Court filing
Jury Trial Excerpt of David Green and McArnold Charlemagne — United States v. Avboraye-Igbenidion (Dkt. 253, D. Md.)
Summary
This partial transcript of June 12, 2023 covers the direct testimony of cooperating witness David Green at the mail fraud trial of Eghosasere Avboraye-Igbenidion before Senior Judge Richard D. Bennett. Green read from his plea agreement to conspiracy to commit mail fraud and its cooperation supplement. He testified that he joined in about August 2018 after lending money to the defendant, whom he had known since childhood, and was offered packages to collect to make the money back. He identified the defendant in court and said he first minimized the defendant's role when speaking to investigators.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Filed July 6, 2023 in Eghosasere Avboraye-Igbenidion; one of 8 filings from this case.
Record facts
| Court | U.S. District Court for the District of Maryland |
|---|---|
| Filed | 2023-07-06 |
Cite this document
“Jury Trial Excerpt of David Green and McArnold Charlemagne — United States v. Avboraye-Igbenidion (Dkt. 253, D. Md.).”
U.S. District Court for the District of Maryland, No. 1:21-cr-00054, Doc. 253, filed 2023-07-06. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-eghosasere-avboraye-igbenidion/2023-07-06-jury-trial-excerpt-of-david-green-and-mcarnold-charlemagne-dkt-253/
, SHA-256 e4085c72b89c4bac49d392cf5e92c9adc38ade88324e1c9015131bece5fc124f.Full text
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 1 of 170
1
1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
2 NORTHERN DIVISION
3 UNITED STATES OF AMERICA,)
Plaintiff, )
4 )
vs. ) CRIMINAL CASE NO. RDB-21-00054
5 )
EGHOSASERE AVBORAYE- )
6 IGBENIDION, )
Defendant. )
7 _________________________)
8
9 Monday, June 12, 2023
Courtroom 5D
10 Baltimore, Maryland
11 JURY TRIAL
EXCERPT OF DAVID GREEN AND MCARNOLD CHARLEMAGNE
12
BEFORE: THE HONORABLE RICHARD D. BENNETT, Senior Judge
13
14 For the Plaintiff:
15 Sean Delaney, Esquire
Christine Goo, Esquire
16 Assistant United States Attorneys
17
For the Defendant:
18
Alfred Guillaume, Esquire
19 CJA Counsel
20
21
22
23
24
25 (Computer-aided transcription of stenotype notes)
Kassandra L. McPherson, RPR - Federal Official Court Reporter
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 2
1 P R O C E E D I N G S
2
(DAVID GREEN, duly sworn.)
3
4 THE CLERK: And while speaking clearly into the
5 microphone, can you please state your full name and spell your
6 last name.
7 THE WITNESS: David Green. Last name G-r-e-e-n.
8 THE CLERK: Thank you.
9 DIRECT EXAMINATION
10 BY MR. DELANEY:
11 Q. Good morning, sir. You've already told us your name,
12 can you tell the members of the jury where you from?
13 A. Florida. Miami, Florida.
14 Q. Born and raised?
15 A. Yes.
16 Q. I'd like to put up on the screen what's been marked as
17 Government's Exhibit No. 10.
18 MR. DELANEY: Court's indulgence, briefly.
19 BY MR. DELANEY:
20 Q. I'd like to draw your attention specifically to
21 paragraph 1 -- well, actually, first off, what are we looking at
22 here?
23 A. Sealed Supplement via a plea agreement.
24 Q. This is a copy of your plea agreement?
25 A. Yes.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 3
1 Q. Okay. And on page 1 of Government's Exhibit No. 10,
2 I'd like for you to read paragraph 1.
3 A. The Defendant agrees to plead guilty to Count One of
4 the Indictment, which charges the Defendant with conspiracy to
5 commit mail fraud, in violation of 18 U.S.C. 1349. The
6 Defendant admits that the Defendant is, in fact, guilty of the
7 offense or offenses and will so advise the Court.
8 Q. I'd like to move forward to page 11 of this document,
9 Government's Exhibit No. 1. Do you recognize your signature on
10 that page?
11 A. Yes, I do.
12 Q. Okay. Now, skipping forward to page 12. Do you
13 recognize this as a Sealed Supplement to your plea agreement?
14 A. Yes, I do.
15 Q. Okay. What do you understand this to be?
16 A. My plea agreement for me to provide truthful
17 information.
18 Q. Let's go ahead and read it. Reading paragraph 1 and
19 1A for us. Can you go ahead and read this for us?
20 A. The Defendant agrees to cooperate with this Office on
21 the following terms and conditions:
22 The Defendant shall fully and truthfully respond to
23 all questions put to the Defendant by federal law enforcement
24 authorities and other designated law enforcement officers. The
25 Defendant shall fully and truthfully disclose to the Government
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 4
1 all information with respect to the Defendant's activities and
2 the activities of others concerning all matters as to which the
3 Government may inquire.
4 Q. And we can stop there. And turn to the next page.
5 Paragraph D up at the top of this page of Government's
6 Exhibit 10. Can you read that?
7 A. The Defendant shall testify fully and truthfully
8 before grand juries and at any trial and other court proceeding
9 with respect to any matters about which this office may require
10 the Defendant's testimony.
11 Q. Okay. And now, under Immunity, paragraph 2, I'll go
12 ahead and read and you tell me if I read it accurately.
13 In order to permit the Defendant to make disclosures
14 to the Government under this agreement, any information and
15 documents that the Defendant fully and truthfully discloses to
16 the Government, during the course of cooperation, pursuant to
17 this Agreement, will not be used against the defendant, directly
18 or indirectly, by this Office in any federal criminal case
19 except as set forth below.
20 What do you understand this to mean?
21 A. That I have to be truthful and that anything that I
22 say can't be used against me for, like, any other charges.
23 Q. Okay. And now moving forward below, under Obligations
24 of the United States Attorney's Office, tell me if I'm reading
25 this portion accurately.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 5
1 If we can highlight three and four, Mr. Kerrigan.
2 Thank you very much. Sorry.
3 If the Defendant fully complies with all of the terms
4 of this agreement and this Sealed Supplement, then in connection
5 with the Defendant's sentencing, this office will inform the
6 Probation Office and the Court of the nature and extent of the
7 Defendant's cooperation; and all other information with respect
8 to the Defendant's background, character, and conduct which this
9 office deems relevant to sentencing, including the conduct that
10 is the subject of any counts of the indictment that this office
11 has agreed to dismiss at sentencing.
12 If this office determines that the defendant has
13 provided substantial assistance in an investigation or
14 prosecution of others, and if the Defendant has fully complied
15 with all obligations under this agreement, and this Sealed
16 Supplement, this office may make a motion, pursuant to USSG
17 Section 5K1.1 and/or 18 U.S.C. section 3353(e), if appropriate,
18 requesting if the Court --
19 And then it continues on the next page. If we can
20 highlight just the first few lines.
21 -- sentence the Defendant in light of the advisory
22 factors set forth in Section 5K1.1(a)(1) through (5), and
23 requesting a downward departure.
24 And then if we can skip forward to Remedies and
25 Breaches and highlight up to 6-2.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 6
1 First off, sir, did I read that accurately?
2 A. Yes.
3 Q. And if you can read for us paragraph 6.
4 A. The Defendant will be in breach of this sealed
5 supplement if any of the following occurs:
6 If the Defendant commits any further crimes, if the
7 Defendant has knowingly withheld information, given false,
8 incomplete, or misleading testimony or information, falsely
9 implicated an innocent person in the commission of a crime,
10 exaggerate the involvement of any person in the commission of a
11 crime in order to appear cooperative, or falsely minimize the
12 involvement of any person, including the defendant, in the
13 commission of a crime.
14 Q. And if we can go ahead and skip forward two more
15 pages. Yep.
16 Do you recognize your signature on this document?
17 A. Yes, I do.
18 Q. Okay. Why don't you go ahead and tell the members of
19 the jury, what is your understanding of what you get out of your
20 testimony here today? What's your deal with the Government?
21 A. That my -- me cooperating would just be considered.
22 There's nothing promised.
23 Q. Can you pull the microphone a little bit closer? It's
24 a little hard to hear.
25 A. That my cooperation will be considered but nothing was
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 7
1 promised to me.
2 Q. And when will that cooperation be considered?
3 A. After this -- or during my sentencing.
4 Q. And who is it that makes the ultimate determination of
5 whether or not you have cooperated to get some benefit?
6 A. The judge.
7 Q. And if you are not truthful in your testimony today,
8 what is your understanding of your deal with the government?
9 A. I'd be -- it would be considered a breach.
10 Q. Okay. Now that we've been through all of that, can
11 you go ahead and tell the members of the jury, in your own
12 words, what your crime was?
13 A. It was the charge of conspiracy to commit mail fraud,
14 and it was a scheme to defraud elderly people.
15 Q. And what did you do?
16 A. I picked up packages containing money.
17 Q. And did you work with others to do so?
18 A. Yes.
19 Q. Okay. Prior to getting involved in this crime, where
20 were you working?
21 A. I was doing event security.
22 Q. And how did that job pay?
23 A. Not very well.
24 Q. Where were you living?
25 A. At the time she was my girlfriend, but currently the
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 8
1 mother of my son.
2 Q. Okay. Do you recall approximately when you got
3 involved in this crime?
4 A. Maybe August 2018.
5 Q. Okay. And how did you get involved in this crime?
6 A. I don't -- I don't understand.
7 Q. Tell us how you got involved. Tell us how you became
8 a member of the conspiracy to which you pleaded guilty.
9 A. Okay. It started with me loaning money to Eghosah.
10 And when it became time for me to collect the money, I was
11 offered an opportunity by Eghosah to collect packages to make
12 the money back, and then some.
13 Q. You used the name Eghosah. Does the individual have a
14 full name, do you know?
15 A. Yes.
16 Q. Can you tell it to us?
17 A. Eghosah Avboraye.
18 Q. And do you recognize him in the courtroom?
19 A. Yes.
20 Q. Can you let us know either by where he's sitting or
21 what he's wearing, can you identify him?
22 A. Yes. He's right here.
23 MR. DELANEY: Let the record reflect that defendant
24 has -- the witness has pointed to the defendant.
25 THE COURT: The record will reflect that the witness
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 9
1 has identified the defendant, Mr. Igbinedion.
2 BY MR. DELANEY:
3 Q. Now, I think, and let me know if I got this wrong, you
4 referred to him as Eghosah?
5 A. Yes.
6 Q. That's what you called him?
7 A. Yes.
8 Q. Okay. And did you know him by any other nicknames?
9 A. Ghost.
10 Q. Okay. Anything else?
11 A. Or people called him Ego.
12 Q. How long did you know Eghosah?
13 A. Since childhood.
14 Q. Okay. Did you guys grow up together?
15 A. Yes.
16 Q. Where did you live?
17 A. Miramar, Florida.
18 Q. How close did you live?
19 A. Relatively close. Two streets away.
20 Q. Do you remember the street names?
21 A. I lived on Arcadia and he lived on Acapulco.
22 Q. When you first spoke to investigators, prior to
23 pleading guilty in this case, were you completely truthful about
24 Eghosah's involvement in the scheme?
25 A. No.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 10
1 Q. How so?
2 A. I minimized his role.
3 Q. How did you do that?
4 A. By leaving him out of how I got involved in the first
5 place.
6 Q. Okay. Did you indicate to investigators that he was
7 involved?
8 A. Excuse me?
9 Q. Did you -- did you tell investigators that he was
10 involved in the scheme at all?
11 A. Yes.
12 Q. Why did you minimize his involvement at the beginning
13 of the scheme?
14 A. I was protecting someone I considered a friend. Or
15 trying to.
16 Q. You testified previously that someone had loaned you
17 money and that precipitated your involvement in this scheme; is
18 that right?
19 A. Yes.
20 Q. Or I'm sorry, was it someone had loaned you money or
21 you loaned --
22 A. I loaned someone money.
23 Q. Okay. Can you tell us what happened?
24 A. As far as?
25 Q. Who did you loan money to?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 11
1 A. Eghosah.
2 Q. How much?
3 A. $700.
4 Q. And did he pay you back promptly?
5 A. No.
6 Q. What happened?
7 A. When it came time, when I was asking for the money
8 back, I was then offered the opportunity to make the money back
9 and then some.
10 Q. Who offered the opportunity to you?
11 A. Eghosah.
12 Q. And what was the opportunity?
13 A. To pick up packages.
14 Q. And where would you be picking up packages?
15 A. Well, it started in Florida.
16 Q. Okay. Were you asked to give addresses for the
17 packages to be delivered?
18 MR. GUILLAUME: Objection.
19 THE COURT: Overruled.
20 THE WITNESS: Yes.
21 BY MR. DELANEY:
22 Q. Who asked you to do so?
23 A. Eghosah.
24 Q. Were you told what was in the packages?
25 A. No.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 12
1 Q. Did you ask?
2 A. No.
3 Q. Why not?
4 A. Because I knew it wasn't completely above board.
5 Q. Did you provide addresses?
6 A. Yes.
7 Q. To whom did you provide them?
8 A. Excuse me?
9 Q. Who did you give them to?
10 A. Eghosah.
11 Q. And what addresses did you give him?
12 A. My grandmother's and the two surroundings neighbors.
13 Q. Can you tell us what your grandmother's address is?
14 A. , Miami Gardens, Florida.
15 Q. And you said you also gave the two neighboring
16 addresses?
17 A. Yes.
18 Q. Why did you give those addresses?
19 A. Because both of them were deceased recently and the
20 houses were empty.
21 Q. Why would empty -- why did you choose empty houses
22 with deceased residents?
23 A. So it would be convincing enough for the delivery
24 driver to drop off the packages.
25 Q. After you provided the addresses what happened next?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 13
1 A. I was then told when the packages would arrive.
2 Q. Who told you this?
3 A. Eghosah.
4 Q. What specifically were you told?
5 A. That it would be coming -- the packages would be
6 delivered to my neighbor's house.
7 Q. What about the other two addresses?
8 A. It hadn't worked out.
9 Q. Were you told to whom the packages would be addressed?
10 A. I don't remember.
11 Q. Okay. Did Eghosah tell you what you had to do when
12 the packages arrived?
13 A. Yes.
14 Q. And what did he tell you?
15 A. To not open them and to let him know when they were --
16 when it arrived.
17 Q. Were you told when they would arrive?
18 A. Yes.
19 Q. How close in time was it to -- how close in time was
20 the delivery time to when you were told it would be delivered?
21 A. A day.
22 Q. Can you tell us about that package delivery?
23 A. As in when it was like the --
24 Q. What happened on the day of delivery?
25 A. The delivery driver -- I was sitting on my porch.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 14
1 Q. On whose porch?
2 A. My grandmother's porch.
3 Q. Was that the porch where the package would be
4 delivered?
5 A. No.
6 Q. Why did you sit on your grandmother's porch?
7 A. To just to avoid, like, trespassing that way.
8 Q. Okay. Okay. What happened?
9 A. The delivery driver came, left the package on the
10 porch. When he left I walked over and then took the package off
11 of the porch.
12 Q. Okay. What did you do next?
13 A. Then I called Eghosah to let him know that I had
14 gotten the package.
15 Q. And what, if anything, did he say?
16 A. I -- I don't remember honestly.
17 Q. Okay. So after you called Eghosah to tell him that
18 you had retrieved the package, what happened next?
19 A. I had received a phone call from somebody named Zo.
20 Q. Had you ever me Zo before?
21 A. No.
22 Q. Over time did you come to learn Zo's full name?
23 A. Yes.
24 Q. What is it?
25 A. Charlemagne.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 15
1 Q. Charlemagne?
2 A. Yes.
3 Q. Did you know whether that was his first or last name?
4 A. No.
5 Q. Okay. When Zo called you can you describe for us the
6 conversation?
7 A. Zo asked me if the package had arrived. I had told
8 him yes, and then he said he'd come over.
9 Q. And what happened next?
10 A. He arrived at my grandmother's house and then -- he
11 then made a phone call.
12 Q. Did you learn who he called?
13 A. Eventually, yes, I did.
14 Q. And what was the name of the person he called?
15 A. Jay.
16 Q. Jay?
17 A. Yes.
18 Q. Did you ever learn Jay's full name?
19 A. No.
20 Q. I'd like to put up on the screen what's been marked as
21 Government's Exhibit No. 11. Do you recognize this individual?
22 A. Yes.
23 Q. Who do you recognize this to be?
24 A. Jay.
25 Q. Okay. So what happened next?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 16
1 A. After that phone call Zo had left and told me that Jay
2 would come pick up the package.
3 Q. And what happened after that?
4 A. About after the sun had went down, nighttime, Jay had
5 arrived at my grandmother's house.
6 Q. How did you know he arrived?
7 A. He had called me.
8 Q. Okay. And what happened when he arrived?
9 A. I went outside with the package and then got inside
10 his vehicle.
11 Q. What was his vehicle?
12 A. A Range Rover.
13 Q. What happened when you got inside his vehicle?
14 A. I handed him the package and then he handed me $50.
15 Q. Okay. Was that how much money you expected to receive
16 that day?
17 A. No.
18 Q. What did you text to receive that day?
19 A. $100.
20 Q. Okay. Did you question him?
21 A. No.
22 Q. Why not?
23 A. Because I kind of just didn't want to make him mad or
24 anything or --
25 Q. Okay. After -- after you gave him the package did you
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 17
1 have any further conversations with him that you can remember?
2 A. Not that I can remember, no.
3 Q. Okay. As time went on did you have further
4 conversations about picking up packages? Yes?
5 A. Yes.
6 Q. With whom?
7 A. I'm drawing a blank. I don't remember now, sorry.
8 Q. Just got to remind you to keep your voice up. You're
9 trailing off a little bit, so I want to make sure that everybody
10 with hear you, okay?
11 A. Okay.
12 Q. Did you speak with Eghosah after this day about
13 picking up more packages?
14 A. Yes.
15 Q. Tell us what you discussed.
16 A. That we -- we would pick up packages in other -- in
17 another state.
18 Q. Okay. And how would that work? How would you get to
19 other states?
20 A. Oh, well, I eventually -- about a day or two later I
21 was asked by Eghosah to send a picture of my ID.
22 Q. To whom?
23 A. To him. To Eghosah.
24 Q. And then what happened?
25 A. And then we, now we, but I later found out that a
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 18
1 flight was booked to Baltimore.
2 Q. Do you know who booked that flight?
3 A. Not really, no.
4 Q. Did you talk with Eghosah about why you were going to
5 fly somewhere?
6 A. Yes.
7 Q. What, if anything, did he tell you?
8 A. That we'd be picking up packages in Baltimore.
9 Q. Did you agree to take a trip to Baltimore to pick up
10 packages?
11 A. Yes.
12 Q. Okay. Did you learn from your experience why you
13 needed to go to Baltimore to do this? Why you couldn't do it in
14 Florida?
15 A. Yes, I had my -- I had my own -- I had reasons why,
16 yes.
17 Q. What reasons were those?
18 A. Well, being from Florida, a lot of those -- things
19 like that kind of are difficult to do.
20 Q. It's difficult to do in Florida?
21 A. Yes.
22 Q. Why is it difficult to do in Florida?
23 MR. GUILLAUME: Objection. Relevance.
24 THE COURT: Sustained. Sustained.
25 BY MR. DELANEY:
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 19
1 Q. Putting up on the screen what's been marked as
2 Government's Exhibit 12. Do you recognize this?
3 A. Yes.
4 Q. What is it?
5 A. A flight record.
6 Q. And if we can just put the first two boxes, blow those
7 up for us to look at. What is the date of this flight?
8 A. September 17 -- September 17th, 2018.
9 Q. Looking down at the bottom, under the box that says
10 flight information and date, can you read that for us?
11 A. The 18th of September 2018.
12 Q. And the departure?
13 A. Miami.
14 Q. And arrive?
15 A. BWI.
16 Q. Okay. And who are the passengers on this flight?
17 A. Me and Eghosah.
18 Q. Do you remember that flight?
19 A. Yes.
20 Q. Okay. What happened when you arrived at BWI?
21 A. Eghosah made a phone call.
22 Q. Do you know who he called?
23 A. Not initially.
24 Q. Did you learn who he called?
25 A. Yes.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 20
1 Q. Who did he call?
2 A. Jay.
3 Q. A what happened next?
4 A. I was informed that we won't be going to Baltimore,
5 we'd be going to Washington, D.C. instead.
6 Q. Who informed you of that?
7 A. Eghosah.
8 Q. Okay. And then what happened?
9 A. We got into an Uber and is went to an Airbnb in
10 Washington, D.C.
11 Q. Putting up on the screen what's been marked as
12 Government's Exhibit 13. Do you recognize this?
13 A. Yes.
14 Q. And what do you recognize it to be?
15 A. The Airbnb that we arrived to in D.C.
16 Q. Approximately how long did you stay at this location?
17 A. Maybe three days to a week.
18 Q. Okay. So you testified that you and Eghosah took an
19 Uber to this location?
20 A. Yes.
21 Q. And was anyone there when you arrived?
22 A. Yes.
23 Q. Who?
24 A. A young lady by the name of Amaya and another young
25 man by the name of Keion.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 21
1 Q. Do you remember either of their last names?
2 A. Amaya's last name was English and Keion's last name
3 was Smith.
4 Q. Okay. And was anyone else there?
5 A. No.
6 Q. Did anyone else arrive during your time there?
7 A. Yes.
8 Q. Who?
9 A. Jay.
10 Q. Okay. Can you tell us what happened after you arrived
11 at the Airbnb?
12 A. Jay came and picked up me and Eghosah and then we just
13 went to get something to eat.
14 Q. Okay. Who paid?
15 A. I can't remember, it was either Eghosah or Jay.
16 Q. Okay. Then what happened?
17 A. Jay then drove me and Eghosah back to the Airbnb.
18 Q. Okay.
19 A. And then we were informed that we have to wake up
20 early in the morning.
21 Q. Who informed you of this?
22 A. Amaya.
23 Q. Okay. So did you, in fact, go to bed?
24 A. Yeah. Well --
25 Q. What happened the next morning?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 22
1 A. We woke up pretty early in the morning, and then we
2 were -- me and Eghosah were dropped off by Amaya to the
3 addresses where packages would be picked up at. Would be
4 delivered to.
5 Q. Were you given information about the delivery?
6 A. Information as in?
7 Q. Did you know when the packages were supposed to
8 arrive?
9 A. When?
10 Q. Yeah.
11 A. No.
12 Q. Okay. Had you ever been to Baltimore before?
13 A. No.
14 Q. Did you know where you were?
15 A. No.
16 Q. Okay. Going to put up on the screen what's been
17 marked as Government's Exhibit 15. Do you recognize -- if we
18 can blow up the phone numbers -- do you recognize the phone
19 numbers on this?
20 A. Yes.
21 Q. Whose phone numbers are they?
22 A. One is my son's mother's phone number, and the other
23 one is mine.
24 Q. That's your phone number?
25 A. Well, yeah.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 23
1 Q. What's your son's mother's name?
2 A. Tequila but it says Teki, which is her nickname.
3 Q. Teki? Okay. If we can move to page 2.
4 Drawing your attention to -- direct your attention to
5 the bottom of the screen. If you can -- do you see, you have a
6 text there at 9:18 p.m. UTC time?
7 A. Yes.
8 Q. Can you read it to us?
9 A. It says: She good, me and Ghost on dusbone and it's
10 taking some damn long.
11 Q. When you say Ghose who are you he referring to?
12 A. Eghosah.
13 Q. And you say -- the print says disbone. What is that?
14 A. A typo.
15 Q. Okay. Let's skip forward to the next page. Right in
16 the middle of the page -- sorry, Mr. Kerrigan. If we can flip
17 to the next page.
18 MR. DELANEY: Court's indulgence. One moment, the
19 screen is frozen, I think. I switched to the document camera.
20 It'll be easier to explain what you're saying. Putting up the
21 third page of this and zooming in on the middle of the page.
22 Do you see the text, your text there that I'm pointing
23 to, can you just read that to us?
24 A. I pressed B instead of the space.
25 Q. So, this one is what you went to say --
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 24
1 A. Yes.
2 Q. -- not this bone?
3 Then putting up the next page of text --
4 THE COURT: These are all part of Government Exhibit
5 15, correct?
6 MR. DELANEY: This is Government Exhibit 15. Thank
7 you, Your Honor.
8 BY MR. DELANEY:
9 Q. Can you read the text that Teki sends to you?
10 A. So who you been with all day?
11 Q. And your response?
12 A. Ghose.
13 Q. And who are you referring to when you say this?
14 A. Eghosah.
15 Q. Okay. If we can switch back to the -- thank you,
16 Mr. Kerrigan.
17 When you first traveled to Baltimore, did you have any
18 idea how long on you would be there for?
19 A. No.
20 Q. Did you ask?
21 A. No.
22 Q. Why did you go?
23 A. I was -- I was what people would consider down bad. I
24 was broke and desperate.
25 Q. All right. Let's go back to that first day. Were you
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 25
1 given specific instructions as to what you were supposed to do
2 when a package arrived?
3 A. Yes.
4 Q. What were the instructions? Well, who gave you those
5 instructions?
6 A. Amaya.
7 Q. What were those instructions?
8 A. To not inform anyone why we were there. To not wait
9 directly on the address where the package would be delivered.
10 And, ultimately, just stay out of sight.
11 Q. Okay. So when you're dropped off at this location,
12 how did you stay out of sight?
13 A. Just kind of went a few houses down. Didn't speak to
14 anyone. I just --
15 Q. Just stood there?
16 A. Sort of, kind of. Walked around, sat. Just --
17 Q. Did a package ultimately arrive?
18 A. Yes.
19 Q. When the package arrived were you by yourself?
20 A. No.
21 Q. Who was there with you?
22 A. Eghosah.
23 Q. When did he arrive?
24 A. Maybe -- I don't remember honestly. Maybe an hour,
25 maybe sometime before my package came.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 26
1 Q. Do you know if he had retrieved a package?
2 A. Yes.
3 Q. Had he?
4 A. Yes.
5 Q. Okay. So what happened when the package arrived?
6 A. Oh, I waited for the delivery driver to leave and then
7 I walked up to the house where the package was delivered and
8 picked up the package and placed it in my bag.
9 Q. What happened after that?
10 A. We informed, I can't remember if it was Jay or Amaya
11 that we have got the package. And then we were -- we went back
12 to the Airbnb.
13 Q. To whom did you give the packages?
14 A. Amaya.
15 Q. Did you see the packages opened?
16 A. No.
17 Q. During the time you were in that first Airbnb did you
18 open any packages?
19 A. No.
20 Q. Did you observe anyone open any packages?
21 A. No.
22 Q. Are you aware of if those packages were opened in the
23 Airbnb?
24 A. At some point, yes, they were.
25 Q. How do you know that?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 27
1 A. There was one day where Jay came and he went into the
2 master bedroom of the Airbnb and walked out with a trash bag
3 full of scraps from the packages.
4 Q. What happened on the second day you were in the
5 Airbnb?
6 A. Same thing. Woke up early in the morning, this time
7 Jay picked up me and Eghosah to go to drop us off to the
8 addresses.
9 Q. Do you remember what he was driving?
10 A. A Mercedes Benz.
11 Q. Was there anything different about this package pick
12 up operation from the one the day before?
13 A. Yeah, slightly.
14 Q. What was different?
15 A. The package, the address that the package was being
16 delivered to that I was at was occupied.
17 Q. It was occupied?
18 A. Yes.
19 Q. How do you know it was occupied?
20 A. Because when I got there it looked like somebody had
21 -- it was furnished.
22 Q. So what --
23 A. And a couple eventually walked out.
24 Q. So what did you do?
25 A. Prior to them walking out I asked Eghosah what should
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 28
1 I do.
2 Q. How did you ask him this?
3 A. I said, hey, there's somebody living here, what do I
4 do?
5 Q. What, if anything, did he say?
6 A. That if they come out tell them that you had important
7 documents sent and the address was messed up.
8 Q. Okay. So what did you do?
9 A. I -- when the couple eventually came up I told them
10 I'm sorry, I apologized and I said that there was a package
11 being delivered here but it was a mistake, and it was important
12 documents. And I told them it was college transcripts, school
13 transcripts.
14 Q. Okay. And what, if any, response did the couple have?
15 MR. GUILLAUME: Objection.
16 THE COURT: Sustained.
17 BY MR. DELANEY:
18 Q. What happened after you spoke to the couple and told
19 them that you were looking for a package with important
20 documents? What happened next?
21 A. Nothing. They told me it was fine.
22 MR. GUILLAUME: Objection.
23 THE COURT: Objection is sustained. You can --
24 questions that are in furtherance of the conspiracy are not
25 hearsay. To the extent that other statements are offered they
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 29
1 should not be offered. He doesn't need to say what people said
2 to them unless it's in furtherance of the conspiracy. A
3 response such as that from a person at the address is not in
4 furtherance of the conspiracy so the objection is sustained.
5 MR. DELANEY: Thank you, Your Honor.
6 BY MR. DELANEY:
7 Q. Did the couple remain at residence after you spoke
8 with them?
9 A. No.
10 Q. Okay. After they left what did you do?
11 A. I proceeded to wait like a house or two down.
12 Q. And ultimately did the package arrive?
13 A. Yes.
14 Q. What happened?
15 A. The delivery driver dropped it off on the like a
16 stair, the stairway in front of the door, and I walked over and
17 picked it up and placed it in my bag.
18 Q. What happened next?
19 A. I informed Eghosah and then -- that's all I can
20 remember really.
21 Q. I believe you testified on moment ago that you stayed
22 in D.C. somewhere from three days to a week --
23 A. Right.
24 Q. -- is that right?
25 A. Correct.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 30
1 Q. Did you pick up packages the entire time you were
2 there?
3 A. No, not the entire time I was there, no.
4 Q. Okay.
5 A. Just the -- like the first day and the second day.
6 Q. Okay. And where did you give the package the second
7 day?
8 A. We gave it to Jay.
9 Q. Okay. Were you paid for this time you spent in D.C.?
10 A. Not initially.
11 Q. Okay. Were you ultimately paid for it?
12 A. Yes.
13 Q. How did you get paid for your work picking up
14 packages?
15 A. Based off of how many packages we picked up and the
16 addresses we provided.
17 Q. We haven't spoken about providing addresses before.
18 Actually, I'll get to that question later.
19 Who was it that paid you?
20 A. Jay.
21 Q. How did Jay pay you?
22 A. In cash.
23 Q. Where were you when Jay paid you?
24 A. Well, the -- that first time we met at a supermarket
25 called Giant, in their parking lot.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 31
1 Q. Did he pay you regularly?
2 A. Not -- I wouldn't say regularly. He paid us when he
3 felt like it.
4 Q. After you stayed in D.C. did you go somewhere else?
5 A. Yes.
6 Q. Where did you go?
7 A. After D.C. we went to Philadelphia.
8 Q. Did you go anywhere before Philadelphia?
9 A. To pick up packages, no.
10 Q. How did you get to Philadelphia?
11 A. We drove.
12 Q. Who is we?
13 A. Me, Eghosah, a guy named Cam, Cameron, and that's all
14 -- that's who I can remember right now.
15 Q. Were you told to go to Philadelphia or were you given
16 a choice?
17 A. We were given a choice.
18 Q. What was your choice?
19 A. Philadelphia, New Jersey, New York or Baltimore.
20 Q. While you were in Philadelphia who was the source of
21 information for where packages would be picked up?
22 A. Jay.
23 Q. And who did Jay communicate the information to?
24 A. Eghosah.
25 Q. How was it communicated to you?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 32
1 A. I'm not -- I don't understand.
2 Q. I'll rephrase. Did you come to learn how Ego --
3 Eghosah received the information from Jay?
4 A. Yeah, through a messenger app.
5 Q. What was the messenger app called?
6 A. Wickr.
7 Q. Wickr?
8 A. Yes.
9 Q. W-i-c --
10 A. K-R.
11 Q. Okay. Is Wickr the same as a normal text message?
12 A. No.
13 Q. How does it differ?
14 A. On the Wickr app the messages are -- they delete
15 themselves after a certain amount of time.
16 Q. Can we put up on the screen Government's Exhibit No.
17 20. Oh, I got it.
18 And do you recognize the two phone numbers that are a
19 party to this conversation?
20 A. Yes.
21 Q. Whose are they?
22 A. Yes, I do.
23 Q. Whose are they? I'm sorry, whose are they?
24 A. One is my phone number and the other one is Eghosah's.
25 Q. If we can pull back. Can you read to us what is said
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 33
1 first by the number ending in 5821 that you've identified as
2 Eghosah's?
3 A. Send me Jay Wick name and yours.
4 Q. What do you understand Jay Wick name to be?
5 A. I believe it said Peimee. It was supposed to be pay
6 me.
7 Q. Okay. If we can blow up the rest of the. Is that
8 what Jay -- and do you see a text there -- oh, I have a dot. Do
9 you see a text there from you?
10 A. Yes.
11 Q. Do you understand -- what do you say?
12 A. Ultimately, meant to put pay me but it says Peimee.
13 Q. How should have it been spelled?
14 A. P-e-i-m-e-e.
15 Q. And was that the name of Jay's Wickr name?
16 A. Yes.
17 Q. And below that, is that your Wickr name?
18 A. Yes.
19 Q. Okay. While you were in Philadelphia did you collect
20 additional packages?
21 A. Yes.
22 Q. Did Eghosah?
23 A. Yes.
24 Q. Was Amaya English there with you?
25 A. No.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 34
1 Q. Did Jay stay there with you?
2 A. No.
3 Q. Where did you stay?
4 A. At a hotel.
5 Q. Okay. Who was responsible for collecting the packages
6 when you picked them up?
7 A. Eghosah.
8 Q. What did you observe, if anything, Eghosah do with the
9 packages when he picked them up from you?
10 A. Just held on to them.
11 Q. Did you observe him give packages to anyone else?
12 A. No.
13 Q. At this point in time in Philadelphia who gave you
14 money to pay you for your services?
15 A. Eghosah.
16 Q. Now, we've alluded to this before. Were you asked at
17 some point in time to find addresses?
18 A. Yes.
19 Q. Who asked you to find addresses?
20 A. Jay.
21 Q. Was anyone else asked to find addresses?
22 A. Yes.
23 Q. Who?
24 A. Pretty much all the parties involved at the time; me,
25 Eghosah, Cam.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 35
1 Q. Okay. How did you -- what was the purpose of the
2 addresses?
3 A. For packages to be delivered.
4 Q. How did you find addresses?
5 A. We drove around looking for --
6 Q. When you say we?
7 A. Me, Eghosah, Cameron drove around looking for vacant
8 homes that looked convincing enough for packages to be delivered
9 to.
10 Q. Were there any other ways in which you found
11 addresses?
12 A. Eventually Zillow was used.
13 Q. How was Zillow used?
14 A. Through filtering houses for sale.
15 Q. And who came up with that idea?
16 A. I don't know who came up with the idea. I know the
17 idea was presented to me through Eghosah.
18 Q. Put up on the screen Government's Exhibit No. 16. And
19 if we can just blow up the entire box. Do you recognize these
20 notes?
21 A. Yes.
22 Q. Whose notes are these?
23 A. Mine.
24 Q. And we see a created and modified date. Why don't you
25 just tell us, what was the last modified date of these notes?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 36
1 A. November 18th, 2018.
2 Q. And what was the purpose of these notes?
3 A. To -- to keep record of addresses for packages to be
4 delivered to that we eventually would send to Jay.
5 Q. And without reading all of the individual addresses,
6 can you give us the location, city and state, of each of those
7 addresses?
8 A. Philadelphia.
9 Q. We can remove that. Thank you very much,
10 Mr. Kerrigan.
11 After Philadelphia, where did you go next?
12 A. New Jersey.
13 Q. Did you meet anybody new in New Jersey?
14 A. Yes.
15 Q. Who did you meet?
16 A. Drawing a blank on the names. Oh.
17 Q. Take your time.
18 A. Keiarah and a young man named Sooraji.
19 Q. Okay. Do you know Keiarah's last name?
20 A. No.
21 Q. Okay. Was Keiarah a member of the group that was
22 picking up packages?
23 A. Yes.
24 Q. What was her role?
25 A. Just to pick up packages.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 37
1 Q. Okay. Did Keiarah have any relationships beyond
2 picking up packages with anyone who was a member of the group?
3 A. Eventually, yes.
4 Q. What was the relationship and to whom?
5 A. It was, I believe, a romantic relationship with
6 Eghosah.
7 Q. And you also mentioned somebody by the name of
8 Sooraji?
9 A. Yes.
10 Q. What was your understanding of how he got involved?
11 A. That Jay brought him in.
12 Q. And about how long was Sooraji there for?
13 A. Roughly a month.
14 Q. Did he work out very well?
15 A. No.
16 Q. Did he ultimately return back where he came from?
17 A. Yes.
18 Q. Did you have an opportunity to meet Zo at some point
19 in time?
20 A. Yes.
21 Q. Where were you when you met Zo?
22 A. New Jersey.
23 Q. And tell us about meeting Zo.
24 A. I can't remember the details, but just he was there
25 and he was kind of a stand-in for Jay.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 38
1 Q. What do you mean by stand-in?
2 A. Well, he was the one who at some point, for a short
3 time, gave us the information of where things -- packages would
4 be delivered to.
5 Q. Got it. Over time were additional people given the
6 ability -- were additional people given the responsibility of
7 opening packages?
8 A. Yes.
9 Q. Who was the first person you remember getting the
10 ability to open packages?
11 A. Amaya.
12 Q. And after Amaya?
13 A. Eghosah. But before Amaya it was Zo actually.
14 Q. Okay. So is it correct to say that Jay was able to
15 open packages?
16 A. Yes.
17 Q. And over time Zo and Amaya?
18 A. Yes.
19 Q. What about after that?
20 A. Eventually Eghosah and then me.
21 Q. How do you know that Eghosah was able to open
22 packages?
23 A. I had to record a video of him doing it.
24 Q. Who asked you to record it?
25 A. Eghosah.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 39
1 Q. Can you give -- were you given any instructions as to
2 how you were to record it?
3 A. Yes. The camera had to be placed above the package
4 and to leave the face of Eghosah out of it, or the person
5 counting.
6 Q. And was this the point in time where you learned what
7 was in the packages?
8 A. Yes.
9 Q. And what was in the package?
10 A. Money.
11 Q. When you say money, what do you mean money? Checks?
12 A. Cash.
13 Q. And how was the cash packaged?
14 A. In various ways. Sometimes they were in magazines,
15 sometime they were in bank envelopes, sometimes they were
16 stuffed in newspaper.
17 Q. And how many times do you think you recorded Eghosah
18 opening packages?
19 A. Anywhere between five to ten times.
20 Q. And I believe you testified that you were ultimately
21 allowed to open packages as well?
22 A. Yes.
23 Q. Who told you you could do that?
24 A. Jay.
25 Q. When you opened packages did you record videos?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 40
1 A. Yes.
2 Q. Why?
3 A. To keep track of the amount of money that was in the
4 package so -- and to kind of insure that no one was stealing
5 money.
6 Q. I want to put up on the scene Government's Exhibit 29.
7 Now this is a video. Have you previously reviewed Government's
8 Exhibit 29?
9 A. Yes.
10 Q. And do you -- do you -- who took the video?
11 A. It's -- I mean, I took it myself.
12 Q. Okay. Let's go ahead and play it. We can stop as we
13 go.
14 (A video was played during which the following occurred:)
15 MR. DELANEY: Let's go ahead and pause it right there.
16 BY MR. DELANEY:
17 Q. Do you remember where you were when you took this
18 video?
19 A. A fast food restaurant.
20 Q. And where is the camera?
21 A. Well, that is a baby changing station and that's the
22 platform that you place the baby on. The camera was placed on
23 -- like on top of the whole thing.
24 Q. Okay. Let's go ahead and watch it. And is there a
25 continuation of that video?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 41
1 A. Yes.
2 Q. Pulling up Government's Exhibit 30. If we can play
3 the video. Okay.
4 What would you do with videos -- did you take other
5 videos beyond that one?
6 A. Yes.
7 Q. What would you do with videos like that?
8 A. Send it to Jay.
9 Q. How would you send it to Jay?
10 A. Via Wickr.
11 Q. Do you remember the amounts that you would find in
12 packages when you open and counted the cash?
13 A. They ranged from about 5,000 to 10,000.
14 Q. What was the biggest one you remember counting?
15 A. About 20,000.
16 Q. How long were you away from home the first time you
17 traveled?
18 A. A couple months.
19 Q. Sorry, just can't hear you.
20 A. A couple months.
21 Q. Okay. And over time did you make more trips?
22 A. Yes.
23 Q. Okay. You originally flew in September of 2018.
24 Moving forward to the winter, do you remember additional people
25 who got involved in the -- in the package pick up business?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 42
1 A. No, I can't remember the names.
2 Q. Okay. Do you know an individual by the name of
3 Leevensky Lambert?
4 A. Oh, yes. Yes.
5 Q. Was he involved?
6 A. Yes.
7 Q. How do you remember meeting -- how do you remember him
8 getting involved?
9 A. I don't remember how, but I remember him being there
10 because I know him personally.
11 Q. Okay. Did you pick up packages with him?
12 A. Yes.
13 Q. Okay. Did you ever come to learn what happened to all
14 that cash?
15 A. Yes.
16 Q. How did you learn this?
17 A. Through -- there was trips taken to New York.
18 Q. Who took trips to New York?
19 A. At first it started with, from my knowledge it was
20 Eghosah.
21 Q. How do you know that?
22 A. Because I was sent -- or I was asked to pick him up
23 from New York.
24 Q. Where did you pick him up? Can you describe it for
25 us?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 43
1 A. It was a lot of jewelry stores around in New York,
2 downtown Manhattan area. It was a high-rise building.
3 Q. And what was -- what was your understanding of why
4 Eghosah was going to New York?
5 A. To drop off a large sum of money, a large lump sum of
6 money.
7 Q. How do you know this?
8 A. Because I eventually started doing drops myself.
9 Q. How was the package -- or how was the money carried?
10 A. It was prepackaged by Jay and then placed in a back
11 pack that I had.
12 Q. Okay. Did you observe Eghosah carrying bags like
13 yours?
14 A. Yes.
15 Q. So can you describe for us the drop when you did it?
16 I'm sorry, I'm going to withdraw that question.
17 Did you ever make a drop with Eghosah?
18 A. Yes.
19 Q. Tell us what happened.
20 A. We went to the high-rise building and then we went to
21 the 13th floor. Yeah, the 13th floor. And then there was a
22 small office. And then there was -- we'd meet a guy there and
23 he'd take the money out and place it in a money counter.
24 Q. Okay. And then what would happen?
25 A. The money would then be counted and then a phone call
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 44
1 was made to Jay by the person who counted the money. And from
2 my understanding it was to confirm the amount that was counted.
3 Q. So did the person to whom you gave the money have an
4 understanding of how much money should be there?
5 A. Yes.
6 Q. And was the purpose of the phone call to communicate
7 whether it matched?
8 A. Yes.
9 Q. How many times did you go with Eghosah to drop off
10 money?
11 A. Not many times. Maybe twice.
12 Q. How many times did you travel with Eghosah to drop off
13 money, whether or not you went in with him or not?
14 A. Maybe five, 10, almost a dozen times maybe.
15 Q. How many times did you personally drop off money?
16 A. About ten times.
17 Q. What --
18 A. Between five and ten times.
19 Q. Understood. When you dropped off money or were
20 present when money was dropped off, did you observe the count?
21 A. A couple times I did, yes.
22 Q. What observation did you make as to much money was
23 counted?
24 A. Six figure amounts. One time it was about 300,000.
25 One time it was about 170,000.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 45
1 MR. DELANEY: Court's indulgence.
2 BY MR. DELANEY:
3 Q. I'd like to go ahead and put up on the screen --
4 sorry. I'm going to put up on the screen what's been marked as
5 Government's Exhibit 28. Do you recognize the telephone number
6 on this?
7 A. Yes. Yes, I do.
8 Q. Whose telephone number is that?
9 A. Eghosah.
10 Q. Is that the contact you gave him in your phone?
11 A. Yes.
12 Q. What is it?
13 A. E with an asterisk.
14 Q. I'd like to move to page 5. And if we can highlight
15 the blue text in the middle of the page.
16 Do you recognize on March 25th, 2019, what -- what
17 that address is?
18 A. Yes.
19 Q. 55 West 47th Street, Suite 620 in New York, New York?
20 A. Yes.
21 Q. What is it?
22 A. That is the building -- that was the building near the
23 high-rise building we had to go to.
24 Q. Why do you say near?
25 A. Because -- I don't know, the Suite 620 is throwing me
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 46
1 off because we went to the 13th floor. That's just my
2 observation of it.
3 Q. Okay. But this address is close to the building you
4 went for the drop?
5 A. Yes.
6 Q. And can you describe the businesses around that area?
7 A. Jewelry stores.
8 Q. Okay. We can go ahead and remove that.
9 All right. Let's put up Government's Exhibit 18,
10 please. All right. If we can just expand that.
11 Do you recognize these notes?
12 A. Yes.
13 Q. And can you tell us the date of modification? Last
14 date of modification?
15 A. January 4, 2019.
16 Q. Are these your notes?
17 A. Yes.
18 Q. What are they?
19 THE COURT: What exhibit is up right now?
20 MR. DELANEY: Government's Exhibit 18.
21 THE COURT: 18? Yes. Thank you.
22 MR. DELANEY: Thank you, Your Honor.
23 BY MR. DELANEY:
24 Q. What are these notes?
25 A. Addresses.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 47
1 Q. Where?
2 A. In Washington, D.C.
3 Q. What's the purpose of these addresses?
4 A. Those addresses were for -- to be provided so packages
5 could be delivered to them.
6 Q. Did you communicate these addresses to anyone else?
7 A. Yes.
8 Q. To whom did you communicate them?
9 A. Jay.
10 Q. Let's put up Government's Exhibit 19. If we can
11 expand this. Thank you, Mr. Kerrigan.
12 Do you recognize these notes?
13 A. Yes.
14 Q. Whose notes are they?
15 A. They're my notes.
16 Q. And what is the last date these notes were modified?
17 A. January 7, 2019.
18 Q. And what are we looking at here?
19 A. Addresses in Baltimore, Maryland.
20 Q. I'm going to draw your attention specifically to the
21 one I'm pointing to right there, 417. Can you read that address
22 to us?
23 A. 417 Southway, Baltimore, Maryland.
24 Q. Okay. And two below that, can you read us that
25 address?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 48
1 A. 216 North Chester Street, Baltimore, Maryland.
2 Q. And the one below that?
3 A. 314 Southway Baltimore, Maryland.
4 Q. Okay. Did you transmit these addresses to anyone?
5 A. Excuse me?
6 Q. Did you send these addresses to anyone?
7 A. Yes.
8 Q. Who did you send them to?
9 A. I sent these to Jay.
10 Q. Why?
11 A. So that way we could have packages delivered to them.
12 Q. If we could put up Government's Exhibit 21 on the
13 screen.
14 Whose notes are these?
15 A. My notes.
16 Q. When are they last modified?
17 A. January 19th, 2019.
18 Q. And what does this list show, in January?
19 A. Just a list of pick ups by individuals.
20 Q. What kind of pick ups?
21 A. Of package pick ups.
22 Q. Why are you listing pick ups in your notes?
23 A. To keep track of the packages picked up for everyone
24 so that they can pet paid.
25 Q. So who can get paid?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 49
1 A. The individuals, Mike, Ego, Keion, and myself.
2 Q. I think you told us about Keion before. Who is Mike?
3 A. That's Mikey who you mentioned earlier.
4 Q. What Mikey's real name, full name?
5 A. Leevensky.
6 Q. Okay. And then if we can blow up this one. No, not
7 when I circle it. No, you can't do it anymore. Can you see
8 this one and read this one to us?
9 A. Ego, five pick ups total.
10 Q. Keep going.
11 A. Thursday, 2801 Maryland Avenue; Friday, 3016 Kenyon
12 Ave and 2802 Maryland Ave. Saturday, two packs at 716 Melville
13 Avenue.
14 Q. And that's on Saturday?
15 A. Yes.
16 Q. I see. So Thursday there's a notation under Keion,
17 three pickups. Can you read that address to us?
18 A. That Thursday?
19 Q. Yep.
20 A. Thursday, 761 Melville.
21 Q. Thank you. Putting up Government's Exhibit No. 22.
22 Do you recognize who are the participants to this
23 conversation?
24 A. I recognize my number but not the 305 number.
25 Q. You recognize the number ending in 0771?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 50
1 A. Yes, that's mine.
2 Q. That's your phone number?
3 A. Yes.
4 Q. You don't recognize whose number that is --
5 A. No.
6 Q. -- ending in 9557 though; is that right?
7 A. No, I don't know that number. I don't remember that
8 number.
9 Q. Pulling back out. Do you recognize the sum and
10 substance of the conversation? Have you reviewed it previously?
11 A. From mine on down?
12 Q. Uh-huh.
13 A. Yours on the truck right now.
14 Q. Have you reviewed this before?
15 A. No.
16 Q. Let's go ahead and skip forward to page 2. And if we
17 can blow up the text in the middle of page that I've circled.
18 Do you recall sending that text?
19 A. Yes.
20 Q. Okay. Do you remember who you sent it to?
21 A. No. Not right now, no. I can't remember.
22 Q. Tell us what you remember about sending that text.
23 A. That it looks like this address, somebody was living
24 there, and I was telling whomever this is to make the excuse
25 that their grandmother messed up, that she was supposed to send
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 51
1 it to 3208 Longview Ave and not Lake Ave and to let them know
2 that you're not from there.
3 Q. Did you come up with that excuse yourself?
4 A. At that specific time, yes.
5 Q. Okay. You testified at that specific time. Had you
6 heard that excuse used prior to that time?
7 A. Yes.
8 Q. Who used it?
9 A. Eghosah.
10 Q. Let's put up Government's Exhibit --
11 MR. DELANEY: Court's indulgence.
12 Yeah, let's go ahead and put up Government's Exhibit
13 23 again. Oh, no, this is the first time we put it up. Putting
14 up Government's Exhibit 23. And if we can look at the
15 participants. Again, we see your telephone number. Do you
16 recognize the other number?
17 A. Yes, I do.
18 Q. Whose number -- I'm sorry for speaking over you,
19 that's my fault. Whose number is that?
20 A. Eghosah.
21 Q. Okay. We can blow it back up again, and just the
22 conversation. Mr. Kerrigan, can you blow up the whole thing?
23 What do you say?
24 A. Send ya ID.
25 Q. And what's the response?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 52
1 A. Eghosah -- Eghosasere Avboraye.
2 Q. Okay. And then if we can click forward to the second
3 page of Government's Exhibit 23. If we blow up the attachment.
4 Just the attachment. If you can blow up that page first. Thank
5 you.
6 Does there appear to be an attachment to it?
7 A. Yes.
8 Q. Okay. And who is sending that attachment?
9 A. Eghosah.
10 Q. And if we can clip now to Government's Exhibit 23A.
11 Does this appear to be a copy of the attachment sent?
12 A. Yes.
13 Q. What does it appear to be?
14 A. Eghosah's ID card.
15 Q. Take that down.
16 Do you recall a time where you learned that some
17 members of the conspiracy had been arrested in Florida?
18 A. Yes.
19 Q. Where were you when you learned that this occurred?
20 A. I was in Baltimore at that time.
21 Q. Let's put up Government's Exhibit 25. Actually,
22 before we do 25 let's just do 24. Government's Exhibit 24. Do
23 you see the date of modification on this?
24 A. Yes.
25 Q. When is it?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 53
1 A. February 9th, 2019.
2 Q. And what is it that we're looking at here?
3 A. Addresses from Philadelphia.
4 Q. And did you communicate those addresses to anyone?
5 A. Yes.
6 Q. To whom?
7 A. Jay.
8 Q. Okay. Now we can go to Government's Exhibit 25.
9 If we can look at the top, who are the participants to
10 this conversation?
11 A. Me and I believe that's Keiarah's number.
12 Q. Okay.
13 THE COURT: You have to keep your voice up please, and
14 speak clearly into the microphone, please.
15 THE WITNESS: I believe that was Keiarah's number.
16 BY MR. DELANEY:
17 Q. Okay. If we can go back to the conversation now. If
18 you can read to us what is the person you believe to be Keiarah
19 say?
20 A. You speaking to Ego today?
21 Q. And your response?
22 A. I did, but he been MIA since about 11.
23 Q. And what did she say?
24 A. Yeah, that's pretty much like all day. Um was he
25 okay? Do you know?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 54
1 Q. And your response?
2 A. I've been hitting up but no answer.
3 Q. Turning to the second page. And then we'll just focus
4 in on the bottom two text boxes. What does Keiarah say?
5 A. Call me.
6 Q. And your response?
7 A. They locked up.
8 Q. And the date on this?
9 A. February 9th, 2019.
10 Q. Okay. Turning to page 3. And if we can blow up
11 starting here and going down to here. Thank you, Mr. Kerrigan.
12 What does Keiarah say?
13 A. He needs you. Call his big brother.
14 Q. Who is big brother?
15 A. It was a joke at the time, but we were talking about
16 Jay.
17 Q. And your response?
18 A. My phone was dead when they called.
19 Q. And what does Keiarah say?
20 A. People, can you please just call his Milk Dud big
21 brother and let him know.
22 Q. Who is Milk Dud big brother?
23 A. Jay.
24 Q. Let's go ahead and put up Government's Exhibit 11. Is
25 that the person you identified before as Jay?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 55
1 A. Yes.
2 Q. Did he goes by Milk Dud?
3 A. He didn't go by Milk Dud that's just what we called
4 him.
5 Q. Would you have called him Milk Dud?
6 A. No.
7 Q. Why not?
8 A. He wouldn't have liked it.
9 Q. Let's go back to Government Exhibit 25, and page 4.
10 And if we can go down to the bottom of the page and just blow it
11 up from there.
12 What does Keiarah say?
13 A. Imma look it all up but it's all Keion fault. I been
14 talking to Ghose. Keion is a gook.
15 Q. And let's just -- what do you say at the bottom of
16 page there at 11:39 p.m. UTC time?
17 A. How was Keion fault, LOL.
18 Q. Okay. Who is Keion if you can remind us?
19 A. He was somebody else involved in the scheme.
20 Q. Okay. Let's turn to page 5. And is -- well, let's
21 start at the top. Let's blow up the first half of it.
22 What does Keiarah say? And if you can just read the
23 three texts that Keiarah writes.
24 A. He was nervous and his mouth ran like water. They
25 literally was asleep in the back and had nothing to worry about.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 56
1 You know how they get to asking questions and digging like they
2 always do. Like they did us in Jersey with Zo. Just digging
3 and nervous. Nervous as Keion was just saying shit that pretty
4 much recanted what Ego and Mikey said. So it looks like a big
5 fat-ass mess. Keion just never dealt with feds because they
6 scared him and it worked.
7 Q. There's a reference here to "like they did us in
8 Jersey with Zo." What is this in reference to?
9 A. A traffic stop.
10 Q. Who was the party to the traffic stop?
11 A. Me. Me, Zo, and Keiarah.
12 Q. And what happened? Was anybody else there?
13 A. I can't remember.
14 Q. Okay. What happened?
15 A. We were stopped by the police for a traffic violation
16 and they kind of made a big deal. They had the dogs and
17 everything on us, I remember that day. And there was a few
18 officers involved looking for -- I believe drugs because they
19 called the drug dog.
20 Q. What were you doing when were you driving?
21 A. I forget what we were doing, but we had packages on us
22 at that moment.
23 Q. If can do the bottom of page 5 of Government's Exhibit
24 25.
25 What did you say?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 57
1 A. He should have stuck to the I don't know.
2 Q. What does that mean?
3 A. It means just any time you don't know what to say to
4 the police just say I don't know.
5 Q. Okay. What does she say at the bottom of the page at
6 11:58?
7 A. He start talking shit about being in a hotel brought
8 Ghose name it, and everything Keion said is opposite of Mikey
9 and Ghose. Whose story match.
10 Q. Turning then to page 6. At the top of the page what
11 is that link?
12 A. I think it was the an arrest record.
13 Q. Okay. And the next date, just look at the remaining
14 text on this page. All of them, if we can fit them in.
15 Can you read it or do you want me to make it bigger?
16 A. No, that's fine, I can read it.
17 Q. What does Keiarah say?
18 A. I found that, and it's odd Keion ain't being charged
19 with nothing at all. Just got off the phone with Ghose, bail
20 hearing at 9 a.m. He has those three charges and they came up
21 with that based off what Keion said. Mind you, police found him
22 sleeping.
23 Q. And you say?
24 A. So you're telling me that Keion is snitching.
25 Q. And Keiarah.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 58
1 A. In other words, but I don't know, it's just odd he has
2 no charges, and Ego says I should know what that mean. He the
3 only one the feds seen nervous as hell. They probably got in
4 his head.
5 Q. Okay. And then what do you say?
6 A. That's crazy. I'm pissed, because Jay left me as
7 well. I fuck with Keion, but bruh, idiot. I told him before,
8 any situation with the cops you tell them I don't know,
9 especially if there was no drugs and he wasn't driving.
10 Q. Okay. Page 7 just the text at the top of page.
11 THE COURT: Mr. Delaney, how many more texts are we
12 going to look at with respect to this dialogue between Keion and
13 the witness?
14 MR. DELANEY: This texts and the two more pages.
15 THE COURT: All right. This is getting a little
16 cumulative now and we have to move on for case management. We
17 have another minute on this, we move on, Mr. Delaney.
18 MR. DELANEY: Thank you very much, Your Honor.
19 BY MR. DELANEY:
20 Q. Let's go ahead and skip forward to page -- I think
21 it's page 10. Actually, let's go to page 11. At the top of the
22 page, what are we looking at here?
23 A. A news article. A link to a news article.
24 Q. Do you remember seeing news articles?
25 A. Yes.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 59
1 Q. Okay. And did you watch the news articles?
2 A. Yes. I read them briefly, yes.
3 Q. What did you learn from the news articles you watched?
4 A. That Mike, Ego, and Keion were arrested in connection
5 with a grandparents scheme, elderly scheme.
6 Q. Okay. And let's go down to the text below this. And
7 one more. I'm sorry, Mr. Kerrigan. Those three and we'll be
8 done.
9 THE COURT: What exhibits are you on now?
10 MR. DELANEY: We're still on Government Exhibit 25.
11 THE COURT: We have another minute on this, Mr.
12 Delaney. We're winding this up.
13 MR. DELANEY: Thank you, Your Honor.
14 BY MR. DELANEY:
15 Q. Page 11. What does Keiarah say?
16 A. Released. He called me.
17 Q. And what do you say?
18 A. Yeah, Jay told me.
19 Q. Okay. We can remove Government's Exhibit 25.
20 After Eghosah was released did you discuss what
21 happened with him?
22 A. Yes.
23 Q. What, if any, conversations did you have with him
24 about what happened?
25 THE COURT: I'm sorry, clarify. With whom is he
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 60
1 speaking now?
2 MR. DELANEY: Eghosah.
3 THE COURT: Okay. But with the defendant Eghosah.
4 It's important to clarify this now.
5 MR. DELANEY: Thank you very much, Your Honor.
6 BY MR. DELANEY:
7
8 Q. What, if anything, did he say?
9 A. He said that Eghosah said that he was in the backseat
10 sleeping and Mikey got out of the vehicle to retrieve a package
11 and the police surrounded them.
12 Q. Okay. Did you discuss what you'd learned from the
13 news stories with Jay?
14 A. Yes.
15 Q. Tell us about that conversation.
16 A. When I brought to Jay's attention the article, I asked
17 him if this was the same thing. Was this related to what we're
18 doing up north here.
19 Q. And what did you mean by this?
20 A. The picking up of packages.
21 Q. Specifically packages from where?
22 A. Elderly people.
23 Q. What was Jay's reaction?
24 A. He nor denied or confirmed, he just brushed me off and
25 told me not to worry.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 61
1 Q. After that conversation did you have another
2 conversation with Jay about it?
3 A. Yes.
4 THE COURT: Mr. Delaney. Mr. Delaney, what are the
5 conversations after the arrest having to do with the furtherance
6 of the conspiracy for which the charges were brought?
7 BY MR. DELANEY:
8 Q. After the arrest that you've testified to did you
9 continue to pick up packages as part of this scheme?
10 A. Yes.
11 Q. Did Eghosah continue to pick up packages as part of
12 this scheme?
13 A. Yes.
14 Q. After you'd first asked Jay -- you've already
15 testified that there was a second conversation with Jay about
16 what you'd learned from the news stories; is that correct?
17 A. Yes.
18 Q. Who else -- was anyone else present for that
19 conversation?
20 A. Yes.
21 Q. Who?
22 A. Eghosah.
23 Q. Tell us about that conversation.
24 A. I then asked -- I asked again, to Jay, is this
25 connected to the packages we've been picking up. And then he
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 62
1 then confirmed yes, this is the -- this is -- the same thing
2 that went on there is what we're doing up here.
3 Q. Did you have an opportunity to observe Eghosah's
4 reaction to Jay as confirmation?
5 A. Yes.
6 Q. What did you observe about his reaction?
7 A. That he wasn't surprised.
8 Q. What makes you say that?
9 A. Just body language, facial expression. Almost like he
10 had known.
11 Q. Subsequent to this conversation with Jay and Eghosah,
12 did you have further conversations with Eghosah about where the
13 money came from?
14 A. Yes.
15 Q. Tell us about those conversations.
16 A. Eghosah basically informed me that this scheme has
17 been going on for sometime and that it's possibly older than me
18 and him.
19 Q. After this conversation did you continue to remain a
20 member of the conspiracy?
21 A. Yes.
22 Q. Why?
23 A. Because I was broke still.
24 Q. To your knowledge, did Eghosah continue to remain a
25 member of the conspiracy?
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 63
1 A. Yes.
2 Q. What if any changes were made to the operation after
3 this Florida arrest?
4 A. We were in -- I was instructed to remove labels from
5 packages when we retrieved them.
6 Q. Who instructed you?
7 A. Eghosah.
8 Q. Any other changes made?
9 A. We were not to smoke in cars and we were not to keep
10 more than one package on our persons at a time.
11 Q. And who made those -- who made those changes?
12 A. It was Jay and Eghosah, they -- was kind of both.
13 Q. Let's put up Government's Exhibit 27. Who are the
14 participants to this conversation?
15 A. Me and Eghosah.
16 Q. If we can pull back out.
17 The conversation itself, when does it take place?
18 Blow up the whole conversation. Thank you.
19 A. March 11, 2019.
20 Q. Okay. Is this after those conversations we just
21 described between you, Jay, and Eghosah?
22 A. Yes.
23 Q. Okay. And is there an attachment at March 11th?
24 A. Yes.
25 Q. Can we put up Government's Exhibit 27A.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 64
1 Does this appear to be that attachment?
2 A. Yes.
3 Q. What is it?
4 A. A money order from Western Union.
5 Q. Okay. In fact, let's go back and put up Government's
6 Exhibit 28 again. And turn to page 5.
7 This address we discussed earlier in New York, who
8 texts that address to you?
9 A. Eghosah.
10 Q. What's the date?
11 A. March 25th, 2019.
12 Q. Your response?
13 A. On my way.
14 Q. And then if we can click to page 6. And what does
15 Eghosah say to you?
16 A. Yo, I'm up here.
17 Q. You pull off that exhibit. I just want to quickly
18 make reference to a couple additional exhibits. Government's
19 Exhibit 31.
20 What is this?
21 A. This is a list of addresses.
22 Q. Who created it?
23 A. Me.
24 Q. Where was it sent? Were they sent anywhere?
25 A. Yes.
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 65
1 Q. Where?
2 A. To Jay.
3 Q. Where were these addresses located?
4 A. Lancaster, Pennsylvania.
5 Q. Exhibit 32. Are these addresses from your notes as
6 well?
7 A. Yes.
8 Q. Where are they located?
9 A. Delaware. Newark, Delaware.
10 Q. Exhibit 36. What is this?
11 A. Oh, this is a tracking of pick ups. A list of pick
12 ups.
13 Q. And Exhibit 37. What is this?
14 A. Another list of pick ups.
15 Q. At some point in time were you arrested?
16 A. Yes.
17 Q. Where were you when you were arrested?
18 A. New Castle, Delaware.
19 Q. What were you doing when you were arrested?
20 A. Picking up a package. Picking up packages.
21 Q. And at that point in time were you charged federally?
22 A. No.
23 Q. Were you charged?
24 A. Yes.
25 Q. Locally there?
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1 A. Yes.
2 Q. Were you later charged federally?
3 A. Yes.
4 Q. And did you make a determination to plead guilty and
5 cooperate?
6 A. Yes.
7 Q. Why?
8 A. Because -- just have responsibility.
9 Q. To whom?
10 A. To family and myself.
11 MR. DELANEY: Court's indulgence.
12 BY MR. DELANEY:
13 Q. Just for the benefit of the record, you identified
14 lists on Government's Exhibit 32, 36, and 37 --
15 A. Yes.
16 Q. -- of notes you kept on your phone?
17 A. Yes.
18 Q. Do you know what you did, if anything, with those
19 notes?
20 A. I sent them over to Jay.
21 Q. Thank you.
22 MR. DELANEY: No further questions at this time Your
23 Honor.
24 THE COURT: Thank you, Mr. Delaney.
25 Mr. Guillaume, would you like a little break before
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EXCERPT OF DAVID GREEN - DIRECT EXAMINATION 67
1 you start your cross-examination?
2 MR. GUILLAUME: That would be fine, Your Honor. Thank
3 you.
4 THE COURT: All right. We'll take a little bit of a
5 break. You should not discuss your testimony with anyone, Mr.
6 Green, when you go out in the hallway, you stay by yourself.
7 And we'll take a ten-minute recess and we'll continue
8 on. We'll probably break for lunch 1:15, 1:20 or something.
9 We're going to take a late morning recess just before noon, so
10 we'll take a ten-minute recess. Thank you.
11 THE CLERK: All rise. The Court stands in recess.
12 (Jury out at 11:52 a.m.)
13 (Recess from 11:53-12:18 p.m.)
14 THE COURT: Go ahead and bring the jury back in.
15 Thank you.
16 By the way, counsel, Government Exhibit No. 10 is the
17 plea agreement as to Mr. Green.
18 MR. DELANEY: Yes.
19 THE COURT: Included in that plea agreement is a
20 stipulation and a statement of facts which does not necessarily
21 come in. So I just want to clarify that. I'll deal with that
22 later, in case, Mr. Guillaume, you're going to make reference to
23 it, the stipulation of facts and the statement of facts does not
24 come into evidence because of hearsay implications. So you're
25 free to cross-examine all you want but that won't be coming into
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 68
1 evidence.
2 MR. GUILLAUME: I didn't plan to talk about the
3 statement of facts.
4 THE COURT: I assume you all understand that but I
5 just want to make sure.
6 MR. DELANEY: Thank you, Your Honor.
7 THE COURT: So all those exhibits which were
8 referenced are in evidence, with the exception of Government's
9 Exhibit 10 that's limited in that fashion.
10 MR. DELANEY: Thank you.
11 (Jury entered courtroom at 12:20 p.m.)
12 THE COURT: Thank you all very much. And we're ready
13 to proceed here with the cross-examination of the witness.
14 You may be seated, Mr. Green.
15 Mr. Guillaume, cross-examination sir.
16 MR. GUILLAUME: Thank you. Thank you, Your Honor.
17 CROSS-EXAMINATION
18 BY MR. GUILLAUME:
19 Q. Good morning, sir.
20 A. Good morning.
21 Q. So, sir, I want to focus a little bit on what you said
22 a moment ago. I'm going to go a little out of order so forgive
23 me, but I want to focus first on something you mentioned a
24 moment ago. You -- would have been February of 2019 when my
25 client was arrested in Florida; is that correct?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 69
1 A. Yes.
2 Q. Okay. And at that time you were living in Baltimore,
3 right?
4 A. I wasn't living there but I was there in Baltimore.
5 Q. Okay. You weren't living in Baltimore at all?
6 A. I wasn't living there, no.
7 Q. Okay. So okay, I'll come back to that in a second.
8 But prior to that February date, the early February of 2019, you
9 were unaware that the packages you were picking up involved an
10 elderly scam; is that correct?
11 A. Yes.
12 Q. You had never discussed that with anyone, including my
13 client, correct?
14 A. No.
15 Q. No?
16 A. No, I didn't discuss it with him. No.
17 Q. Right. Didn't discuss it with him, didn't discuss it
18 with Jay, didn't discuss it with Amaya, correct?
19 A. Correct.
20 Q. So you were, as far as you knew the money could have
21 come from any source to that point, correct?
22 A. Yes.
23 Q. And you -- when they were arrested -- he was arrested
24 with two other people; is that right?
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 70
1 Q. Both of whom you know, correct?
2 A. Yes.
3 Q. Laveensky Lambert is one?
4 A. Yes.
5 Q. Also known as Mikey?
6 A. Correct.
7 Q. And Keion Smith, correct?
8 A. Yes.
9 Q. Keion Smith is from Baltimore, right?
10 A. Yes, he is.
11 Q. Right. And he had traveled to Florida at some point
12 presumably, correct?
13 A. Yes.
14 Q. Okay. He wasn't living there, right?
15 A. No.
16 Q. All right. And you are from Florida but were staying
17 in a variety of places including Baltimore; is that correct?
18 A. Yes.
19 Q. Okay. Now, you've referenced a conversation that you
20 had with Jay regarding what you had read in the newspaper; is
21 that right?
22 A. Yes.
23 Q. And this newspaper was in Florida, correct?
24 A. Yes.
25 Q. So you read an online version of that?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 71
1 A. Yes, I did. Yes.
2 Q. Right. And at some point my client was detained. He
3 was actually locked up as a result of that, right, initially.
4 A. Yes.
5 Q. Then he was released at some point thereafter?
6 A. Yes.
7 Q. So we're talking February of 2019. Do you remember if
8 it was within the month of February or was it in March or after
9 when he was released, do you remember?
10 A. I believe it to be February, yes.
11 Q. Sometime later after the arrest date?
12 A. Yes.
13 Q. Okay. And you testified that you were still working
14 in the package operation at that time, right?
15 A. Yes.
16 Q. February -- in February of 2019, I want to be
17 specific. And your testimony was that my client, according to
18 you, was also working in that operation, correct?
19 A. Yes.
20 Q. Okay. Now, at some point you have a conversation.
21 You actually testified that you had two conversations with Jay,
22 right?
23 A. Two --
24 Q. Two separate conversations regarding what you had read
25 based on your -- the Florida arrest and based on your reading of
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 72
1 those newspaper articles, right?
2 A. Yes.
3 Q. First time Jay, you said, brushed you off; is that
4 right?
5 A. Correct.
6 Q. Second time you said Jay confirmed that the Florida
7 arrests were related to an elderly scheme is what -- the term
8 I'm going to use; is that right?
9 A. Yes.
10 Q. That was the first time you had heard it?
11 A. The first time he had confirmed, yes.
12 Q. And my client, you said, was present during that
13 conversation, right?
14 A. Yes.
15 Q. And he didn't -- my client didn't say anything, but
16 you said based on his body language you interpreted that he
17 knew; is that correct?
18 A. Yes.
19 Q. But he didn't say anything out of his mouth, correct?
20 A. Correct.
21 Q. Okay. And you guys had been friends very long time;
22 is that right?
23 A. Yes.
24 Q. In fact, you grew up together.
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 73
1 Q. You knew his family? His brothers and sisters?
2 A. Yes.
3 Q. And you knew his mother.
4 A. Yes.
5 Q. Okay. You guys lived -- went to high school together.
6 A. Yes.
7 Q. And lived very close to one another growing up.
8 A. Yes, we did.
9 Q. Okay. Matter of fact, you had a hand in introducing
10 him to his wife; is that right? Through a mutual friend.
11 A. You're saying -- I'm sorry.
12 Q. Did you have a hand in introducing my client to his
13 current wife?
14 A. No.
15 Q. Through a mutual friend of yours?
16 A. No, I didn't have a hand in that.
17 Q. Okay. But you do know her. You do know his wife
18 though, right?
19 A. Yes.
20 Q. Now, you know, at some point around this time frame
21 you -- and you were friends with him -- let's be clear. You
22 were friends with him, him being my client, you were friends
23 with him throughout. You've never stopped being friends, right?
24 A. No, we never stopped being friends.
25 Q. Okay. Current situation set aside, but you were -- at
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 74
1 that time you were friends and you've known him his whole life,
2 or pretty much most of his life, right?
3 A. Yes. Yes.
4 Q. Right. So you were aware that he got married, right?
5 He has a wife, yes?
6 A. Yes. Yes.
7 Q. Right. So he married a woman, yes?
8 A. Yes.
9 Q. Okay. And he was living with that woman in Chester,
10 Pennsylvania at some point, right?
11 A. Yes.
12 Q. Okay. And you were aware of this.
13 A. Correct.
14 Q. Okay. And did you -- I think you've gone by the house
15 before, right?
16 A. Yes, I have.
17 Q. He actually moved from Florida to live in this part of
18 the country, right?
19 A. Yes.
20 Q. Okay. Because his wife was not from Florida, is she?
21 A. No.
22 Q. She's from Baltimore, right? Or Maryland.
23 A. Not sure. I know she's from this area, yes.
24 Q. Okay. And you're not from here so you're not
25 necessarily familiar with all the different areas, right?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 75
1 A. Correct.
2 Q. Okay. And you're aware that at one point my client
3 was working with Peloton and tried to recruit you to work with
4 Peloton, or recruit you to work at Peloton with him around the
5 same time frame; is that right?
6 A. I'm sorry, Peleton.
7 Q. Pele ton the company. Have you heard of it?
8 A. Yes. The workout witness machines, yeah.
9 Q. Right. Were you aware that my client was working for
10 Pele ton at one point?
11 A. At some point, yes.
12 Q. Right. Would it have been around this time, this time
13 frame we've been discussing that you talked about previously on
14 direct examination?
15 A. Is this the February date?
16 Q. Not necessarily the February date, but in the general
17 timeframe that we've been referencing. I guess September 2018
18 to February 2019 dates have been specifically discussed, in the
19 victim -- March 2019 thereafter. Those have been the dates that
20 have been discussed.
21 A. I don't remember honestly. I don't remember where he
22 was working at. As far as the time frames, I don't remember.
23 Q. But you do know --
24 A. I remember him working at Pele ton, yes.
25 Q. That was my question. It's been awhile.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 76
1 Sir, at some point in March of 2019, you were
2 arrested; is that correct?
3 A. Yes.
4 Q. Okay. And that was in the state of Delaware, right?
5 A. Yes, it was.
6 Q. Okay. You were arrested. You were not alone when
7 were you arrested, correct?
8 A. No, I was not.
9 Q. You were -- you've already testified that you were
10 working package pick ups, right?
11 A. Yes.
12 Q. And at this time you were aware that -- of the source
13 of the money in the packages, right?
14 A. Yes.
15 Q. Okay. And you were actually working with another
16 person named Kyrie Oliver; is that right?
17 A. Yes.
18 Q. Kyrie Oliver, at the time, was a juvenile, right?
19 A. Yes, he was.
20 Q. And he's from Baltimore, right?
21 A. Correct.
22 Q. He actually is a relative of a woman you were dating
23 in Baltimore, right?
24 A. Yes.
25 Q. And her name is Norel; is that correct?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 77
1 A. Yes.
2 Q. And you actually not only were you dating her you were
3 living with her; is that right?
4 A. Yeah. Yes.
5 Q. Right. So you recruited her relative, Mr. Oliver, who
6 was a juvenile at the time in 2019, to help you with your
7 package pick ups; is that right?
8 A. Yes.
9 Q. And at that time, in March of 2019, a lot of people
10 you had previously worked with were not working in the package
11 pick up operation anymore; is that correct?
12 A. I'm sorry, say again.
13 Q. So a lot of the people, in March of 2019 when you were
14 arrested in Delaware with Mr. Oliver.
15 A. Right.
16 Q. A lot of people who you had previously worked with,
17 that you had mentioned, you said my client was working with but
18 I'll leave that for another set of questions. I'm talking about
19 Mr. Lambert, Mr. Smith, Keion Smith, those folks were not -- no
20 longer working with you; is that correct?
21 A. No. Yeah, that's correct.
22 Q. Okay. Now, you were working under the direction of
23 Jay; is that correct?
24 A. Yes.
25 Q. And Jay's not -- Jay's not his real name; is that
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 78
1 right?
2 A. Yeah, that's not his real name.
3 Q. You didn't -- at the time did you know what his real
4 name was in March of 2019?
5 A. I never ever found out what his real name was.
6 Q. But you -- it's been referenced in your direct
7 testimony the name Medard Ulysse, does that sound familiar?
8 A. Who?
9 Q. Medard Ulysses?
10 A. I've only heard that name up until just now.
11 Q. And who do you understand that name to be?
12 A. I don't know whose name that is.
13 Q. Okay. Could I see Government's Exhibit 4.
14 MR. GUILLAUME: Court's brief indulgence.
15 BY MR. GUILLAUME:
16 Q. Showing you for the record what's been previously
17 admitted as Government Exhibit No. 11. This, in fact, is the
18 person you referred to as Jay. You identified him a couple
19 times; is that right?
20 A. Yes.
21 Q. And there was testimony a moment ago about a nickname,
22 Milk Dud head or something like that.
23 A. Yes.
24 Q. That was the name that was called -- people called him
25 behind his back.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 79
1 A. Correct.
2 Q. Okay. And the one of the reasons would be for calling
3 him behind his back is because you learned through your time
4 with Jay he had a very violent temper; is that correct?
5 A. Yes.
6 Q. He physically abused people, correct?
7 A. Not that I witnessed, but yes.
8 Q. Okay. You heard about stories of him hurting people;
9 is that correct?
10 A. Correct.
11 Q. In fact, you testified, I believe, that when you met
12 with him you didn't complain about getting shortchanged on the
13 money you were owed because you didn't want any problems; is
14 that right?
15 A. Correct.
16 Q. Is it fair to say that Jay is a very intimidating
17 person?
18 A. Yes.
19 Q. In fact, he beat Charlemagne or Zo; isn't that
20 correct?
21 A. I didn't witness that.
22 Q. Okay. You were not there for that.
23 A. I was not there for that.
24 Q. Did you just hear about it?
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 80
1 MR. GUILLAUME: You can take the exhibit down. Thank
2 you.
3 BY MR. GUILLAUME:
4 Q. And Jay was the person who was running this
5 organization; is that right?
6 A. Yes.
7 Q. Okay. He made payments to people that were working
8 under him?
9 A. Yes.
10 Q. Such as yourself?
11 A. Correct.
12 Q. My client, and anyone else; is that correct?
13 A. Yes.
14 Q. Okay. And he paid in cash, right?
15 A. Yes, he did.
16 Q. Okay. So I want to talk a minute, going back to the
17 timeline of your arrest and everything. I want you to refocus
18 back on March 2019 when you were arrested in Delaware.
19 The circumstances of that arrest were that you were
20 trying to get a package from a home and the homeowner -- you and
21 the homeowner had some sort of interaction; is that fair to say?
22 A. Yes.
23 Q. And then the homeowner called police and the police
24 showed up. The police showed up to the scene.
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 81
1 Q. And you were subsequently arrested.
2 A. Yes.
3 Q. Okay. You gave a statement to the police at the time
4 that wasn't true, right? About what was in the contents of the
5 package and that it was your package?
6 A. Yes.
7 Q. Okay.
8 A. Correct.
9 Q. But that wasn't true, was it?
10 A. It was not true.
11 Q. Okay. And then you were arrested on the scene; is
12 that right?
13 A. Yes.
14 Q. And were brought to jail in Delaware.
15 A. Yes.
16 Q. Okay. I'd like to draw your attention to Government's
17 39, please.
18 MR. GUILLAUME: Court's brief indulgence.
19 THE COURT: Certainly.
20 BY MR. GUILLAUME:
21 Q. Sir, if you could just listen to this call. I'm going
22 to ask you to listen to a few seconds of it. I'm going to stop
23 and then I'm going to ask you some more questions and then I'm
24 asking to ask you about it again, okay?
25 Could I have Government's 39, please.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 82
1 (Phone call was played.)
2 BY MR. GUILLAUME:
3 Q. Sir, do you recognize the voices of that recording?
4 A. Yes.
5 Q. Who -- who is talking?
6 A. Me and the mother of my son.
7 Q. Okay. And her name is -- you've already said Tequila,
8 right?
9 A. Yes.
10 Q. If we could continue with Government's 39 for a few
11 moments.
12 (Phone call played.)
13 Q. Sir, that's, in fact, the call was made the day were
14 you arrested; is that true?
15 A. Yes.
16 Q. Okay. And you're looking for someone to bail you out
17 of jail, right?
18 A. Yes.
19 Q. It's fair to say you did not like being there.
20 A. Yes.
21 Q. Where you were at the time.
22 A. Correct.
23 Q. And you asked your girlfriend, whose I guess the
24 mother of your child.
25 A. Correct.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 83
1 Q. You asked her to call my client; is that correct?
2 A. Yes.
3 Q. Because he's your friend, right?
4 A. Yes.
5 Q. You've known him a long time.
6 A. Yes.
7 Q. Right. And you trust him.
8 A. At the time, yes.
9 Q. Now, sir, your girlfriend at that time did not know
10 you had this other relationship in Baltimore with Ms. Norel, did
11 she?
12 A. No.
13 Q. And she -- does she know now?
14 A. Yes.
15 Q. Okay. So you're not with Ms. Norel anymore you're
16 with your child's mother?
17 A. No. Neither.
18 Q. Okay. So you were in a relationship, long distance,
19 but had another relationship at the same time during that time;
20 is that correct?
21 A. Yes.
22 Q. And you would stay in on the East Coast, Northeast --
23 I'm going to refer to Maryland on up as the Northeast,
24 Mid-Atlantic, for weeks and months at a time during -- from that
25 timeframe of say September 2018 to March of 2019 when that call
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 84
1 was made; is that correct?
2 A. Correct.
3 Q. Okay. And, in fact, you were released from custody in
4 Delaware; is that right?
5 A. Yes.
6 Q. And there was -- as Mr. Delaney said a moment ago, it
7 was a state charge, right?
8 A. Yes, it was.
9 Q. You were not charged federally?
10 A. I wasn't.
11 Q. But eventually you were charged federally; is that
12 correct?
13 A. Yes, I was.
14 Q. Do you remember the timing of that? Would that have
15 been December of 2019 when you got -- learned you had a warrant
16 for your arrest in federal court?
17 A. Yes.
18 Q. Okay. Do you remember being notified by the FBI that
19 you had to turn yourself in?
20 A. Yes.
21 Q. And that would have -- I know you probably don't
22 remember the approximate date, but you didn't turn yourself in
23 immediately, did you.
24 A. Say again.
25 Q. I know you probably don't remember the exact date of
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 85
1 when that call was or when you received that information about
2 your arrest, but you did not turn yourself in immediately,
3 correct?
4 A. Correct.
5 Q. I want to say at least three to four days passed
6 before you actually turned yourself in, right?
7 A. Yes.
8 Q. And that's not because the FBI said you could take
9 that long, that's just how long it took you to turn yourself in;
10 is that right?
11 A. Yes.
12 Q. So you are arrested eventually, and you have federal
13 charges. You haven't been convicted of anything at that point,
14 you haven't pled guilty to anything at that point immediately
15 after, the month or so after you got charged federally, right?
16 A. Can you rephrase?
17 Q. Yes, that was a poorly phrased question. I'm going to
18 take it step by step.
19 When you got charged federally, the charges stemmed
20 from what you did in this part of the country; is that correct?
21 As well as in other parts but primarily here, correct?
22 A. And you're talking about federal charge?
23 Q. Here in Maryland. I'm sorry.
24 A. Yes.
25 Q. Okay. So presumably you were -- you had a lawyer
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 86
1 representing you on those federal charges in Maryland, right?
2 A. I'm not understanding.
3 Q. Did you get a lawyer once you got the charges in
4 federal court?
5 A. In this -- I'm just trying to understand the time.
6 Are you talking about after I was arrested federally in Florida?
7 Q. Right.
8 A. Because I turned myself in in Florida.
9 Q. Right.
10 A. And after a certain amount of time I was transferred
11 up here.
12 Q. Right. And you got a lawyer when you got here, right?
13 A. Yes.
14 Q. You've always had a lawyer representing you since
15 you've been in federal court in Maryland. I know were you
16 physically located in Florida at the time of the arrest warrant,
17 but you were brought back here, as you said, and you always had
18 a lawyer at all stages, correct?
19 A. As far as the federal charges, yes.
20 Q. Right. Only talking about the federal charges.
21 A. Okay.
22 Q. Right. And sometimes, shortly thereafter, you decided
23 to speak with the government, the prosecutor in this case; is
24 that correct?
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 87
1 Q. Okay. You spoke with them a number of times, right?
2 A. Yes.
3 Q. First time would have been March of 2020; does that
4 sound about right?
5 A. Yes.
6 Q. Okay. And at that meeting you -- I'm presuming your
7 lawyer attended the meeting, is that correct, with you?
8 A. Yes.
9 Q. And you gave information about yours and other peoples
10 involvement in the package pick up case, correct?
11 A. Yes.
12 Q. Okay. And, in fact, you Mr. Delaney asked you about
13 what's called a minimization. You said you minimized my
14 client's role, or weren't completely truthful about his
15 participation during that first meeting, or during a meeting. I
16 don't know if it was the first or the second, but at some point
17 that is true, correct?
18 A. You're asking me if during the first meeting or the
19 meetings that -- where I minimized his involvement?
20 Q. Correct.
21 A. Yeah, I did. Yes.
22 Q. Okay. Because at that time my client was not charged
23 with any federal crime, correct?
24 A. Correct.
25 Q. Okay.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 88
1 A. Not to my knowledge, but yeah.
2 Q. Not to your knowledge at that time. In fact, you had
3 maintained communication with him after you got arrested, right?
4 A. Yeah.
5 Q. Federally.
6 A. For a short time, yes.
7 Q. And you let him know, hey, I have this charges and
8 here's what I'm considering doing. You had these discussions
9 with him, correct?
10 A. Honestly I don't remember. I'm trying to figure out
11 what you're asking me. You're asking me if I had conversations
12 about what I would do?
13 Q. Let me ask it to you this way. Without saying what
14 you were going to do or not going to do, after you received your
15 federal charges in Maryland you still talked to my client, your
16 friend, right?
17 A. Yes.
18 Q. Okay. And you met with the government in March of
19 2020, and then you met with them again a few months later, would
20 that have been October of that same year? October of 2020, does
21 that sound right?
22 A. Yes.
23 Q. Okay. And you gave information both times as to yours
24 and other people's involvement.
25 A. Correct.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 89
1 Q. And when asked on direct examination about why you did
2 certain things, why you pled guilty, I think that was the
3 question, or a similar type of question, your response was you
4 owed it to your family; is that right?
5 A. And myself, yes.
6 Q. Right, and yourself. Because obviously, Mr. Green,
7 you don't want to go to jail for any long period of time or any
8 time; is that correct?
9 A. You could say that, yes.
10 Q. All right. And some time thereafter you entered into
11 an agreement to plead guilty, right?
12 A. Yes.
13 Q. Now, you've -- again, you've had a lawyer the entire
14 time, there's been no break with you and your lawyer. You've
15 been represented since those -- during those meetings and since,
16 correct?
17 A. Yes.
18 Q. So you had the advice of counsel at every stage,
19 right?
20 A. Yes.
21 Q. Right. So you pled guilty to certain crime as we saw,
22 and I'll reference your plea agreement in a moment, but you
23 also, in addition to pleading guilty, agree to cooperate with
24 the government; is that right?
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 90
1 Q. Become a government witness, correct?
2 A. Yes.
3 Q. And as Mr. Delaney pointed out to you, there's certain
4 requirements that had to be met. Most importantly that have you
5 to tell the truth, right?
6 A. Yes.
7 Q. Right. And your understanding as you testified to, is
8 that the judge determines what, if any, sentence reduction
9 you'll receive, right?
10 A. Yes.
11 Q. And -- but the judge can't do anything without the
12 government approval; is that correct? Is that your
13 understanding? The government has to make the recommendation.
14 A. Correct. Yes.
15 Q. Okay. And Mr. Green, you met the government in an
16 interview setting approximately three on four times. Does that
17 sound about right?
18 A. Yes.
19 Q. Okay. Recently, in preparation for this case I'm
20 sure, and then back -- back in 2020?
21 A. Yes.
22 Q. Okay. And you did not testify in front of a grand
23 jury; is that correct?
24 A. No, I did not.
25 Q. Okay. So once you were arrested in March of 2019 in
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 91
1 Delaware, you have a few months before you're charged federally,
2 you're not incarcerated during that time, correct?
3 A. Correct.
4 Q. You're back living in Florida, right?
5 A. Yes.
6 Q. Did you ever return back up north after that time?
7 A. After I was arrested?
8 Q. Right.
9 A. No.
10 Q. You stayed down in Florida?
11 A. I stayed down in Florida.
12 Q. And while you're in Florida are you working?
13 A. Yes.
14 Q. Okay. And then you get a call from the FBI saying
15 that there's been a warrant -- there is a warrant for your
16 arrest; is that right?
17 A. Yes.
18 Q. Now, if we can pull up --
19 MR. GUILLAUME: Court's brief indulgence.
20 BY MR. GUILLAUME:
21 Q. -- Government's Exhibit No. 10. Okay.
22 Sir, I'm showing you for the record what's marked as
23 Government's Exhibit 10. And you recognize this document?
24 A. Yes.
25 Q. This, in fact, is the plea agreement that you entered
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 92
1 into with the government, correct?
2 A. Yes.
3 Q. It's got a lot of different pages. This is the cover
4 page, right?
5 A. Yes.
6 Q. And I'd like to go to the second page, please.
7 Mr. Kerrigan, can you, on the count in that box there, can you
8 enlarge that, please? For the count, the statute and
9 everything.
10 This document explains a number of things. One of
11 which is the potential maximum prison time you will face in this
12 case; is that correct?
13 A. Correct.
14 Q. And sir, what is your understanding as to the maximum
15 time by law that could be imposed in this case?
16 A. Twenty years.
17 Q. Okay. And that's noticed right here in the agreement;
18 is that correct?
19 A. Yes.
20 Q. Okay. Thank you. You can take that down. Thank you.
21 Sir, I want to talk to you about your trips that
22 you've testified to and get into a little bit more detail if I
23 could. Your first time traveling to this area was in September
24 of 2018, correct?
25 A. Yes.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 93
1 Q. And you flew to BWI but you did not work in Baltimore,
2 you worked in D.C.; is that right?
3 A. That's right.
4 Q. Okay. And actually, I'm sorry, before we talk about
5 that I want to just clarify something. That first package that
6 you did in Florida, that you testified about in your
7 grandmother's neighborhood.
8 A. Yes. What about it?
9 Q. That day, when you got that package and you didn't get
10 the money that you were supposed to, you met with Zo and then
11 Jay as well, right? Or just with Jay?
12 A. Are you asking me if that day when I received the
13 package if I met with Zo and Jay. Yes, I met Zo earlier and Jay
14 later, yes.
15 Q. And the purpose of meeting Zo was to just tell him
16 that it had been completed?
17 A. Wait. Yeah, from him my understanding he wanted to
18 confirm the package.
19 Q. Okay. So Zo was -- was Zo on the same level as Jay?
20 A. From what I observed, yes.
21 Q. So Zo and Jay wasn't like you, my client, or other
22 people like Keion and Lambert, right?
23 A. Right.
24 Q. Zo was on a different level. So I'm sorry. Going
25 back to -- going back to the trip to D.C. And that's when you
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 94
1 met for the first time Amaya English; is that right?
2 A. Yes.
3 Q. And she actually, you learned, was Jay's girlfriend;
4 is that right?
5 A. Yes.
6 Q. And he was very protective of her, wasn't he?
7 A. Yes, I could say that. Yes.
8 Q. He didn't like her talking to other men, things like
9 that. Controlling is the word I'm going to use, would you agree
10 to that?
11 A. Yeah, I could agree to that.
12 Q. But Amaya was the one giving out orders in D.C.; is
13 that correct?
14 A. Yes.
15 Q. She gave instructions to both you and my client,
16 right?
17 A. Yes.
18 Q. And you were to inform Amaya or Jay when you picked up
19 packages, correct?
20 A. Yes.
21 Q. Okay. And my client did the same, right?
22 A. Yes.
23 Q. Okay. And I just want to get into a little bit about
24 this application you talked about, Wickr. It's an application
25 that could be downloaded on a phone, like on a smart phone; is
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 95
1 that right?
2 A. Yes.
3 Q. But it's a secure application, is it not?
4 A. Meaning?
5 Q. Secure meaning that it's encrypted. Do you known
6 whether it's encrypted?
7 A. No.
8 Q. Well, I'll ask you this question this way. What did
9 you understand Wickr's capabilities to be and why did you use
10 it?
11 A. Initially, I didn't -- I never heard of it. I was
12 told to use it by Eghosah because that after a certain amount of
13 time the messages would delete themselves.
14 Q. And did you, in fact, use it?
15 A. Yes, I did.
16 Q. And was that true, did the messages delete themselves
17 that you sent?
18 A. Yes, they did.
19 Q. When you were charged in this case and began
20 cooperating with the government, did you ever voluntarily turn
21 your phone over at any time to them, to the government?
22 A. Yes.
23 Q. And going back to the D.C., the time you were here in
24 D.C. You said you're here three to seven days, more or less
25 that first time?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 96
1 A. Yes.
2 Q. And how much money did you make, can you remember?
3 A. After leaving D.C. I received $1,500. Just before
4 leaving D.C. I received $1,500.
5 Q. From Jay?
6 A. From Jay.
7 Q. Okay. And he gave that to you personally, put the
8 money in your hand.
9 A. Yes.
10 Q. Okay. And then you continued to work up until the
11 time that you were arrested in Delaware, right?
12 A. Yes.
13 Q. Now, when you were -- when you would come back from
14 Florida you would stay for varying times; is that correct? From
15 a month to a week, it just depends, right?
16 A. Yes.
17 Q. And my client wasn't always with you; is that right?
18 He wasn't always here the same time you were here.
19 A. Correct.
20 Q. And the typical work week for you when you were
21 working, what was it?
22 A. Are you --
23 Q. What days would you work?
24 A. Are you referring to the packages?
25 Q. Correct.
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 97
1 A. Tuesday to Saturday, if I'm remembering correctly.
2 Q. Okay. So basically Tuesday to Saturday is then you
3 did the bulk of the work?
4 A. Right.
5 Q. And you said there were times when my client was not
6 with you, you guys weren't together. You were working and he --
7 you were working somewhere, he could be wherever, you don't know
8 where he is; is that right?
9 A. Yes.
10 Q. Okay. You testified about going to New York. How
11 many times total would you say you went to New York?
12 A. In general, just going to New York?
13 Q. Going to New York as part of this operation. Sorry,
14 let me be very specific.
15 A. I want to say anywhere from like -- anywhere between 5
16 to 10 times.
17 Q. And are these times that you went into different
18 buildings those five to ten times, or just that you were present
19 in New York in connection with this, one way are the other?
20 A. The latter.
21 Q. The latter being you weren't always going inside the
22 building?
23 A. I didn't always go inside the building, no.
24 Q. How many times did you go inside the building during
25 those ten times?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 98
1 A. Maybe five times. Four or five times.
2 Q. And isn't it true that you always go into the building
3 by yourself, never with someone else; is that right?
4 A. No, it wasn't always like that.
5 Q. Sometimes you went in --
6 A. Sometimes I would go in by myself, sometimes I was
7 accompanying someone else.
8 Q. Okay. And going back to this, there's rules that you
9 became aware of pretty early on when you started working this
10 operation, right?
11 A. Yes.
12 Q. That you had to follow.
13 A. Yes.
14 Q. Now, you've written a lot of notes, and those are
15 notes that were written in your personal phone; is that right?
16 A. Yes.
17 Q. And you wrote those notes to yourself, so essentially
18 you could keep track of monies that you were owed?
19 A. Yes.
20 Q. Okay. And some of those notes you wrote were
21 addresses that you were scouting out to provide to Jay, right?
22 A. Yes.
23 Q. Now, Jay would take addresses -- actually, Jay paid
24 people more money if they could gave him addresses to use; is
25 that right?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 99
1 A. Yes.
2 Q. Okay. And so anybody could do it but -- and it was
3 always given -- the information was always given to Jay. Any of
4 the workers could do it is what I'm saying.
5 A. Yes.
6 Q. And during your time with this package pick up stuff,
7 there were lots of different people who would come and go, some
8 of whom you knew and some of whom you didn't know; is that
9 correct?
10 A. Yes.
11 Q. And during the actual pick ups of packages, isn't it
12 true that Jay sometimes would sent multiple people to the same
13 location to have coverage for that particular package?
14 A. I don't understand what -- sorry. You're asking me --
15 Q. I'll rephrase the question. I'll ask it a different
16 way. When you received information from Jay about where to
17 go --
18 A. Right.
19 Q. -- to your knowledge, do you know if Jay would provide
20 that information it, that same pick up information to multiple
21 different persons?
22 A. By saying -- you mean the same address?
23 Q. The same address, correct.
24 A. No. To my knowledge, no, I don't remember.
25 Q. So it was one person, as far as you know, one person
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 100
1 for each location?
2 A. Yes.
3 Q. Okay. And there were times when you -- there were
4 times though when were you not by yourself, is that correct,
5 when you picked up packages?
6 A. Yes.
7 Q. Now, going back to kind of the structure of things,
8 there was a rule that you learned early on that was not to open
9 the packages correct?
10 A. Correct.
11 Q. And that came from Jay and Amaya, right?
12 A. Yes.
13 Q. And Zo -- did Zo also let that be known to you as
14 well?
15 A. Yes.
16 Q. So you didn't -- you obeyed that order, right?
17 A. Yes.
18 Q. And you never saw anyone of the people on your level
19 disobeying the order, particularly my client, right?
20 A. Yes.
21 Q. Now, the packages that came, when you first got
22 involved with this, they were in varying sizes, correct? Some
23 small, some large?
24 A. Yes.
25 Q. And they all weighed -- they would weigh presumably
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 101
1 different amounts, like the actual weight of the packages.
2 A. Yes.
3 Q. And you also turned those packages over to Jay; is
4 that right?
5 A. I wouldn't always to Jay, but for the most part, Jay.
6 Amaya.
7 Q. Now, you never called anyone pretending to be somebody
8 else, did you?
9 A. No, I did not.
10 Q. You never witnessed my client calling anyone,
11 pretending to be anybody else?
12 A. No, I did not.
13 Q. Did you ever see anybody calling and pretending to be
14 anybody else that you worked ed with at the time?
15 A. No, I did not.
16 Q. Okay. And when you communicated with Jay would it be
17 regular text message, Wickr, or both?
18 A. Wickr.
19 Q. Okay. So always on Wickr with Jay.
20 A. Always on Wickr with Jay.
21 Q. But when you communicated with my client wasn't with
22 exclusively through Wickr; is that right?
23 A. Correct.
24 Q. Because you guys have known each other for a really
25 long time, correct?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 102
1 A. Correct.
2 Q. Okay. And during the course of your time working,
3 isn't it true that you came to understand that Jay had people
4 above him; is that correct?
5 A. It wasn't confirmed, it was more of a theory, but we
6 kind of just -- drew that conclusion, yes.
7 Q. The workers drew that conclusion. Or you drew that
8 conclusion.
9 A. Yeah.
10 Q. Okay.
11 MR. GUILLAUME: Court's brief indulgence.
12 THE COURT: Take your time.
13 BY MR. GUILLAUME:
14 Q. Sir, are you aware of when my client was, in fact,
15 charged federally in connection with this case, if you're aware?
16 A. No. I don't know when. I don't know when. Is that
17 what you're asking me?
18 Q. You don't know when?
19 A. I don't know the when.
20 Q. Okay. But you know it was after you were, correct?
21 A. Yes.
22 Q. Okay. And sir, I just want to make one thing very
23 clear, I want to understand. None of the other people that were
24 in the home, or the places that you stayed during the course of
25 your employment with the this operation, none of those other
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 103
1 people talked about the source of -- or what was in the
2 packages, and if they did know money was there the source of the
3 money. So that's actually two different questions there but --
4 A. Okay. So no one spoke about it.
5 Q. Nobody.
6 A. Nobody spoke about it.
7 Q. So you were shown a message -- I think is Government's
8 Exhibit 28. If you could pull that up, please -- of an address.
9 Is this the one with the address in New York? 25, I'm sorry.
10 Mr. Kerrigan, can we highlight the address in the blue, please.
11 Oops.
12 Sir, this is something that you were shown on direct
13 examination --
14 THE COURT: What exhibit is this?
15 MR. GUILLAUME: I'm sorry. This is Government Exhibit
16 28.
17 THE COURT: All right. Thank you.
18 BY MR. GUILLAUME:
19 Q. This is an address that was shown to you by
20 Mr. Delaney a few moments ago and you mentioned that the suite
21 number was, I belive the word you used, throwing you off or
22 threw you off?
23 A. Yes.
24 Q. Okay. You testified that you went to the 13th floor
25 of a building in New York?
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 104
1 A. Yes.
2 Q. And that was always the same location?
3 A. Yes, it was always the 13th floor.
4 Q. Okay. And this location here is not the location; is
5 that correct?
6 A. Yeah. I believe -- correct.
7 Q. It's not. Okay. And the suite number is definitely
8 not on the 13th floor, according to what's listed here; is that
9 right?
10 A. Correct.
11 Q. Thank you. I don't need to see it anymore. Thank
12 you.
13 Sir, how soon did you start opening packages in this
14 operation? If you started in September, when is the first time
15 you're opening a package and doing like you did -- that we saw
16 in the video? When does that happen?
17 A. I don't remember the actual date or time, the specific
18 time.
19 Q. Would it have been immediately upon working, or would
20 it have been working a few months or --
21 A. It was a couple months.
22 Q. It was a couple as in two or--
23 A. Yeah, two months. Two maybe.
24 Q. And sir, just a couple more questions. With respect
25 to the trip that you testified to about in Philadelphia and New
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EXCERPT OF DAVID GREEN - CROSS-EXAMINATION 105
1 Jersey, the Philadelphia trip, do you remember if Raven was
2 present during that trip? An individual by the name of Raven?
3 She also working in -- working during that trip as part of this
4 package scheme?
5 A. That name sounds a familiar.
6 Q. Is Raven a friend of yours?
7 A. No.
8 Q. In New Jersey there's Mr. Delaney mentioned someone by
9 the name Sooraji. And you said that you understood that Jay had
10 brought that person into the -- into the package organization;
11 is that right?
12 A. Yes.
13 Q. Okay. But Sooraji did not work out; is that right?
14 A. Yes.
15 Q. He didn't work out because he you didn't get along
16 with lots of people; is that correct?
17 A. Correct.
18 Q. Including you and including my client, right?
19 A. Yes.
20 Q. In New Jersey you talked about the fact that
21 Charlemagne or Zo took over for Jay; is that correct?
22 A. Correct.
23 Q. All right. And that Jay was missing for awhile; is
24 that right?
25 A. He was -- Jay -- this is -- I'm a little confused on
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EXCERPT OF DAVID GREEN - REDIRECT EXAMINATION 106
1 the timeframe in which you're asking it.
2 Q. I'll withdraw that question and just say -- ask it
3 this way. And this will my last question, or one of my last
4 questions, it's not my last.
5 THE COURT: It's always dangerous to say that, Mr.
6 Guillaume.
7 MR. GUILLAUME: Yes, that's why I corrected myself.
8 BY MR. GUILLAUME:
9 Q. With respect to Charlemagne taking over, I want you to
10 just -- I just want to narrow in on the fact that what that
11 means. That means, I'm assuming, that you then reported to him
12 as opposed to Jay, and he took over the things like paying
13 people and that sort of stuff; is that right?
14 A. Yes.
15 Q. Okay. Thank you.
16 MR. GUILLAUME: No further questions.
17 THE COURT: Thank you very much, Mr. Guillaume.
18 Any redirect are, Mr. Delaney?
19 MR. DELANEY: Yes, Your Honor. And I think we can
20 finish it before the lunch break.
21 THE COURT: That's fine.
22 REDIRECT EXAMINATION
23 BY MR. DELANEY:
24 Q. Mr. Green, you were asked on cross-examination if you
25 wanted to go to jail. The answer to that is?
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EXCERPT OF DAVID GREEN - REDIRECT EXAMINATION 107
1 A. No.
2 Q. No. Does the government make the decision if you go
3 to jail or not at the end of this?
4 A. No, they don't.
5 Q. Who make the determination?
6 A. The judge.
7 Q. You were asked, as far as you know, whether the money
8 prior to February 2019, if the money in the package could have
9 come from, quote, any source. And you testified on direct that
10 you didn't ask what was in the package, right?
11 A. Correct.
12 Q. Why?
13 A. Because I knew it wasn't legal. It wasn't aboveboard.
14 Q. And this you were given instructions prior to February
15 2019 about the contents of the package, right?
16 A. Yes.
17 Q. Prior to you being given the ability to open the
18 package, what were the instructions given to the people about
19 the contents of the package?
20 A. To not open the package.
21 Q. You testified on direct that you and Eghosah were
22 ultimately allowed to open the package; is that right?
23 A. Yes.
24 Q. What about Keion? Did Keion get to open the package?
25 A. No.
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EXCERPT OF DAVID GREEN - REDIRECT EXAMINATION 108
1 Q. What about Sooraji? Did Sooraji get to open the
2 package?
3 A. No.
4 Q. What about Mikey Lambert, did he?
5 A. No.
6 Q. You were asked a question about when Eghosah was
7 released from custody, whether it was February or March to get
8 the timing down, right?
9 A. Right.
10 Q. Let's go to Government's Exhibit 25, page 11. Pulling
11 up this. The statement from that, I believe you testified, is
12 from Keiarah. What is it?
13 A. Released. He called me.
14 Q. And your response?
15 A. Yeah, Jay told me.
16 Q. The date?
17 A. February 10th, 2019.
18 Q. Thank you.
19 Putting up Government's Exhibit 27.
20 Is that a communication between you and Ghose?
21 Turning to page 2.
22 What are these series of numbers and letters?
23 A. A tracking number.
24 Q. And the date?
25 A. March 23rd, 2019.
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EXCERPT OF DAVID GREEN - REDIRECT EXAMINATION 109
1 Q. Thank you. You were asked some questions about where
2 Ghose's wife was from; is that right?
3 A. I'm sorry, excuse me?
4 Q. You were asked about some questions about where the
5 defendant's wife was from?
6 A. Yes.
7 Q. And you testified that she was from the area --
8 A. Yes.
9 Q. -- generally?
10 When you traveled with the defendant to the
11 Baltimore-D.C. area, did you travel here to visit his wife or
12 then girlfriend?
13 A. No.
14 Q. What was the purpose of your travels with the
15 defendant to this area?
16 A. To retrieve packages. To continue to retrieve
17 packages.
18 Q. Government's Exhibit 28, page 5. Let's look at the --
19 let's look at the date of these conversations. What is the
20 date?
21 A. March 25th, 2019.
22 Q. Do you know what happened the day after this? Do you
23 remember?
24 A. I believe this is the time I was arrested.
25 Q. Okay. What -- what were you texting about here the
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1 day before you were arrested with the defendant? Regardless of
2 the specific location, what was this -- what were these text
3 about?
4 A. A drop.
5 Q. What kind of drop?
6 A. The drop for -- the drop of the money.
7 Q. The money from the scheme?
8 A. The money from the scheme, yes.
9 MR. DELANEY: Nothing further, Your Honor.
10 THE COURT: Thank you very much, Mr. Delaney. There's
11 no recross, is there Mr. Guillaume?
12 MR. GUILLAUME: Court's brief indulgence, Your Honor.
13 THE COURT: Okay. Sure.
14 MR. GUILLAUME: No further questions. Thank you.
15 THE COURT: All right. Thank you very much.
16 Mr. Green, you may step down, sir. You should not
17 discuss your testimony with anyone until this trial concludes in
18 the event you're called back to the witness stand. And there is
19 a sequestration order. So you should not be discussing your
20 testimony with anyone until this case is over.
21 THE WITNESS: Okay.
22 THE COURT: Thank you very much. You're excused.
23 THE WITNESS: Thank you.
24 (Mr. Green was excused at 1:09 p.m.)
25 THE COURT: With that, we'll take our lunch recess.
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1 It's now ten after one. We'll break for lunch until ten minutes
2 after two, and we'll start promptly with the third government
3 witness promptly ten after two.
4 Thank you very much.
5 THE CLERK: All rise. This Court stands in recess.
6 (Jury out at 1:09 p.m.)
7 (RECESS was taken at 1:10 - 2:21 p.m.)
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1 THE COURT: Thank you all for our quick break here in
2 the afternoon. And we'll be going right up to five o'clock. But
3 at five o'clock on the dime we'll stop at five o'clock.
4 With that, you all may be seated. And Ms. Goo, the
5 next government witness.
6 MS. GOO: Yes, Your Honor. The government calls to the
7 stand McArnold Charlemagne.
8 THE COURT: All right.
9 Mr. Charlemagne, if you'll come over here to be sworn.
10 (MCARNOLD CHARLEMAGNE, duly sworn.)
11 THE CLERK: Speaking clearly into the microphone can
12 you please state your full name and spell your last name for the
13 record.
14 THE WITNESS: My name is McArnold Charlemagne.
15 Charlemagne, C-h-a-r-l-e-m-a-g-n-e.
16 THE CLERK: Thank you.
17 THE COURT: Thank you, Mr. Charlemagne. If you'll
18 keep your voice up and speak clearly into the microphone for
19 purposes of the court reporter, Ms. McPherson.
20 And Ms. Goo, you may proceed.
21 MS. GOO: Thank you, Your Honor.
22 DIRECT EXAMINATION
23 BY MS. GOO:
24 Q. Good afternoon, Mr. Charlemagne.
25 A. Good afternoon.
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1 Q. Mr. Charlemagne, and again if you just keep your voice
2 up and speak slowly that would be that would help tremendously.
3 A. Yes. Yes.
4 Q. Thank you. Now, Mr. Charlemagne, where do you
5 currently live?
6 A. 2240 --
7 Q. No, no. Just the city and state that you live.
8 A. Miramar, Florida.
9 THE COURT: I beg your pardon, what did you say?
10 THE WITNESS: Miramar, Florida. The state Florida.
11 THE COURT: Okay. Thank you.
12 THE WITNESS: Yes.
13 BY MS. GOO:
14 Q. How long have you lived in Florida for?
15 A. Almost 20 years.
16 Q. Did there come a point in time in which you became
17 involved in a package scheme?
18 A. Yes.
19 Q. And as a result of your participation in that scheme,
20 were you charged federally here in the United States District
21 Court in the District of Maryland?
22 A. Yes.
23 Q. And are you represented by Mr. Paul Kramer?
24 A. Yes.
25 Q. And is -- as a part of your case did there come a
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1 point in time in which you reached a plea agreement?
2 A. Yes.
3 Q. So did you plead guilty to the charges here in this
4 courthouse?
5 A. Yes, I did. Yes.
6 Q. If we could bring up Government's Exhibit 55.
7 So Mr. Charlemagne, directing your attention to the
8 screen in front of you, Government's Exhibit 55. Have you seen
9 this document before?
10 A. Yes.
11 Q. And what is it?
12 A. It's my guilty plea basically, yes.
13 Q. Okay. So if we could zoom in to paragraph 1.
14 And Mr. Charlemagne, if you could just read that first
15 paragraph.
16 A. The Defendant agrees to plead guilty to Count One of
17 the Indictment, which charge the Defendant with conspiracy to
18 commit mail fraud, in violation of 18 U.S.C. 1349.
19 Q. Okay. And you can stop there for now.
20 So Mr. Charlemagne, you pled guilty to the conspiracy
21 to commit mail fraud; is that correct?
22 A. Yes.
23 Q. If we could turn to page 9 of the document. And I'm
24 sorry, one page back please. All right. Now, on page -- and I
25 apologize, that's page 8. Do you see the signature in the
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1 middle?
2 A. Yes.
3 Q. And whose signature is that?
4 A. That's my signature.
5 Q. Okay. And the signature below that is whose?
6 A. Mr. Kramer. Paul Kramer, yes.
7 Q. And so you've had an opportunity to review this
8 agreement with Mr. Kramer; is that correct?
9 A. Yes.
10 Q. Okay. And if we could go to -- I believe it's page 10
11 of this. Page 11, please. 12. Okay.
12 Now, directing your attention to page 12 of this
13 exhibit title Sealed Supplement to Plea Agreement. Have you had
14 a chance to review this sealed supplement with Mr. Kramer as
15 well?
16 A. Yes.
17 Q. And does this summarize, essentially, your cooperation
18 with the government?
19 A. Yes.
20 Q. And what is your understanding as to what you're
21 required to do pursuant to this agreement?
22 A. To tell the truth about what I've done.
23 Q. Okay.
24 A. Yes.
25 Q. And is it your understanding that you're to cooperate
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1 fully with federal law enforcement in terms of telling the
2 truth?
3 A. Yes.
4 Q. Okay. Now, we've talked a bit about this agreement
5 previously, correct?
6 A. Yes.
7 Q. And in that conversation has there been any specific
8 promise made to you about a specific sentence recommendation
9 that I or Mr. Delaney is going to make at the conclusion of your
10 case?
11 A. No.
12 Q. Have you been sentenced yet in your case?
13 A. No.
14 Q. Okay. And what is your understanding as to who will
15 determine your sentence?
16 A. I guess -- I don't know if it's this judge, but the
17 judge. The judge, yeah.
18 Q. Okay. All right. And what is your understanding as
19 to what the government, so me and Mr. Delaney, what we're going
20 to do at the conclusion of your testimony?
21 A. I'm sorry?
22 Q. So once you're done testifying in this case --
23 A. Yes.
24 Q. -- what is your understanding as to what me and Mr.
25 Delaney are going to do for you?
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1 A. I don't -- I mean, I guess -- I mean, I don't know. I
2 don't know basically.
3 Q. Okay. Is it your understanding that perhaps we're
4 going to share that information with the judge?
5 A. Yes.
6 Q. About what you did.
7 A. Yes. Yes.
8 Q. To detail whatever cooperation you provided.
9 A. Yes. I would hope, yes.
10 Q. All right. But again, no specific promise has been
11 made to you --
12 A. No.
13 Q. -- about what the sentence recommendation is going to
14 be, correct?
15 A. No. No.
16 Q. Now, let's talk about your involvement in that scheme.
17 How did you -- who introduced you to this package scheme?
18 A. Jay, but his name is Ulysse Medard, yes.
19 Q. Okay. And if we could show Government's Exhibit 11.
20 Do you recognize the person in Government's Exhibit
21 11?
22 A. Yes.
23 Q. Who is that?
24 A. That's Jay. That's -- yeah, Jay. Ulysse Medard, yes.
25 Q. And did you later learn that his name is -- I believe
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1 you said Ulysse Medard?
2 A. Yes. Ulysse Medard, yes.
3 Q. When did you meet him?
4 A. Oh, I would say end of 2018. 2018. The year '18,
5 yes.
6 Q. 2018 or was it --
7 A. Yes.
8 Q. Was it possibly 2017? I can show you a document to
9 hopefully refresh your recollection.
10 A. Please. Please, yeah. Please. I want to say -- no,
11 end of 2017, yes. 2017, yes.
12 Q. Where did you meet him?
13 A. In Miami.
14 Q. What did he tell you about an opportunity or the
15 scheme?
16 A. We was -- to help him basically with picking up
17 packages.
18 Q. And again, the he is who?
19 A. He is the --
20 Q. Sorry. The he that you're talking about, about
21 picking up the packages, who is the he?
22 A. I'm talking as far as Jay.
23 Q. Okay.
24 A. Yes.
25 Q. So Jay was giving this -- was asking you to help him
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1 in picking up packages?
2 A. Yes.
3 Q. Okay. What did he -- and where were you going to have
4 to do this?
5 A. We started in Miami.
6 Q. Okay. And what happened for the very first package in
7 Miami?
8 A. I waited, it did not came, and he paid me.
9 Q. And I'm sorry?
10 A. He paid me. Like he gave me money, yes.
11 Q. Okay. And this was Jay that paid you.
12 A. Yes, for the first one.
13 Q. So even though the package didn't arrive --
14 A. Yes.
15 Q. -- Jay gave you money.
16 A. Yes.
17 Q. How much money did Jay give you?
18 A. 100.
19 Q. Now, we're gonna get more details about the package
20 operation, but before we go there, was there a point in time in
21 which you were also involved with wire transfers?
22 A. Yes.
23 Q. Okay. And could you just talk briefly about what Jay
24 asked you to do with regard to wire transfers?
25 A. He would ask me to give him the account number and
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1 basically the information from my account. And then he would
2 wire the money afterwards.
3 Q. Okay. And did you have a bank account in January of
4 2018 with TD Bank?
5 A. Yes.
6 Q. Showing you Government's Exhibit 63. And if we could
7 zoom in on the bottom portion titled Other Credits.
8 Now, Mr. Charlemagne, do you recognize Government's
9 Exhibit with 33?
10 A. Yes.
11 Q. So what is it?
12 A. It's wire incoming Stanley Collins, 38,000.
13 Q. And whose account is this?
14 A. That's mine.
15 Q. Okay. Now, at the very -- so in this portion that's
16 been -- that's larger on the screen, January 17th, again, could
17 you just read that line into the record?
18 A. The first January 17?
19 Q. Yes.
20 A. Wire incoming, Stanley Collins.
21 Q. And what was the amount?
22 A. Amount? 38,000.
23 Q. Did you know Stanley Collins?
24 A. No.
25 Q. And did this wire occur after you had given your
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1 information to Jay?
2 A. Yes.
3 Q. What did you do with the funds from this wire that
4 came into your account?
5 A. I withdrew it and I give it to him.
6 Q. Did you receive anything from Jay after having done
7 this?
8 A. Yes. Yes.
9 Q. What did you receive?
10 A. I don't remember the amount, but he gave me something,
11 I would say, as part of it. I don't remember the amount but
12 yes.
13 Q. Okay. But you got something for the wire going into
14 your account?
15 A. Yes. Yes.
16 Q. Approximately how many times was your account used for
17 this purpose?
18 A. Two more times. And then I use only the friend of
19 mine to -- yes, so I would say three total.
20 Q. What if anything happened to your bank account?
21 A. Afterward, a couple days later, or even weeks, it got
22 I would say locked, frozen. It doesn't work anymore.
23 Q. So were you allowed to use your account at that point?
24 A. After that, no, I can't. It's closed.
25 Q. And just to be clear, you also provided the name of --
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1 did you provide the account of another friend was it you said?
2 A. Yes.
3 Q. Okay. And how long -- or how many times did Jay use
4 your other friend's account, if you recall?
5 A. I would say one time, because it was a business
6 account. Yes.
7 Q. I'm sorry?
8 A. One time. One time. It was a business account.
9 Q. Okay. You said business account?
10 A. Yes.
11 Q. All right. Now, so you're doing the package pick up
12 the one time, and then there's the wire transfers now a couple
13 of times.
14 A. Yes.
15 Q. And how long, just in general, did you work with Jay
16 for?
17 A. Beginning of 2019.
18 Q. Through the beginning of 2019?
19 A. Yes.
20 Q. Okay. So from the end of 2017 through the beginning
21 of 2019?
22 A. I have taken a break in between, and then -- because
23 the last time was in beginning of 2019, yes.
24 Q. Okay. So would it be fair to say a little bit more
25 than a year?
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1 A. Yes. Yes.
2 Q. So in the year or so that you're working with Jay, how
3 much of that was the wire transfers and how much of it was the
4 packages through the mail?
5 A. I'm --
6 Q. Let me ask a different question. Was most of the work
7 that you did with Jay the picking up the packages through the
8 mail?
9 A. Yes. Through the mail, yes.
10 Q. All right. Now, did you travel to other cities to
11 pick up packages?
12 A. Yes.
13 Q. Where did you travel to?
14 A. Traveled to Maryland, New Jersey. Yes.
15 Q. Okay.
16 A. And Washington, D.C. also. Say again?
17 Q. I'm sorry, what was that?
18 A. Washington, D.C. Yes.
19 Q. All right. Now, what was the first -- did you travel
20 with Jay?
21 A. The first time we went to D.C. We drove to D.C.
22 Q. And whose car did you take?
23 A. Jay's car.
24 Q. What kind of car was it?
25 A. It's a BMW X7 I believe.
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1 Q. Okay.
2 A. It's a white one.
3 Q. So just pausing there for a second. Did Jay have more
4 than one vehicle in the different cities?
5 A. When we travel, the first time, I think the first time
6 I think he has one car the first time, yeah.
7 Q. But in the course of the time that you new him and
8 worked with him, did he have different types of vehicles?
9 A. Oh, yes. Yes. I was allowed to have -- like every
10 members, we were allowed to have one car. I remember I have
11 one, I don't know if I can say member's name, but everyone was
12 allowed to have one car, yes.
13 Q. Okay. And did Jay drive expensive cars?
14 A. Yes. Yes. He had a Benz something. I don't remember
15 which one. He had a gray Benz I believe, yes.
16 Q. And when you say Benz, are you referring to Mercedes
17 Benz?
18 A. Yes, Mercedes Benz, yes.
19 Q. Now, when you were in the D.C.-Baltimore area, how
20 much would you get for picking up a package?
21 A. From 50 to $100.
22 Q. And where did you stay when you were in the
23 Baltimore-D.C. area that first trip?
24 A. The most of -- Motel 6 most of the time, yes.
25 Q. Okay. Showing you Government's Exhibit 137. If we
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1 could go to first page 8. I direct your attention to page 8 of
2 Government Exhibit 137. Do you see the name of the customer at
3 the top?
4 A. Name you said?
5 Q. Yes. Under the -- where it says guest folio.
6 A. Oh, yes. Yes. Yes. Sorry. Yes.
7 Q. And whose name is that?
8 A. That's my name.
9 Q. Who's Andre?
10 A. That's my middle name, and Charlemagne, yes, is my
11 last name.
12 Q. What is the check-in and check-out date for this day?
13 A. April 24th check-in. Check-out April 25th.
14 Q. And who were you with when you stayed at the Motel 6
15 at this time?
16 A. I guess me, I think Ego.
17 Q. Let me ask a different question. Were you traveling
18 with Jay at this point in time?
19 A. Yes. Yes.
20 Q. Okay. All right. If we go to the page 9. Okay. And
21 were there -- so actually, if we could actually go back to page
22 8.
23 Mr. Charlemagne, do you see what the room number is?
24 If you could zoom that it in.
25 A. You mean the 437?
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1 Q. Yes, so Room 437, okay. So that's for April 24th to
2 April 25th?
3 A. Yes.
4 Q. And if we go to the next page. And what is the room
5 number on page 9?
6 A. 439.
7 Q. So those are different rooms.
8 A. Yes.
9 Q. Did you reserve rooms for Jay under your name?
10 A. Not for Jay but for other people, yes.
11 Q. For other people?
12 A. Yes.
13 Q. Now, if we go to the next page. So this is page 10.
14 Again, if you can read the name into the record.
15 A. My name, Andre Charlemagne, yes.
16 Q. And what's the check-in and check-out date?
17 A. April 27 check-in, and April 28 check-out.
18 Q. And again, turning to the next page after that. And
19 again, if you could just read the room number in.
20 A. 329.
21 Q. Okay. So Mr. Charlemagne, is it again, two rooms for
22 the same date?
23 A. Yes. Yes.
24 Q. So is it fair to assume that you rented a room for
25 somebody else that was working with you?
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1 A. Yes.
2 Q. Now, did there come a point in time in which you did
3 meet someone by the name of Ego or Ghost?
4 A. Yes. Ego, yes.
5 Q. And what do you recall about how you first met him?
6 A. They sent a package to his place, to his house.
7 Q. Okay.
8 A. Then he gave it to his friend and there was some money
9 missing. And then Ego went and take care of it. And then he
10 bring the money back to Jay. And then -- yes.
11 Q. Okay. So how did you learn about this whole thing
12 about the package going to Ego's house and there was money
13 missing? Who gave you that information?
14 A. Okay. Jay sat with me, I don't remember the amount
15 but there was one thousand or two thousand missing. And then
16 Ego went in, I guess -- I think -- I don't assume, but somebody
17 took the money from the package. Ego then went and get the
18 money from that somebody. And then he gave the package to us
19 and that's how Jay knows about Ego and he was selling me about
20 Ego, yes.
21 Q. And so when -- again, this information you're getting
22 about this was from Jay?
23 A. Yes. Yes. Yes.
24 Q. Did Jay tell you about anything else Ego did once he
25 discovered that money was missing from the package?
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1 A. He, I would say pushed up -- he has a interaction,
2 like severe interaction with his mom. Because that's how -- I
3 believe the mom, I believe, took a part of the money. And Ego
4 has like, I would say rough up his mom to get the money and
5 bring it to Jay.
6 Q. When Jay was giving you this information about Ego,
7 how did Jay respond to the fact that Ego roughed up his own
8 mother to get the money back?
9 A. It's like he showed some kind of -- he will do
10 everything for the operation. It's like a trust thing. It's
11 like, you know what, he doesn't know us but he's willing to do
12 that for us. That's what we kind put it through to me.
13 Q. And is that when Ego started working with all of you?
14 A. Yes. I would say the following day, even the same
15 week he start working for us, yes.
16 Q. Showing you Government's Exhibit 57. Do you recognize
17 this photo?
18 A. Yes.
19 Q. And what is this a picture of?
20 A. It's a confirmation for the package.
21 Q. Now, if we could just zoom in on the receiver
22 information.
23 A. Yes.
24 Q. Now do you recognize that address?
25 A. 2645 -- yes.
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1 Q. And what address is that?
2 A. That's Ego's.
3 Q. And can you zoom back out. And can you just read the
4 name of sender there?
5 A. Say again? The sender?
6 Q. Read the name of the sender.
7 A. Martha Spark.
8 Q. And now if we could pull up Exhibit 56 at the same
9 time as 57. Okay.
10 And directing your attention to name of the shipper.
11 So it's the second row, if you could read that, please.
12 A. Martha Sparks, yes.
13 Q. And could you read the tracking number from
14 Government's Exhibit 57? So that's the screenshot, or the
15 picture of phone, could you read that tracking number?
16 A. 780834240315.
17 Q. And is that the same tracking number that's listed for
18 -- in the FedEx shipping information? If you could read the
19 FedEx that's right in front of you.
20 A. Yes. 780834240315. Yes. It is, yes.
21 Q. And what is the date of the delivery? So that's going
22 to be the -- circling it right for you now.
23 A. May 7, 2018.
24 Q. Okay. And again, what is the address?
25 A. 2645 Acapulco Drive.
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1 Q. And again, whose address is that?
2 A. That's Ego's address.
3 Q. So is this the package that was delivered to Ego's
4 house?
5 A. Yes.
6 Q. So after the package gets delivered to Ego's house,
7 that's, you said, when Ego started working with all of you?
8 A. The following day he starts -- we talk to him and he
9 start working with us, yes. Yes.
10 Q. Did you -- and when you first started working with
11 Ego, was it in Florida or was it somewhere else?
12 A. I can't recall. But --
13 Q. Actually --
14 A. I can't recall, but I know --
15 Q. That's fine. I'm going to direct your attention to
16 Government's Exhibit 58A. And if we could zoom in on the
17 passenger information and the flight information.
18 A. Yeah, that's mine. That's mine, my name.
19 Q. And if you could just read in the flight information.
20 So the date that this flight departed?
21 A. May 9, 2018.
22 Q. Okay. And --
23 A. Miami to --
24 Q. And it was departing from where?
25 A. From Miami to Baltimore, to BWI.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 131
1 Q. Okay. All right. And I'm going to fast forward a
2 little bit for you. If we could pull up Exhibit 58. So this is
3 -- that was your flight up to Baltimore; is that correct?
4 A. Yes.
5 Q. And again, I'm just going to just zoom in on the
6 flight information and passenger information. First, if you
7 could read the flight information, the date that the flight
8 left.
9 A. May 15, 2018.
10 Q. And it was departing from where?
11 A. From D.C. Air, that's Reagan thing to Miami airport,
12 yes.
13 Q. And who are the passenger on this flight?
14 A. Ulysse Medard. That's Ego. Christopher, that's
15 somebody that was working with us. And the last one is me,
16 McArnold, yes.
17 Q. So were all four of you in the D.C.-Baltimore area
18 working between that period of time prior to this flight
19 leaving?
20 A. Yes. Yes.
21 Q. Where did you stay again when were you up in Baltimore
22 this time?
23 A. I'm sure it's Motel 6.
24 Q. Showing you Government's Exhibit 137, page 12, okay.
25 Again, and who is the person that's associated with this
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 132
1 specific reservation?
2 A. That's mine. Mine. Yes.
3 Q. And what's the check-in and check-out date?
4 A. May 11, 2018, and May 13, 2018.
5 Q. So what were you, Ego, Jay and Chris doing on this
6 trip?
7 A. Picking up packages.
8 Q. Do you know how many?
9 A. Total or for the week?
10 Q. Like on average per day.
11 A. Per day? Each person, depending on the amount of
12 person with a pick up, on or two packages. So that week I say
13 if I pick up ten packages and Ego would pick up ten or so, then
14 Amaya, I believe, like there's a lot of people. So I would say
15 about 30 to 40 packages that week, yes.
16 Q. So that's for everybody that's involved.
17 A. It can be more. Because there's some weeks where
18 everybody is picking up packages so it goes over a hundred, yes.
19 Q. Okay. So let me ask you this question. Who were you
20 working with on this trip in addition to Ego, Jay, and Chris?
21 A. So many names I don't remember. I know the Chris guy,
22 yes. I forgot that name.
23 Q. And you mentioned --
24 A. And Amaya.
25 Q. And who was Amaya?
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 133
1 A. I would say that's Jay's girlfriend. I mean, she's
2 like one of us in a way.
3 Q. And did you -- let me just stop with Amaya for a
4 second. Did you work more with Amaya during the time that you
5 were working with Jay?
6 A. Say again.
7 Q. Did you work a lot with Amaya during the time that you
8 were working with Jay?
9 A. Yes. Yes.
10 Q. So you got to know her very well?
11 A. Yes, I know her fairly well.
12 Q. Well, in terms of -- now let's focus on you. Again,
13 you, Ego, and Chris and Amaya.
14 A. Yes.
15 Q. You mentioned that you guys were picking up packages.
16 A. Yes.
17 Q. Was there anything else were you doing other than
18 picking up packages?
19 A. At the end of the week, on the weekend, we would be
20 assigned to basically get addresses, location. So for the next
21 week, that's when the package would come. Would go to that
22 location.
23 Q. Could you explain a little bit what do you mean by
24 that?
25 A. Okay. So on the week -- the week we get the packages,
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 134
1 we get them. And on the weekend, I would say from Friday we
2 start picking up -- we start looking for empty location for the
3 package to be -- to get there. And also, if we know somebody at
4 that location, we would kind of, like, incentivize that, can we
5 use your location for the package to get there.
6 Q. How would you incentivize that?
7 A. Depending if it's somebody's friend, we be allowed to
8 give you some money. So let's say, Jay gave us 100, either it's
9 people living in that area, they'll give part of their money to
10 that person giving the location.
11 Q. So is the person who is scouting that address, they
12 will give a portion of their money to the person who the package
13 is being delivered to?
14 A. Yes. Yes.
15 Q. Okay. And who was scouting addresses? Was it --
16 A. Everybody. I would say everybody. Me, Ego, Amaya.
17 Like everybody. Because we need that to make more money, I
18 would say, because we have -- because Jay would take -- everyone
19 has to give us ten addresses.
20 Q. And how often would you have to give ten addresses?
21 A. He ask us for every week and every weekend. So we
22 tried to do that every weekend.
23 Q. Okay. And before we get too much further down the
24 line, I haven't asked you this question. So what are you
25 supposed to do -- how are you getting the information about the
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1 packages at this point?
2 A. The screenshot you showed me, that's what Jay would
3 send to us and we have to send it. We would know the tracking
4 number and then we wait at that location basically.
5 Q. And how would he send you the photograph that we had
6 up? With the tracking information and the address.
7 A. There's an app called Wickr. Like he would send it to
8 us. And also we have -- we communicate via What's App to, you
9 know, this is where you're going and things like that.
10 Q. And Mr. Charlemagne, if you could keep your voice up a
11 little bit. Thank you. Thank you.
12 A. Sorry.
13 Q. Now, when a package arrived what were you responsible
14 for doing?
15 A. I would go to the driver, show them the tracking and
16 stuff like that, pick up the package. If the package gets to
17 the location, like we incentivize before, he or she will give us
18 the package and then we get the packet and go back to Jay.
19 Q. If the package was being delivered to an address that
20 was unoccupied, so kind of like a vacant address, what would you
21 do in that situation?
22 A. I would stand in front of house. And since I have the
23 tracking I would present it to the FedEx, present it to them and
24 show them to them and they don't ask question and they gave it
25 to us.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 136
1 Q. Once you get the package, what did you did with the
2 package?
3 A. Beginning, I get the package and then I'll go to one
4 of the location and then I'll open the package and do the money
5 on the package and then it I can confirm it with Jay basically.
6 Q. Okay. So there was a point -- did you -- how soon
7 into your work with Jay did you start opening packages?
8 A. They have a time, but I would say when he start
9 trusting me, because it's money we talking about. So he would
10 let me open the packages and then start counting them.
11 Q. How many -- was that something that happened often
12 where somebody was trusted and allowed to count the money or --
13 A. Yes. Yes.
14 Q. Who was allowed to open the money?
15 A. I was allowed. Amaya was allowed. Ego was allowed.
16 Yes. Those are the people like Jay trust. There was somebody
17 in Miami but it's like mostly when Jay's in Miami but not all
18 the time. I forgot his name, but yes.
19 Q. So when you -- in terms of the places where you were
20 running the package scheme --
21 A. Yes.
22 Q. -- could -- what cities again did you go to?
23 A. D.C. area, Maryland, because not only Baltimore, we go
24 to a lot outside Baltimore, and we also went Jersey. That's
25 what I know. I don't know when I left if they went there still.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 137
1 Q. And also Miami?
2 A. Miami, yes. Miami.
3 Q. And just showing you Government's Exhibit 64. Were in
4 Baltimore in June of 2018, as well?
5 A. Yes. I believe so, yes. I don't see anything.
6 Q. So Government's Exhibit 64. I'm actually going to
7 start with the fourth page of that exhibit.
8 Do you see something here where it mentions a name on
9 the card?
10 A. That's my name.
11 Q. Okay. And did you pay for motel rooms for other
12 people that you were working with?
13 A. Yes. Yes.
14 Q. And showing you the guest information. What is the
15 name of the guest at the Motel 6?
16 A. That's Ego's. That's Ego's name, yes.
17 Q. And what is the check-in and check-out date?
18 A. June 1st check-in, June 2nd check-out.
19 Q. Did there come a point in which you learned that the
20 packages that you were picking up were part of a fraud scheme?
21 A. The first time I was aware of it, it's -- it was
22 actually at Ego's spot. Somebody sent the package to that --
23 the address Ego was assigned to. That lady get the package, and
24 usually the sender sometimes leave their phone number and she
25 had her phone number. That lady called the sender, and I don't
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 138
1 know what they discussed, but that lady for the location of the
2 package now, she was mad at Ego. And she was like, oh, what are
3 you are guys doing, blah --
4 MR. GUILLAUME: Objection.
5 THE COURT: Sustained.
6 MR. DELANEY: Actually, Your Honor --
7 THE COURT: Sustained.
8 BY MS. GOO:
9 Q. Mr. Charlemagne, where did you learn this information
10 from?
11 A. From Ego.
12 MS. GOO: Your Honor, may I ask to re-ask the question
13 again?
14 THE COURT: If it's in furtherance -- if the
15 discussion is in furtherance of the conspiracy it's admissible.
16 Otherwise, in terms of statements that are not in terms of
17 furtherance of conspiracy, it's not admissible. So rephrase the
18 question, I don't know what the answer is going to be.
19 MS. GOO: Yes, Your Honor.
20 THE COURT: Exclamation as to one member of a
21 conspiracy do not amount to statements that are in furtherance
22 of the conspiracy.
23 MS. GOO: But as to intent, Your Honor, in regard to
24 the conspiracy.
25 THE COURT: Well, that's a separate matter, but it's
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1 not in furtherance of the conspiracy.
2 MS. GOO: Yes, Your Honor.
3 BY MS. GOO:
4 Q. Mr. Charlemagne --
5 MS. GOO: Court's -- actually, brief indulgence.
6 THE COURT: You may rephrase the question with respect
7 to comments that were made with respect to indications of
8 knowledge, okay, but it's not in furtherance of the conspiracy.
9 MS. GOO: But, Your Honor, if it is a statement by the
10 defendant himself --
11 THE COURT: That's correct, in terms of a statement by
12 the defendant in terms of his mental state of mind you're
13 permitted to ask that question, that's correct.
14 BY MS. GOO:
15 Q. Mr. Charlemagne, what did Ego tell you?
16 A. The lady of that location was --
17 THE COURT: First, it would be helpful if you put the
18 date on this, and some time reference, Ms. Goo, if the witness
19 is able to do that. You asked when he became aware of the fraud
20 scheme. It's a fair question, the jurors would like to know
21 when did this occur. What is the date that this occurred.
22 BY MS. GOO:
23 Q. Mr. Charlemagne, do you recall, generally speaking,
24 when this occurred?
25 A. The actual date?
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 140
1 Q. Do you know the actual date?
2 A. No.
3 Q. Do you recall when, in relation to Ego's -- beginning
4 of his participation in May of 2018, when in relation to that
5 you had this conversation with him?
6 A. I don't know a date per se, but I would say --
7 Q. If you could give us some kind of general timeframe.
8 If you --
9 A. I would say between June -- June to --
10 THE COURT: June of what year, sir? June of what
11 year, please.
12 THE WITNESS: June of 2018 to September 2018 I would
13 say. Yes.
14 THE COURT: All right. You may continue.
15 MS. GOO: Thank you.
16 BY MS. GOO:
17 Q. So again, Mr. Charlemagne, as to that conversation
18 that you had with Ego, sometime in between June and September of
19 2018, which I think we can safely call perhaps the summer of
20 2018.
21 A. Yes.
22 Q. Would that be accurate?
23 A. Yes. You can say that, yes.
24 Q. Would it be -- what did he tell you?
25 A. Basically the lady, she was mad at him because when
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 141
1 the lady -- okay. The lady's talk to the sender and the sender,
2 I don't know what the sender said, the sender said, but she was
3 mad as to why we were doing that and why he was kind of -- he
4 was part of that basically. She got mad at Ego. And Ego
5 explained that to me.
6 Q. Okay. Did Ego tell you how he responded to the woman
7 who had received the package?
8 A. Yes. I would paraphrase. It's more like, let it go
9 and then just get the package. Because it's like he did not
10 want to further the explanation to that, you know, to the lady
11 that -- location basically, yes.
12 Q. So that he didn't want to continue the conversation
13 further; is that fair to say?
14 A. Yeah. Yeah. Because he knows, because when he comes
15 to me, he's like oh, this is what they doing. And then we have
16 a like -- an understanding. Oh, this is how they get those
17 things, because this was a mystery for us how the money comes
18 basically. So that's how he comes to me. And I'm like oh,
19 okay. And then basically, yeah.
20 Q. So Ego comes to have this conversation with you
21 correct?
22 A. Yes. Yes.
23 Q. And did the two of you discuss it at some length?
24 A. Yes. At that time, because when he comes, because I
25 remember we were waiting and then he comes to me and he talk to
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 142
1 me about that and I am like oh, okay. And we have a clear
2 understanding. Like that's what happened for this package, yes.
3 Q. What was the conclusion of this discussion between you
4 and Ego?
5 A. My understanding, I don't know as far as Ego, that
6 they have to convince whoever the sender is, to send the money
7 basically.
8 Q. Okay. And what were you doing? What was happening
9 with these people that were sending the money?
10 A. At that -- ma'am, I'm sorry, what do you mean?
11 Q. Okay. I'm sorry. Let me ask the question a different
12 way. What were you -- what was your understanding as to what
13 was occurring to cause the people to send the money?
14 A. Whoever convincing, like some -- they have to convince
15 the other party, the sender, to send the money. That's my
16 understanding.
17 Q. Okay. And how were they doing that, if you know?
18 A. I would say I know afterward when I'm reading about
19 it, but that's in the detail. But I knew it's like they
20 convince that other party to send them money, yes.
21 Q. Okay. So they're doing something to convince people?
22 A. Doing something to convince, yes.
23 Q. All right. Now over time --
24 THE COURT: Just so the record is clear, Ms. Goo, with
25 the earlier evidentiary ruling, that was admissible under 8033
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1 in terms of the state of mind of the defendant. It was not a
2 statement in the furtherance of conspiracy under 801(d)(2)(e)
3 and it was admitted for that reason.
4 BY MS. GOO:
5 Q. Now, in terms of your involvement with the conspiracy
6 and the package scheme did you get more responsibility over
7 time?
8 A. Yes.
9 Q. Okay. And what did -- what kind of extra
10 responsibility did you get?
11 A. One of the responsibility was like basically to bring
12 the money to the other party, that I would say the caller
13 people. That's what I would say. So they would -- yes.
14 Q. And I'm sorry, I didn't understand what you said. The
15 which people?
16 A. The -- the --
17 Q. No. You can use the word that you said, I couldn't
18 hear what that word was.
19 A. I said caller, like the people that convince the other
20 party, yes.
21 Q. Caller. Okay.
22 A. So we would go ahead and get the money. On Sunday I,
23 they give me the total amount, and then I get the bag and I
24 bring it to them. And they would count it, he confirm with his
25 people and then I confirm it with Jay, and then I leave.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 144
1 Q. Okay. So let's -- we're going to spend a little bit
2 of time talking about that. Before we get into kind of the
3 money that you had to transport.
4 A. Yes.
5 Q. You're talking about these caller people. So if you
6 were --
7 A. No caller. Caller.
8 Q. Right. The caller people, right?
9 A. Yes.
10 Q. In terms of where everybody was in terms of a
11 hierarchy of the scheme, where are the caller people in relation
12 to where you are?
13 A. Okay. I would say them; Jay, because he's like
14 responsible for everything; and then it was I at first. Then I
15 would say Amaya and then Ego came second. I would say in like
16 -- because Amaya, Ego, and I were the same level basically,
17 because we would do everything I do, Ego would do it. He would
18 open the packet, the same thing with Amaya. And then everybody
19 else. Meaning, in Baltimore the people we hired, we -- we get.
20 So they would be at the bottom, because they don't know really
21 what's inside of the package. The responsibility is pick up
22 package, bring it to us. That's it.
23 Q. So would it be fair to characterize your
24 responsibility as kind of like a manager role?
25 A. You can say that, yes.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 145
1 Q. Okay. So again, in terms of who was in the manager
2 position, who was that over time?
3 A. I, Ego, Amaya.
4 Q. Okay. Now, when packages were picked up --
5 A. Yes.
6 Q. -- did you ever receive packages from the people that
7 were working for you?
8 A. They would bring me the package, yes.
9 Q. Okay. What did you do with the packages when you
10 received it?
11 A. I would go to the room, my room I would say. I open
12 the package, I would take a video and then I start counting the
13 money in the package. And then once I know it's the quantity
14 that was told, that was like confirmed, and I -- I would say I
15 accept it basically, and I do that for every single package,
16 yes.
17 Q. So you would count the money that was in the package.
18 A. Yes.
19 Q. And what number did you compare it to? How did you
20 get that information?
21 A. The screenshot you have earlier, we had those
22 screenshot with the amount on top basically.
23 Q. What happened if the amount that you received through
24 the message was different than what was in the package?
25 A. That's why we have recording. We video, we record the
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 146
1 package because at the beginning it happened. When I -- let's
2 say they said nine thousand, right, and I have eight thousand.
3 And I'm like, there's one thousand missing. They may think I
4 have something to do with it, so the best thing to do is we
5 record on the video when I'm opening the package. So now if
6 anything missing they can see I did not take the money. So I
7 would count the money and tell them this is what is, and then I
8 said okay, it's confirm. If it not I said this is what it is so
9 it is missing either five hundred, one thousand, yes.
10 Q. Who did you send those videos too?
11 A. I would send it to Jay.
12 Q. Did you observe Amaya opening packages?
13 A. Yes.
14 Q. And taking the video?
15 A. Yes.
16 Q. Did you ever observe Ego opening packages?
17 A. Yes.
18 Q. And what did you see him do when he was opening?
19 A. Opening the package up, counting, confirm it, and then
20 yes, the same thing as I do, yes.
21 Q. Approximately how many times did you open the
22 packages, if you can recall?
23 A. For every single package. So for all of them.
24 Q. So do you have a ballpark figure as to how many you
25 opened?
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1 A. I would say if I was responsible, like if -- I don't
2 know.
3 Q. Like -- okay.
4 A. One hundred, two hundred. It's a lot, yes. A lot of
5 packages.
6 Q. What was the average amount of money that was in a
7 package?
8 A. Some of them I would say 9,000. 8,000, 9,000.
9 Q. What is the most amount of money that you saw in a
10 package?
11 A. I opened one with 40,000.
12 Q. How many times did you see Ego hoping a package?
13 A. Every day. All the time. Like when he was when he
14 was at the same level. Because at the beginning, no, but when
15 he was at same level yes, every day, because he's like me.
16 Q. How long -- at what point, if you recall, not
17 necessarily a specific date but a general period of time, when
18 was Ego at the same level as you?
19 A. Pretty soon. Pretty soon. Because I can't give a
20 date or time because it's -- it's so long. But the things I
21 would say, Ego and I we're from Miami, so we Jay's people all
22 the way, because everybody else is like outsider because they
23 are from other cities. Meaning if they're from D.C., they're
24 from D.C., or from Maryland they are from Maryland. But Amaya
25 is different because she has some kind of thing with Jay
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1 basically. I don't know if you understand.
2 Q. So you don't know how many times you saw -- you don't
3 know when Ego became a manager.
4 A. Very soon. I would say very soon.
5 Q. I think we used like the beginning of May 2018 as the
6 beginning time in which he started.
7 A. So --
8 Q. So using that as a reference point, how far into or
9 how long was he with it before he became a manager as well?
10 A. I would say June or July.
11 Q. Okay. Of what year?
12 A. 2018. 2018. Yes.
13 Q. Now, let's -- we're going to talk an a little bit
14 about Amaya. What was Amaya responsible for when were you in
15 the Baltimore and D.C. area?
16 A. Okay. Since that's her state, that's her city, she
17 knows more people than everybody else so she would -- I would
18 say, kind of -- how could I say. You know when you hire
19 somebody you can vouch for that person. You can say, okay, this
20 is -- he's good. So she would be responsible of that. She
21 would also have all the same responsibility as I, opening
22 package, do everything. Sometimes we use storage. We put our
23 name on the storage, so when we get the money -- so let's say,
24 we in this area and we don't want to go to the Motel 8, or Motel
25 9 to leave the package, we would put the money, the packages in
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1 the storage. There's so much we have done, like yes. That was
2 Amaya basically yes.
3 Q. So was Amaya also in charge of directing people to
4 certain addresses?
5 A. Yes. Yes.
6 Q. Showing you Government's Exhibit 59. First focusing
7 on the participants of the conversation. Who was this a
8 communication between?
9 A. That's between Amaya and I. Amaya and I.
10 Q. Okay. If we could show the messages. And if you
11 could, just starting with the message dated July 11th, 2018, at
12 5:35 a.m. And going down just the last three messages, if we
13 could show those.
14 A. Okay.
15 Q. If you could just read the first message.
16 A. Kilo 29 White Avenue, you, as I. 3032 Aran Avenue.
17 Ego. 2210 North Calvert Street. First one was D Lo.
18 Q. And who is this message from?
19 A. From Amaya.
20 Q. To who?
21 A. To me. To I.
22 Q. Okay. And what is this information in the --
23 A. It's the location we have to go for the packages.
24 Q. So whose D Lo?
25 A. I think it's -- I believe it's DiAngelo something. I
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1 forgot his name.
2 Q. And was that somebody who was working with you here in
3 the Baltimore area?
4 A. Yes.
5 Q. So what was D Lo supposed to do a 2914 White Avenue?
6 A. To go pick up packages. That's his spot.
7 Q. And the second line, you?
8 A. That's me. I have to go to that location to pick up
9 the package in that location.
10 Q. And to the best of your knowledge, did you go and pick
11 up a package there?
12 A. Yes. If it's not coming, but yes, that's when I go
13 there. I wait for the package and I pick it up, yes.
14 Q. Okay. And the last line is for who?
15 A. Ego. 2210 North Calvert Street. Yes.
16 Q. Okay. And again, what was your understanding as to
17 Ego's responsibility as to that address?
18 A. To pick up packages. Yes.
19 MS. GOO: Your Honor, I have another set of texts
20 messages and a bit more to go in my outline.
21 THE COURT: It's time to stop now. It's five o'clock,
22 we're going to stop on the dime. We'll get started again -- you
23 all were on time today, great, and hopefully we don't have any
24 preliminary matters, but sometimes we have to expedite matters.
25 We'll see you all tomorrow and we'll plan to start
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 151
1 promptly at 9:30. I'll stay up here on the bench with
2 scheduling matters for counsel, and you all are excused for the
3 day.
4 And Mr. Charlemagne, you'll be coming back to the
5 witness stand tomorrow. You should not discuss your testimony
6 with anyone between now and when you come back on the witness
7 stand tomorrow. Not counsel, no one, okay. You just stay to
8 yourself. We'll see you tomorrow on the witness stand at 9:30
9 tomorrow morning.
10 THE WITNESS: 9:30. Thank you.
11 THE COURT: Thank you very much. You're excused as
12 well, sir.
13 THE WITNESS: Thank you.
14
15 (Witness excused.)
16 (Jury excused at 5:00 p.m.)
17 THE COURT: Okay, with that, in terms of scheduling
18 here -- you all may be seated for a moment, Mr. Delaney.
19 Tell me, after you finish Mr. Charlemagne, give me the
20 order of the witnesses so Mr. Guillaume knows who's coming next
21 and in what order. The order is very important. So who will be
22 witness number six, Mr. Delaney?
23 MR. DELANEY: After Mr. Charlemagne finishes testimony
24 we expect to play the testimony of Francis William.
25 THE COURT: Witness number six will be?
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 152
1 MR. DELANEY: The video testimony of Francis Williams.
2 THE COURT: Hold on one second, please. Okay.
3 MR. DELANEY: Then Sooraji Paliwal.
4 THE COURT: He will be a witness appearing in court.
5 MR. DELANEY: Correct. Witness number 7.
6 THE COURT: Then.
7 MR. DELANEY: Then Aaron St. Juste will be witness
8 number 8.
9 THE COURT: Okay.
10 MR. DELANEY: Then the video testimony of Lloyd
11 Harkey.
12 THE COURT: Hold on one second, please. And that
13 would be witness number 9 right.
14 MR. DELANEY: Uh-huh.
15 THE COURT: Okay.
16 MR. DELANEY: Then in person testimony from Amaya
17 English.
18 THE COURT: Witness number 10.
19 MR. DELANEY: I'm sorry, I've been corrected by
20 counsel.
21 Correct, Your Honor. Before witness Amaya English we
22 will call witness Norman Shifflet.
23 THE COURT: Norman Shifflet. Is, I see, a detective.
24 Norman Shifflet from the Baltimore Police Department will be
25 witness 10.
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EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 153
1 MR. DELANEY: That's right, Your Honor.
2 THE COURT: And then Amaya English will be witness 11.
3 MR. DELANEY: If there's time, yes.
4 THE COURT: So Mr. Guillaume is aware and my is aware,
5 after we finish with Mr. Charlie main we'll have the video of
6 Francis witness yes, ma'ams to be followed by the testimony of
7 Sooraji pal wall number 7 Aaron Saint Juste, witness number 8;
8 Lloyd Harkey, a video, witness number 9; Detective Norman
9 Shifflet Baltimore Police Department, witness 10; and then Amaya
10 English, witness number 11.
11 All right. Are there any other matters for me to
12 address this afternoon or to anticipate for tomorrow morning
13 according to the Government?
14 MR. DELANEY: No.
15 THE COURT: Mug anything else from your point of you.
16 MR. GUILLAUME: No, Your Honor.
17 THE COURT: With that this court stands adjourned for
18 the day. Thank you very much.
19 (The proceedings concluded at 5:03 p.m.)
20
21
22
23
24
25
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Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 154 of 170
EXCERPT OF MCARNOLD CHARLEMAGNE - DIRECT EXAMINATION 154
1 CERTIFICATE OF OFFICIAL REPORTER
2 I, Kassandra L. McPherson, Registered Professional
Reporter, in and for the United States District Court for the
3 District of Maryland, do hereby certify, pursuant to 28 U.S.C. §
753, that the foregoing is a true and correct transcript of the
4 stenographically-reported proceedings held in the above-entitled
matter and that the transcript page format is in conformance
5 with the regulations of the Judicial Conference of the United
States.
6 Dated this 13th day of June 2023.
7 -S-
______________________________________
8 KASSANDRA L. MCPHERSON, RPR
FEDERAL OFFICIAL COURT REPORTER
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 155 of 170
1
$ 46:1, 103:24, 84:15, 90:25, 314 [1] - 48:3 137:15 9:21, 129:25
104:3, 104:8, 107:8, 107:15, 32 [2] - 65:5, 6-2 [1] - 5:25 accept [1] -
$1,500 [2] - 96:3, 154:6 108:17, 108:25, 66:14 620 [2] - 45:19, 145:15
96:4 15 [4] - 22:17, 109:21, 122:17, 3208 [1] - 51:1 45:25 accompanying
$100 [2] - 16:19, 24:5, 24:6, 122:18, 122:21, 329 [1] - 126:20 63 [1] - 120:6 [1] - 98:7
124:21 131:9 122:23 33 [1] - 120:9 64 [2] - 137:3, according [3] -
$50 [1] - 16:14 16 [1] - 35:18 2020 [4] - 87:3, 3353(e [1] - 5:17 137:6 71:17, 104:8,
$700 [1] - 11:3 17 [2] - 19:8, 88:19, 88:20, 36 [2] - 65:10, 153:13
120:18 90:20 66:14 7 account [14] -
' 170,000 [1] - 2023 [2] - 1:9, 37 [2] - 65:13, 119:25, 120:1,
44:25 154:6 66:14 7 [5] - 47:17, 120:3, 120:13,
'18 [1] - 118:4 17th [2] - 19:8, 21 [1] - 48:12 38,000 [2] - 58:10, 129:23, 121:4, 121:14,
120:16 216 [1] - 48:1 120:12, 120:22 152:5, 153:7 121:16, 121:20,
0 18 [6] - 3:5, 5:17, 22 [1] - 49:21 39 [3] - 81:17, 716 [1] - 49:12 121:23, 122:1,
46:9, 46:20, 2210 [2] - 149:17, 81:25, 82:10 753 [1] - 154:3 122:4, 122:6,
0771 [1] - 49:25 46:21, 114:18 150:15 761 [1] - 49:20 122:8, 122:9
18th [2] - 19:11, 2240 [1] - 113:6 4 780834240315 [2] accurate [1] -
1 36:1 23 [3] - 51:13, - 129:16, 129:20 140:22
19 [1] - 47:10 51:14, 52:3 4 [3] - 46:15, 55:9, accurately [3] -
1 [6] - 2:21, 3:1, 19th [1] - 48:17 23A [1] - 52:10 78:13 8 4:12, 4:25, 6:1
3:2, 3:9, 3:18, 1:09 [2] - 110:24, 23rd [1] - 108:25 40 [1] - 132:15 activities [2] - 4:1,
114:13 111:6 24 [2] - 52:22 40,000 [1] - 8 [7] - 114:25, 4:2
10 [15] - 2:17, 3:1, 1:10 [1] - 111:7 24th [2] - 125:13, 147:11 125:1, 125:22, actual [5] - 99:11,
4:6, 44:14, 1:15 [1] - 67:8 126:1 417 [2] - 47:21, 148:24, 152:8, 101:1, 104:17,
58:21, 67:16, 1:20 [1] - 67:8 25 [9] - 52:21, 47:23 153:7 139:25, 140:1
68:9, 91:21, 52:22, 53:8, 437 [2] - 125:25, 8,000 [1] - 147:8 addition [2] -
1A [1] - 3:19
91:23, 97:16, 55:9, 56:24, 126:1 801(d)(2)(e [1] - 89:23, 132:20
1st [1] - 137:18
115:10, 126:13, 59:10, 59:19, 439 [1] - 126:6 143:2 additional [5] -
152:18, 152:25, 103:9, 108:10 8033 [1] - 142:25 33:20, 38:5,
153:9 2 47th [1] - 45:19
25th [5] - 45:16, 38:6, 41:24,
10,000 [1] - 41:13 9 64:18
100 [2] - 119:18,
2 [4] - 4:11, 23:3, 64:11, 109:21, 5
50:16, 108:21 125:13, 126:2 address [31] -
134:8 20 [2] - 32:17, 2645 [2] - 128:25, 5 [7] - 5:22, 45:14, 9 [8] - 57:20, 12:13, 25:9,
10th [1] - 108:17 113:15 129:25 55:20, 56:23, 114:23, 125:20, 27:15, 28:7,
11 [15] - 3:8, 20,000 [1] - 41:15 27 [3] - 63:13, 64:6, 97:15, 126:5, 130:21, 29:3, 45:17,
15:21, 53:22, 2017 [4] - 118:8, 108:19, 126:17 109:18 148:25, 152:13, 46:3, 47:21,
54:24, 58:21, 118:11, 122:20 27A [1] - 63:25 5,000 [1] - 41:13 153:8 47:25, 49:17,
59:15, 63:19, 2018 [27] - 8:4, 50 [1] - 124:21 9,000 [2] - 147:8 50:23, 64:7,
28 [7] - 45:5, 64:6,
78:17, 108:10, 19:8, 19:11, 55 [3] - 45:19, 9557 [1] - 50:6 64:8, 99:22,
103:8, 103:16,
115:11, 117:19, 36:1, 41:23, 114:6, 114:8 9:18 [1] - 23:6 99:23, 103:8,
109:18, 126:17,
117:21, 132:4, 75:17, 83:25, 56 [1] - 129:8 9:30 [3] - 151:1, 103:9, 103:10,
154:3
153:2, 153:10 92:24, 118:4, 57 [3] - 128:16, 151:8, 151:10 103:19, 128:24,
2801 [1] - 49:11
11:39 [1] - 55:16 118:6, 120:4, 129:9, 129:14 9th [2] - 53:1, 54:9 129:1, 129:24,
2802 [1] - 49:12
11:52 [1] - 67:12 129:23, 130:21, 58 [1] - 131:2 130:1, 130:2,
29 [3] - 40:6, 40:8,
11:53-12:18 [1] - 131:9, 132:4, 5821 [1] - 33:1 A 134:11, 135:6,
149:16
67:13 137:4, 140:4, 58A [1] - 130:16 135:19, 135:20,
2914 [1] - 150:5
11:58 [1] - 57:6 140:12, 140:19, a.m [3] - 57:20, 137:23, 150:17,
2:21 [1] - 111:7 59 [1] - 149:6
11th [2] - 63:23, 140:20, 148:5, 67:12, 149:12 153:12
2nd [1] - 137:18 5:00 [1] - 151:16
149:11 148:12, 149:11 Aaron [2] - 152:7, addressed [1] -
5:03 [1] - 153:19
12 [6] - 1:9, 3:12, 2019 [32] - 45:16, 153:7 13:9
19:2, 115:11,
3 5:35 [1] - 149:12
ability [3] - 38:6, addresses [40] -
46:15, 47:17, 5D [1] - 1:9
115:12, 131:24 48:17, 53:1, 3 [1] - 54:10 38:10, 107:17 11:16, 12:5,
5K1.1 [1] - 5:17
12:20 [1] - 68:11 54:9, 63:19, 30 [2] - 41:2, able [3] - 38:14, 12:11, 12:16,
5K1.1(a)(1 [1] -
13 [2] - 20:12, 64:11, 68:24, 132:15 38:21, 139:19 12:18, 12:25,
5:22
132:4 69:8, 71:7, 300,000 [1] - above-entitled [1] 13:7, 22:3, 27:8,
1349 [2] - 3:5, 71:16, 75:18, 44:24 - 154:4 30:16, 30:17,
114:18 75:19, 76:1,
6 aboveboard [1] - 34:17, 34:19,
3016 [1] - 49:11
137 [3] - 124:25, 77:6, 77:9, 6 [7] - 6:3, 57:10, 107:13 34:21, 35:2,
3032 [1] - 149:16
125:2, 131:24 77:13, 78:4, 64:14, 124:24, abused [1] - 79:6 35:4, 35:11,
305 [1] - 49:24
13th [7] - 43:21, 80:18, 83:25, 125:14, 131:23, Acapulco [2] - 36:3, 36:5, 36:7,
31 [1] - 64:19
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2
46:25, 47:3, Airbnb [9] - 20:9, 126:15 arrive [9] - 13:1, Ave [4] - 49:12, 57:21, 71:25,
47:4, 47:6, 20:15, 21:11, answer [3] - 54:2, 13:17, 19:14, 51:1 72:16
47:19, 48:4, 21:17, 26:12, 106:25, 138:18 21:6, 22:8, Avenue [5] - beat [1] - 79:19
48:6, 53:3, 53:4, 26:17, 26:23, anticipate [1] - 25:17, 25:23, 49:11, 49:13, became [7] - 8:7,
64:21, 65:3, 27:2, 27:5 153:12 29:12, 119:13 149:16, 150:5 8:10, 98:9,
65:5, 98:21, airport [1] - apologize [1] - arrived [15] - average [2] - 113:16, 139:19,
98:23, 98:24, 131:11 114:25 13:12, 13:16, 132:10, 147:6 148:3, 148:9
133:20, 134:15, Alfred [1] - 1:18 apologized [1] - 15:7, 15:10, avoid [1] - 14:7 become [1] - 90:1
134:19, 134:20, allowed [12] - 28:10 16:5, 16:6, 16:8, aware [13] - bed [1] - 21:23
149:4 39:21, 107:22, app [4] - 32:4, 19:20, 20:15, 26:22, 74:4, bedroom [1] -
adjourned [1] - 121:23, 124:9, 32:5, 32:14, 20:21, 21:10, 74:12, 75:2, 27:2
153:17 124:10, 124:12, 135:7 25:2, 25:19, 75:9, 76:12, BEFORE [1] -
admissible [3] - 134:7, 136:12, App [1] - 135:8 26:5, 135:13 98:9, 102:14, 1:12
138:15, 138:17, 136:14, 136:15 appear [5] - 6:11, article [3] - 58:23, 102:15, 137:21, beg [1] - 113:9
142:25 alluded [1] - 52:6, 52:11, 60:16 139:19, 153:4 began [1] - 95:19
admits [1] - 3:6 34:16 52:13, 64:1 articles [4] - awhile [2] - 75:25, beginning [11] -
admitted [2] - almost [3] - appearing [1] - 58:24, 59:1, 105:23 10:12, 122:17,
78:17, 143:3 44:14, 62:9, 152:4 59:3, 72:1 122:18, 122:20,
advice [1] - 89:18 113:15 application [3] - aside [1] - 73:25 B 122:23, 136:3,
advise [1] - 3:7 alone [1] - 76:6 94:24, 95:3 asleep [1] - 55:25 140:3, 146:1,
advisory [1] - Amaya [43] - appropriate [1] - ass [1] - 56:5 baby [2] - 40:21, 147:14, 148:5,
5:21 20:24, 21:22, 5:17 assigned [2] - 40:22 148:6
afternoon [4] - 22:2, 25:6, approval [1] - 133:20, 137:23 background [1] - behind [2] -
112:2, 112:24, 26:10, 26:14, 90:12 assistance [1] - 5:8 78:25, 79:3
112:25, 153:12 33:24, 38:11, approximate [1] - 5:13 backseat [1] - belive [1] - 103:21
afterwards [1] - 38:12, 38:13, 84:22 Assistant [1] - 60:9 below [7] - 4:19,
120:2 38:17, 69:18, April [6] - 125:13, 1:16 bad [1] - 24:23 4:23, 33:17,
ago [6] - 29:21, 94:1, 94:12, 126:1, 126:2, associated [1] - bag [4] - 26:8, 47:24, 48:2,
68:22, 68:24, 94:18, 100:11, 126:17 131:25 27:2, 29:17, 59:6, 115:5
78:21, 84:6, 101:6, 132:14, Aran [1] - 149:16 assume [3] - 68:4, 143:23 bench [1] - 151:1
103:20 132:24, 132:25, Arcadia [1] - 9:21 126:24, 127:16 bags [1] - 43:12 benefit [2] - 7:5,
agree [4] - 18:9, 133:3, 133:4, area [15] - 43:2, assuming [1] - bail [2] - 57:19, 66:13
89:23, 94:9, 133:7, 133:13, 46:6, 74:23, 106:11 82:16 BENNETT [1] -
94:11 134:16, 136:15, 92:23, 109:7, asterisk [1] - ballpark [1] - 1:12
agreed [1] - 5:11 144:15, 144:16, 109:11, 109:15, 45:13 146:24 Benz [6] - 27:10,
agreement [17] - 144:18, 145:3, 124:19, 124:23, Atlantic [1] - Baltimore [37] - 124:14, 124:15,
2:23, 2:24, 3:13, 146:12, 147:24, 131:17, 134:9, 83:24 1:10, 18:1, 18:8, 124:16, 124:17,
3:16, 4:14, 5:4, 148:14, 149:2, 136:23, 148:15, attachment [7] - 18:9, 18:13, 124:18
5:15, 67:17, 149:3, 149:9, 148:24, 150:3 52:3, 52:4, 52:6, 20:4, 22:12, best [2] - 146:4,
67:19, 89:11, 149:19, 152:16, areas [1] - 74:25 52:8, 52:11, 24:17, 31:19, 150:10
89:22, 91:25, 152:21, 153:2, arrest [12] - 57:12, 63:23, 64:1 47:19, 47:23, between [14] -
92:17, 114:1, 153:9 61:5, 61:8, 63:3, attended [1] - 48:1, 48:3, 39:19, 44:18,
115:8, 115:21, Amaya's [1] - 21:2 71:11, 71:25, 87:7 52:20, 69:2, 58:12, 63:21,
116:4 AMERICA [1] - 80:17, 80:19, attention [11] - 69:4, 69:5, 70:9, 97:15, 108:20,
Agreement [2] - 1:3 84:16, 85:2, 2:20, 23:4, 70:17, 74:22, 122:22, 131:18,
4:17, 115:13 amount [17] - 86:16, 91:16 47:20, 60:16, 76:20, 76:23, 140:9, 140:18,
agrees [3] - 3:3, 32:15, 40:3, arrested [24] - 81:16, 114:7, 83:10, 93:1, 142:3, 149:8,
3:20, 114:16 44:2, 86:10, 52:17, 59:4, 115:12, 125:1, 109:11, 124:23, 149:9, 151:6
ahead [17] - 3:18, 95:12, 120:21, 65:15, 65:17, 129:10, 130:15 130:25, 131:3, beyond [2] - 37:1,
3:19, 4:12, 6:14, 120:22, 121:10, 65:19, 68:25, Attorney's [1] - 131:21, 136:23, 41:5
6:18, 7:11, 121:11, 127:14, 69:23, 76:2, 4:24 136:24, 137:4, big [6] - 54:13,
40:12, 40:15, 132:11, 138:21, 76:6, 76:7, Attorneys [1] - 144:19, 148:15, 54:14, 54:20,
40:24, 45:3, 143:23, 145:22, 77:14, 80:18, 1:16 150:3, 152:24, 54:22, 56:4,
46:8, 50:16, 145:23, 147:6, 81:1, 81:11, August [1] - 8:4 153:9 56:16
51:12, 54:24, 147:9 82:14, 85:12, authorities [1] - Baltimore-D.C [2] bigger [1] - 57:15
58:20, 67:14, amounts [3] - 86:6, 88:3, 3:24 - 109:11, 124:23 biggest [1] -
143:22 41:11, 44:24, 90:25, 91:7, AVBORAYE [1] - Bank [1] - 120:4 41:14
aided [1] - 1:25 101:1 96:11, 109:24, 1:5 bank [3] - 39:15, bit [14] - 6:23,
ain't [1] - 57:18 AND [1] - 1:11 110:1 Avboraye [2] - 120:3, 121:20 17:9, 67:4,
Air [1] - 131:11 Andre [2] - 125:9, arrests [1] - 72:7 8:17, 52:1 based [5] - 30:15, 68:21, 92:22,
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3
94:23, 116:4, brothers [1] - 40:20, 40:22 87:22, 91:1, 132:20, 132:21, Collins [3] -
122:24, 131:2, 73:1 Cameron [2] - 95:19, 102:15, 133:13 120:12, 120:20,
133:23, 135:11, brought [7] - 31:13, 35:7 113:20 Christine [1] - 120:23
144:1, 148:13, 37:11, 57:7, capabilities [1] - charges [14] - 3:4, 1:15 coming [5] - 13:5,
150:20 60:16, 61:6, 95:9 4:22, 57:20, Christopher [1] - 67:25, 150:12,
blah [1] - 138:3 81:14, 86:17, car [6] - 123:22, 58:2, 61:6, 131:14 151:4, 151:20
blank [2] - 17:7, 105:10 123:23, 123:24, 85:13, 85:19, circle [1] - 49:7 comments [1] -
36:16 bruh [1] - 58:7 124:6, 124:10, 86:1, 86:3, circled [1] - 50:17 139:7
blow [14] - 19:6, brushed [2] - 124:12 86:19, 86:20, circling [1] - commission [3] -
22:18, 33:7, 60:24, 72:3 card [2] - 52:14, 88:7, 88:15, 129:22 6:9, 6:10, 6:13
35:19, 49:6, building [11] - 137:9 114:3 circumstances commit [4] - 3:5,
50:17, 51:21, 43:2, 43:20, care [1] - 127:9 Charlemagne [29] [1] - 80:19 7:13, 114:18,
51:22, 52:3, 45:22, 45:23, carried [1] - 43:9 - 14:25, 15:1, cities [4] - 123:10, 114:21
52:4, 54:10, 46:3, 97:22, carrying [1] - 79:19, 105:21, 124:4, 136:22, commits [1] - 6:6
55:10, 55:21, 97:23, 97:24, 43:12 106:9, 112:7, 147:23 communicate [6]
63:18 98:2, 103:25 cars [2] - 63:9, 112:9, 112:14, city [3] - 36:6, - 31:23, 44:6,
blue [2] - 45:15, buildings [1] - 124:13 112:17, 112:24, 113:7, 148:16 47:6, 47:8, 53:4,
103:10 97:18 case [16] - 4:18, 113:1, 113:4, CJA [1] - 1:19 135:8
BMW [1] - 123:25 bulk [1] - 97:3 9:23, 58:16, 114:7, 114:14, clarify [4] - 59:25, communicated
board [1] - 12:4 business [4] - 67:22, 86:23, 114:20, 120:8, 60:4, 67:21, [3] - 31:25,
body [2] - 62:9, 41:25, 122:5, 87:10, 90:19, 125:10, 125:23, 93:5 101:16, 101:21
72:16 122:8, 122:9 92:12, 92:15, 126:15, 126:21, clear [5] - 73:21, communication
bone [1] - 24:2 businesses [1] - 95:19, 102:15, 135:10, 138:9, 102:23, 121:25, [3] - 88:3,
booked [2] - 18:1, 46:6 110:20, 113:25, 139:4, 139:15, 142:1, 142:24 108:20, 149:8
18:2 BWI [4] - 19:15, 116:10, 116:12, 139:23, 140:17, clearly [4] - 2:4, company [1] -
born [1] - 2:14 19:20, 93:1, 116:22 151:4, 151:19, 53:14, 112:11, 75:7
bottom [9] - 19:9, 130:25 CASE [1] - 1:4 151:23 112:18 compare [1] -
23:5, 54:4, BY [35] - 2:10, cash [6] - 30:22, charlemagne [1] - CLERK [6] - 2:4, 145:19
55:10, 55:15, 2:19, 9:2, 11:21, 39:12, 39:13, 112:15 2:8, 67:11, complain [1] -
56:23, 57:5, 18:25, 24:8, 41:12, 42:14, CHARLEMAGNE 111:5, 112:11, 79:12
120:7, 144:20 28:17, 29:6, 80:14 [2] - 1:11, 112:16 completed [1] -
box [3] - 19:9, 40:16, 45:2, Castle [1] - 65:18 112:10 click [2] - 52:2, 93:16
35:19, 92:7 46:23, 53:16, certain [7] - Charlie [1] - 153:5 64:14 completely [3] -
boxes [2] - 19:6, 58:19, 59:14, 32:15, 86:10, check [14] - client [25] - 68:25, 9:23, 12:4,
54:4 60:6, 61:7, 89:2, 89:21, 125:12, 125:13, 69:13, 71:2, 87:14
breach [2] - 6:4, 66:12, 68:18, 90:3, 95:12, 126:16, 126:17, 71:17, 72:12, complied [1] -
7:9 78:15, 80:3, 149:4 132:3, 137:17, 72:15, 73:12, 5:14
Breaches [1] - 81:20, 82:2, certainly [1] - 137:18 73:22, 75:2, complies [1] - 5:3
5:25 91:20, 102:13, 81:19 check-in [7] - 75:9, 77:17, Computer [1] -
break [8] - 66:25, 103:18, 106:8, CERTIFICATE [1] 125:12, 125:13, 80:12, 83:1, 1:25
67:5, 67:8, 106:23, 112:23, - 154:1 126:16, 126:17, 87:22, 88:15, Computer-aided
89:14, 106:20, 113:13, 138:8, certify [1] - 154:3 132:3, 137:17, 93:21, 94:15, [1] - 1:25
111:1, 112:1, 139:3, 139:14, chance [1] - 137:18 94:21, 96:17, concerning [1] -
122:22 139:22, 140:16, 115:14 check-out [7] - 97:5, 100:19, 4:2
brief [6] - 78:14, 143:4 changes [3] - 125:12, 125:13, 101:10, 101:21, concluded [1] -
81:18, 91:19, 63:2, 63:8, 126:16, 126:17, 102:14, 105:18 153:19
102:11, 110:12, C 63:11 132:3, 137:17, client's [1] - 87:14 concludes [1] -
139:5 changing [1] - 137:18 clip [1] - 52:10 110:17
briefly [3] - 2:18, C-h-a-r-l-e-m-a-g 40:21 checks [1] - 39:11 close [6] - 9:18, conclusion [6] -
59:2, 119:23 -n-e [1] - 112:15 character [1] - 5:8 Chester [2] - 48:1, 9:19, 13:19, 102:6, 102:7,
bring [8] - 67:14, caller [8] - 143:12, characterize [1] - 74:9 46:3, 73:7 102:8, 116:9,
114:6, 127:10, 143:19, 143:21, 144:23 child [1] - 82:24 closed [1] - 116:20, 142:3
128:5, 143:11, 144:5, 144:7, charge [5] - 7:13, child's [1] - 83:16 121:24 conditions [1] -
143:24, 144:22, 144:8, 144:11 84:7, 85:22, childhood [1] - closer [1] - 6:23 3:21
145:8 Calvert [2] - 114:17, 149:3 9:13 Coast [1] - 83:22 conduct [2] - 5:8,
broke [2] - 24:24, 149:17, 150:15 charged [13] - choice [3] - 31:16, collect [3] - 8:10, 5:9
62:23 Cam [2] - 31:13, 57:18, 65:21, 31:17, 31:18 8:11, 33:19 Conference [1] -
brother [4] - 34:25 65:23, 66:2, choose [1] - collecting [1] - 154:5
54:13, 54:14, camera [4] - 84:9, 84:11, 12:21 34:5 confirm [7] - 44:2,
54:21, 54:22 23:19, 39:3, 85:15, 85:19, Chris [4] - 132:5, college [1] - 28:12 93:18, 136:5,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 158 of 170
4
143:24, 143:25, 53:17, 60:15, 79:9, 79:10, 39:5, 41:14, 152:4, 153:17 95:24, 96:3,
146:8, 146:19 61:1, 61:2, 79:15, 79:20, 136:10, 145:12, court's [6] - 96:4, 109:11,
confirmation [2] - 61:15, 61:19, 80:11, 80:12, 146:19 78:14, 81:18, 123:16, 123:18,
62:4, 128:20 61:23, 62:11, 81:8, 82:22, country [2] - 91:19, 102:11, 123:21, 124:23,
confirmed [6] - 62:19, 63:14, 82:25, 83:1, 74:18, 85:20 110:12, 139:5 131:11, 136:23,
60:24, 62:1, 63:17, 63:18, 83:20, 84:1, counts [1] - 5:10 Court's [5] - 2:18, 147:23, 147:24,
72:6, 72:11, 70:19, 71:20, 84:2, 84:12, couple [15] - 23:18, 45:1, 148:15
102:5, 145:14 72:13, 116:7, 85:3, 85:4, 27:23, 28:9, 51:11, 66:11 D.C.-Baltimore
conformance [1] 140:5, 140:17, 85:20, 85:21, 28:14, 28:18, courthouse [1] - [2] - 124:19,
- 154:4 141:12, 141:20, 86:18, 86:24, 29:7, 41:18, 114:4 131:17
confused [1] - 149:7 87:7, 87:10, 41:20, 44:21, courtroom [2] - damn [1] - 23:10
105:25 conversations 87:17, 87:20, 64:18, 78:18, 8:18, 68:11 dangerous [1] -
connected [1] - [11] - 17:1, 17:4, 87:23, 87:24, 104:21, 104:22, Courtroom [1] - 106:5
61:25 59:23, 61:5, 88:9, 88:25, 104:24, 121:21, 1:9 date [37] - 19:7,
connection [4] - 62:12, 62:15, 89:8, 89:16, 122:12 cover [1] - 92:3 19:10, 35:24,
5:4, 59:4, 97:19, 63:20, 71:21, 90:1, 90:12, course [4] - 4:16, coverage [1] - 35:25, 46:13,
102:15 71:24, 88:11, 90:14, 90:23, 102:2, 102:24, 99:13 46:14, 47:16,
consider [1] - 109:19 91:2, 91:3, 92:1, 124:7 crazy [1] - 58:6 52:23, 54:8,
24:23 convicted [1] - 92:12, 92:13, COURT [69] - 1:1, created [2] - 57:13, 64:10,
considered [5] - 85:13 92:18, 92:24, 8:25, 11:19, 35:24, 64:22 69:8, 71:11,
6:21, 6:25, 7:2, convince [6] - 94:13, 94:19, 18:24, 24:4, Credits [1] - 120:7 75:15, 75:16,
7:9, 10:14 142:6, 142:14, 96:14, 96:19, 28:16, 28:23, crime [9] - 6:9, 84:22, 84:25,
considering [1] - 142:20, 142:21, 96:25, 99:9, 46:19, 46:21, 6:11, 6:13, 7:12, 104:17, 108:16,
88:8 142:22, 143:19 99:23, 100:4, 53:13, 58:11, 7:19, 8:3, 8:5, 108:24, 109:19,
conspiracy [21] - convincing [3] - 100:9, 100:10, 58:15, 59:9, 87:23, 89:21 109:20, 125:12,
3:4, 7:13, 8:8, 12:23, 35:8, 100:22, 101:23, 59:11, 59:25, crimes [1] - 6:6 126:16, 126:22,
28:24, 29:2, 142:14 101:25, 102:1, 60:3, 61:4, CRIMINAL [1] - 129:21, 130:20,
29:4, 52:17, cooperate [4] - 102:4, 102:20, 66:24, 67:4, 1:4 131:7, 132:3,
61:6, 62:20, 3:20, 66:5, 104:5, 104:6, 67:14, 67:19, 137:17, 139:18,
criminal [1] - 4:18
62:25, 114:17, 89:23, 115:25 104:10, 105:16, 68:4, 68:7, 139:21, 139:25,
CROSS [1] -
114:20, 138:15, cooperated [1] - 105:17, 105:21, 68:12, 81:19, 140:1, 140:6,
68:17
138:17, 138:21, 7:5 105:22, 107:11, 102:12, 103:14, 147:17, 147:20
cross [5] - 67:1,
138:22, 138:24, cooperating [2] - 114:21, 115:8, 103:17, 106:5, dated [1] - 149:11
67:25, 68:13,
139:1, 139:8, 6:21, 95:20 116:5, 117:14, 106:17, 106:21, Dated [1] - 154:6
68:15, 106:24
143:2, 143:5 cooperation [6] - 131:3, 139:11, 110:10, 110:13, dates [2] - 75:18,
CROSS-
contact [1] - 4:16, 5:7, 6:25, 139:13, 141:21, 110:15, 110:22, 75:19
EXAMINATION
45:10 7:2, 115:17, 152:5, 152:21, 110:25, 112:1, dating [2] - 76:22,
[1] - 68:17
containing [1] - 117:8 154:3 112:8, 112:17, 77:2
cross-
7:16 cooperative [1] - corrected [2] - 113:9, 113:11, David [1] - 2:7
examination [4]
contents [3] - 6:11 106:7, 152:19 138:5, 138:7, DAVID [2] - 1:11,
- 67:1, 68:13,
81:4, 107:15, cops [1] - 58:8 correctly [1] - 138:14, 138:20, 2:2
68:15, 106:24
107:19 copy [2] - 2:24, 97:1 138:25, 139:6, days [6] - 20:17,
cross-examine
continuation [1] - 52:11 Counsel [1] - 1:19 139:11, 139:17, 29:22, 85:5,
[1] - 67:25
40:25 correct [110] - counsel [5] - 140:10, 140:14, 95:24, 96:23,
cumulative [1] -
continue [9] - 24:5, 29:25, 67:16, 89:18, 142:24, 150:21, 121:21
58:16
61:9, 61:11, 38:14, 61:16, 151:2, 151:7, 151:11, 151:17, dead [1] - 54:18
current [2] -
62:19, 62:24, 68:25, 69:10, 152:20 151:25, 152:2, deal [4] - 6:20,
73:13, 73:25
67:7, 82:10, 69:13, 69:18, count [7] - 44:20, 152:4, 152:6, 7:8, 56:16,
custody [2] -
109:16, 140:14, 69:19, 69:21, 92:7, 92:8, 152:9, 152:12, 67:21
84:3, 108:7
141:12 70:1, 70:6, 70:7, 136:12, 143:24, 152:15, 152:18, dealt [1] - 56:5
customer [1] -
continued [1] - 70:12, 70:17, 145:17, 146:7 152:23, 153:2, deceased [2] -
125:2
96:10 70:23, 71:18, Count [2] - 3:3, 153:4, 153:15, 12:19, 12:22
continues [1] - 72:5, 72:17, 114:16 153:17, 154:8 December [1] -
5:19 72:19, 72:20, counted [5] - Court [7] - 3:7, D 84:15
controlling [1] - 74:13, 75:1, 41:12, 43:25, 5:6, 5:18, 67:11, decided [1] -
D.C [26] - 20:5,
94:9 76:2, 76:7, 44:1, 44:2, 111:5, 113:21, 86:22
20:10, 20:15,
conversation [27] 76:21, 76:25, 44:23 154:2 decision [1] -
29:22, 30:9,
- 15:6, 32:19, 77:11, 77:20, counter [1] - court [7] - 4:8, 107:2
31:4, 31:7, 47:2,
49:23, 50:10, 77:21, 77:23, 43:23 84:16, 86:4, deems [1] - 5:9
93:2, 93:25,
51:22, 53:10, 79:1, 79:4, 79:6, counting [5] - 86:15, 112:19, Defendant [21] -
94:12, 95:23,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 159 of 170
5
1:6, 1:17, 3:3, 65:9, 65:18, DiAngelo [1] - dismiss [1] - 5:11 43:15, 43:17, 27:25, 29:19,
3:4, 3:6, 3:20, 76:4, 77:14, 149:25 disobeying [1] - 44:9, 44:12, 31:13, 31:24,
3:22, 3:23, 3:25, 80:18, 81:14, differ [1] - 32:13 100:19 44:15, 46:4, 32:3, 33:22,
4:7, 4:13, 4:15, 84:4, 91:1, different [19] - distance [1] - 110:4, 110:5, 34:7, 34:8,
5:3, 5:14, 5:21, 96:11 27:11, 27:14, 83:18 110:6 34:15, 34:25,
6:4, 6:6, 6:7, delete [3] - 32:14, 74:25, 92:3, District [4] - dropped [5] - 35:7, 35:17,
114:16, 114:17 95:13, 95:16 93:24, 97:17, 113:20, 113:21, 22:2, 25:11, 37:6, 38:13,
defendant [13] - delivered [19] - 99:7, 99:15, 154:2, 154:3 29:15, 44:19, 38:20, 38:21,
4:17, 5:12, 6:12, 11:17, 13:6, 99:21, 101:1, DISTRICT [2] - 44:20 38:25, 39:4,
8:23, 8:24, 9:1, 13:20, 14:4, 103:3, 123:6, 1:1, 1:1 drops [1] - 43:8 39:17, 42:20,
60:3, 109:10, 22:4, 25:9, 26:7, 124:4, 124:8, DIVISION [1] - 1:2 drove [5] - 21:17, 43:4, 43:12,
109:15, 110:1, 27:16, 28:11, 125:17, 126:7, document [8] - 31:11, 35:5, 43:17, 44:9,
139:10, 139:12, 35:3, 35:8, 36:4, 142:11, 145:24, 3:8, 6:16, 23:19, 35:7, 123:21 44:12, 45:9,
143:1 38:4, 47:5, 147:25 91:23, 92:10, drug [1] - 56:19 51:9, 51:20,
Defendant's [5] - 48:11, 130:3, difficult [3] - 114:9, 114:23, drugs [2] - 56:18, 52:1, 52:9,
4:1, 4:10, 5:5, 130:6, 134:13, 18:19, 18:20, 118:8 58:9 59:20, 60:2,
5:7, 5:8 135:19 18:22 documents [4] - Dud [6] - 54:20, 60:3, 60:9,
defendant's [1] - delivery [10] - digging [2] - 56:1, 4:15, 28:7, 54:22, 55:2, 61:11, 61:22,
109:5 12:23, 13:20, 56:2 28:12, 28:20 55:3, 55:5, 62:11, 62:12,
definitely [1] - 13:22, 13:24, dime [2] - 112:3, dog [1] - 56:19 78:22 62:16, 62:24,
104:7 13:25, 14:9, 150:22 dogs [1] - 56:16 duly [2] - 2:2, 63:7, 63:12,
defraud [1] - 7:14 22:5, 26:6, DIRECT [2] - 2:9, done [5] - 59:8, 112:10 63:15, 63:21,
DELANEY [54] - 29:15, 129:21 112:22 115:22, 116:22, during [22] - 4:16, 64:9, 64:15,
2:10, 2:18, 2:19, denied [1] - 60:24 direct [9] - 23:4, 121:6, 149:1 7:3, 21:6, 26:17, 95:12, 107:21,
8:23, 9:2, 11:21, departed [1] - 75:14, 78:6, door [1] - 29:16 40:14, 72:12, 108:6
18:25, 23:18, 130:20 89:1, 103:12, dot [1] - 33:8 83:19, 83:24, Eghosah's [5] -
24:6, 24:8, departing [2] - 107:9, 107:21, down [18] - 16:4, 87:15, 87:18, 9:24, 32:24,
28:17, 29:5, 130:24, 131:10 125:1, 130:15 19:9, 24:23, 89:15, 91:2, 33:2, 52:14,
29:6, 40:15, Department [2] - directing [4] - 25:13, 29:11, 97:24, 99:6, 62:3
40:16, 45:1, 152:24, 153:9 114:7, 115:12, 50:11, 52:15, 99:11, 102:2, Eghosasere [1] -
45:2, 46:20, departure [2] - 129:10, 149:3 54:11, 55:10, 102:24, 105:2, 52:1
46:22, 46:23, 5:23, 19:12 direction [1] - 59:6, 80:1, 105:3, 133:4, EGHOSASERE
51:11, 53:16, describe [4] - 77:22 133:7 [1] - 1:5
91:10, 91:11,
58:14, 58:18, 15:5, 42:24, directly [2] - 4:17, 92:20, 108:8, dusbone [1] - Ego [52] - 9:11,
58:19, 59:10, 43:15, 46:6 25:9 110:16, 134:23, 23:9 32:2, 49:1, 49:9,
59:13, 59:14, described [1] - disbone [1] - 149:12 53:20, 56:4,
60:2, 60:5, 60:6, 63:21 23:13 downloaded [1] - E 58:2, 59:4,
61:7, 66:11, designated [1] - disclose [1] - 3:25 94:25 125:16, 127:3,
66:12, 66:22, 3:24 discloses [1] - downtown [1] - early [6] - 21:20, 127:4, 127:9,
67:18, 68:6, desperate [1] - 4:15 43:2 22:1, 27:6, 69:8, 127:16, 127:17,
68:10, 106:19, 24:24 disclosures [1] - downward [1] - 98:9, 100:8 127:19, 127:20,
106:23, 110:9, detail [3] - 92:22, 4:13 5:23 easier [1] - 23:20 127:24, 128:3,
138:6, 151:23, 117:8, 142:19 discovered [1] - East [1] - 83:22 128:6, 128:7,
dozen [1] - 44:14
152:1, 152:3, details [2] - 37:24, 127:25 eat [1] - 21:13 128:13, 130:7,
draw [3] - 2:20,
152:5, 152:7, 119:19 discuss [10] - ed [1] - 101:14 130:11, 131:14,
47:20, 81:16
152:10, 152:14, detained [1] - 59:20, 60:12, Eghosah [79] - 132:5, 132:13,
drawing [3] -
152:16, 152:19, 71:2 67:5, 69:16, 8:9, 8:11, 8:13, 132:20, 133:13,
17:7, 23:4,
153:1, 153:3, detective [1] - 69:17, 69:18, 8:17, 9:4, 9:12, 134:16, 136:15,
36:16
153:14 152:23 110:17, 141:23, 11:1, 11:11, 137:23, 138:2,
drew [3] - 102:6,
Delaney [19] - Detective [1] - 151:5 11:23, 12:10, 138:11, 139:15,
102:7
1:15, 58:11, 153:8 13:3, 13:11, 140:18, 141:4,
discussed [6] - drive [1] - 124:13
58:17, 59:12, 14:13, 14:17, 141:6, 141:20,
determination [3] 17:15, 64:7, Drive [1] - 129:25
61:4, 66:24, 17:12, 17:21, 142:4, 142:5,
- 7:4, 66:4, 69:12, 75:18, driver [6] - 12:24,
84:6, 87:12, 17:23, 18:4, 144:15, 144:16,
107:5 75:20, 138:1 13:25, 14:9,
90:3, 103:20, 19:17, 19:21, 144:17, 145:3,
determine [1] - discussing [2] - 26:6, 29:15,
105:8, 106:18, 20:7, 20:18, 146:16, 147:12,
116:15 75:13, 110:19 135:15
110:10, 116:9, 21:12, 21:15, 147:18, 147:21,
determines [2] - discussion [2] - driving [3] - 27:9,
116:19, 116:25, 21:17, 22:2, 148:3, 149:17,
5:12, 90:8 138:15, 142:3 56:20, 58:9
151:18, 151:22 23:12, 24:14, 150:15
dialogue [1] - discussions [1] - drop [13] - 12:24,
Delaware [10] - 25:22, 27:7, Ego's [10] -
58:12 88:8 27:7, 43:5,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 160 of 170
6
127:12, 129:2, 142:25 108:10, 108:19, 139:20, 141:13, figure [3] - 44:24, 2:13, 9:17,
130:2, 130:3, exact [1] - 84:25 109:18, 114:6, 144:23 88:10, 146:24 11:15, 12:14,
130:6, 137:16, exaggerate [1] - 114:8, 117:19, fairly [1] - 133:11 filtering [1] - 18:14, 18:18,
137:22, 140:3, 6:10 117:20, 120:6, false [1] - 6:7 35:14 18:20, 18:22,
150:17 examination [7] - 120:9, 124:25, falsely [2] - 6:8, fine [5] - 28:21, 52:17, 63:3,
eight [1] - 146:2 67:1, 68:13, 125:2, 128:16, 6:11 57:16, 67:2, 68:25, 70:11,
either [5] - 8:20, 68:15, 75:14, 129:8, 129:14, familiar [3] - 106:21, 130:15 70:16, 70:23,
21:1, 21:15, 89:1, 103:13, 130:16, 131:2, 74:25, 78:7, finish [3] - 71:25, 72:6,
134:8, 146:9 106:24 131:24, 137:3, 105:5 106:20, 151:19, 74:17, 74:20,
elderly [5] - 7:14, EXAMINATION 137:6, 149:6 family [3] - 66:10, 153:5 86:6, 86:8,
59:5, 60:22, [4] - 2:9, 68:17, exhibits [3] - 73:1, 89:4 finishes [1] - 86:16, 91:4,
69:10, 72:7 106:22, 112:22 59:9, 64:18, far [9] - 10:24, 151:23 91:10, 91:11,
employment [1] - examine [1] - 68:7 69:20, 75:22, first [54] - 2:21, 91:12, 93:6,
102:25 67:25 expand [2] - 86:19, 99:25, 5:20, 6:1, 9:22, 96:14, 113:8,
empty [4] - 12:20, except [1] - 4:19 46:10, 47:11 107:7, 118:22, 10:4, 15:3, 19:6, 113:10, 113:14,
12:21, 134:2 exception [1] - expect [1] - 142:5, 148:8 24:17, 24:25, 130:11
encrypted [2] - 68:8 151:24 fashion [1] - 68:9 26:17, 30:5, fly [1] - 18:5
95:5, 95:6 EXCERPT [1] - expected [1] - fast [2] - 40:19, 30:24, 33:1, focus [4] - 54:3,
end [5] - 107:3, 1:11 16:15 131:1 38:9, 41:16, 68:21, 68:23,
118:4, 118:11, exclamation [1] - expedite [1] - fat [1] - 56:5 42:19, 51:13, 133:12
122:20, 133:19 138:20 150:24 fat-ass [1] - 56:5 52:4, 55:21, focusing [1] -
ending [3] - 33:1, exclusively [1] - expensive [1] - fault [3] - 51:19, 61:14, 68:23, 149:6
49:25, 50:6 101:22 124:13 55:13, 55:17 72:3, 72:10, folio [1] - 125:5
enforcement [3] - excuse [7] - 10:8, experience [1] - FBI [3] - 84:18, 72:11, 87:3, folks [1] - 77:19
3:23, 3:24, 12:8, 48:5, 18:12 85:8, 91:14 87:15, 87:16, follow [1] - 98:12
116:1 50:24, 51:3, explain [2] - February [17] - 87:18, 92:23, followed [1] -
English [7] - 21:2, 51:6, 109:3 23:20, 133:23 53:1, 54:9, 93:5, 94:1, 153:6
33:24, 94:1, excused [6] - explained [1] - 68:24, 69:8, 95:25, 100:21, following [5] -
152:17, 152:21, 110:22, 110:24, 141:5 71:7, 71:8, 104:14, 114:14, 3:21, 6:5, 40:14,
153:2, 153:10 151:2, 151:11, explains [1] - 71:10, 71:16, 119:6, 119:12, 128:14, 130:8
enlarge [1] - 92:8 151:15, 151:16 92:10 75:15, 75:16, 120:18, 123:19, food [1] - 40:19
entered [3] - exhibit [7] - explanation [1] - 75:18, 107:8, 123:21, 124:5, FOR [1] - 1:1
68:11, 89:10, 46:19, 64:17, 141:10 107:14, 108:7, 124:6, 124:23, foregoing [1] -
91:25 65:10, 80:1, expression [1] - 108:17 125:1, 127:5, 154:3
entire [4] - 30:1, 103:14, 115:13, 62:9 FEDERAL [1] - 130:10, 131:6, forget [1] - 56:21
30:3, 35:19, 137:7 extent [2] - 5:6, 154:8 137:21, 139:17, forgive [1] - 68:22
89:13 Exhibit [69] - 28:25 federal [13] - 3:23, 144:14, 149:6, forgot [3] -
entitled [1] - 2:17, 3:1, 3:9, extra [1] - 143:9 4:18, 84:16, 149:15, 149:17 132:22, 136:18,
154:4 4:6, 15:21, 19:2, 85:12, 85:22, fit [1] - 57:14 150:1
five [12] - 39:19,
envelopes [1] - 20:12, 22:17, F 86:1, 86:4, format [1] - 154:4
39:15 24:4, 24:6, 86:15, 86:19, 44:14, 44:18, forth [2] - 4:19,
especially [1] - 32:16, 35:18, face [2] - 39:4, 86:20, 87:23, 49:9, 97:18, 5:22
58:9 40:6, 40:8, 41:2, 92:11 88:15, 116:1 98:1, 112:2, forward [11] - 3:8,
Esquire [3] - 1:15, 45:5, 46:9, facial [1] - 62:9 federally [11] - 112:3, 146:9, 3:12, 4:23, 5:24,
1:15, 1:18 46:20, 47:10, fact [18] - 3:6, 65:21, 66:2, 150:21 6:14, 23:15,
essentially [2] - 48:12, 49:21, 21:23, 64:5, 84:9, 84:11, flew [2] - 41:23, 41:24, 50:16,
98:17, 115:17 51:10, 51:12, 72:24, 73:9, 85:15, 85:19, 93:1 52:2, 58:20,
event [2] - 7:21, 51:14, 52:3, 78:17, 79:11, 86:6, 88:5, 91:1, flight [16] - 18:1, 131:1
110:18 52:10, 52:21, 79:19, 82:13, 102:15, 113:20 18:2, 19:5, 19:7, four [5] - 5:1,
eventually [11] - 52:22, 53:8, 84:3, 87:12, FedEx [3] - 19:10, 19:16, 85:5, 90:16,
15:13, 17:20, 54:24, 55:9, 88:2, 91:25, 129:18, 129:19, 19:18, 130:17, 98:1, 131:17
27:23, 28:9, 56:23, 59:10, 95:14, 102:14, 135:23 130:19, 130:20, fourth [1] - 137:7
35:12, 36:4, 59:19, 63:13, 105:20, 106:10, feds [2] - 56:5, 131:3, 131:6, frame [3] - 73:20,
37:3, 38:20, 63:25, 64:6, 128:7 58:3 131:7, 131:13, 75:5, 75:13
43:8, 84:11, 64:19, 65:5, factors [1] - 5:22 felt [1] - 31:3 131:18 frames [1] - 75:22
85:12 65:13, 66:14, facts [4] - 67:20, few [9] - 5:20, flip [1] - 23:16 Francis [3] -
evidence [3] - 67:16, 68:9, 67:23, 68:3 25:13, 56:17, floor [6] - 43:21, 151:24, 152:1,
67:24, 68:1, 78:13, 78:17, fair [8] - 79:16, 81:22, 82:10, 46:1, 103:24, 153:6
68:8 91:21, 91:23, 80:21, 82:19, 88:19, 91:1, 104:3, 104:8 fraud [6] - 3:5,
evidentiary [1] - 103:8, 103:15, 122:24, 126:24, 103:20, 104:20 Florida [33] - 7:13, 114:18,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 161 of 170
7
114:21, 137:20, Giant [1] - 30:25 63:13, 63:25, 110:12, 110:14, 73:5
I
139:19 girlfriend [6] - 64:5, 64:18, 138:4, 153:16 high-rise [3] -
free [1] - 67:25 7:25, 82:23, 66:14, 68:8, Guillaume [9] - 43:2, 43:20, ID [3] - 17:21,
Friday [2] - 49:11, 83:9, 94:3, 78:13, 81:16, 1:18, 66:25, 45:23 51:24, 52:14
134:1 109:12, 133:1 81:25, 82:10, 67:22, 68:15, highlight [5] - 5:1, idea [4] - 24:18,
friend [10] - 10:14, given [14] - 6:7, 91:21, 91:23, 106:6, 106:17, 5:20, 5:25, 35:15, 35:16,
73:10, 73:15, 22:5, 25:1, 103:7, 108:10, 110:11, 151:20, 45:14, 103:10 35:17
83:3, 88:16, 31:15, 31:17, 108:19, 109:18, 153:4 himself [1] - identified [5] -
105:6, 121:18, 38:5, 38:6, 39:1, 114:6, 114:8, guilty [14] - 3:3, 139:10 9:1, 33:1, 54:25,
122:1, 127:8, 99:3, 107:14, 117:19, 117:20, 3:6, 8:8, 9:23, hire [1] - 148:18 66:13, 78:18
134:7 107:17, 107:18, 120:6, 120:8, 66:4, 85:14, hired [1] - 144:19 identify [1] - 8:21
friend's [1] - 120:25 124:25, 128:16, 89:2, 89:11, hitting [1] - 54:2 idiot [1] - 58:7
122:4 gonna [1] - 129:14, 130:16, 89:21, 89:23, hold [2] - 152:2, IGBENIDION [1] -
friends [7] - 119:19 131:24, 137:3, 114:3, 114:12, 152:12 1:6
72:21, 73:21, Goo [5] - 1:15, 137:6, 149:6 114:16, 114:20 home [3] - 41:16, Igbinedion [1] -
73:22, 73:23, 112:4, 112:20, grand [2] - 4:8, guy [3] - 31:13, 80:20, 102:24 9:1
73:24, 74:1 139:18, 142:24 90:22 43:22, 132:21 homeowner [3] - Imma [1] - 55:13
front [5] - 29:16, GOO [18] - 112:6, grandmother [1] - guys [7] - 9:14, 80:20, 80:21, immediately [4] -
90:22, 114:8, 112:21, 112:23, 50:25 72:21, 73:5, 80:23 84:23, 85:2,
129:19, 135:22 113:13, 138:8, grandmother's 97:6, 101:24, homes [1] - 35:8 85:14, 104:19
frozen [2] - 23:19, 138:12, 138:19, [7] - 12:12, 133:15, 138:3 honestly [4] - Immunity [1] -
121:22 138:23, 139:2, 12:13, 14:2, 14:16, 25:24, 4:11
fuck [1] - 58:7 139:3, 139:5, 14:6, 15:10, H 75:21, 88:10 implicated [1] -
full [7] - 2:5, 8:14, 139:9, 139:14, 16:5, 93:7 Honor [25] - 24:7, 6:9
14:22, 15:18, 139:22, 140:15, grandparents [1] half [1] - 55:21 29:5, 46:22, implications [1] -
27:3, 49:4, 140:16, 143:4, - 59:5 hallway [1] - 67:6 58:18, 59:13, 67:24
112:12 150:19 gray [1] - 124:15 hand [4] - 73:9, 60:5, 66:23, important [5] -
fully [7] - 3:22, gook [1] - 55:14 great [1] - 150:23 73:12, 73:16, 67:2, 68:6, 28:6, 28:11,
3:25, 4:7, 4:15, Government [14] green [6] - 67:17, 96:8 68:16, 106:19, 28:19, 60:4,
5:3, 5:14, 116:1 - 3:25, 4:3, 68:14, 89:6, handed [2] - 110:9, 110:12, 151:21
funds [1] - 121:3 4:14, 4:16, 6:20, 90:15, 106:24, 16:14 112:6, 112:21, importantly [1] -
furnished [1] - 24:4, 24:6, 55:9, 110:16 hard [1] - 6:24 138:6, 138:12, 90:4
27:21 59:10, 67:16, Green [3] - 2:7, Harkey [2] - 138:19, 138:23, imposed [1] -
furtherance [11] - 78:17, 103:15, 67:6, 110:24 152:11, 153:8 139:2, 139:9, 92:15
28:24, 29:2, 125:2, 153:13 GREEN [2] - 1:11, head [2] - 58:4, 150:19, 152:21, IN [1] - 1:1
29:4, 61:5, government [17] - 2:2 78:22 153:1, 153:16 incarcerated [1] -
138:14, 138:15, 7:8, 86:23, grew [1] - 72:24 hear [5] - 6:24, HONORABLE [1] 91:2
138:17, 138:21, 88:18, 89:24, group [2] - 36:21, 17:10, 41:19, - 1:12 incentivize [3] -
139:1, 139:8, 90:1, 90:12, 37:2 79:24, 143:18 hope [1] - 117:9 134:4, 134:6,
143:2 90:13, 90:15, grow [1] - 9:14 heard [6] - 51:6, hopefully [2] - 135:17
92:1, 95:20, growing [1] - 73:7 72:10, 75:7, 118:9, 150:23 included [1] -
G 95:21, 107:2, guess [6] - 75:17, 78:10, 79:8, hoping [1] - 67:19
111:2, 112:5, 82:23, 116:16, 95:11 147:12 including [6] -
G-r-e-e-n [1] - 2:7 112:6, 115:18, 117:1, 125:16, hearing [1] - hotel [2] - 34:4, 5:9, 6:12, 69:12,
Gardens [1] - 116:19 127:16 57:20 57:7 70:17, 105:18
12:14 Government's guest [3] - 125:5, hearsay [2] - hour [1] - 25:24 incoming [2] -
general [5] - [60] - 2:17, 3:1, 137:14, 137:15 28:25, 67:24 house [11] - 13:6, 120:12, 120:20
75:16, 97:12, 3:9, 4:5, 15:21, GUILLAUME [28] held [2] - 34:10, 15:10, 16:5, incomplete [1] -
122:15, 140:7, 19:2, 20:12, - 11:18, 18:23, 154:4 26:7, 29:11, 6:8
147:17 22:17, 32:16, 28:15, 28:22, hell [1] - 58:3 74:14, 127:6, indicate [1] - 10:6
generally [2] - 35:18, 40:6, 67:2, 68:2, help [4] - 77:6, 127:12, 130:4, indications [1] -
109:9, 139:23 40:7, 41:2, 45:5, 68:16, 68:18, 113:2, 118:16, 130:6, 135:22 139:7
Ghose [7] - 23:11, 46:9, 46:20, 78:14, 78:15, 118:25 houses [4] - Indictment [2] -
24:12, 55:14, 47:10, 48:12, 80:1, 80:3, helpful [1] - 12:20, 12:21, 3:4, 114:17
57:8, 57:9, 49:21, 51:10, 81:18, 81:20, 139:17 25:13, 35:14 indictment [1] -
57:19, 108:20 51:12, 51:14, 82:2, 91:19, hereby [1] - 154:3 hundred [4] - 5:10
Ghose's [1] - 52:3, 52:10, 91:20, 102:11, hierarchy [1] - 132:18, 146:9, indirectly [1] -
109:2 52:21, 52:22, 102:13, 103:15, 144:11 147:4 4:18
Ghost [3] - 9:9, 53:8, 54:24, 103:18, 106:7, high [4] - 43:2, hurting [1] - 79:8 individual [5] -
23:9, 127:3 56:23, 59:19, 106:8, 106:16, 43:20, 45:23, 8:13, 15:21,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 162 of 170
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36:5, 42:2, intimidating [1] - 61:14, 61:15, joke [1] - 54:15 57:24, 58:7, 42:3, 70:3,
105:2 79:16 61:24, 62:4, Judge [1] - 1:12 58:12, 59:4, 77:19, 93:22,
individuals [2] - introduced [1] - 62:11, 63:12, judge [8] - 7:6, 70:7, 70:9, 108:4
48:19, 49:1 117:17 63:21, 65:2, 90:8, 90:11, 77:19, 93:22, Lancaster [1] -
indulgence [11] - introducing [2] - 66:20, 69:18, 107:6, 116:16, 107:24 65:4
2:18, 23:18, 73:9, 73:12 70:20, 71:21, 116:17, 117:4 Keion's [1] - 21:2 language [2] -
45:1, 51:11, investigation [1] - 72:3, 72:6, Judicial [1] - Kenyon [1] - 62:9, 72:16
66:11, 78:14, 5:13 77:23, 78:18, 154:5 49:11 large [3] - 43:5,
81:18, 91:19, investigators [3] - 79:4, 79:16, July [2] - 148:10, kept [1] - 66:16 100:23
102:11, 110:12, 9:22, 10:6, 10:9 80:4, 93:11, 149:11 Kerrigan [10] - larger [1] - 120:16
139:5 involved [19] - 93:13, 93:19, June [11] - 1:9, 5:1, 23:16, last [20] - 2:6, 2:7,
inform [3] - 5:5, 7:19, 8:3, 8:5, 93:21, 94:18, 137:4, 137:18, 24:16, 36:10, 15:3, 21:1, 21:2,
25:8, 94:18 8:7, 10:4, 10:7, 96:5, 96:6, 140:9, 140:10, 47:11, 51:22, 35:25, 36:19,
information [40] - 10:10, 34:24, 98:21, 98:23, 140:12, 140:18, 54:11, 59:7, 46:13, 47:16,
3:17, 4:1, 4:14, 37:10, 41:25, 99:3, 99:12, 148:10 92:7, 103:10 48:16, 106:3,
5:7, 6:7, 6:8, 42:5, 42:8, 99:16, 99:19, juries [1] - 4:8 Kilo [1] - 149:16 106:4, 112:12,
19:10, 22:5, 55:19, 56:18, 100:11, 101:3, jurors [1] - 139:20 kind [24] - 16:23, 122:23, 125:11,
22:6, 31:21, 69:9, 100:22, 101:5, 101:16, JURY [1] - 1:11 18:19, 25:13, 131:15, 149:12,
31:23, 32:3, 113:17, 119:21, 101:19, 101:20, jury [9] - 2:12, 25:16, 37:25, 150:14
38:3, 85:1, 87:9, 132:16 102:3, 105:9, 6:19, 7:11, 40:4, 48:20, late [1] - 67:9
88:23, 99:3, involvement [10] - 105:21, 105:23, 67:12, 67:14, 56:16, 63:12, latter [2] - 97:20,
99:16, 99:20, 6:10, 6:12, 9:24, 105:25, 106:12, 68:11, 90:23, 100:7, 102:6, 97:21
117:4, 120:1, 10:12, 10:17, 108:15, 117:18, 111:6, 151:16 110:5, 123:24, Laveensky [1] -
121:1, 127:13, 87:10, 87:19, 117:24, 118:22, Juste [2] - 152:7, 128:9, 128:12, 70:3
127:21, 128:6, 88:24, 117:16, 118:25, 119:11, 153:7 134:4, 135:20, law [4] - 3:23,
128:22, 129:18, 143:5 119:15, 119:17, juvenile [2] - 140:7, 141:3, 3:24, 92:15,
130:17, 130:19, it'll [1] - 23:20 119:23, 121:1, 76:18, 77:6 143:9, 144:2, 116:1
131:6, 131:7, itself [1] - 63:17 121:6, 122:3, 144:24, 147:25, lawyer [8] - 85:25,
134:25, 135:6, 122:15, 123:2, 148:18 86:3, 86:12,
137:14, 138:9, 123:7, 123:20,
K
J knowingly [1] - 86:14, 86:18,
145:20, 149:22 124:3, 124:13, K-R [1] - 32:10 6:7 87:7, 89:13,
informed [7] - jail [5] - 81:14, 125:18, 126:9, KASSANDRA [1] knowledge [8] - 89:14
20:4, 20:6, 82:17, 89:7, 126:10, 127:10, - 154:8 42:19, 62:24, learn [12] - 14:22,
21:19, 21:21, 106:25, 107:3 127:14, 127:19, Kassandra [1] - 88:1, 88:2, 15:12, 15:18,
26:10, 29:19, January [7] - 127:22, 127:24, 154:2 99:19, 99:24, 18:12, 19:24,
62:16 46:15, 47:17, 128:5, 128:6, keep [11] - 17:8, 139:8, 150:10 32:2, 42:13,
innocent [1] - 6:9 48:17, 48:18, 128:7, 132:5, 36:3, 40:3, known [7] - 62:10, 42:16, 59:3,
inquire [1] - 4:3 120:3, 120:16, 132:20, 133:5, 48:23, 49:10, 70:5, 74:1, 83:5, 117:25, 127:11,
inside [6] - 16:9, 120:18 133:8, 134:8, 53:13, 63:9, 95:5, 100:13, 138:9
16:13, 97:21, Jay [137] - 15:15, 134:18, 135:2, 98:18, 112:18, 101:24 learned [10] -
97:23, 97:24, 15:16, 15:24, 135:18, 136:5, 113:1, 135:10 knows [4] - 39:6, 52:16,
144:21 16:1, 16:4, 20:2, 136:7, 136:16, 127:19, 141:14, 52:19, 60:12,
Keiarah [15] -
instead [2] - 20:5, 21:9, 21:12, 143:25, 144:13, 148:17, 151:20 61:16, 79:3,
36:18, 36:21,
23:24 21:15, 21:17, 146:11, 147:25 Kramer [5] - 84:15, 94:3,
37:1, 53:18,
instructed [2] - 26:10, 27:1, Jay's [11] - 15:18, 54:4, 54:12, 113:23, 115:6, 100:8, 137:19
63:4, 63:6 27:7, 30:8, 33:15, 60:16, 54:19, 55:12, 115:8, 115:14 least [1] - 85:5
instructions [8] - 30:20, 30:21, 60:23, 77:25, 55:22, 55:23, Kyrie [2] - 76:16, leave [6] - 26:6,
25:1, 25:4, 25:5, 30:23, 31:22, 94:3, 123:23, 56:11, 57:17, 76:18 39:4, 77:18,
25:7, 39:1, 31:23, 32:3, 133:1, 136:17, 57:25, 59:15, 137:24, 143:25,
33:3, 33:4, 33:8, 147:21
94:15, 107:14,
Jersey [11] -
108:12 L 148:25
107:18 34:1, 34:20, Keiarah's [3] - leaving [4] - 10:4,
insure [1] - 40:4 36:4, 37:11, 31:19, 36:12, 36:19, 53:11, labels [1] - 63:4 96:3, 96:4,
intent [1] - 138:23 37:25, 38:14, 36:13, 37:22, 53:15 lady [8] - 20:24, 131:19
interaction [3] - 39:24, 41:8, 56:2, 56:8, 137:23, 137:25,
Keion [23] - Leevensky [2] -
80:21, 128:1, 41:9, 43:10, 105:1, 105:8, 138:1, 139:16,
20:25, 49:1, 42:3, 49:5
128:2 44:1, 47:9, 48:9, 105:20, 123:14, 140:25, 141:1,
49:2, 49:16, left [7] - 14:9,
interpreted [1] - 53:7, 54:16, 136:24 141:10
55:13, 55:14, 14:10, 16:1,
72:16 54:23, 54:25, jewelry [2] - 43:1, 55:17, 55:18, lady's [1] - 141:1 29:10, 58:6,
interview [1] - 58:6, 59:18, 46:7 56:3, 56:5, 57:8, Lake [1] - 51:1 131:8, 136:25
90:16 60:13, 61:2, job [1] - 7:22 57:18, 57:21, Lambert [5] - legal [1] - 107:13
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 163 of 170
9
length [1] - 134:4, 134:5, 43:2 95:4, 95:5, 88:18, 88:19, 127:13, 127:15,
141:23 134:10, 135:4, March [19] - 144:19, 147:23 90:4, 90:15, 127:25, 146:3,
less [1] - 95:24 135:17, 136:4, 45:16, 63:19, means [3] - 57:3, 93:10, 93:13, 146:6, 146:9
letters [1] - 138:1, 139:16, 63:23, 64:11, 106:11 94:1, 127:5 mistake [1] -
108:22 141:11, 149:23, 71:8, 75:19, meant [1] - 33:12 MIA [1] - 53:22 28:11
level [7] - 93:19, 150:8, 150:9 76:1, 77:9, Medard [7] - 78:7, Miami [15] - 2:13, modification [3] -
93:24, 100:18, locked [3] - 54:7, 77:13, 78:4, 78:9, 117:18, 12:14, 19:13, 46:13, 46:14,
144:16, 147:14, 71:3, 121:22 80:18, 83:25, 117:24, 118:1, 118:13, 119:5, 52:23
147:15, 147:18 LOL [1] - 55:17 87:3, 88:18, 118:2, 131:14 119:7, 130:23, modified [4] -
life [2] - 74:1, 74:2 Longview [1] - 90:25, 108:7, meet [7] - 36:13, 130:25, 131:11, 35:24, 35:25,
light [1] - 5:21 51:1 108:25, 109:21, 36:15, 37:18, 136:17, 137:1, 47:16, 48:16
limited [1] - 68:9 look [8] - 19:7, 154:6 43:22, 118:3, 137:2, 147:21 mom [3] - 128:2,
line [4] - 120:17, 51:14, 53:9, marked [7] - 2:16, 118:12, 127:3 microphone [5] - 128:3, 128:4
134:24, 150:7, 55:13, 57:13, 15:20, 19:1, meeting [8] - 2:5, 6:23, 53:14, moment [9] -
150:14 58:12, 109:18, 20:11, 22:17, 37:23, 42:7, 112:11, 112:18 23:18, 29:21,
lines [1] - 5:20 109:19 45:4, 91:22 87:6, 87:7, Mid [1] - 83:24 56:22, 68:22,
link [2] - 57:11, looked [2] - married [2] - 74:4, 87:15, 87:18, Mid-Atlantic [1] - 68:24, 78:21,
58:23 27:20, 35:8 74:7 93:15 83:24 84:6, 89:22,
list [5] - 48:18, looking [11] - Martha [2] - meetings [2] - middle [6] - 151:18
48:19, 64:21, 2:21, 19:9, 129:7, 129:12 87:19, 89:15 23:16, 23:21, moments [2] -
65:11, 65:14 28:19, 35:5, MARYLAND [1] - Melville [2] - 45:15, 50:17, 82:11, 103:20
listed [2] - 104:8, 35:7, 47:18, 1:1 49:12, 49:20 115:1, 125:10 Monday [1] - 1:9
129:17 53:2, 56:18, Maryland [19] - member [6] - 8:8, Mike [3] - 49:1, money [86] - 7:16,
listen [2] - 81:21, 58:22, 82:16, 1:10, 47:19, 36:21, 37:2, 49:2, 59:4 8:9, 8:10, 8:12,
81:22 134:2 47:23, 48:1, 62:20, 62:25, Mikey [6] - 49:3, 10:17, 10:20,
listing [1] - 48:22 looks [2] - 50:23, 48:3, 49:11, 138:20 56:4, 57:8, 10:22, 10:25,
lists [1] - 66:14 56:4 49:12, 74:22, member's [1] - 60:10, 70:5, 11:7, 11:8,
literally [1] - lump [1] - 43:5 83:23, 85:23, 124:11 108:4 16:15, 34:14,
55:25 lunch [4] - 67:8, 86:1, 86:15, members [5] - Mikey's [1] - 49:4 39:10, 39:11,
live [5] - 9:16, 106:20, 110:25, 88:15, 113:21, 2:12, 6:18, 7:11, Milk [6] - 54:20, 40:3, 40:5, 43:5,
9:18, 74:17, 111:1 123:14, 136:23, 52:17, 124:10 54:22, 55:2, 43:6, 43:9,
113:5, 113:7 147:24, 154:3 men [1] - 94:8 55:3, 55:5, 43:23, 43:25,
lived [5] - 9:21, M master [1] - 27:2 mental [1] - 78:22 44:1, 44:3, 44:4,
73:5, 73:7, match [1] - 57:9 139:12 mind [3] - 57:21, 44:10, 44:13,
113:14 ma'am [1] - matched [1] - mentioned [8] - 139:12, 143:1 44:15, 44:19,
living [12] - 7:24, 142:10 44:7 37:7, 49:3, mine [10] - 22:23, 44:20, 44:22,
28:3, 50:23, ma'ams [1] - matter [3] - 73:9, 68:23, 77:17, 35:23, 50:1, 62:13, 64:4,
69:2, 69:4, 69:5, 153:6 138:25, 154:4 103:20, 105:8, 50:11, 120:14, 69:20, 76:13,
69:6, 70:14, machines [1] - matters [6] - 4:2, 132:23, 133:15 121:19, 130:18, 79:13, 93:10,
74:9, 77:3, 91:4, 75:8 4:9, 150:24, mentions [1] - 132:2 96:2, 96:8,
134:9 mad [5] - 16:23, 151:2, 153:11 137:8 minimization [1] - 98:24, 103:2,
Lloyd [2] - 138:2, 140:25, maximum [2] - Mercedes [3] - 87:13 103:3, 107:7,
152:10, 153:8 141:3, 141:4 92:11, 92:14 27:10, 124:16, minimize [2] - 107:8, 110:6,
Lo [3] - 149:17, magazines [1] - McArnold [3] - 124:18 6:11, 10:12 110:7, 110:8,
149:24, 150:5 39:14 112:7, 112:14, mess [1] - 56:5 minimized [3] - 119:10, 119:15,
mail [7] - 3:5, 131:16 message [7] - 10:2, 87:13, 119:17, 120:2,
loan [1] - 10:25
7:13, 114:18, MCARNOLD [2] - 32:11, 101:17, 87:19 127:8, 127:10,
loaned [4] -
114:21, 123:4, 1:11, 112:10 103:7, 145:24, minute [5] - 127:12, 127:17,
10:16, 10:20,
123:8, 123:9 MCPHERSON [1] 149:11, 149:15, 58:17, 59:11, 127:18, 127:25,
10:21, 10:22
main [1] - 153:5 - 154:8 149:18 67:7, 67:10, 128:3, 128:4,
loaning [1] - 8:9
maintained [1] - McPherson [2] - messages [6] - 80:16 128:8, 134:8,
locally [1] - 65:25
88:3 112:19, 154:2 32:14, 95:13, minutes [1] - 134:9, 134:12,
located [3] - 65:3,
man [2] - 20:25, mean [14] - 4:20, 95:16, 149:10, 111:1 134:17, 136:4,
65:8, 86:16
36:18 38:1, 39:11, 149:12, 150:20 Miramar [3] - 136:9, 136:12,
location [25] -
management [1] - 40:11, 57:2, messed [2] - 28:7, 9:17, 113:8, 136:14, 141:17,
20:16, 20:19,
58:16 58:2, 60:19, 50:25 113:10 142:6, 142:9,
25:11, 36:6,
manager [4] - 99:22, 117:1, messenger [2] - misleading [1] - 142:13, 142:15,
99:13, 100:1,
144:24, 145:1, 125:25, 133:1, 32:4, 32:5 6:8 142:20, 143:12,
104:2, 104:4,
148:3, 148:9 133:23, 142:10 met [12] - 30:24, missing [8] - 143:22, 144:3,
110:2, 133:20,
Manhattan [1] - meaning [4] - 37:21, 79:11, 105:23, 127:9, 145:13, 145:17,
133:22, 134:2,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 164 of 170
10
146:6, 146:7, 21:2, 23:1, 33:3, 100:18, 101:7, Northeast [2] - obeyed [1] - 77:14
147:6, 147:9, 33:4, 33:15, 101:10 83:22, 83:23 100:16 once [6] - 86:3,
148:23, 148:25 33:17, 36:19, New [24] - 31:19, NORTHERN [1] - objection [7] - 90:25, 116:22,
monies [1] - 37:7, 42:2, 49:4, 36:12, 36:13, 1:2 11:18, 18:23, 127:24, 136:1,
98:18 57:8, 76:25, 37:22, 42:17, notation [1] - 28:15, 28:22, 145:13
month [4] - 37:13, 77:25, 78:2, 42:18, 42:23, 49:16 28:23, 29:4, One [2] - 3:3,
71:8, 85:15, 78:4, 78:5, 78:7, 43:1, 43:4, notes [22] - 1:25, 138:4 114:16
96:15 78:10, 78:11, 45:19, 64:7, 35:20, 35:22, Obligations [1] - one [64] - 22:22,
months [8] - 78:12, 78:24, 97:10, 97:11, 35:25, 36:2, 4:23 22:23, 23:18,
41:18, 41:20, 82:7, 105:2, 97:12, 97:13, 46:11, 46:16, obligations [1] - 23:25, 27:1,
83:24, 88:19, 105:5, 105:9, 97:19, 103:9, 46:24, 47:12, 5:15 27:12, 32:24,
91:1, 104:20, 112:12, 112:14, 103:25, 104:25, 47:14, 47:15, observation [2] - 38:2, 40:4, 41:5,
104:21, 104:23 117:18, 117:25, 105:8, 105:20, 47:16, 48:14, 44:22, 46:2 41:14, 44:24,
morning [10] - 121:25, 124:11, 123:14 48:15, 48:22, observe [9] - 44:25, 47:21,
2:11, 21:20, 125:2, 125:4, new [3] - 36:13, 65:5, 66:16, 26:20, 34:8, 48:2, 49:6, 49:8,
21:25, 22:1, 125:7, 125:8, 65:18, 124:7 66:19, 98:14, 34:11, 43:12, 58:3, 59:7,
27:6, 67:9, 125:10, 125:11, Newark [1] - 65:9 98:15, 98:17, 44:20, 62:3, 63:10, 70:3,
68:19, 68:20, 126:9, 126:14, news [7] - 58:23, 98:20 62:6, 146:12, 73:7, 75:2,
151:9, 153:12 126:15, 127:3, 58:24, 59:1, nothing [6] - 6:22, 146:16 75:10, 79:2,
most [7] - 74:2, 129:4, 129:6, 59:3, 60:13, 6:25, 28:21, observed [1] - 92:10, 94:12,
90:4, 101:5, 129:10, 130:18, 61:16 55:25, 57:19, 93:20 97:19, 99:25,
123:6, 124:24, 132:22, 136:18, newspaper [4] - 110:9 obviously [1] - 102:22, 103:4,
147:9 137:8, 137:10, 39:16, 70:20, noticed [1] - 89:6 103:9, 106:3,
mostly [1] - 137:15, 137:16, 70:23, 72:1 92:17 occupied [3] - 111:1, 114:24,
136:17 148:23, 150:1 next [22] - 4:4, notified [1] - 27:16, 27:17, 119:12, 122:5,
Motel [6] - 124:24, named [4] - 5:19, 12:25, 84:18 27:19 122:8, 122:12,
125:14, 131:23, 14:19, 31:13, 14:12, 14:18, November [1] - occur [2] - 124:2, 124:4,
137:15, 148:24 36:18, 76:16 15:9, 15:25, 36:1 120:25, 139:21 124:6, 124:10,
motel [1] - 137:11 names [5] - 9:20, 20:3, 21:25, number [45] - occurred [4] - 124:11, 124:12,
mother [6] - 8:1, 21:1, 36:16, 23:15, 23:17, 22:22, 22:24, 40:14, 52:19, 124:15, 127:15,
73:3, 82:6, 42:1, 132:21 24:3, 28:20, 32:24, 33:1, 139:21, 139:24 131:15, 133:2,
82:24, 83:16, narrow [1] - 29:18, 36:11, 45:5, 45:8, occurring [1] - 136:3, 138:20,
128:8 106:10 57:13, 112:5, 49:24, 49:25, 142:13 143:11, 146:3,
mother's [2] - nature [1] - 5:6 126:4, 126:13, 50:2, 50:4, 50:7, occurs [1] - 6:5 146:9, 147:4,
22:22, 23:1 near [2] - 45:22, 126:18, 133:20, 50:8, 51:15, October [2] - 147:11, 149:17,
motion [1] - 5:16 45:24 151:20 51:16, 51:18, 88:20 151:7, 152:2,
mouth [2] - 55:24, necessarily [4] - nickname [2] - 51:19, 53:11, odd [2] - 57:18, 152:12
72:19 67:20, 74:25, 23:2, 78:21 53:15, 87:1, 58:1 online [1] - 70:25
move [5] - 3:8, 75:16, 147:17 nicknames [1] - 92:10, 103:21, OF [4] - 1:1, 1:3, oops [1] - 103:11
23:3, 45:14, need [3] - 29:1, 9:8 104:7, 108:23, 1:11, 154:1 open [20] - 13:15,
58:16, 58:17 104:11, 134:17 nighttime [1] - 119:25, 125:23, offense [1] - 3:7 26:18, 26:20,
moved [1] - 74:17 needed [1] - 16:4 126:5, 126:19, offenses [1] - 3:7 38:10, 38:15,
moving [2] - 4:23, 18:13 nine [1] - 146:2 129:13, 129:15, offered [5] - 8:11, 38:21, 39:21,
41:24 needs [1] - 54:13 NO [1] - 1:4 129:17, 135:4, 11:8, 11:10, 41:12, 100:8,
mug [1] - 153:15 neighbor's [1] - nobody [2] - 137:24, 137:25, 28:25, 29:1 107:17, 107:20,
multiple [2] - 13:6 103:5, 103:6 145:19, 151:22, 107:22, 107:24,
Office [4] - 3:20,
99:12, 99:20 neighborhood [1] none [2] - 102:23, 151:25, 152:5, 108:1, 136:4,
4:18, 4:24, 5:6
mutual [2] - - 93:7 102:25 152:8, 152:13, 136:10, 136:14,
office [7] - 4:9,
73:10, 73:15 neighboring [1] - noon [1] - 67:9 152:18, 153:7, 144:18, 145:11,
5:5, 5:9, 5:10,
mystery [1] - 12:15 norel [1] - 83:10 153:8, 153:10 146:21
5:12, 5:16,
141:17 neighbors [1] - Norel [2] - 76:25, numbers [5] - opened [5] -
43:22
12:12 83:15 22:18, 22:19, 26:15, 26:22,
officers [2] - 3:24,
nervous [3] - normal [1] - 32:11 22:21, 32:18, 39:25, 146:25,
N 108:22
56:18
147:11
55:24, 56:3, Norman [4] - OFFICIAL [2] -
name [69] - 2:5, 58:3 152:22, 152:23, opening [11] -
154:1, 154:8
2:6, 2:7, 2:11, Nervous [1] - 56:3 152:24, 153:8 O 38:7, 39:18,
often [2] - 134:20,
8:13, 8:14, never [10] - 56:5, North [3] - 48:1, 104:13, 104:15,
136:11
14:22, 15:3, 69:12, 73:23, 149:17, 150:15 o'clock [4] - 136:7, 146:5,
older [1] - 62:17
15:14, 15:18, 73:24, 78:5, north [2] - 60:18, 112:2, 112:3, 146:12, 146:16,
Oliver [4] - 76:16,
20:24, 20:25, 95:11, 98:3, 91:6 150:21 146:18, 146:19,
76:18, 77:5,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 165 of 170
11
148:21 25:25, 26:1, 22:3, 22:7, 58:20, 58:21, passed [1] - 85:5 period [3] - 89:7,
operation [11] - 26:5, 26:7, 26:8, 26:13, 26:15, 58:22, 59:15, passenger [3] - 131:18, 147:17
27:12, 63:2, 26:11, 27:11, 26:18, 26:20, 64:6, 64:14, 130:17, 131:6, permit [1] - 4:13
71:14, 71:18, 27:15, 28:10, 26:22, 27:3, 92:4, 92:6, 131:13 permitted [1] -
77:11, 97:13, 28:19, 29:12, 30:1, 30:14, 108:10, 108:21, passengers [1] - 139:13
98:10, 102:25, 30:6, 39:3, 39:9, 30:15, 31:9, 109:18, 114:23, 19:16 person [27] - 6:9,
104:14, 119:20, 40:4, 41:25, 31:21, 33:20, 114:24, 114:25, Paul [2] - 113:23, 6:10, 6:12,
128:10 43:9, 48:21, 34:5, 34:9, 115:10, 115:11, 115:6 15:14, 29:3,
opportunity [8] - 60:10, 63:10, 34:11, 35:3, 115:12, 125:1, pause [1] - 40:15 38:9, 39:4, 44:1,
8:11, 11:8, 65:20, 71:14, 35:8, 36:3, 125:20, 125:21, pausing [1] - 44:3, 53:18,
11:10, 11:12, 76:10, 77:7, 36:22, 36:25, 126:4, 126:5, 124:3 54:25, 76:16,
37:18, 62:3, 77:10, 80:20, 37:2, 38:3, 38:7, 126:13, 126:18, pay [8] - 7:22, 78:18, 79:17,
115:7, 118:14 81:5, 87:10, 38:10, 38:15, 131:24, 137:7, 11:4, 30:21, 80:4, 99:25,
opposed [1] - 93:5, 93:9, 38:22, 39:7, 154:4 31:1, 33:5, 105:10, 117:20,
106:12 93:13, 93:18, 39:18, 39:21, pages [3] - 6:15, 33:12, 34:14, 131:25, 132:11,
opposite [1] - 99:6, 99:13, 39:25, 41:12, 58:14, 92:3 137:11 132:12, 134:10,
57:8 104:15, 105:4, 42:11, 47:4, paid [14] - 21:14, paying [1] - 134:11, 134:12,
order [10] - 4:13, 105:10, 107:8, 48:11, 48:23, 30:9, 30:11, 106:12 148:19, 152:16
6:11, 64:4, 107:10, 107:15, 56:21, 60:20, 30:13, 30:19, payments [1] - personal [1] -
68:22, 100:16, 107:18, 107:19, 60:21, 61:9, 30:23, 31:2, 80:7 98:15
100:19, 110:19, 107:20, 107:22, 61:11, 61:25, 48:24, 48:25, Peimee [2] - 33:5, personally [3] -
151:20, 151:21 107:24, 108:2, 63:5, 65:20, 80:14, 98:23, 33:12 42:10, 44:15,
orders [1] - 94:12 113:17, 117:17, 69:9, 76:13, 119:8, 119:10, Pele [3] - 75:7, 96:7
organization [2] - 119:6, 119:13, 94:19, 96:24, 119:11 75:10, 75:24 persons [2] -
80:5, 105:10 119:19, 122:11, 99:11, 100:5, pal [1] - 153:7 Peleton [1] - 75:6 63:10, 99:21
originally [1] - 124:20, 127:6, 100:9, 100:21, Paliwal [1] - 152:3 Peloton [3] - 75:3, pet [1] - 48:24
41:23 127:12, 127:17, 101:1, 101:3, paragraph [8] - 75:4 Philadelphia [13]
otherwise [1] - 127:18, 127:25, 103:2, 104:13, 2:21, 3:2, 3:18, - 31:7, 31:8,
Pennsylvania [2]
138:16 128:20, 130:3, 109:16, 109:17, 4:5, 4:11, 6:3, 31:10, 31:15,
- 65:4, 74:10
outline [1] - 130:6, 133:21, 118:17, 118:21, 114:13, 114:15 31:19, 31:20,
people [49] - 7:14,
150:20 134:3, 134:5, 119:1, 123:4, paraphrase [1] - 33:19, 34:13,
9:11, 24:23,
outside [2] - 16:9, 134:12, 135:13, 123:7, 123:11, 141:8 36:8, 36:11,
29:1, 38:5, 38:6,
136:24 135:16, 135:18, 132:7, 132:12, pardon [1] - 113:9 53:3, 104:25,
41:24, 54:20,
outsider [1] - 135:19, 136:1, 132:13, 132:15, parking [1] - 105:1
60:22, 69:24,
147:22 136:2, 136:3, 132:18, 133:15, 30:25 Phone [1] - 82:1
77:9, 77:13,
overruled [1] - 136:4, 136:5, 133:18, 133:25, part [14] - 24:4, phone [26] -
77:16, 78:24,
11:19 136:20, 137:22, 135:1, 136:7, 61:9, 61:11, 14:19, 15:11,
79:6, 79:8, 80:7,
137:23, 138:2, 136:10, 137:20, 74:17, 85:20, 16:1, 19:21,
owed [3] - 79:13, 93:22, 98:24,
141:7, 141:9, 145:4, 145:6, 97:13, 101:5, 22:18, 22:21,
89:4, 98:18 99:7, 99:12,
142:2, 143:6, 145:9, 146:12, 105:3, 113:25, 22:22, 22:24,
own [3] - 7:11, 100:18, 102:3,
144:21, 144:22, 146:16, 146:22, 121:11, 128:3, 32:18, 32:24,
18:15, 128:7 102:23, 103:1,
145:8, 145:12, 147:5, 148:25, 134:9, 137:20, 43:25, 44:6,
105:16, 106:13,
145:13, 145:15, 149:23, 150:6, 141:4 45:10, 50:2,
P 145:17, 145:24, 150:18
107:18, 126:10,
participants [5] - 126:11, 132:14, 54:18, 57:19,
P-e-i-m-e-e [1] - 146:1, 146:5, packet [2] - 49:22, 51:15, 66:16, 82:12,
134:9, 136:16,
33:14 146:19, 146:23, 135:18, 144:18 53:9, 63:14, 94:25, 95:21,
137:12, 142:9,
147:7, 147:10, packs [1] - 49:12 149:7 98:15, 129:15,
p.m [9] - 23:6, 142:13, 142:21,
147:12, 148:22, page [64] - 3:1, participation [3] - 137:24, 137:25
55:16, 67:13, 143:13, 143:15,
148:25, 150:9, 3:8, 3:10, 3:12, 87:15, 113:19, photo [1] - 128:17
68:11, 110:24, 143:19, 143:25,
150:11, 150:13 4:4, 4:5, 5:19, 140:4 photograph [1] -
111:6, 111:7, 144:5, 144:8,
151:16, 153:19 packaged [1] - 23:3, 23:15, particular [1] - 135:5
144:11, 144:19,
39:13 23:16, 23:17, 99:13 phrased [1] -
pack [1] - 43:11 145:6, 147:21,
packages [104] - 23:21, 24:3, particularly [1] - 85:17
package [120] - 148:17, 149:3
7:16, 8:11, 45:14, 45:15, 100:19 physically [2] -
13:22, 14:3, people's [1] -
11:13, 11:14, 50:16, 50:17, parties [1] - 34:24 79:6, 86:16
14:9, 14:10, 88:24
11:17, 11:24, 52:3, 52:4, 54:3, parts [1] - 85:21
14:14, 14:18, peoples [1] - 87:9 pick [41] - 11:13,
12:24, 13:1, 54:10, 55:9,
15:7, 16:2, 16:9, party [6] - 32:19, per [3] - 132:10, 16:2, 17:16,
13:5, 13:9, 55:10, 55:16,
16:14, 16:25, 56:10, 142:15, 132:11, 140:6 18:9, 27:11,
13:12, 17:4, 55:20, 56:23,
25:2, 25:9, 142:20, 143:12, perhaps [2] - 30:1, 31:9,
17:13, 17:16, 57:5, 57:10,
25:17, 25:19, 143:20 117:3, 140:19 36:25, 41:25,
18:8, 18:10, 57:14, 58:10,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 166 of 170
12
42:11, 42:22, 2:24, 3:13, 3:16, prepackaged [1] - protective [1] - 110:14 90:9, 121:6,
42:24, 48:19, 67:17, 67:19, 43:10 94:6 quick [1] - 112:1 121:9, 145:6
48:20, 48:21, 89:22, 91:25, preparation [1] - provide [6] - 3:16, quickly [1] - 64:17 received [11] -
48:22, 49:9, 114:1, 114:12 90:19 12:5, 12:7, quote [1] - 107:9 14:19, 32:3,
61:9, 61:11, Plea [1] - 115:13 present [7] - 98:21, 99:19, 85:1, 88:14,
65:11, 65:14, plead [5] - 3:3, 44:20, 61:18, 122:1 R 93:12, 96:3,
76:10, 77:7, 66:4, 89:11, 72:12, 97:18, provided [6] - 96:4, 99:16,
77:11, 87:10, 114:3, 114:16 105:2, 135:23 5:13, 12:25, raised [1] - 2:14 141:7, 145:10,
99:6, 99:11, pleaded [1] - 8:8 presented [1] - 30:16, 47:4, ran [1] - 55:24 145:23
99:20, 122:11, pleading [2] - 35:17 117:8, 121:25 Range [1] - 16:12 receiver [1] -
123:11, 132:12, 9:23, 89:23 pressed [1] - providing [1] - ranged [1] - 41:13 128:21
132:13, 135:16, pled [4] - 85:14, 23:24 30:17 Raven [3] - 105:1, recently [2] -
144:21, 150:6, 89:2, 89:21, presumably [3] - pull [8] - 6:23, 105:2, 105:6 12:19, 90:19
150:8, 150:10, 114:20 70:12, 85:25, 32:25, 63:16, RDB-21-00054 [1] recess [7] - 67:7,
150:13, 150:18 point [34] - 26:24, 100:25 64:17, 91:18, - 1:4 67:9, 67:10,
picked [14] - 7:16, 34:13, 34:17, presuming [1] - 103:8, 129:8, re [1] - 138:12 67:11, 67:13,
21:12, 22:3, 37:18, 38:2, 87:6 131:2 re-ask [1] - 138:12 110:25, 111:5
26:8, 27:7, 39:6, 65:15, pretending [3] - pulling [3] - 41:2, reached [1] - RECESS [1] -
29:17, 30:15, 65:21, 69:21, 101:7, 101:11, 50:9, 108:10 114:1 111:7
31:21, 34:6, 70:11, 71:2, 101:13 purpose [7] - reaction [3] - recognize [29] -
34:9, 48:23, 71:5, 71:20, pretty [8] - 22:1, 35:1, 36:2, 44:6, 60:23, 62:4, 3:9, 3:13, 6:16,
94:18, 100:5, 73:20, 74:10, 34:24, 53:24, 47:3, 93:15, 62:6 8:18, 15:21,
145:4 75:2, 75:10, 56:3, 74:2, 98:9, 109:14, 121:17 read [38] - 3:2, 15:23, 19:2,
picking [23] - 75:11, 76:1, 147:19 purposes [1] - 3:18, 3:19, 4:6, 20:12, 20:14,
11:14, 17:4, 85:13, 85:14, previously [8] - 112:19 4:12, 6:1, 6:3, 22:17, 22:18,
17:13, 18:8, 87:16, 113:16, 10:16, 40:7, pursuant [4] - 19:10, 23:8, 32:18, 35:19,
30:13, 36:22, 114:1, 119:20, 50:10, 75:13, 4:16, 5:16, 23:23, 24:9, 45:5, 45:16,
37:2, 60:20, 121:23, 125:18, 77:10, 77:16, 115:21, 154:3 32:25, 47:21, 46:11, 47:12,
61:25, 65:20, 127:2, 135:1, 78:16, 116:5 pushed [1] - 47:24, 49:8, 49:22, 49:24,
69:9, 118:16, 136:6, 137:19, primarily [1] - 128:1 49:17, 53:18, 49:25, 50:4,
118:21, 119:1, 147:16, 148:8, 85:21 put [27] - 2:16, 55:22, 57:15, 50:9, 51:16,
123:7, 124:20, 153:15 print [1] - 23:13 3:23, 15:20, 57:16, 59:2, 82:3, 91:23,
132:7, 132:18, pointed [2] - 8:24, prison [1] - 92:11 19:6, 22:16, 70:20, 70:25, 117:20, 120:8,
133:15, 133:18, 90:3 Probation [1] - 32:16, 33:12, 71:24, 114:14, 128:16, 128:24
134:2, 137:20 pointing [2] - 5:6 35:18, 40:6, 120:17, 126:14, recollection [1] -
pickups [1] - 23:22, 47:21 problems [1] - 45:3, 45:4, 46:9, 126:19, 129:3, 118:9
49:17 Police [2] - 79:13 47:10, 48:12, 129:6, 129:11, recommendatio
picture [3] - 152:24, 153:9 proceed [2] - 51:10, 51:12, 129:13, 129:15, n [3] - 90:13,
17:21, 128:19, police [8] - 56:15, 68:13, 112:20 51:13, 52:21, 129:18, 130:19, 116:8, 117:13
129:15 57:4, 57:21, proceeded [1] - 54:24, 63:13, 131:7, 149:15 record [18] - 8:23,
pissed [1] - 58:6 60:11, 80:23, 29:11 63:25, 64:5, reading [5] - 3:18, 8:25, 19:5, 36:3,
place [5] - 10:5, 80:24, 81:3 proceeding [1] - 96:7, 128:12, 4:24, 36:5, 38:23, 38:24,
40:22, 43:23, poorly [1] - 85:17 4:8 139:17, 148:22, 71:25, 142:18 39:2, 39:25,
63:17, 127:6 porch [7] - 13:25, proceedings [2] - 148:25 ready [1] - 68:12 57:12, 66:13,
placed [5] - 26:8, 14:1, 14:2, 14:3, 153:19, 154:4 putting [7] - 19:1, Reagan [1] - 78:16, 91:22,
29:17, 39:3, 14:6, 14:10, Professional [1] - 20:11, 23:20, 131:11 112:13, 120:17,
40:22, 43:10 14:11 154:2 24:3, 49:21, real [5] - 49:4, 126:14, 142:24,
places [3] - 70:17, portion [4] - 4:25, promise [2] - 51:13, 108:19 77:25, 78:2, 145:25, 146:5
102:24, 136:19 120:7, 120:15, 116:8, 117:10 78:3, 78:5 recorded [1] -
Plaintiff [2] - 1:3, 134:12 promised [2] - Q really [4] - 18:3, 39:17
1:14 position [1] - 6:22, 7:1 29:20, 101:24, recording [2] -
plan [2] - 68:2, 145:2 quantity [1] - 144:20 82:3, 145:25
promptly [4] -
150:25 possibly [2] - 145:13 reason [1] - 143:3 recross [1] -
11:4, 111:2,
platform [1] - 62:17, 118:8 111:3, 151:1 questions [13] - reasons [3] - 110:11
40:22 potential [1] - prosecution [1] - 3:23, 28:24, 18:15, 18:17, recruit [2] - 75:3,
play [3] - 40:12, 92:11 56:1, 66:22, 79:2 75:4
5:14
41:2, 151:24 precipitated [1] - 77:18, 81:23, recanted [1] - recruited [1] -
prosecutor [1] -
played [3] - 40:14, 10:17 103:3, 104:24, 56:4 77:5
86:23
82:1, 82:12 preliminary [1] - 106:4, 106:16, receive [6] - redirect [1] -
protecting [1] -
plea [10] - 2:23, 150:24 109:1, 109:4, 16:15, 16:18, 106:18
10:14
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 167 of 170
13
REDIRECT [1] - relevant [1] - 5:9 5:18, 5:23 67:11, 111:5 28:12, 73:5 41:9, 48:6, 48:8,
106:22 remain [3] - 29:7, require [1] - 4:9 role [4] - 10:2, scouting [3] - 50:25, 51:24,
reduction [1] - 62:19, 62:24 required [1] - 36:24, 87:14, 98:21, 134:11, 135:3, 135:5,
90:8 remaining [1] - 115:21 144:24 134:15 135:7, 142:6,
refer [1] - 83:23 57:13 requirements [1] romantic [1] - scraps [1] - 27:3 142:13, 142:15,
reference [7] - Remedies [1] - - 90:4 37:5 screen [14] - 2:16, 142:20, 146:10,
56:7, 56:8, 5:24 reservation [1] - room [6] - 125:23, 15:20, 19:1, 146:11
64:18, 67:22, remember [55] - 132:1 126:4, 126:19, 20:11, 22:16, sender [11] -
89:22, 139:18, 9:20, 13:10, reserve [1] - 126:24, 145:11 23:5, 23:19, 129:4, 129:5,
148:8 14:16, 17:1, 126:9 Room [1] - 126:1 32:16, 35:18, 129:6, 137:24,
referenced [3] - 17:2, 17:7, residence [1] - rooms [4] - 126:7, 45:3, 45:4, 137:25, 141:1,
68:8, 70:19, 19:18, 21:1, 29:7 126:9, 126:21, 48:13, 114:8, 141:2, 142:6,
78:6 21:15, 25:24, residents [1] - 137:11 120:16 142:15
referencing [1] - 26:10, 27:9, 12:22 rough [1] - 128:4 screenshot [4] - sending [4] -
75:17 29:20, 31:14, respect [8] - 4:1, roughed [1] - 129:14, 135:2, 50:18, 50:22,
referred [2] - 9:4, 37:24, 38:9, 4:9, 5:7, 58:12, 128:7 145:21, 145:22 52:8, 142:9
78:18 40:17, 41:11, 104:24, 106:9, roughly [1] - se [1] - 140:6 sends [1] - 24:9
referring [4] - 41:14, 41:24, 139:6, 139:7 37:13 sealed [2] - 6:4, Senior [1] - 1:12
23:11, 24:13, 42:1, 42:7, 42:9, respond [2] - Rover [1] - 16:12 115:14 sent [12] - 28:7,
96:24, 124:16 50:7, 50:20, 3:22, 128:7 row [1] - 129:11 Sealed [5] - 2:23, 42:22, 48:9,
reflect [2] - 8:23, 50:21, 50:22, responded [1] - RPR [1] - 154:8 3:13, 5:4, 5:15, 50:20, 52:11,
8:25 56:13, 56:17, 141:6 rule [1] - 100:8 115:13 64:24, 66:20,
refocus [1] - 58:24, 71:7, response [11] - rules [1] - 98:8 Sean [1] - 1:15 95:17, 99:12,
80:17 71:9, 75:21, 24:11, 28:14, ruling [1] - 142:25 seated [3] - 68:14, 127:6, 137:22
refresh [1] - 118:9 75:22, 75:24, 29:3, 51:25, running [2] - 80:4, 112:4, 151:18 sentence [5] -
regard [2] - 84:14, 84:18, 53:21, 54:1, 136:20 second [17] - 5:21, 90:8,
119:24, 138:23 84:22, 84:25, 54:6, 54:17, 27:4, 30:5, 30:6, 116:8, 116:15,
regarding [2] - 88:10, 96:2, 64:12, 89:3, 52:2, 54:3, 117:13
99:24, 104:17,
S sentenced [1] -
70:20, 71:24 108:14 61:15, 69:7,
regardless [1] - 105:1, 109:23, responsibility [9] safely [1] - 140:19 72:6, 87:16, 116:12
110:1 121:10, 121:11, - 38:6, 66:8, Saint [1] - 153:7 92:6, 124:3, sentencing [4] -
Registered [1] - 124:10, 124:14, 143:6, 143:10, sale [1] - 35:14 129:11, 133:4, 5:5, 5:9, 5:11,
154:2 127:14, 132:21, 143:11, 144:21, sat [2] - 25:16, 144:15, 150:7, 7:3
regular [1] - 141:25 144:24, 148:21, 127:14 152:2, 152:12 separate [2] -
101:17 remembering [1] 150:17 Saturday [4] - seconds [1] - 71:24, 138:25
regularly [2] - - 97:1 responsible [6] - 49:12, 49:14, 81:22 September [10] -
31:1, 31:2 remind [2] - 17:8, 34:5, 135:13, 97:1, 97:2 Section [2] - 5:17, 19:8, 19:11,
regulations [1] - 55:18 144:14, 147:1, saw [5] - 89:21, 5:22 41:23, 75:17,
154:5 remove [4] - 36:9, 148:14, 148:20 100:18, 104:15, section [1] - 5:17 83:25, 92:23,
related [2] - 46:8, 59:19, rest [1] - 33:7 147:9, 148:2 secure [2] - 95:3, 104:14, 140:12,
60:17, 72:7 63:4 restaurant [1] - scam [1] - 69:10 95:5 140:18
relation [3] - rented [1] - 40:19 scared [1] - 56:6 security [1] - 7:21 sequestration [1]
140:3, 140:4, 126:24 result [2] - 71:3, scene [3] - 40:6, see [24] - 23:5, - 110:19
144:11 rephrase [5] - 113:19 80:24, 81:11 23:22, 26:15, series [1] - 108:22
relationship [5] - 32:2, 85:16, retrieve [3] - scheduling [2] - 33:8, 33:9, services [1] -
37:4, 37:5, 99:15, 138:17, 60:10, 109:16 151:2, 151:17 35:24, 49:7, 34:14
83:10, 83:18, 139:6 retrieved [3] - scheme [25] - 49:16, 51:15, set [5] - 4:19,
83:19 reported [2] - 14:18, 26:1, 7:14, 9:24, 52:23, 78:13, 5:22, 73:25,
relationships [1] - 106:11, 154:4 63:5 10:10, 10:13, 101:13, 104:11, 77:18, 150:19
37:1 REPORTER [2] - return [2] - 37:16, 10:17, 55:19, 114:25, 125:2, setting [1] - 90:16
relative [2] - 154:1, 154:8 91:6 59:5, 61:9, 125:23, 137:5, seven [1] - 95:24
76:22, 77:5 reporter [1] - review [2] - 115:7, 61:12, 62:16, 137:8, 146:6, severe [1] - 128:2
relatively [1] - 112:19 115:14 72:7, 105:4, 146:18, 147:12, shall [3] - 3:22,
9:19 Reporter [1] - reviewed [3] - 110:7, 110:8, 150:25, 151:8, 3:25, 4:7
released [7] - 154:2 40:7, 50:10, 113:17, 113:19, 152:23 share [1] - 117:4
59:16, 59:20, represented [2] - 50:14 117:16, 117:17, seeing [1] - 58:24 Shifflet [4] -
71:5, 71:9, 84:3, 89:15, 113:23 RICHARD [1] - 118:15, 136:20, selling [1] - 152:22, 152:23,
108:7, 108:13 representing [2] - 1:12 137:20, 139:20, 127:19 152:24, 153:9
relevance [1] - 86:1, 86:14 rise [5] - 43:2, 143:6, 144:11 send [19] - 17:21, shipper [1] -
18:23 requesting [2] - 43:20, 45:23, school [2] - 33:3, 36:4, 41:8, 129:10
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 168 of 170
14
shipping [1] - snitching [1] - 76:12, 103:1, 11:15, 42:19, stood [1] - 25:15 22:7, 25:1, 33:5,
129:18 57:24 103:2, 107:9 43:8, 98:9, stop [10] - 4:4, 50:25, 93:10,
shit [2] - 56:3, someone [9] - Southway [2] - 104:14, 119:5, 40:12, 56:9, 134:25, 150:5
57:7 10:14, 10:16, 47:23, 48:3 128:13, 130:7, 56:10, 81:22, surprised [1] -
short [2] - 38:2, 10:20, 10:22, space [1] - 23:24 130:10, 148:6, 112:3, 114:19, 62:7
88:6 82:16, 98:3, Spark [1] - 129:7 150:22 133:3, 150:21, surrounded [1] -
shortchanged [1] 98:7, 105:8, Sparks [1] - starting [2] - 150:22 60:11
- 79:12 127:3 129:12 54:11, 149:11 stopped [3] - surroundings [1]
shortly [1] - 86:22 sometime [5] - speaking [6] - starts [1] - 130:8 56:15, 73:23, - 12:12
show [7] - 48:18, 25:25, 39:15, 2:4, 51:18, state [11] - 2:5, 73:24 sustained [7] -
117:19, 118:8, 62:17, 71:11, 53:20, 60:1, 17:17, 36:6, storage [3] - 18:24, 28:16,
135:15, 135:24, 140:18 112:11, 139:23 76:4, 84:7, 148:22, 148:23, 28:23, 29:4,
149:10, 149:13 sometimes [10] - specific [12] - 112:12, 113:7, 149:1 138:5, 138:7
showed [4] - 39:14, 39:15, 25:1, 51:4, 51:5, 113:10, 139:12, stores [2] - 43:1, switch [1] - 24:15
80:24, 128:9, 86:22, 98:5, 71:17, 97:14, 143:1, 148:16 46:7 switched [1] -
135:2 98:6, 99:12, 104:17, 110:2, statement [8] - stories [3] - 23:19
showing [9] - 137:24, 148:22, 116:7, 116:8, 67:20, 67:23, 60:13, 61:16, sworn [3] - 2:2,
78:16, 91:22, 150:24 117:10, 132:1, 68:3, 81:3, 79:8 112:9, 112:10
120:6, 124:25, somewhere [5] - 147:17 108:11, 139:9, story [1] - 57:9
128:16, 131:24, 18:5, 29:22, specifically [5] - 139:11, 143:2 street [1] - 9:20 T
137:3, 137:14, 31:4, 97:7, 2:20, 13:4, statements [3] - Street [4] - 45:19,
149:6 130:11 47:20, 60:21, 28:25, 138:16, 48:1, 149:17, TD [1] - 120:4
shown [3] - 103:7, son [2] - 8:1, 82:6 75:18 138:21 150:15 Teki [3] - 23:2,
103:12, 103:19 son's [2] - 22:22, spell [2] - 2:5, STATES [2] - 1:1, streets [1] - 9:19 23:3, 24:9
sight [2] - 25:10, 23:1 112:12 1:3 structure [1] - telephone [3] -
25:12 soon [6] - 104:13, spelled [1] - 33:13 states [1] - 17:19 100:7 45:5, 45:8,
signature [6] - 136:6, 147:19, spend [1] - 144:1 States [5] - 1:16, stuck [1] - 57:1 51:15
3:9, 6:16, 148:4 spent [1] - 30:9 4:24, 113:20, stuff [3] - 99:6, temper [1] - 79:4
114:25, 115:3, Sooraji [9] - spoken [1] - 154:2, 154:5 106:13, 135:16 ten [14] - 39:19,
115:4, 115:5 36:18, 37:8, 30:17 station [1] - 40:21 stuffed [1] - 39:16 44:16, 44:18,
similar [1] - 89:3 37:12, 105:9, spot [2] - 137:22, statute [1] - 92:8 subject [1] - 5:10 67:7, 67:10,
single [2] - 105:13, 108:1, 150:6 stay [12] - 20:16, subsequent [1] - 97:18, 97:25,
145:15, 146:23 152:3, 153:7 St [1] - 152:7 25:10, 25:12, 62:11 111:1, 111:3,
sisters [1] - 73:1 sorry [35] - 5:2, stage [1] - 89:18 34:1, 34:3, 67:6, subsequently [1] 132:13, 134:19,
sit [1] - 14:6 10:20, 17:7, stages [1] - 86:18 83:22, 96:14, - 81:1 134:20
sitting [2] - 8:20, 23:16, 28:10, stair [1] - 29:16 124:22, 131:21, substance [1] - ten-minute [2] -
13:25 32:23, 41:19, stairway [1] - 151:1, 151:7 50:10 67:7, 67:10
situation [3] - 43:16, 45:4, 29:16 stayed [6] - 29:21, substantial [1] - Tequila [2] - 23:2,
58:8, 73:25, 51:18, 59:7, stand [8] - 37:25, 31:4, 91:10, 5:13 82:7
135:21 59:25, 73:11, 38:1, 110:18, 91:11, 102:24, suite [2] - 103:20, term [1] - 72:7
six [3] - 44:24, 75:6, 77:12, 112:7, 135:22, 125:14 104:7 terms [15] - 3:21,
151:22, 151:25 85:23, 93:4, 151:5, 151:7, staying [1] - Suite [2] - 45:19, 5:3, 116:1,
sizes [1] - 100:22 93:24, 97:13, 151:8 70:16 45:25 133:12, 136:19,
skip [5] - 5:24, 99:14, 103:9, stand-in [2] - stealing [1] - 40:4 sum [3] - 43:5, 138:16, 139:11,
6:14, 23:15, 103:15, 109:3, 37:25, 38:1 stemmed [1] - 50:9 139:12, 143:1,
50:16, 58:20 114:24, 116:21, stands [3] - 85:19 summarize [1] - 143:5, 144:10,
skipping [1] - 118:20, 119:9, 67:11, 111:5, stenographicall 115:17 145:1, 151:17
3:12 122:7, 123:17, 153:17 y [1] - 154:4 testified [21] -
summer [1] -
sleeping [2] - 125:6, 135:12, Stanley [3] - stenographicall 10:16, 20:18,
140:19
57:22, 60:10 142:10, 142:11, 120:12, 120:20, y-reported [1] - 29:21, 39:20,
sun [1] - 16:4
slightly [1] - 143:14, 152:19 120:23 154:4 51:5, 61:8,
Sunday [1] -
27:13 sort [3] - 25:16, start [15] - 55:21, stenotype [1] - 61:15, 71:13,
143:22
slowly [1] - 113:2 80:21, 106:13 57:7, 67:1, 1:25 71:21, 76:9,
supermarket [1] -
small [2] - 43:22, sound [4] - 78:7, 104:13, 111:2, step [3] - 85:18, 79:11, 90:7,
30:24
100:23 87:4, 88:21, 128:15, 130:9, 110:16 92:22, 93:6,
supplement [2] -
90:17 134:2, 136:7, still [5] - 59:10, 97:10, 103:24,
smart [1] - 94:25 6:5, 115:14
sounds [1] - 136:8, 136:10, 62:23, 71:13, 104:25, 107:9,
Smith [5] - 21:3, Supplement [5] -
105:5 137:7, 145:12, 88:15, 136:25 107:21, 108:11,
70:7, 70:9, 2:23, 3:13, 5:4,
source [6] - 150:25 stipulation [2] - 109:7
77:19 5:16, 115:13
31:20, 69:21, started [12] - 8:9, 67:20, 67:23 testify [2] - 4:7,
smoke [1] - 63:9 supposed [7] -
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 169 of 170
15
90:22 140:14, 142:24, 40:11, 40:17, 93:25, 104:25, type [1] - 89:3 32:16, 33:7,
testifying [1] - 150:21, 151:10, 42:18, 85:9, 105:1, 105:2, types [1] - 124:8 34:6, 34:9,
116:22 151:11, 151:13, 105:21, 106:12, 105:3, 124:23, typical [1] - 96:20 35:15, 35:16,
testimony [18] - 151:17, 151:25, 127:17, 128:3 132:6, 132:20 typo [1] - 23:14 35:18, 35:19,
4:10, 6:8, 6:20, 152:2, 152:4, top [9] - 4:5, trips [4] - 41:21, 36:22, 36:25,
7:7, 67:5, 71:17, 152:6, 152:9, 40:23, 53:9, 42:17, 42:18, U 37:2, 40:6, 41:2,
78:7, 78:21, 152:12, 152:15, 55:21, 57:10, 92:21 41:25, 42:11,
110:17, 110:20, 152:18, 152:23, 58:10, 58:21, truck [1] - 50:13 U.S.C [4] - 3:5, 42:22, 42:24,
116:20, 151:5, 153:2, 153:4, 125:3, 145:22 true [10] - 81:4, 5:17, 114:18, 45:3, 45:4, 46:9,
151:23, 151:24, 153:15, 153:17 total [5] - 49:9, 81:9, 81:10, 154:3 46:19, 47:10,
152:1, 152:10, themselves [3] - 97:11, 121:19, 82:14, 87:17, Uber [2] - 20:9, 48:12, 48:23,
152:16, 153:6 32:15, 95:13, 132:9, 143:23 95:16, 98:2, 20:19 49:6, 49:21,
text [19] - 16:18, 95:16 track [3] - 40:3, 99:12, 102:3, ultimate [1] - 7:4 50:17, 50:25,
23:6, 23:22, theory [1] - 102:5 48:23, 98:18 154:3 ultimately [8] - 51:3, 51:10,
24:3, 24:9, thereafter [4] - tracking [9] - trust [3] - 83:7, 25:10, 25:17, 51:12, 51:13,
32:11, 33:8, 71:5, 75:19, 65:11, 108:23, 128:10, 136:16 29:12, 30:11, 51:14, 51:21,
33:9, 45:15, 86:22, 89:10 129:13, 129:15, trusted [1] - 33:12, 37:16, 51:22, 52:3,
50:17, 50:18, third [2] - 23:21, 129:17, 135:3, 136:12 39:20, 107:22 52:4, 52:21,
50:22, 54:4, 111:2 135:6, 135:15, trusting [1] - Ulysse [6] - 78:7, 53:13, 54:2,
57:14, 58:10, thousand [6] - 135:23 136:9 117:18, 117:24, 54:7, 54:10,
59:6, 101:17, 127:15, 146:2, traffic [3] - 56:9, truth [3] - 90:5, 118:1, 118:2, 54:24, 55:11,
110:2 146:3, 146:9 56:10, 56:15 115:22, 116:2 131:14 55:13, 55:21,
texting [1] - three [12] - 5:1, trailing [1] - 17:9 truthful [5] - 3:16, Ulysses [1] - 78:9 57:20, 59:12,
109:25 20:17, 29:22, transcript [2] - 4:21, 7:7, 9:23, unaware [1] - 60:18, 60:20,
texts [5] - 55:23, 49:17, 55:23, 154:3, 154:4 87:14 69:9 61:9, 61:11,
58:11, 58:14, 57:20, 59:7, transcription [1] - truthfully [4] - under [12] - 4:11, 61:25, 62:2,
64:8, 150:19 85:5, 90:16, 1:25 3:22, 3:25, 4:7, 4:14, 4:23, 5:15, 63:13, 63:18,
THE [87] - 1:1, 95:24, 121:19, transcripts [2] - 4:15 19:9, 49:16, 63:25, 64:5,
1:1, 1:12, 2:4, 149:12 28:12, 28:13 trying [4] - 10:15, 77:22, 80:8, 64:16, 65:20,
2:7, 2:8, 8:25, threw [1] - 103:22 transferred [1] - 80:20, 86:5, 125:5, 126:9, 69:9, 71:3,
11:19, 11:20, throughout [1] - 86:10 88:10 142:25, 143:2 72:24, 73:7,
18:24, 24:4, 73:23 transfers [4] - Tuesday [2] - understood [2] - 77:11, 78:10,
28:16, 28:23, throwing [2] - 119:21, 119:24, 97:1, 97:2 44:19, 105:9 80:24, 83:23,
46:19, 46:21, 45:25, 103:21 122:12, 123:3 turn [9] - 4:4, Union [1] - 64:4 86:11, 87:10,
53:13, 53:15, Thursday [4] - transmit [1] - 48:4 55:20, 64:6, UNITED [2] - 1:1, 91:6, 91:18,
58:11, 58:15, 49:11, 49:16, transport [1] - 84:19, 84:22, 1:3 94:18, 96:10,
59:9, 59:11, 49:18, 49:20 144:3 85:2, 85:9, United [5] - 1:16, 99:6, 99:20,
59:25, 60:3, timeframe [4] - 95:20, 114:23 4:24, 113:20, 100:5, 103:8,
trash [1] - 27:2
61:4, 66:24, 75:17, 83:25, turned [3] - 85:6, 154:2, 154:5 108:11, 108:19,
travel [6] - 44:12,
67:4, 67:11, 106:1, 140:7 86:8, 101:3 112:2, 112:18,
109:11, 123:10, unless [1] - 29:2
67:14, 67:19, timeline [1] - 113:2, 114:6,
123:13, 123:19, turning [5] - 54:3, unoccupied [1] -
68:4, 68:7, 80:17 118:16, 118:21,
124:5 54:10, 57:10, 135:20
68:12, 81:19, timing [2] - 84:14, 119:1, 122:11,
traveled [5] - 108:21, 126:18 up [160] - 2:16,
102:12, 103:14, 108:8 123:7, 123:11,
24:17, 41:17, twenty [1] - 92:16 4:5, 5:25, 7:16,
103:17, 106:5, 124:20, 128:1,
title [1] - 115:13 70:11, 109:10, twice [1] - 44:11 9:14, 11:13,
106:17, 106:21, 128:4, 128:7,
titled [1] - 120:7 123:14 two [29] - 6:14, 11:14, 15:20,
110:10, 110:13, 129:8, 131:2,
today [4] - 6:20, traveling [2] - 9:19, 12:12, 16:2, 17:4, 17:8,
110:15, 110:21, 131:3, 131:21,
7:7, 53:20, 92:23, 125:17 12:15, 13:7, 17:13, 17:16,
110:22, 110:23, 132:7, 132:12,
150:23 travels [1] - 17:20, 19:6, 18:8, 18:9, 19:1,
110:25, 111:5, 132:13, 132:18,
together [4] - 109:14 29:11, 32:18, 19:7, 20:11,
112:1, 112:8, 133:15, 133:18,
9:14, 72:24, tremendously [1] 47:24, 49:12, 21:12, 21:19,
112:11, 112:14, 134:2, 135:6,
73:5, 97:6 - 113:2 54:4, 58:14, 22:1, 22:3,
112:16, 112:17, 135:10, 135:16,
tomorrow [6] - trespassing [1] - 69:24, 71:21, 22:16, 22:18,
113:9, 113:10, 137:20, 144:21,
150:25, 151:5, 14:7 71:23, 71:24, 23:20, 24:3,
113:11, 113:12, 145:4, 146:19,
151:7, 151:8, trial [2] - 4:8, 103:3, 104:22, 26:7, 26:8, 27:6,
138:5, 138:7, 150:6, 150:8,
151:9, 153:12 110:17 104:23, 111:2, 27:7, 27:12,
138:14, 138:20, 150:11, 150:13,
ton [3] - 75:7, TRIAL [1] - 1:11 111:3, 121:18, 28:7, 28:9,
138:25, 139:6, 150:18, 151:1
75:10, 75:24 tried [2] - 75:3, 126:21, 127:15, 29:17, 30:1,
139:11, 139:17, ups [11] - 48:19,
took [11] - 14:10, 134:22 132:12, 141:23, 30:13, 30:15,
140:10, 140:12, 48:20, 48:21,
20:18, 40:10, trip [9] - 18:9, 147:4 31:9, 31:21,
48:22, 49:9,
Kassandra L. McPherson, RPR - Federal Official Court Reporter
Case 1:21-cr-00054-RDB Document 253 Filed 07/06/23 Page 170 of 170
16
65:11, 65:12, waiting [1] - wife [8] - 73:10, 143:18 93:24, 100:13,
65:14, 76:10, 141:25 73:13, 73:17, words [2] - 7:12, 105:21
77:7, 99:11 wake [1] - 21:19 74:5, 74:20, 58:1 Zo's [1] - 14:22
USSG [1] - 5:16 walked [6] - 109:2, 109:5, workers [2] - zoom [7] - 114:13,
UTC [2] - 23:6, 14:10, 25:16, 109:11 99:4, 102:7 120:7, 125:24,
55:16 26:7, 27:2, William [1] - workout [1] - 75:8 128:21, 129:3,
27:23, 29:16 151:24 worry [2] - 55:25, 130:16, 131:5
V walking [1] - Williams [1] - 60:25 zooming [1] -
27:25 152:1 writes [1] - 55:23 23:21
vacant [2] - 35:7, wall [1] - 153:7 willing [1] - written [2] -
135:20 warrant [4] - 128:11 98:14, 98:15 §
variety [1] - 70:17 84:15, 86:16, winding [1] - wrote [2] - 98:17,
various [1] - 91:15 59:12 98:20 § [1] - 154:3
39:14 Washington [5] - winter [1] - 41:24
varying [2] - 20:5, 20:10, wire [10] - 119:21, X
96:14, 100:22 47:2, 123:16, 119:24, 120:2,
vehicle [5] - 123:18 120:12, 120:20, X7 [1] - 123:25
16:10, 16:11, watch [2] - 40:24, 120:25, 121:3,
16:13, 60:10, 59:1 121:13, 122:12, Y
124:4 watched [1] - 59:3 123:3
vehicles [1] - water [1] - 55:24 withdraw [2] - year [7] - 88:20,
124:8 ways [2] - 35:10, 43:16, 106:2 118:4, 122:25,
version [1] - 39:14 withdrew [1] - 123:2, 140:10,
70:25 wearing [1] - 8:21 121:5 140:11, 148:11
via [3] - 2:23, week [13] - 20:17, withheld [1] - 6:7 years [2] - 92:16,
41:10, 135:8 29:22, 96:15, WITNESS [11] - 113:15
victim [1] - 75:19 96:20, 128:15, 2:7, 11:20, yo [1] - 64:16
video [16] - 38:23, 132:9, 132:12, 53:15, 110:21, York [16] - 31:19,
40:7, 40:10, 132:15, 133:19, 110:23, 112:14, 42:17, 42:18,
40:14, 40:18, 133:21, 133:25, 113:10, 113:12, 42:23, 43:1,
40:25, 41:3, 134:21 140:12, 151:10, 43:4, 45:19,
104:16, 145:12, weekend [4] - 151:13 64:7, 97:10,
145:25, 146:5, 133:19, 134:1, witness [31] - 97:11, 97:12,
146:14, 152:1, 134:21, 134:22 8:24, 8:25, 97:13, 97:19,
152:10, 153:5, weeks [3] - 83:24, 58:13, 68:13, 103:9, 103:25
153:8 121:21, 132:17 75:8, 79:21, young [3] - 20:24,
videos [5] - 39:25, weigh [1] - 100:25 90:1, 110:18, 36:18
41:4, 41:5, 41:7, weighed [1] - 111:3, 112:5, yourself [14] -
146:10 100:25 139:18, 151:5, 25:19, 51:3,
violation [3] - 3:5, weight [1] - 101:1 151:6, 151:8, 67:6, 80:10,
56:15, 114:18 West [1] - 45:19 151:15, 151:22, 84:19, 84:22,
violent [1] - 79:4 Western [1] - 64:4 151:25, 152:4, 85:2, 85:6, 85:9,
visit [1] - 109:11 152:5, 152:7, 89:6, 98:3,
white [1] - 124:2
voice [5] - 17:8, 152:13, 152:18, 98:17, 100:4,
White [2] -
53:13, 112:18, 152:21, 152:22, 151:8
149:16, 150:5
113:1, 135:10 whole [5] - 40:23, 152:25, 153:2,
voices [1] - 82:3 51:22, 63:18, 153:6, 153:7, Z
voluntarily [1] - 74:1, 127:11 153:8, 153:9,
95:20 153:10 Zillow [2] - 35:12,
WIC [1] - 32:9
vouch [1] - witnessed [2] - 35:13
Wick [2] - 33:3,
148:19 79:7, 101:10 Zo [25] - 14:19,
33:4
vs [1] - 1:4 witnesses [1] - 14:20, 15:5,
Wickr [14] - 32:6,
151:20 15:7, 16:1,
32:7, 32:11,
woke [2] - 22:1, 37:18, 37:21,
W 32:14, 33:15,
37:23, 38:13,
33:17, 41:10, 27:6
wait [5] - 25:8, woman [4] - 74:7, 38:17, 56:2,
94:24, 101:17,
29:11, 93:17, 74:9, 76:22, 56:8, 56:11,
101:18, 101:19,
135:4, 150:13 141:6 79:19, 93:10,
101:20, 101:22,
waited [2] - 26:6, word [4] - 94:9, 93:13, 93:15,
135:7
119:8 103:21, 143:17, 93:19, 93:21,
Wickr's [1] - 95:9
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