parties that you weren't

24   to begin your deliberations until you got the documents, but

25   when we realized it was going to be a little bit longer for


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 1   the documents, the parties consented to allow you to begin

 2   your deliberations without the documents, which was

 3   communicated to you, again, with the expectation that those

 4   documents would be coming fairly shortly.

 5              But now as additional time has passed and you still

 6   don't have the documents, I've decided to direct you to pause

 7   your deliberations for the day.        And we will be putting the

 8   documents together once and for all this afternoon into this

 9   evening, as long as it takes for there to be a stack of

10   documents ready for you to go tomorrow morning at 9:00.

11              I want to underscore to you that I'm not happy that

12   this has transpired this way.       And I know we've taken a lot of

13   your time for this trial and this has been an even greater

14   inconvenience over the last couple hours dealing with this.

15              I apologize that this has happened, but we're going

16   to try to get it fixed the rest of this afternoon, into this

17   evening, and make sure we have a stack for you at 9:00

18   tomorrow morning.

19              I've also, just to save us a little time of the

20   back-and-forth, spoken with the parties and they've consented

21   that once all 12 of you are here in the morning and you have

22   that stack of documents, you can continue your deliberations

23   at that point.    I'm not going to bring you back into the

24   courtroom just to tell you to continue your deliberations.

25              So, again, you have my apologies that this has


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 1   happened.    I'm sorry that it's happened.       I'm sorry that it's

 2   inconvenienced you, but we will hopefully have things straight

 3   and ready for you to go full speed ahead with your

 4   deliberations with everything you need at 9:00 tomorrow

 5   morning.

 6               All right.   Thank you very much.      And, again, I

 7   apologize.

 8               And to the two alternates, I'll release the jury and

 9   then I need to talk to the two alternates as well.

10               Thank you.   Y'all have a good evening.

11               (The jury exited the courtroom at 4:47 p.m.)

12               THE COURT:   All right.    Y'all can be seated.

13               Jurors 27 and 30, hello.     I want to thank you also

14   for being here throughout this case and the attention you've

15   given it.    I've spoken with the parties and what we're going

16   to do, instead of continue to hold you here while the rest of

17   the jury deliberates and have you come back tomorrow while

18   they deliberate, I'm instead going to release you on the

19   condition that you will keep your cell phones with you and

20   have them at the ready should we lose one of the other jurors

21   for some reason tomorrow or however long they deliberate, we

22   may still need to bring one or both of you back to become

23   jurors.

24               Does that make sense?

25               All right.   Both Jurors 27 and 30 are indicating,


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 1   yes, it makes sense.

 2              So thank you for your service on this jury.             It may

 3   well be that I don't see you again.           If not, thank you.

 4              Take care.

 5              (Alternate jurors excused.)

 6              THE COURT:   Anything else this evening, Counsel?

 7              MS. CHAIKEN:      No, Your Honor.

 8              THE COURT:   And just so I'm abundantly clear on this,

 9   I don't care if -- it's 4:48, I don't care if it takes to 5:58

10   or 6:58 or 3:00-in-the-morning-48, let's make darn sure we

11   have that stack ready to go for the jury at 9:00.               Okay.

12              MS. WEBSTER:      Yes, sir.

13              MR. MARSHALL:     Your Honor, I think we have all our

14   exhibits in.    I don't think we need to stay.          We only had a

15   few anyway, Judge.

16              THE COURT:   I understand that, Mr. Marshall, but

17   thank you.    All right.

18              Best of luck.     And, again, I understand the

19   situation.    And had I had a, you know, when I was practicing,

20   a gigantic case with a million pages of documents and without

21   a paralegal, I probably would have had a similar problem.                So

22   all will be well.

23              Take care, everyone.

24              (After a recess at 4:49 p.m., the proceedings were

25   continued as follows on February 15, 2024:)


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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 14th Day of February, 2024.
10
11
12
13
14                             ________________________________

15                             PENNY PRITTY COUDRIET, RMR, CRR
                               OFFICIAL COURT REPORTER
16
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            UNITED STATES DISTRICT COURT - OFFICIAL CERTIFIED TRANSCRIPT
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                        1                  ACCEPT [2] - 144:16, 147:1                AMENDMENT [3] - 167:16, 167:25,
                                           ACCEPTABLE [1] - 171:21                    168:10
1 [5] - 147:7, 164:13, 165:21, 165:22      ACCIDENT [2] - 160:6                      AMERICA [1] - 141:4
12 [3] - 151:22, 167:3, 175:21             ACCOMPLISH [1] - 154:18                   AN [1] - 1:2
14 [4] - 141:11, 151:21, 167:3, 167:20     ACCOUNTS [1] - 157:14                     AND [3] - 1:4, 1:7, 141:6
14TH [1] - 179:9                           ACCURATE [2] - 144:17, 169:24             ANN [1] - 141:18
15 [1] - 177:25                            ACCURATELY [1] - 145:8                    ANSWER [4] - 145:10, 164:21, 164:22,
18 [1] - 163:13                            ACT [13] - 143:12, 148:4, 148:5, 150:9,    164:25
1:20-CR-00296-JPB [1] - 141:5               153:3, 153:19, 154:5, 155:9, 160:4,      ANY [1] - 1:9
1:39 [1] - 168:23                           160:7, 163:21                            ANYWAY [1] - 177:15
1:59 [1] - 142:1                           ACTED [3] - 152:5, 160:10, 160:12         APOLOGIES [1] - 175:25
                                           ACTING [1] - 148:7                        APOLOGIZE [2] - 175:15, 176:7
                        2                  ACTION [4] - 149:17, 152:10, 156:5,       APPEAL [1] - 166:21
2 [1] - 164:18                              156:13                                   APPEAR [1] - 145:9
2024 [3] - 141:11, 177:25, 179:9           ACTIVITIES [1] - 158:5                    APPEARANCES [1] - 141:13
27 [4] - 166:7, 166:9, 176:13, 176:25      ACTIVITY [8] - 157:1, 157:3, 158:10,      APPLICATION [1] - 156:6
28 [1] - 147:7                              158:14, 158:15, 158:19, 158:20,          APPLIES [1] - 160:15
2:30-SOMETHING [1] - 174:21                 158:21                                   APPLY [2] - 160:17, 174:4
                                           ACTS [4] - 148:10, 148:13, 148:16,        APPRECIATE [1] - 172:10
                                            149:4                                    ARE [1] - 1:8
                        3                  ACTUAL [1] - 144:9                        ARGUING [1] - 167:20
30 [5] - 147:7, 166:7, 166:9, 176:13,      ADD [1] - 161:8                           ARGUMENT [2] - 167:17, 167:20
 176:25                                    ADDITION [1] - 165:12                     ARRIVING [1] - 143:25
3:00-IN-THE-MORNING-48 [1] - 177:10        ADDITIONAL [2] - 168:19, 175:5            ASSERTS [1] - 144:9
                                           ADDRESS [1] - 163:6                       ASSETS [1] - 149:8
                        4                  ADMISSION [1] - 145:14                    ASSISTANT [1] - 141:16
41 [1] - 147:7                             ADMITTED [3] - 143:18, 143:19, 173:21     ASSOCIATE [1] - 148:14
42 [1] - 147:4                             ADVANCE [1] - 156:6                       ASSOCIATED [1] - 148:17
46 [1] - 147:8                             ADVANCES [1] - 155:9                      ASSOCIATING [1] - 155:6
47 [1] - 147:8                             AFFAIRS [1] - 143:13                      ASSUME [1] - 143:22
4:31 [1] - 168:24                          AFFECT [2] - 158:5, 161:19                AT [1] - 142:1
4:43 [1] - 174:10                          AFFECTS [2] - 157:19, 157:21              ATLANTA [3] - 141:2, 141:25, 142:1
4:45 [1] - 174:20                          AFORESAID [1] - 179:8                     ATTACHED [1] - 1:6
4:47 [1] - 176:11                          AFTER [1] - 1:7                           ATTACHING [1] - 1:9
4:48 [1] - 177:9                           AFTERNOON [2] - 175:8, 175:16             ATTEMPT [2] - 148:23, 156:12
4:49 [1] - 177:24                          AGENT [3] - 148:6, 148:13, 154:7          ATTEMPTED [2] - 149:6, 150:20
                                           AGO [1] - 170:6                           ATTENTION [1] - 176:14
                                           AGREE [5] - 142:17, 154:1, 155:20,        ATTORNEYS [1] - 141:16
                        5                   159:9, 162:4                             ATTRIBUTION [1] - 171:16
59 [2] - 147:7, 165:1                      AGREED [7] - 151:5, 154:17, 165:9,        AUTHORIZES [1] - 148:13
5:58 [1] - 177:9                            165:23, 169:7, 169:14, 174:1             AUTOMATICALLY [1] - 155:10
                                           AGREEMENT [4] - 154:4, 154:10,            AVERAGE [1] - 146:12
                        6                   162:10, 165:20                           AVOID [1] - 173:24
                                           AHEAD [2] - 171:11, 176:3                 AVOIDANCE [1] - 160:22
6 [1] - 164:18
                                           AID [1] - 146:14                          AVOIDS [1] - 160:25
6:58 [1] - 177:10
                                           AIDS [2] - 148:8, 148:11                  AWARE [3] - 160:12, 160:19, 167:18
                                           ALLEGE [2] - 155:12, 159:6
                        8                  ALLEGED [8] - 150:16, 150:17, 150:21,
8 [1] - 141:6
                                                                                                       B
                                            153:10, 153:15, 153:17, 154:24, 160:3
                                           ALLOW [2] - 146:17, 175:1                 BABASIJIBOMI [1] - 141:15
                        9                  ALLOWED [1] - 146:24                      BACK-AND-FORTH [1] - 175:20
                                           ALLOWS [1] - 158:1                        BAD [1] - 160:9
90 [1] - 1:5                                                                         BANK [12] - 147:12, 147:16, 151:1,
                                           ALONE [2] - 153:6, 162:2
9:00 [4] - 175:10, 175:17, 176:4, 177:11                                              151:13, 154:2, 154:18, 155:12,
                                           ALTERNATE [2] - 166:9, 177:5
                                           ALTERNATES [4] - 172:12, 172:15,           157:25, 158:7, 162:23, 164:24, 165:22
                        A                   176:8, 176:9                             BANKS [1] - 165:24
ABETS [2] - 148:8, 148:11                  ALTERNATIVE [2] - 159:4, 159:9            BASED [3] - 142:12, 143:8, 168:14
ABILITY [1] - 145:7                        ALTERNATIVES [1] - 159:7                  BASIS [1] - 168:1
ABUNDANTLY [1] - 177:8                     AMENABLE [1] - 169:20                     BE [2] - 1:3, 1:4
                                                                                     BECOME [4] - 155:10, 162:12, 172:7,
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 176:22                                  CERTIFY [1] - 179:6                     COMPLETE [2] - 159:10, 162:19
BECOMES [1] - 154:7                      CETERA [1] - 174:15                     COMPLETED [1] - 142:6
BEFORE [1] - 141:10                      CHAIKEN [8] - 141:14, 168:3, 169:25,    CONCEAL [2] - 157:5, 158:25
BEGIN [8] - 142:7, 169:3, 169:11,         170:25, 171:23, 172:19, 173:7, 177:7   CONCEALED [1] - 159:3
 169:16, 169:21, 171:7, 174:24, 175:1    CHAIKEN [4] - 168:2, 169:24, 171:22,    CONCEALMENT [2] - 158:23, 159:1
BEHALF [3] - 141:14, 141:17, 141:20       172:18                                 CONCEALS [2] - 149:25, 152:18
BELIEF [3] - 159:14, 159:16, 159:19      CHAIN [1] - 144:11                      CONCERNED [1] - 144:6
BELIEFS [1] - 162:13                     CHANGE [3] - 151:21, 156:7, 162:11      CONCERNING [2] - 143:7, 144:21
BELIEVES [1] - 160:24                    CHANGED [1] - 168:15                    CONCLUSIONS [2] - 144:5, 171:3
BELLATOR [1] - 164:14                    CHARGE [5] - 142:20, 147:11, 147:14,    CONDITION [1] - 176:19
BEST [1] - 177:18                         159:10, 166:15                         CONDUCT [3] - 156:22, 157:9, 160:13
BETTER [1] - 164:3                       CHARGED [12] - 147:6, 147:8, 147:21,    CONDUCTED [1] - 156:22
BETWEEN [4] - 157:14, 158:10, 158:11,     147:22, 147:23, 148:4, 154:19,         CONDUCTING [1] - 159:2
 165:5                                    155:14, 161:22, 163:14, 163:15,        CONFIRMED [1] - 174:23
BEYOND [18] - 142:10, 143:1, 143:5,       168:16                                 CONJUNCTIVE [1] - 159:6
 143:11, 143:15, 148:20, 149:4,          CHARGES [3] - 147:4, 159:23, 161:14     CONNECTED [1] - 168:14
 150:19, 151:20, 151:23, 154:15,         CHARGING [1] - 164:13                   CONSENT [5] - 171:7, 171:10, 172:15,
 155:18, 156:1, 156:20, 159:8, 159:13,   CHEAT [2] - 149:17, 152:10               173:2, 173:20
 160:1, 161:5                            CHECK [3] - 164:16, 169:1, 169:12       CONSENTED [3] - 169:6, 175:1, 175:20
BINDING [1] - 143:20                     CHECKS [2] - 157:25                     CONSIDER [7] - 142:25, 143:17,
BIT [2] - 169:17, 174:25                 CHOOSE [2] - 163:20, 174:16              144:15, 145:17, 161:15, 161:17,
BONDS [1] - 157:16                       CHOSE [1] - 142:24                       161:25
BOTTOM [1] - 170:10                      CIRCUMSTANCES [2] - 144:12, 145:18      CONSIDERED [1] - 143:10
BOULEE [1] - 141:10                      CIRCUMSTANTIAL [3] - 144:7, 144:11,     CONSIDERING [2] - 144:4, 162:8
BOX [1] - 157:16                          144:14                                 CONSPIRACIES [1] - 168:12
BRIEFING [1] - 168:15                    CITE [1] - 1:5                          CONSPIRACY [17] - 147:22, 148:1,
BRING [8] - 166:2, 170:11, 170:13,       CLEAR [1] - 177:8                        154:4, 154:7, 154:11, 154:14, 155:7,
 171:15, 172:4, 172:25, 175:23, 176:22   CLEARLY [2] - 145:10, 170:15             155:8, 155:11, 162:23, 162:25,
BRINGING [2] - 173:4, 173:5              CLERK [1] - 162:20                       164:13, 164:24, 167:19, 167:20,
BUNCH [2] - 167:18, 167:19               CLERK [3] - 164:7, 165:17, 172:12        167:23, 168:7
BURDEN [1] - 143:4                       CLOSE [5] - 160:2, 165:16, 165:17,      CONSPIRATOR [2] - 154:22, 155:10
BUSINESS [4] - 153:21, 158:10, 159:19,    169:22, 172:24                         CONSPIRATORS [2] - 154:13, 154:24
 168:12                                  CLOSED [1] - 161:7                      CONSPIRE [1] - 154:1
BUSINESSES [3] - 158:10, 158:11,         CLOSING [4] - 167:17, 167:22, 168:7,    CONSPIRED [6] - 147:12, 155:12,
 158:12                                   168:15                                  155:17, 155:19, 155:21, 168:8
BY [3] - 1:4, 1:6, 141:23                CM/ECF [2] - 1:3, 1:5                   CONSPIRING [2] - 147:24, 155:14
                                         COINS [1] - 157:24                      CONSTITUTE [1] - 159:20
                  C                      COMING [2] - 173:4, 175:4               CONSTRUCTIVE [3] - 167:16, 167:25,
                                         COMMERCE [6] - 152:7, 157:20,            168:9
CANNOT [3] - 142:25, 159:15
                                          157:22, 158:4, 158:5, 158:9            CONTAINS [2] - 160:24, 161:1
CAPACITY [3] - 150:4, 152:22, 152:24
                                         COMMIT [13] - 147:12, 147:24, 148:9,    CONTEMPORANEOUS [1] - 168:4
CARE [4] - 177:4, 177:9, 177:23
                                          154:5, 154:18, 155:12, 155:13,         CONTENTS [1] - 161:2
CAREFULLY [1] - 143:9
                                          155:14, 155:17, 155:19, 155:21,        CONTINUE [5] - 173:13, 173:14, 175:22,
CARELESSNESS [2] - 159:18, 161:10
                                          162:23, 164:14                          175:24, 176:16
CARLA [2] - 141:6, 141:20
                                         COMMITMENT [1] - 156:6                  CONTINUED [2] - 168:24, 177:25
CARRIED [3] - 149:6, 150:20, 154:2
                                         COMMITTED [5] - 147:15, 159:5,          CONTROL [2] - 157:6, 159:1
CARRY [7] - 148:23, 149:7, 150:23,
                                          159:24, 160:2, 160:7                   CONTROLLED [6] - 148:25, 160:25,
 151:17, 152:8, 165:10
                                         COMMITTING [1] - 147:23                  161:1, 161:4, 161:6, 161:12
CARRYING [2] - 153:15, 154:13
                                         COMMON [4] - 143:9, 144:5, 154:18,      CONVENIENCE [1] - 163:24
CASE [24] - 142:5, 143:10, 143:18,
                                          155:6                                  CONVICTION [1] - 159:8
 143:23, 145:5, 155:11, 160:16,
                                         COMMONLY [1] - 156:17                   CONVINCED [3] - 143:14, 143:15,
 160:17, 161:17, 161:23, 162:7, 162:9,
                                         COMMUNICATE [1] - 165:25                 162:12
 162:10, 162:14, 162:17, 166:10,
                                         COMMUNICATED [1] - 175:3                CONVINCING [1] - 143:12
 166:11, 168:16, 171:3, 171:11,
                                         COMMUNICATION [1] - 152:7               COPY [2] - 147:9, 165:13
 174:14, 176:14, 177:20, 179:8
                                         COMMUNICATIONS [6] - 150:23,            CORPORATION [2] - 156:9, 158:8
CAUSED [2] - 152:6, 171:16
                                          151:17, 153:19, 153:21, 153:23,        CORRECT [2] - 173:17, 179:7
CAUTION [2] - 161:21, 166:4
                                          169:24                                 COUDRIET [2] - 141:24, 179:15
CELL [1] - 176:19
                                         COMPANIES [1] - 165:23                  COUNSEL [2] - 166:14, 177:6
CERTAIN [3] - 155:6, 156:16, 159:24
                                         COMPANY [1] - 165:21                    COUNSEL [10] - 151:1, 162:20, 163:6,
CERTIFICATE [1] - 157:17
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 167:8, 169:12, 169:13, 169:20, 173:2,    DECEPTION [1] - 146:8                    DEPUTY [3] - 164:7, 165:17, 172:12
 173:10, 173:15                           DECIDE [14] - 142:9, 144:17, 144:23,     DERIVED [1] - 158:17
COUNSEL'S [2] - 161:8, 169:12              145:14, 146:7, 147:3, 150:3, 152:21,    DESCRIBE [2] - 164:3, 165:23
COUNT [3] - 147:5, 161:14, 165:4           162:1, 162:2, 162:7, 165:5, 171:8,      DESCRIBED [1] - 156:5
COUNT [5] - 147:7, 164:13, 164:18,         171:9                                   DESCRIBING [2] - 151:13, 162:23
 165:1                                    DECIDED [3] - 166:20, 171:19, 175:6      DESIGNED [1] - 157:5
COUNTRY [1] - 157:24                      DECIDING [1] - 142:5                     DETAIL [1] - 146:10
COUNTS [9] - 147:5, 147:11, 147:14,       DECISION [8] - 142:12, 143:1, 144:1,     DETAILS [3] - 150:15, 153:9, 154:23
 147:22, 155:11, 155:14, 164:12, 165:1     144:19, 146:9, 150:5, 152:23, 152:25    DETERMINE [2] - 161:5, 161:23
COUNTS [3] - 147:7, 147:8                 DECISIONMAKER [2] - 150:6, 153:1         DEVISED [1] - 151:25
COUPLE [5] - 162:21, 174:19, 174:20,      DECISIONS [1] - 145:17                   DIFFER [1] - 145:11
 175:14                                   DEDUCTIONS [1] - 144:5                   DIFFERENCE [1] - 144:13
COURSE [3] - 149:16, 152:9, 153:21        DEFENDANT [78] - 142:10, 142:14,         DIFFERENT [1] - 146:1
COURT [2] - 163:22, 166:2                  142:20, 142:21, 142:22, 142:23,         DIFFERENTLY [1] - 162:13
COURT [47] - 1:4, 1:7, 1:10, 141:1,        142:24, 143:2, 143:14, 145:13,          DIRECT [5] - 144:7, 144:8, 144:14,
 141:24, 141:25, 142:1, 142:3, 151:5,      145:15, 145:21, 148:2, 148:3, 148:8,     163:21, 175:6
 151:8, 151:10, 151:12, 163:16, 164:8,     148:10, 148:11, 148:12, 148:15,         DIRECTING [1] - 148:6
 165:18, 166:22, 166:25, 167:2, 167:8,     148:17, 148:18, 148:21, 149:3, 149:6,   DIRECTION [1] - 148:7
 167:10, 168:2, 168:17, 168:20,            149:13, 150:19, 150:25, 151:2, 151:3,   DIRECTLY [2] - 145:10, 158:18
 168:25, 170:1, 170:3, 170:5, 170:22,      151:14, 151:19, 151:25, 152:5, 152:6,   DIRECTS [1] - 148:13
 171:6, 171:15, 171:24, 172:1, 172:3,      153:15, 154:14, 154:20, 154:25,         DISBELIEVE [1] - 144:19
 172:14, 172:20, 172:22, 172:24,           155:3, 155:12, 155:17, 155:19,          DISCUSS [1] - 162:9
 173:12, 174:3, 174:8, 174:11, 176:12,     155:21, 155:25, 156:3, 156:4, 156:19,   DISCUSSED [1] - 173:23
 177:6, 177:8, 177:16, 179:3, 179:15       156:22, 156:24, 157:4, 159:11,
                                                                                   DISCUSSING [3] - 155:6, 162:10, 163:2
COURT [4] - 166:23, 167:15, 167:17,        159:21, 159:22, 160:19, 160:21,
                                                                                   DISCUSSIONS [2] - 142:7, 174:23
 167:24                                    160:24, 161:3, 161:5, 161:11, 161:17,
                                                                                   DISGUISE [2] - 157:5, 158:25
COURT'S [1] - 142:19                       161:18, 161:20, 161:21, 161:24,
                                                                                   DISOBEY [1] - 160:9
COURTROOM [9] - 142:2, 165:11,             162:1, 162:21, 162:22, 162:24,
                                                                                   DISPOSITION [1] - 157:12
 166:4, 167:7, 173:5, 174:10, 175:24,      162:25, 163:3, 163:4, 163:14, 164:15
                                                                                   DISPROVE [1] - 144:12
 176:11                                   DEFENDANT [5] - 147:6, 147:8, 147:11,
                                                                                   DISREGARD [3] - 142:18, 143:24,
COURTROOM [3] - 164:7, 165:17,             160:16, 160:17
                                                                                    160:10
 172:12                                   DEFENDANT [2] - 141:17, 141:20
                                                                                   DISTRICT [6] - 141:1, 141:1, 141:10,
CREDIT [1] - 157:15                       DEFENDANT'S [3] - 143:5, 143:7,
                                                                                    141:25, 179:3, 179:4
CRIME [29] - 148:2, 148:9, 148:18,         160:18
                                                                                   DIVISION [1] - 141:2
 148:19, 148:23, 149:3, 150:22,           DEFENDANTS [5] - 147:5, 147:21,
                                                                                   DOCKET [2] - 1:6, 141:5
 150:25, 151:16, 151:19, 153:24,           155:14, 161:15, 163:15
                                                                                   DOCUMENT [1] - 174:14
 153:25, 154:2, 155:22, 155:25,           DEFENDANTS [1] - 141:8
                                                                                   DOCUMENT [1] - 1:10
 156:12, 156:16, 156:19, 159:3,           DEFENDANTS [1] - 147:14
                                                                                   DOCUMENTS [21] - 169:18, 170:12,
 159:23, 159:25, 160:2, 160:19,           DEFENSE [2] - 159:10, 170:7
                                                                                    170:14, 170:17, 171:11, 171:18,
 161:14, 161:16, 161:18, 161:19,          DEFRAUD [21] - 148:24, 149:7, 149:13,
                                                                                    171:20, 173:15, 173:20, 174:13,
 163:4, 163:5                              149:16, 149:23, 150:1, 150:9, 150:14,
                                                                                    174:15, 174:24, 175:1, 175:2, 175:4,
CRIMES [7] - 147:4, 155:15, 155:17,        150:23, 151:17, 152:1, 152:5, 152:8,
                                                                                    175:6, 175:8, 175:10, 175:22, 177:20
 155:20, 155:21, 161:22, 161:24            152:9, 152:16, 152:19, 153:3, 153:8,
                                                                                   DONE [3] - 148:5, 148:6, 160:4
CRIMINAL [1] - 154:6                       153:23, 159:11, 159:12
                                                                                   DOUBT [21] - 142:11, 143:2, 143:6,
CRIMINALLY [2] - 148:10, 148:15           DEFRAUDING [2] - 150:18, 153:18
                                                                                    143:7, 143:8, 143:11, 143:15, 148:21,
CRR [2] - 141:24, 179:15                  DEGREE [3] - 157:19, 157:21, 158:6
                                                                                    149:5, 150:19, 151:20, 151:24,
CSO [1] - 172:3                           DELIBERATE [6] - 160:22, 166:10,
                                                                                    154:16, 155:18, 156:2, 156:21, 159:8,
CURRENCY [2] - 157:15, 157:24              167:4, 167:7, 176:18, 176:21
                                                                                    159:13, 160:2, 161:5
                                          DELIBERATELY [2] - 160:25, 161:7
                                                                                   DOWN [2] - 166:1, 179:7
                   D                      DELIBERATES [1] - 176:17
                                                                                   DRIVE [2] - 173:16, 173:23
                                          DELIBERATING [2] - 169:19, 169:21
DARN [1] - 177:10                                                                  DURING [8] - 142:13, 143:25, 146:1,
                                          DELIBERATIONS [17] - 142:8, 146:15,
DARRELL [1] - 168:9                                                                 146:11, 146:14, 147:9, 164:2, 167:16
                                           147:10, 162:5, 163:22, 169:4, 169:11,
DATE [8] - 159:24, 160:1, 160:2, 160:3,                                            DURRETT [1] - 141:18
                                           169:16, 171:7, 171:19, 173:4, 174:24,
 165:1, 165:2, 165:7, 165:10                                                       DUTY [1] - 142:4
                                           175:2, 175:7, 175:22, 175:24, 176:4
DAVID [1] - 141:20
                                          DELIVERY [2] - 157:12, 158:2
DAYS [1] - 1:5
                                          DENY [2] - 161:1, 168:20                                   E
DEALING [2] - 172:8, 175:14
                                          DEPOSIT [2] - 156:9, 158:7               E-MAIL [1] - 163:9
DECEIVE [5] - 149:17, 150:12, 152:10,
                                          DEPOSIT [3] - 157:14, 157:16, 157:17     EDITS [1] - 163:13
 153:6, 159:21
                                          DEPOSITS [1] - 156:8                     EFFECT [1] - 158:24
 Case 1:20-cr-00296-JPB-CMS                     Document 1032               Filed 06/14/24          Page 44 of 49

                                                                                                                       183


EFFECTIVELY [2] - 149:25, 152:17          146:10, 149:10, 149:19, 149:21,          163:25, 164:5, 165:2, 165:3, 165:5,
EITHER [6] - 142:14, 144:14, 151:11,      149:25, 150:2, 150:4, 152:4, 152:14,     165:7, 165:8, 165:10, 165:12, 167:5,
 162:20, 164:16, 166:3                    152:18, 152:20, 152:22, 152:24,          169:5, 171:3
ELECTRONIC [1] - 174:15                   160:18, 160:20, 160:21                  FORMAL [2] - 142:20, 154:10
ELEMENT [2] - 158:23, 160:19             FACTS [9] - 142:10, 144:1, 144:11,       FORMED [1] - 159:14
ELMO [1] - 164:1                          151:20, 151:23, 154:15, 156:1,          FORMS [1] - 164:10
EMPHASIZE [2] - 146:19, 161:10            156:20, 162:16                          FORTH [1] - 175:20
EMPLOYEE [1] - 148:13                    FACTUAL [1] - 143:23                     FOSTER [2] - 141:7, 141:17
ENGAGE [1] - 156:16                      FAILS [1] - 143:2                        FOSTER [8] - 147:6, 147:11, 147:15,
ENTERED [2] - 142:2, 174:10              FAIR [1] - 171:10                         160:17, 164:11, 164:15, 168:8, 170:7
ENTITLED [1] - 146:19                    FAIRLY [2] - 174:14, 175:4               FOSTER'S [4] - 164:8, 165:5, 173:10,
ENTRY [1] - 1:6                          FAITH [3] - 159:10, 159:12, 159:20        173:15
EQUIVALENT [1] - 160:23                  FALSE [23] - 147:16, 149:1, 149:9,       FRAUD [22] - 147:12, 147:13, 147:16,
ERROR [1] - 159:17                        149:11, 149:18, 149:20, 149:24,          151:1, 151:2, 151:13, 151:15, 153:15,
ESQ [6] - 141:14, 141:15, 141:15,         150:8, 150:10, 152:1, 152:3, 152:11,     154:2, 154:3, 154:19, 155:13, 157:3,
 141:18, 141:18, 141:20                   152:13, 152:17, 153:2, 153:4, 153:13,    158:22, 162:23, 162:24, 164:14,
ESSENTIAL [1] - 160:18                    155:22, 156:3, 156:10, 156:13,           164:24
ESTABLISH [2] - 155:7, 159:18             159:22, 163:2                           FRAUDULENT [16] - 149:9, 149:11,
ESTABLISHED [1] - 168:12                 FALSELY [1] - 145:23                      149:18, 149:21, 149:24, 150:10,
ET [1] - 174:15                          FAR [1] - 169:24                          152:1, 152:11, 152:13, 152:17, 153:4,
EVENING [4] - 175:9, 175:17, 176:10,     FEBRUARY [2] - 177:25, 179:9              153:13, 159:15, 159:18, 159:22
 177:6                                   FEBRUARY [1] - 141:11                    FROM [1] - 1:9
EVENT [2] - 155:5, 168:6                 FEDERAL [2] - 156:9, 158:7               FULL [1] - 176:3
EVIDENCE [32] - 142:12, 142:21,          FEDERAL [8] - 148:23, 149:15, 150:22,    FULL [1] - 1:9
 142:23, 143:10, 143:17, 143:18,          151:16, 153:25, 155:22, 156:16,         FULLY [1] - 162:8
 143:20, 144:3, 144:4, 144:6, 144:8,      158:16
 144:11, 144:14, 144:15, 144:16,         FEDERALLY [4] - 147:17, 149:15,                             G
 145:12, 145:13, 145:17, 145:20,          155:23, 163:3
                                                                                  GENERAL [1] - 155:1
 145:22, 145:24, 146:16, 148:3, 159:1,   FELONY [1] - 158:16
                                                                                  GENTLEMEN [3] - 163:17, 164:10,
 159:17, 161:16, 161:23, 162:8,          FEW [4] - 144:24, 163:18, 174:19,
                                                                                   174:12
 162:17, 168:11, 171:5, 173:21            177:15
                                                                                  GEORGIA [4] - 141:1, 141:25, 142:1,
EXACT [1] - 159:25                       FIELD [1] - 146:24
                                                                                   179:4
EXAMINE [1] - 162:11                     FILED [3] - 1:3, 1:8, 1:10
                                                                                  GIFT [1] - 157:12
EXAMPLE [7] - 160:23, 161:9, 161:13,     FINANCIAL [13] - 147:17, 148:24,
                                                                                  GIGANTIC [1] - 177:20
 164:12, 164:17, 165:22                   148:25, 149:7, 149:8, 149:13, 155:23,
                                                                                  GIVEN [5] - 147:9, 169:1, 170:24,
EXCEPT [1] - 143:23                       156:17, 156:23, 157:13, 157:18,
                                                                                   171:10, 176:15
EXCHANGE [1] - 157:15                     158:3, 158:6
                                                                                  GOALS [1] - 155:7
EXCLUDE [1] - 143:6                      FINE [7] - 151:11, 169:20, 171:14,
                                                                                  GOVERNING [1] - 147:18
EXCLUSIVE [1] - 153:14                    172:8, 172:14, 172:19, 174:3
                                                                                  GOVERNMENT [1] - 141:14
EXCUSE [3] - 147:19, 152:23, 159:15      FINISH [1] - 157:9
                                                                                  GOVERNMENT [19] - 142:9, 142:15,
EXCUSED [1] - 177:5                      FIRST [8] - 147:21, 164:7, 164:10,
                                                                                   143:1, 145:13, 150:15, 151:10, 153:9,
EXHIBITRON [3] - 164:2, 164:3, 164:5      165:4, 166:13, 168:3, 169:23, 170:6
                                                                                   154:8, 154:12, 155:16, 155:18,
EXHIBITS [9] - 143:19, 165:14, 165:16,   FIXED [2] - 166:15, 175:16
                                                                                   156:14, 158:23, 159:12, 159:24,
 167:6, 169:7, 171:3, 174:4, 174:13,     FLASH [2] - 173:16, 173:23
                                                                                   160:1, 164:23, 167:1, 167:21
 177:14                                  FOLLOW [3] - 142:16, 142:17, 169:17
                                                                                  GOVERNMENT'S [5] - 143:4, 143:6,
EXIST [1] - 160:21                       FOLLOW-UP [1] - 169:17
                                                                                   160:16, 160:17, 167:17
EXISTED [1] - 160:20                     FOLLOWING [1] - 1:2
                                                                                  GRAB [1] - 172:3
EXISTENCE [1] - 168:11                   FOLLOWING [6] - 149:4, 151:20,
                                                                                  GREATER [2] - 146:20, 175:13
EXITED [2] - 167:7, 176:11                151:23, 154:15, 156:1, 156:20
                                                                                  GROSS [1] - 158:19
EXPECTATION [2] - 174:17, 175:3          FOLLOWS [2] - 168:24, 177:25
                                                                                  GROUP [1] - 164:14
EXPERIENCE [1] - 146:24                  FOOLISHNESS [1] - 161:11
                                                                                  GUESS [1] - 174:4
EXPLAIN [4] - 142:16, 147:18, 162:5,     FOR [2] - 1:5, 141:1
                                                                                  GUILT [4] - 142:21, 143:1, 143:5, 143:7
 170:8                                   FORBIDS [2] - 160:9, 160:11
                                                                                  GUILTY [30] - 142:10, 143:3, 143:14,
EXTENSION [2] - 156:7, 157:15            FOREGOING [1] - 179:6
                                                                                   148:2, 149:3, 150:25, 151:19, 154:14,
EYES [1] - 161:7                         FOREIGN [6] - 157:19, 157:22, 158:4,
                                                                                   155:4, 155:20, 155:25, 156:19,
EYEWITNESS [1] - 144:10                   158:5, 158:9, 158:16
                                                                                   161:18, 161:24, 162:1, 162:2, 162:3,
                                         FOREPERSON [6] - 163:21, 165:2,
                                                                                   162:24, 163:1, 163:4, 163:5, 164:16,
                                          165:7, 165:9, 174:16
                   F                                                               164:20, 164:22, 165:6
                                         FORGET [1] - 146:5
FACT [21] - 144:9, 144:12, 145:23,                                                GYMNASTICS [1] - 171:8
                                         FORM [15] - 158:1, 158:19, 163:23,
 Case 1:20-cr-00296-JPB-CMS                     Document 1032               Filed 06/14/24            Page 45 of 49

                                                                                                                         184


                                           147:9, 150:16, 150:21, 153:10, 154:9,
                  H                                                                                    J
                                           154:19, 155:12, 156:6, 159:5, 159:23,
HALF [4] - 149:24, 152:17, 170:6,          161:14, 161:22, 164:13, 165:14,         J.P [1] - 141:10
 170:19                                    165:21, 167:5                           JACKSON [3] - 147:8, 147:14, 160:16
HALF-TRUTH [1] - 152:17                  INDIFFERENCE [2] - 149:22, 152:15         JACKSON [2] - 141:6, 141:20
HAPPY [1] - 175:11                       INDIRECTLY [1] - 158:18                   JACKSON'S [1] - 165:3
HARD [1] - 174:14                        INDIVIDUALLY [1] - 161:18                 JOINED [2] - 154:21, 155:2
HAS [1] - 1:8                            INFLUENCE [5] - 150:5, 152:23, 152:25,    JOINS [1] - 148:9
HEARD [3] - 164:1, 170:22, 171:13          156:5, 156:12                           JUDGE [4] - 151:7, 172:2, 172:23,
HEARING [1] - 161:9                      INFLUENCED [3] - 142:13, 146:17,           177:15
HEART [2] - 154:11, 156:12                 156:15                                  JUDGE [2] - 162:2, 166:23
HEAVY [1] - 143:4                        INJURY [4] - 150:12, 150:13, 153:6,       JUDGE [1] - 141:10
HELD [1] - 159:14                          153:7                                   JUDGES [2] - 162:15, 162:16
HELD [1] - 142:1                         INNOCENCE [1] - 142:23                    JUDGMENT [1] - 159:17
HELLO [1] - 176:13                       INNOCENT [2] - 142:22, 146:7              JUROR [1] - 166:7
HELP [1] - 152:8                         INSTEAD [3] - 163:15, 176:16, 176:18      JURORS [1] - 176:25
HELPFUL [1] - 146:23                     INSTITUTION [16] - 147:17, 148:24,        JURORS [10] - 146:18, 162:8, 166:5,
HEREBY [1] - 179:6                         149:1, 149:7, 149:9, 149:14, 149:15,     166:7, 166:9, 176:13, 176:20, 176:23,
HESITATE [1] - 162:11                      155:24, 156:5, 156:8, 156:13, 156:15,    177:5
HESITATION [1] - 143:13                    157:13, 158:4, 158:6, 163:3             JURY [1] - 141:9
HIGH [1] - 160:20                        INSTRUCT [1] - 142:4                      JURY [29] - 142:2, 142:4, 142:6, 163:18,
HOLD [1] - 176:16                        INSTRUCTION [2] - 160:15, 171:1            163:20, 164:10, 164:15, 165:8,
HONEST [2] - 159:19, 162:13              INSTRUCTIONS [9] - 142:6, 142:18,          166:13, 167:4, 167:7, 167:10, 169:3,
HONESTLY [2] - 159:14                      142:19, 143:24, 147:25, 162:19,          169:4, 169:10, 169:16, 169:19,
HONOR [28] - 151:11, 163:10, 163:11,       165:13, 167:6, 169:6                     169:21, 170:11, 170:23, 171:15,
 163:12, 166:17, 166:19, 167:9,          INSTRUMENT [1] - 157:17                    172:4, 174:10, 174:12, 176:8, 176:11,
 167:14, 168:3, 168:19, 169:25, 170:2,   INSTRUMENTS [3] - 157:23, 158:1            176:17, 177:2, 177:11
 170:4, 170:25, 171:1, 171:14, 171:23,   INSURANCE [2] - 156:9, 158:7
 171:25, 172:10, 172:19, 172:21,         INSURED [6] - 147:17, 149:15, 155:23,                        K
 173:7, 173:8, 173:9, 173:10, 173:18,      156:8, 158:7, 163:3                     KAUSHAL [5] - 141:15, 151:11, 163:12,
 177:7, 177:13                           INTENDED [5] - 149:13, 149:17, 152:10,     166:18, 167:1
HONORABLE [1] - 141:10                     153:14, 159:21                          KEEP [2] - 146:3, 176:19
HOPEFULLY [2] - 170:19, 176:2            INTENSIVE [1] - 174:14                    KIND [5] - 154:5, 154:10, 156:25,
HOUR [2] - 170:5, 170:19                 INTENT [23] - 149:23, 150:1, 150:9,        158:14, 168:14
HOURS [3] - 171:18, 174:20, 175:14         150:10, 150:12, 150:13, 152:5,          KINDS [1] - 156:17
HOWEVER [1] - 1:8                          152:16, 152:18, 153:3, 153:4, 153:6,    KNOWING [2] - 148:22, 154:22
                                           153:7, 156:4, 159:11, 159:12, 159:16,   KNOWINGLY [13] - 147:12, 149:6,
                   I                       159:18, 160:8, 160:11, 171:15            150:9, 150:20, 151:25, 153:3, 153:25,
                                         INTENTIONAL [1] - 146:8                    155:22, 156:4, 156:13, 156:16,
IDENTIFIED [1] - 162:20
                                         INTENTIONALLY [3] - 148:9, 148:17,         156:22, 160:4
IDENTITIES [1] - 154:24
                                           160:5                                   KNOWLEDGE [6] - 144:9, 146:23,
ILL [1] - 170:7
                                         INTEREST [2] - 145:4, 162:16               160:18, 160:22, 160:23, 161:2
IMPARTIALLY [1] - 143:9
                                         INTERESTS [1] - 155:7                     KNOWN [3] - 150:7, 153:2, 156:17
IMPORTANT [6] - 143:13, 144:18,
                                         INTERPRETATION [1] - 144:2                KNOWS [3] - 149:22, 152:14, 156:11
  145:23, 146:10, 150:2, 152:20
                                         INTERRUPT [1] - 173:12
IMPRESS [1] - 144:25
                                         INTERSTATE [11] - 150:22, 151:16,
IMPRESSION [1] - 169:8
                                           152:7, 153:13, 153:19, 153:22,
                                                                                                      L
IMPRESSIONS [1] - 146:20                                                           LADIES [3] - 163:17, 164:10, 174:12
                                           157:19, 157:22, 158:4, 158:5, 158:9
IN [3] - 1:3, 1:4, 142:1                                                           LAPSE [1] - 146:7
                                         INVESTMENT [1] - 157:25
INACCURATELY [1] - 146:6                                                           LAST [1] - 175:14
                                         INVOLVED [3] - 156:25, 158:4, 158:13
INC [1] - 164:14                                                                   LAUNDERING [2] - 147:18, 156:18
                                         INVOLVES [1] - 164:11
INCLUDES [5] - 143:18, 149:16, 157:14,                                             LAW [13] - 142:5, 142:16, 142:17,
                                         INVOLVING [3] - 157:22, 158:2, 158:3
  157:24, 158:7                                                                     142:19, 142:21, 143:24, 147:18,
                                         IS [1] - 1:2
INCLUDING [3] - 145:18, 158:19,                                                     158:16, 160:9, 160:10, 160:11,
                                         ISSUE [6] - 143:23, 167:9, 170:24,
  165:19                                                                            160:13, 162:20
                                           171:17, 172:7, 173:22
INCONVENIENCE [1] - 175:14                                                         LAWYERS [1] - 143:20
                                         ISSUES [7] - 163:7, 166:14, 166:15,
INCONVENIENCED [1] - 176:2                                                         LEARNING [1] - 160:25
                                           169:2, 170:9, 171:17, 174:13
INDEPENDENT [1] - 146:16                                                           LEAST [2] - 155:2, 158:10
                                         ITSELF [3] - 153:13, 154:12, 159:3
INDICATING [1] - 176:25                                                            LEE [5] - 163:25, 164:6, 164:18, 165:15,
INDICTMENT [18] - 142:20, 147:4,                                                    169:12
 Case 1:20-cr-00296-JPB-CMS                       Document 1032               Filed 06/14/24           Page 46 of 49

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LEGAL [1] - 144:13                        MISTAKEN [1] - 159:16                     NOTE [1] - 147:21
LEIGH [1] - 141:18                        MOMENT [4] - 147:20, 157:8, 162:18,       NOTES [5] - 146:11, 146:14, 146:15,
LINE [1] - 170:10                          168:17                                    146:17, 146:19
LINE [1] - 1:7                            MONETARY [3] - 157:17, 157:23             NOTHING [1] - 168:19
LIST [1] - 174:3                          MONEY [14] - 147:17, 148:25, 149:8,       NUMBER [2] - 144:20, 147:6
LISTED [3] - 164:12, 165:6, 165:24         149:17, 152:10, 156:17, 156:24,          NUMBER [2] - 1:6, 1:7
LITIGATED [2] - 167:18, 167:19             157:2, 157:12, 157:20, 157:25,
LOAN [5] - 150:12, 156:7, 157:11,          158:13, 158:15, 159:2                                        O
 157:15, 168:8                            MOORE [1] - 141:15
                                                                                    OBJECT [1] - 164:23
LOCATION [2] - 157:6, 158:25              MORNING [8] - 170:13, 170:24, 171:20,
                                                                                    OBJECTED [1] - 166:16
LOSE [1] - 176:20                          173:3, 175:10, 175:18, 175:21, 176:5
                                                                                    OBJECTION [4] - 161:9, 166:20, 167:1,
LOSS [4] - 150:11, 150:13, 153:5, 153:7   MOST [2] - 143:13, 146:12
                                                                                     168:4
LOST [1] - 166:8                          MOTION [1] - 168:21
                                                                                    OBJECTIONS [1] - 166:24
LUCK [1] - 177:18                         MOTIONS [1] - 167:18
                                                                                    OBSERVE [1] - 145:8
                                          MOVE [1] - 167:24
                                                                                    OBTAINED [1] - 158:18
                   M                      MOVING [1] - 157:20
                                                                                    OCCASION [1] - 155:3
                                          MR [16] - 151:7, 151:9, 151:11, 163:11,
MAIL [1] - 163:9                                                                    OCCURRED [1] - 159:25
                                           163:12, 166:18, 166:23, 167:1, 170:4,
MANAGEMENT [1] - 159:17                                                             OCCURS [1] - 160:23
                                           171:1, 171:14, 172:2, 172:23, 173:9,
MANNER [1] - 154:17                        173:14, 177:13                           OF [10] - 1:2, 1:5, 1:6, 141:1, 141:4,
MARSHALL [13] - 141:20, 151:7, 151:9,     MS [24] - 151:4, 151:6, 163:10, 166:17,    141:9, 141:14, 141:17, 141:20, 179:4
 163:11, 166:23, 170:4, 171:1, 171:14,     166:19, 167:9, 167:14, 168:3, 168:19,    OFFENSE [5] - 147:23, 147:24, 154:15,
 172:2, 172:23, 173:9, 173:14, 177:13      169:25, 170:2, 170:18, 170:25,            159:5, 162:25
MARSHALL [6] - 151:8, 170:3, 171:13,       171:23, 171:25, 172:10, 172:19,          OFFENSES [3] - 147:15, 147:19, 147:20
 172:1, 172:22, 177:16                     172:21, 173:7, 173:8, 173:18, 174:7,     OFFERS [1] - 145:13
MATERIAL [18] - 149:10, 149:12,            177:7, 177:12                            OFFICER [1] - 166:2
 149:19, 149:21, 149:25, 150:2, 150:4,    MUELLER [1] - 151:21                      OFFICER [1] - 174:9
 152:4, 152:14, 152:18, 152:20,           MULTIPLE [3] - 159:4, 159:6, 168:12       OFFICIAL [6] - 1:2, 1:3, 1:4, 1:8, 141:24,
 152:22, 152:24, 153:11, 153:12,          MULTIPLICITOUS [1] - 167:19                179:15
 167:16, 167:25, 168:1                    MUST [36] - 142:5, 142:9, 142:12,         ON [3] - 141:14, 141:17, 141:20
MATERIALS [2] - 165:19, 174:18             142:13, 142:16, 142:17, 142:18,          ONCE [3] - 173:3, 175:8, 175:21
MATTER [4] - 144:22, 146:25, 150:6,        143:1, 143:2, 143:17, 144:15, 144:16,    ONE [26] - 144:25, 145:15, 150:21,
 152:25                                    145:14, 145:17, 146:6, 146:14,            155:2, 155:9, 155:19, 157:8, 157:22,
MATTERS [1] - 144:3                        146:15, 146:16, 147:1, 147:2, 148:20,     159:7, 161:15, 161:18, 162:9, 162:18,
MAY [2] - 1:3, 1:5                         150:18, 155:20, 158:24, 159:1,            162:20, 163:20, 164:7, 164:11, 166:5,
MEAN [3] - 144:16, 146:3, 147:1            159:12, 160:10, 161:10, 161:15,           167:9, 167:20, 167:23, 168:7, 168:17,
MEANS [13] - 150:9, 152:9, 153:3,          161:16, 161:19, 161:25, 162:3, 162:4,     169:15, 176:20, 176:22
 153:14, 157:9, 157:11, 157:18,            162:7, 162:9                             ONES [1] - 166:20
 157:20, 158:9, 158:17, 158:21, 160:4,                                              ONLY [2] - 1:3, 1:7
 160:7                                                                              OPEN [1] - 142:1
                                                             N
MEMBER [3] - 154:6, 154:7, 170:7                                                    OPINION [7] - 143:23, 146:24, 147:2,
MEMBERS [4] - 142:4, 154:9, 154:10,       NAMED [1] - 154:9                          147:3, 159:14, 159:16, 162:11
 163:21                                   NAMES [1] - 154:23                        OPPORTUNITY [2] - 145:7, 146:13
MEMORIES [1] - 146:20                     NATURAL [3] - 150:5, 152:22, 152:24       OPPOSED [1] - 167:21
MEMORY [3] - 145:6, 146:7, 146:14         NATURALLY [1] - 146:5                     OPTIONS [1] - 165:6
MENTIONED [1] - 165:4                     NATURE [5] - 150:16, 153:10, 157:6,       OR [1] - 1:9
MERELY [4] - 148:22, 155:6, 158:24,        158:25, 159:3                            ORDERS [1] - 157:25
 159:2                                    NECESSARILY [1] - 144:21                  ORDINARILY [1] - 148:5
MESSAGE [3] - 166:1, 169:17, 172:13       NECESSARY [1] - 142:10                    OUTCOME [1] - 145:5
MIGHT [3] - 146:23, 164:3, 174:5          NEED [10] - 160:12, 166:11, 170:11,       OUTSIDE [1] - 158:12
MILLION [1] - 177:20                       172:17, 174:5, 176:4, 176:9, 176:22,     OWN [4] - 143:13, 144:1, 144:2, 162:11
MIND [2] - 146:3, 162:11                   177:14                                   OWNED [1] - 148:25
MINOR [1] - 154:25                        NEGLIGENCE [1] - 161:10                   OWNERS [1] - 168:13
MINUTES [7] - 170:17, 170:19, 170:21,     NEGOTIABLE [1] - 158:1                    OWNERSHIP [3] - 157:6, 158:2, 158:25
 171:18, 174:19                           NEVER [2] - 161:25, 162:5
MISLED [1] - 156:15                       NEXT [1] - 160:15
                                          NO [1] - 141:5
                                                                                                        P
MISSED [1] - 163:18
                                          NORMAL [1] - 153:21                       P.M [5] - 168:23, 168:24, 174:10,
MISSTATED [1] - 146:6
                                          NORMALLY [2] - 153:20, 172:6               176:11, 177:24
MISSTATEMENT [1] - 146:9
                                          NORTHERN [2] - 141:1, 179:4               PACKAGE [1] - 160:24
MISTAKE [3] - 146:3, 159:17, 160:5
 Case 1:20-cr-00296-JPB-CMS                     Document 1032               Filed 06/14/24          Page 47 of 49

                                                                                                                      186


PACKAGE'S [1] - 161:2                    POTENTIALLY [1] - 172:16                 PUTTING [2] - 173:23, 175:7
PACKET [1] - 165:18                      PRACTICING [1] - 177:19
PAGE [3] - 151:21, 163:13, 164:18        PRECISE [2] - 150:16, 153:10                               Q
PAGE [1] - 1:7                           PREJUDICE [1] - 142:14
                                                                                  QUESTIONS [3] - 144:24, 145:9, 164:25
PAGES [3] - 151:22, 177:20, 179:6        PREPARED [1] - 163:23
PARALEGAL [3] - 170:8, 172:5, 177:21     PRESENT [2] - 148:19, 155:5
PARDON [1] - 163:17                      PRESENTED [1] - 142:13                                     R
PART [5] - 144:20, 153:23, 157:5,        PRESERVE [1] - 166:20                    RADIO [2] - 150:22, 151:16
 164:21, 173:22                          PRESERVED [1] - 168:5                    RAISED [1] - 168:4
PARTIAL [1] - 1:9                        PRESUMES [1] - 142:21                    RE [1] - 162:11
PARTICIPANT [1] - 148:21                 PRETENSES [9] - 149:1, 149:9, 149:11,    RE-EXAMINE [1] - 162:11
PARTICIPATE [1] - 157:10                  149:18, 150:11, 152:2, 152:3, 152:11,   REACH [5] - 144:5, 162:9, 164:19,
PARTICIPATED [2] - 148:17, 151:25         153:5                                    164:20, 164:21
PARTICULAR [2] - 144:21, 145:2           PRETTY [1] - 169:2                       READ [1] - 151:14
PARTIES [9] - 165:15, 165:20, 165:23,    PREVIOUS [1] - 166:24                    READING [2] - 163:7, 163:8
 173:20, 173:25, 174:23, 175:1,          PREVIOUSLY [2] - 166:16, 166:20          READY [9] - 169:9, 169:18, 170:14,
 175:20, 176:15                          PRINTED [1] - 173:22                      170:17, 174:9, 175:10, 176:3, 176:20,
PARTNER [1] - 154:7                      PRINTING [1] - 173:24                     177:11
PARTNERSHIP [1] - 154:6                  PRIORITY [1] - 146:15                    REAL [2] - 143:8, 162:15
PARTY [1] - 171:16                       PRITTY [2] - 141:24, 179:15              REALIZED [1] - 174:25
PASSED [1] - 175:5                       PROBABILITY [1] - 160:20                 REASON [4] - 143:9, 145:2, 161:7,
PAUSE [3] - 170:12, 171:19, 175:6        PROBLEM [1] - 177:21                      176:21
PDF [1] - 1:2                            PROCEEDINGS [3] - 168:23, 177:24,        REASONABLE [21] - 142:11, 143:1,
PENNY [2] - 141:24, 179:15                179:7                                    143:7, 143:8, 143:11, 143:15, 148:20,
PEOPLE [6] - 146:5, 154:9, 155:6,        PROCEEDINGS [2] - 141:9, 142:1            149:4, 150:3, 150:19, 151:20, 151:23,
 158:10, 158:11, 158:12                  PROCEEDS [4] - 156:25, 157:7, 158:17,     152:21, 154:16, 155:18, 156:1,
PERFORMED [1] - 148:3                     159:1                                    156:20, 159:8, 159:13, 160:1, 161:5
PERHAPS [1] - 146:12                     PROCESS [1] - 174:2                      REASONABLY [1] - 160:2
PERIOD [1] - 1:5                         PRODUCE [1] - 142:23                     REASONING [1] - 144:4
PERMISSIBLE [1] - 169:19                 PROHIBITED [1] - 1:9                     RECEIPTS [1] - 158:19
PERMISSION [1] - 161:8                   PROMISE [2] - 157:11, 170:21             RECEIVE [1] - 173:3
PERMITTED [1] - 146:11                   PROMISES [9] - 149:2, 149:10, 149:12,    RECESS [2] - 168:23, 177:24
PERSON [18] - 144:8, 146:23, 148:5,       149:19, 150:11, 152:2, 152:3, 152:12,   RECKLESS [2] - 149:22, 152:15
 148:6, 148:8, 148:9, 148:11, 148:12,     153:5                                   RECOLLECTION [2] - 144:2, 146:16
 148:16, 150:3, 152:21, 154:22, 155:8,   PROMPTLY [1] - 166:3                     RECORD [3] - 169:1, 173:19, 174:5
 156:11, 160:10, 160:12, 172:25          PROOF [8] - 143:4, 143:6, 143:11,        RECORDED [1] - 141:23
PERSON'S [3] - 150:5, 152:23, 152:25      144:11, 148:16, 148:18, 155:7           REFER [1] - 147:9
PERSONAL [2] - 145:4, 157:25             PROPERTY [10] - 148:25, 149:8,           REFERENCES [1] - 165:21
PERSONALLY [2] - 148:3, 153:16            149:18, 152:11, 156:24, 157:2,          REFERENCING [1] - 1:7
PERSONS [2] - 154:4, 154:17               157:13, 158:13, 158:15, 158:17          REGARDING [1] - 156:6
PHONES [1] - 176:19                      PROPRIETY [1] - 168:16                   RELATED [2] - 161:16, 171:4
PHRASE [3] - 157:23, 158:6, 158:21       PROVE [24] - 142:22, 143:1, 143:5,       RELATING [1] - 149:19
PHRONT [1] - 164:14                       144:12, 148:2, 150:13, 150:15,          RELEASE [4] - 170:23, 172:16, 176:8,
PLACES [1] - 162:21                       150:17, 153:7, 153:9, 153:11, 153:12,    176:18
PLAN [11] - 149:16, 152:9, 154:9,         153:17, 154:8, 154:12, 155:16,          RELIED [2] - 150:6, 153:1
 154:11, 154:13, 154:18, 154:21,          156:14, 158:23, 158:24, 159:12,         RELY [2] - 143:12, 147:3
 154:23, 154:25, 155:2                    159:25, 160:1, 161:11                   REMEMBER [2] - 146:5, 162:15
PLANNING [1] - 174:1                     PROVED [11] - 142:9, 143:14, 149:4,      REMEMBERS [1] - 146:4
PLAYED [1] - 154:25                       150:19, 151:20, 151:23, 154:15,         REMINDS [1] - 171:2
PLUS [1] - 170:6                          156:1, 156:20, 159:7, 164:23            RENEW [1] - 166:19
PM [2] - 141:6, 142:1                    PROVES [1] - 155:18                      REPORT [4] - 155:23, 156:3, 156:10,
POINT [6] - 144:21, 157:10, 166:11,      PROVING [2] - 150:12, 153:6               156:14
 170:10, 170:16, 175:23                  PUNISHMENT [2] - 161:25, 162:2           REPORTER [4] - 1:4, 1:8, 141:24,
PORTION [1] - 1:5                        PURCHASE [2] - 157:11, 157:16             179:15
POSITION [1] - 169:12                    PURPOSE [7] - 150:16, 153:10, 154:20,    REPRESENTATION [4] - 149:20,
POSITIVE [1] - 160:22                     155:1, 155:9, 158:24, 160:9              149:24, 152:13, 152:16
POSSESSES [1] - 160:24                   PURPOSELY [1] - 160:8                    REPRESENTATIONS [10] - 149:1,
POSSESSION [2] - 161:4, 161:12           PURPOSES [1] - 154:6                      149:10, 149:11, 149:19, 150:11,
POSSIBLE [3] - 143:5, 148:2, 166:3       PUT [4] - 163:25, 164:5, 173:18, 174:4    152:2, 152:3, 152:12, 153:5, 159:21
 Case 1:20-cr-00296-JPB-CMS                      Document 1032               Filed 06/14/24           Page 48 of 49

                                                                                                                          187


REPRINT [1] - 151:22                      SIGN [4] - 165:1, 165:2, 165:7, 165:10   SUBSTANCE [5] - 160:25, 161:1, 161:4,
REQUESTING [1] - 167:15                   SIGNIFICANCE [1] - 146:8                  161:6, 161:12
REQUIRED [1] - 159:11                     SIMILAR [2] - 150:21, 177:21             SUBSTANTIAL [1] - 159:2
REQUIRES [2] - 148:16, 159:11             SIMILARLY [1] - 159:16                   SUBSTANTIALLY [1] - 150:20
RESPOND [1] - 166:3                       SIMPLE [1] - 146:3                       SUBSTANTIVE [5] - 147:15, 147:19,
RESPONSIBLE [3] - 148:10, 148:12,         SIMPLY [4] - 148:18, 155:5, 162:14,       147:23, 155:15
 148:16                                    165:5                                   SUCCEED [1] - 159:20
REST [3] - 170:12, 175:16, 176:16         SINGLE [1] - 142:18                      SUCCEEDED [3] - 150:18, 153:18,
RESTART [2] - 173:4, 173:13               SITUATION [1] - 177:19                    154:13
RESTRICTED [1] - 1:4                      SMALL [1] - 163:13                       SUFFICIENT [5] - 150:13, 153:7, 155:3,
RESULT [1] - 154:2                        SOMEONE [9] - 145:14, 149:17, 150:24,     155:18, 159:8
RETAINED [1] - 158:18                      151:18, 152:1, 152:10, 154:1, 163:8,    SUGGEST [1] - 144:23
RETURN [1] - 155:20                        172:3                                   SUGGESTED [1] - 168:7
REVIEWING [1] - 151:1                     SOMETIMES [1] - 169:3                    SUGGESTION [1] - 170:23
RIM [1] - 168:14                          SOON [1] - 174:17                        SUPPOSED [1] - 163:19
RMR [2] - 141:24, 179:15                  SORRY [4] - 170:20, 173:12, 176:1        SWITCH [1] - 163:19
ROLE [1] - 154:25                         SOURCE [2] - 157:6, 158:25               SYMPATHY [1] - 142:14
ROOM [5] - 142:7, 163:20, 165:9, 167:4,   SPEAKER [2] - 149:21, 152:14
 169:4                                    SPECIAL [1] - 146:23                                         T
RULE [1] - 160:13                         SPECIALIZED [1] - 146:22
                                                                                   TAL [1] - 141:14
RULES [1] - 142:5                         SPECIFIC [8] - 142:10, 147:25, 150:10,
                                                                                   TEAM [1] - 170:7
                                           153:4, 153:14, 160:13, 161:22, 161:24
                                                                                   TECHNICAL [1] - 146:22
                   S                      SPECIFICALLY [4] - 147:6, 147:16,
                                                                                   TELDRIN [2] - 164:15, 168:8
                                           157:3, 167:17
SAFE [1] - 157:15                                                                  TELDRIN [2] - 141:7, 141:17
                                          SPECIFIED [2] - 157:2, 158:21
SALE [2] - 157:11, 157:16                                                          TELEVISION [2] - 150:23, 151:17
                                          SPECIFIES [1] - 159:4
SAMIR [1] - 141:15                                                                 TEND [2] - 144:12, 146:5
                                          SPECTATOR [1] - 148:22
SARALIENE [1] - 141:18                                                             TENDENCY [3] - 150:5, 152:23, 152:25
                                          SPEED [1] - 176:3
SAVE [1] - 175:19                                                                  TERM [1] - 158:17
                                          SPOKEN [2] - 175:20, 176:15
SCENE [2] - 148:19, 155:5                                                          TESTIFIED [2] - 145:8, 145:23
                                          STACK [8] - 169:5, 169:22, 173:3,
SCHEME [14] - 148:24, 149:7, 149:16,                                               TESTIFY [2] - 142:24, 142:25
                                           174:18, 175:9, 175:17, 175:22, 177:11
 150:17, 150:18, 150:20, 150:23,                                                   TESTIFYING [1] - 144:21
                                          STAND [1] - 166:11
 151:17, 152:1, 152:8, 152:9, 153:11,                                              TESTIMONY [8] - 143:19, 144:8,
                                          STANDBY [1] - 172:16
 153:17, 153:23                                                                     144:18, 145:11, 145:12, 146:1,
                                          START [3] - 157:9, 164:8, 169:19
SCIENTIFIC [1] - 146:22                                                             146:21, 147:2
                                          STARTS [1] - 163:13
SEATED [5] - 142:3, 167:13, 168:25,                                                THE [51] - 1:2, 1:4, 1:6, 1:7, 1:8, 1:10,
                                          STATE [2] - 146:24, 158:16
 174:11, 176:12                                                                     141:1, 141:10, 141:14, 141:17,
                                          STATEMENT [17] - 145:14, 145:15,
SECOND [1] - 164:21                                                                 141:20, 142:3, 151:5, 151:8, 151:10,
                                           145:18, 145:20, 149:20, 149:23,
SECRET [1] - 162:5                                                                  151:12, 163:16, 164:8, 165:18,
                                           150:7, 152:13, 152:16, 153:1, 153:2,
SECURITIES [1] - 158:1                                                              166:22, 166:25, 167:2, 167:8, 167:10,
                                           155:23, 156:3, 156:10, 156:14, 163:2
SECURITY [1] - 166:2                                                                168:2, 168:17, 168:20, 168:25, 170:1,
                                          STATEMENTS [1] - 147:16
SEE [5] - 159:23, 163:9, 165:3, 165:21,                                             170:3, 170:5, 170:22, 171:6, 171:15,
                                          STATES [6] - 141:1, 141:4, 141:10,
 177:3                                                                              171:24, 172:1, 172:3, 172:14, 172:20,
                                           141:16, 141:25, 179:3
SEEK [1] - 162:16                                                                   172:22, 172:24, 173:12, 174:3, 174:8,
                                          STATES [1] - 158:11
SEEM [1] - 145:6                                                                    174:11, 176:12, 177:6, 177:8, 177:16
                                          STATES [2] - 158:11, 158:12              THEREAFTER [1] - 174:17
SEND [2] - 169:6, 169:7
                                          STATUTE [1] - 159:4                      THEREIN [1] - 165:24
SENDING [2] - 157:20, 173:24
                                          STAY [1] - 177:14                        THEY'VE [1] - 175:20
SENSE [5] - 143:9, 144:5, 172:7,
                                          STENOGRAPHICALLY [1] - 141:23            THINKING [1] - 169:21
 176:24, 177:1
                                          STEP [1] - 167:21                        THOMAS [1] - 168:9
SENT [5] - 153:20, 169:22, 174:16,
                                          STICKERING [1] - 173:25                  THROUGHOUT [1] - 176:14
 174:20, 174:22
                                          STILL [3] - 169:18, 175:5, 176:22        TO [2] - 1:5, 1:9
SENTENCE [1] - 163:13
                                          STIPULATION [1] - 165:22                 TOGETHER [2] - 168:13, 175:8
SEPARATE [6] - 147:4, 153:22, 153:23,
                                          STOCK [1] - 157:16                       TOMORROW [7] - 174:6, 174:7, 175:10,
 155:15, 161:14, 164:9
                                          STOOD [1] - 167:22                        175:18, 176:4, 176:17, 176:21
SEPARATELY [2] - 161:16, 161:17
                                          STRAIGHT [1] - 176:2                     TRACK [1] - 166:8
SERVICE [1] - 177:2
                                          STUFF [2] - 172:6, 173:25                TRADE [1] - 158:9
SESSION [1] - 141:6
                                          SUBJECT [1] - 166:24                     TRAINING [1] - 146:23
SHORTLY [4] - 165:19, 167:5, 169:5,
                                          SUBMITTED [1] - 173:16                   TRANSACTION [15] - 156:23, 156:25,
 175:4
                                          SUBMITTING [1] - 173:11                   157:4, 157:9, 157:10, 157:11, 157:13,
SHOWED [1] - 168:11
 Case 1:20-cr-00296-JPB-CMS                       Document 1032                Filed 06/14/24   Page 49 of 49

                                                                                                           188


 157:18, 157:21, 158:2, 158:3, 158:14,    VERBAL [1] - 171:8
 159:2                                    VERDICT [19] - 155:20, 161:19, 162:3,
TRANSACTIONS [1] - 156:17                  162:6, 163:23, 163:25, 164:5, 164:10,
TRANSCRIPT [1] - 179:7                     164:20, 164:22, 165:2, 165:3, 165:5,
TRANSCRIPT [5] - 1:3, 1:6, 1:8, 1:9,       165:8, 165:9, 165:12, 167:5, 169:5
 141:9                                    VERSUS [1] - 163:6
TRANSCRIPTS [1] - 1:3                     VIOLATING [1] - 160:14
TRANSFER [3] - 157:12, 157:14, 158:2      VOLUME [1] - 141:6
TRANSMISSION [1] - 153:16                 VOLUNTARILY [2] - 160:5, 160:8
TRANSMITTED [3] - 152:6, 152:7,           VOTED [1] - 166:5
 153:12                                   VS [1] - 141:5
TRANSPIRED [1] - 175:12
TRAVELERS [1] - 157:24                                       W
TRIAL [8] - 142:13, 143:25, 146:2,
                                          WAIT [1] - 167:10
 146:11, 161:21, 164:2, 168:11, 175:13
                                          WAYS [2] - 159:4, 159:6
TRIAL [1] - 141:9
                                          WEBSTER [10] - 151:5, 166:22, 167:12,
TRIED [1] - 156:22
                                           168:18, 170:1, 170:16, 171:24, 172:5,
TROUBLE [1] - 170:11
                                           172:20, 173:17
TRUE [2] - 144:16, 179:6
                                          WEBSTER [18] - 141:18, 151:4, 151:6,
TRUTH [8] - 145:1, 145:3, 146:4,
                                           163:10, 166:17, 166:19, 167:9,
 149:23, 149:25, 152:15, 152:17,
                                           167:14, 168:19, 170:2, 170:18,
 162:16
                                           171:25, 172:10, 172:21, 173:8,
TRY [4] - 154:18, 162:9, 171:8, 175:16
                                           173:18, 174:7, 177:12
TRYING [1] - 174:2
                                          WEIGHT [3] - 144:13, 145:16, 146:20
TURNED [2] - 171:18, 174:19
                                          WHOLE [3] - 142:18, 144:20, 157:5
TURNS [1] - 173:21
                                          WILL [1] - 1:4
TWO [10] - 145:16, 151:22, 154:4,
                                          WILLFUL [1] - 148:21
 154:17, 155:15, 155:21, 158:10,
                                          WILLFULLY [9] - 147:12, 148:13,
 164:9, 176:8, 176:9
                                           153:25, 154:21, 155:2, 155:17,
TYPICAL [1] - 169:2
                                           155:19, 160:7, 160:12
                                          WILLING [1] - 143:12
                   U                      WIRE [22] - 147:13, 147:16, 150:22,
ULTIMATELY [1] - 159:20                    151:2, 151:15, 151:16, 152:7, 153:13,
UNANIMOUS [1] - 162:4                      153:14, 153:16, 153:19, 153:20,
UNANIMOUSLY [3] - 159:9, 164:15,           153:22, 154:3, 154:19, 155:13, 157:3,
 164:23                                    157:20, 158:21, 162:24, 164:14,
UNDER [3] - 145:18, 148:7, 158:16          164:24
UNDERSCORE [1] - 175:11                   WISH [1] - 165:25
UNDULY [1] - 146:17                       WITH [1] - 1:10
UNFORTUNATE [1] - 172:7                   WITHDRAWAL [1] - 157:14
UNFORTUNATELY [2] - 170:5, 171:18         WITNESS [14] - 144:18, 144:20, 144:23,
UNIMPORTANT [1] - 146:10                   144:25, 145:2, 145:4, 145:6, 145:7,
UNITED [6] - 141:1, 141:4, 141:10,         145:9, 145:23, 145:25, 146:1, 146:4,
 141:16, 141:25, 179:3                     146:6
UNITED [2] - 158:11, 158:12               WITNESS'S [3] - 145:11, 147:1, 147:2
UNLAWFUL [11] - 154:5, 154:11,            WITNESSES [2] - 143:19, 144:20
 154:18, 154:20, 154:23, 155:1, 157:1,    WORD [3] - 159:7, 160:4, 160:7
 157:2, 158:14, 158:19, 158:21            WORDS [5] - 148:20, 154:5, 155:13,
UNLESS [2] - 160:20, 170:16                162:4, 163:14
UNTRUE [4] - 149:22, 152:14, 156:10,      WRAP [1] - 174:2
 156:11                                   WRITE [1] - 166:1
UP [6] - 162:13, 165:1, 167:22, 169:17,   WRITING [1] - 166:3
 173:1, 174:2
                                                             Y
                   V                      Y'ALL [6] - 142:3, 167:13, 168:25,
VARIANCE [2] - 167:16, 168:1               169:6, 176:10, 176:12
VARIOUS [1] - 165:15                      YOU [2] - 1:5, 1:8
VENTURE [1] - 159:19                      YOURSELF [6] - 144:24, 145:15,
                                           145:22, 146:17, 147:3, 162:7


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