Hockridge Motion for New Trial - Brady Violation (US v. Reis & Hockridge)

Summary

Defendant Stephanie Hockridge's Motion for New Trial Based on Newly Disclosed Brady Evidence, filed in the United States District Court for the Northern District of Texas, Fort Worth Division, Case No. 4:24-cr-00287-O (02) (Document 341, 11/06/25), under Federal Rule of Criminal Procedure 33(b)(1). It states that Ms. Hockridge was tried in June 2025 on a five-count indictment and was acquitted of all but the first count, which charged a conspiracy under 18 U.S.C. § 1349. It argues that interviews the Government conducted in 2023 with three Newly Disclosed Government Witnesses contradict the testimony of Eric Karnezis, on whom the Government relied heavily at trial. The motion asks the Court to vacate the conviction and order a new trial on Count One.

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Case 4:24-cr-00287-O

Document 341

Filed 11/06/25

Page 1 of 6

PageID 8545

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
STEPHANIE HOCKRIDGE, a/k/a
STEPHANIE REIS,
Defendants.

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Case No. 4:24 CR-00287-O
(02)

DEFENDANT STEPHANIE HOCKRIDGE’S MOTION
FOR NEW TRIAL BASED ON NEWLY DISCLOSED BRADY EVIDENCE
Defendant Stephanie Hockridge, by and through the undersigned counsel, moves pursuant
to Federal Rule of Criminal Procedure 33(b)(1) for a new trial on the grounds of newly disclosed
evidence that the Government had previously failed to produce to the defense, in violation of Brady
v. Maryland, 527 U.S. 83 (1963), and its progeny. Though the Government intends to use this
evidence at sentencing, and although the evidence contains material information that is favorable
to the defense, the Government did not provide the evidence to Ms. Hockridge prior to her trial. A
new trial is the proper remedy. In support of this motion, Ms. Hockridge respectfully states:
1.

In June 2025, Ms. Hockridge was tried on a five-count indictment alleging that Ms.

Hockridge was part of a scheme and conspiracy to commit wire fraud by submitting materially
false applications for loans funded by the Paycheck Protection Program (PPP) during the
COVID-19 pandemic of 2020 and 20201. See Superseding Indictment (Doc. #163). Ms. Hockridge
was acquitted of all but the first count of the indictment, which charged a conspiracy under
18 U.S.C. § 1349.

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2.

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In support of its allegation that Ms. Hockridge had participated in a conspiracy, the

Government relied heavily at trial on the testimony of Eric Karnezis, who claimed that Ms.
Hockridge had instructed him on how to falsify loan applications he submitted to Ms. Hockridge.
Karnezis was testifying pursuant to a plea agreement, from which he hoped to obtain a more
favorable sentencing recommendation from the Government.
3.

Karnezis’s testimony, and therefore his credibility, were key to the Government’s

case. Critically, Karnezis testified that he learned how to commit PPP fraud from Ms. Hockridge
when he first met her in January 2021. In addition, although Ms. Hockridge introduced
communications in which Karnezis provided false explanations to Ms. Hockridge for issues she
and her team had discovered in applications submitted through Karnezis’s channel, Karnezis
testified that those messages were designed to create a “clean” paper trail to cover up Ms.
Hockridge’s supposed earlier oral instructions about how to commit fraud (of which the
Government presented no corroborating evidence).
4.

Karnezis’s testimony, however, is contradicted by evidence that the Government

has only recently produced to Ms. Hockridge’s counsel—months after trial. In 2023 (more than
two years before Ms. Hockridge’s trial), the Government conducted several interviews during its
investigation into Karnezis: one with Newly Disclosed Government Witness #1 (“GW-1”), Ex. A;
another with Newly Disclosed Government Witness #2 (“GW-2”), Ex. B; and a third with Newly
Disclosed Government Witness #3 (“GW-3”), Ex. C. 1 GW-3 had submitted falsified loan
applications through Karnezis and one of his associates. GW-2 had been a participant in Karnezis’s

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At the Government’s request, the names of witnesses in the newly disclosed evidence have
been redacted and Ms. Hockridge has contemporaneously filed a motion seeking to file the referenced exhibits under seal.
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conspiracy, and he disclosed details about the means and structure of the conspiracy while GW-1
and GW-2 had sat in a jail cell together.
5.

Importantly, the newly disclosed interview recordings and transcripts reveal that,

contrary to his trial testimony, Karnezis had been assisting others to commit PPP fraud before he
ever met Ms. Hockridge.
6.

In addition, the newly disclosed evidence undermines several other important

aspects of Karnezis’s testimony—not only impeaching Karnezis’s credibility as a witness, but
negating key elements of the Government’s case. Examples of those discrepancies include:
•

Evidence that Karnezis was involved in a wide-ranging conspiracy to commit PPP
fraud (involving corrupt SBA employees, money laundering, and members of the
infamous “Bloods” gang) that is vastly different from anything Ms. Hockridge is
alleged to have been involved in.

•

Evidence that Karnezis’s fraudulent actions involved people and transactions totally
disconnected from Ms. Hockridge, which undermines the Government’s claim that Ms.
Hockridge knowingly conspired with Karnezis.

•

Evidence that Karnezis charged substantially more for his fraudulent activities than
VIPPP charged the borrowers it worked with, which sets him at cross-purposes to Ms.
Hockridge and provided a motive for him to hide his activities from her (not to conspire
with her).

7.

Although the Government has opposed Ms. Hockridge’s request for it to produce

other investigative materials relating to the three previously undisclosed Government witnesses,
see Resp. (Doc. #332), the Government offers no explanation for its failure to disclose the newly
disclosed evidence before trial as required by the Fifth Amendment. The Due Process Clause
requires that the Government disclose evidence in its possession that is (1) favorable to a defendant
and (2) material to guilt or punishment. See Brady v. Maryland, 373 U.S. 83, 87 (1963). This
affirmative obligation attaches “irrespective of the good or bad faith of the prosecution.” Id. The
Brady doctrine applies both to substantive and impeachment evidence, and it “encompasses
evidence known only to police and investigators and not to the prosecutor,” such that “the
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individual prosecutor has a duty to learn of any favorable evidence known to the others acting on
the government’s behalf in [the] case, including the police.” Strickler v. Green, 527 U.S. 263, 280–
81 (1999) (quotation omitted).
8.

Because the newly disclosed evidence undermines essential elements of the

Government’s case and impeach Karnezis’s credibility, they are favorable to Ms. Hockridge’s
defense.
9.

In light of the importance of Karnezis to the Government’s case and the

contradictions between his testimony and the newly disclosed evidence, the evidence is also
material in that it creates a reasonable probability the jury would not have convicted Ms. Hockridge
on the sole count on which it returned a guilty verdict had it been made available to the defense.
Had the newly disclosed evidence been produced before trial, Ms. Hockridge’s counsel could also
have engaged in additional investigation regarding the information disclosed in the recordings,
reports, and transcripts of the interviews, which may very well have led to the discovery of
additional exculpatory evidence beyond what is recited in the recordings, reports, and transcripts
themselves. The Government’s decision to selectively produce only some of the fruits of its
investigation into Karnezis before trial deprived Ms. Hockridge and her counsel of that opportunity.
10.

Whether the withheld recordings, reports, and transcripts are considered

individually or collectively, the evidence contained within them comfortably satisfies Brady’s
materiality standard. As the Fifth Circuit has explained, undisclosed evidence must be considered
in light of its cumulative effect to assess its “potential impact on the outcome of the trial.” United
States v. Sipe, 388 F.3d 471, 491 (5th Cir. 2004).
11.

When the Government violates Brady by withholding favorable and material

evidence, a new trial is the appropriate remedy. United States v. Runyan, 290 F.3d 223 (5th Cir.

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2002). No other remedy would be sufficient here to correct for the Government’s failure to produce
evidence that bears so critically on the credibility of the Government’s star witness and the very
existence of the conspiracy charged in the indictment.
12.

Even if a new trial were not required under Brady, the failure to produce such

plainly relevant evidence prior to trial, especially when combined with the numerous other
irregularities in Ms. Hockridge’s trial and prosecution previously identified in her original Motion
for New Trial (Doc. #265) and its supporting memorandum (Doc. #269), makes ordering a new
trial required by the interest of justice. See Fed. R. Crim. P. 33(a); United States v. Riddle, 103
F.3d 423, 435 (5th Cir. 1997) (“Looking at the cumulative effect of the errors, we are persuaded
that they are not harmless and require a new trial.”).
13.

A memorandum of law in support of this motion is filed contemporaneously

herewith.
WHEREFORE Defendant Stephanie Hockridge respectfully requests that the Court vacate
her conviction and order a new trial on Count One of the Superseding Indictment, at which she
will have the benefit of the previously undisclosed Brady material, and to enter any such other and
further relief as the Court may deem just and proper.
Dated: November 6, 2025

Respectfully submitted,
BRYAN CAVE LEIGHTON PAISNER LLP
/s/ Richard E. Finneran
RICHARD E. FINNERAN
MARK A. SRERE
KEVIN H. JENCO
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
Tel: (314) 259-2000
Fax: (314) 259-2020

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richard.finneran@bclplaw.com
mark.srere@bclplaw.com
kevin.jenco@bclplaw.com
Attorneys for Defendant Stephanie Hockridge
CERTIFICATE OF SERVICE
I hereby certify that on November 6, 2025, a true and correct copy of the foregoing
document was served on all counsel of record by operation of the Court’s CM/ECF system.
/s/ Richard E. Finneran
RICHARD E. FINNERAN

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