Court filing
Exhibit A — Transcript of Detention Hearing, United States v. Sniders Jean-Jacques
Filed April 4, 2026 in U.S. v. Spike; one of 6 filings from this case.
Record facts
| Court | U.S. District Court for the District of Massachusetts |
|---|---|
| Filed | 2026-04-04 |
U.S. District Court for the District of Massachusetts · No. 1:26-cr-10031-RGS · Doc. 46-1 · 2026-04-04 · Docket on CourtListener
Full text
EXHIBIT A
Transcript of Detention Hearing
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NOS. 26-MJ-02277 and 26-MJ-02278-CRIMINAL-ELFENBEIN
UNITED STATES OF AMERICA,
Miami, Florida
Plaintiff,
February 13, 2026
vs.
11:25 a.m.
SNIDERS JEAN-JACQUES,
Defendant.
Pages 1 to 75
______________________________________________________________
DETENTION HEARING
(TRANSCRIBED FROM THE DIGITAL AUDIO RECORDING)
BEFORE THE HONORABLE MARTY FULGUEIRA ELFENBEIN,
UNITED STATES MAGISTRATE JUDGE
APPEARANCES:
FOR THE GOVERNMENT:
MARIA GUZMAN, ESQ.
ASSISTANT UNITED STATES ATTORNEY
99 Northeast Fourth Street
Miami, Florida 33132
FOR THE DEFENDANT:
MARCOS BEATON, ESQ.
ASSISTANT FEDERAL PUBLIC DEFENDER
150 West Flagler Street
Miami, Florida 33130
TRANSCRIBED BY:
LISA EDWARDS, RDR, CRR
Reporterlisaedwards@gmail.com
(305) 439-7168
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THE COURTROOM DEPUTY: Calling on Page 6 of Page 7,
Case No. 26-MJ-2277 and 2278-Elfenbein, United States of
America versus Sniders Jean-Jacques.
Counsel, please state your name for the record,
beginning with the Government.
MS. GUZMAN: Yes, your Honor. Good morning. Maria
Guzman on behalf of the United States.
THE COURT: Thank you, Ms. Guzman.
MR. BEATON: And good morning, your Honor. Marcos
Beaton on behalf of Mr. Jean-Jacques, who is present with me
and standing next to me.
THE COURT: All right. Good morning, Mr. Beaton.
And good morning, Mr. Jean-Jacques.
Before we go forward, I just want to -- I see that we
still have our interpreter here. And I'm noticing, I don't
think we need her services for the morning calendar.
My recollection is that Mr. Jean-Jacques is fluent in
English. Am I correct, Mr. Beaton?
MR. BEATON: We don't need an interpreter.
THE COURT: Okay. Great.
In that case, Madam Interpreter, you are excused. I'm
sorry you were here for the last hearing. I just looked over
and I saw that you were there, and I figured that you probably
have other places that you probably could be.
All right. Folks, good morning. We are here on a
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removal hearing as well as a pretrial detention hearing. I
recall that when Mr. Jean-Jacques was before me earlier in the
week, he was still contemplating the possibility about whether
or not he wanted to have the proceedings here or in the
District of Massachusetts, where the charges are pending.
So, Mr. Beaton, are we going forward with the hearing
here or what would your client like to do?
MR. BEATON: So this morning Mr. Jean-Jacques informed
me that he would like to proceed with the detention hearing
here.
THE COURT: Okay.
MR. BEATON: The removal he's going to waive, but the
bail detention hearing we will have here.
THE COURT: Okay. Well, in that case, let's take up
the one matter that's not contested. Let's take that one up
first and then we'll do the detention hearing.
So let me ask him some questions. Has he already
filled out the waiver for the identity hearing?
MR. BEATON: Not as to just identity.
THE COURT: Okay. There's a form.
[Inaudible], is it up there already?
THE COURTROOM DEPUTY: Yes.
THE COURT: If you look over there, my courtroom deputy
has probably already pre-filled out just in case you needed it
a document. Oh, yes. You need -- it's one for each case.
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MR. BEATON: That's right.
(Confers with the Defendant privately.)
Mr. Jean-Jacques has signed both of them. May I hand
them to the Court?
THE COURT: Yes, please.
THE DEFENDANT: Good morning, your Honor.
THE COURT: Good morning, sir. I'm going to ask you
some questions about your decision to waive the identity
hearing.
So, [inaudible], put him under oath, please.
THE COURTROOM DEPUTY: Please raise your right hand to
be sworn.
(Whereupon, the Defendant was duly sworn.)
THE COURTROOM DEPUTY: You can put your hand down.
THE COURT: Okay, Mr. Jean-Jacques. I'm going to tell
you what I tell everyone when I put them under oath: You are
now under oath, so if you intentionally answer any of my
questions falsely, that is a separate crime which is a crime of
perjury that is punishable by up to five years in prison.
Do you understand that?
THE DEFENDANT: Yes, your Honor.
THE COURT: Okay. Why don't you tell me -- start off
by telling me how old you are, sir.
THE DEFENDANT: I'm 38.
THE COURT: And how far did you go in school?
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THE DEFENDANT: I went to college, [inaudible]
associate and all of my [inaudible]. I went through. I got,
like, 26 certificates from college. Your Honor, it's an
A-track.
THE COURT: Okay. And you're able to speak and
understand English. Am I right?
THE DEFENDANT: Yes. I speak seven languages.
THE COURT: Okay. Perfect.
Have you been diagnosed with any mental illness or any
addiction to narcotics?
THE DEFENDANT: No, your Honor, but I do take seizure
medication.
THE COURT: Okay. That's actually the next question
I'm going to ask you.
THE DEFENDANT: And also I take -- I take the seizure
medication. One of the side effects was, like, making me
anxiety. So they gave me another medication for that.
THE COURT: Okay. So you take something for seizures
and for anxiety?
THE DEFENDANT: Yes.
THE COURT: Have you taken any of those medications in
the last 24 hours?
THE DEFENDANT: I took them last night and this morning
for my seizure.
THE COURT: Okay. Do either one of those -- do you
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know the name of the medications?
THE DEFENDANT: One of them is -- not off the top of my
hand. I couldn't remember. One of them is Keppra, Keppra for
seizure.
THE COURT: Okay.
THE DEFENDANT: The other one is -- I don't know,
ma'am.
THE COURT: Okay. Do either one of those medications
impact your ability to understand what's happening here in
court?
THE DEFENDANT: No, your Honor.
THE COURT: Do you feel like you're thinking clearly
this morning?
THE DEFENDANT: Yes, your Honor.
THE COURT: Okay. I want to make sure you understand
that you have the right to force the Government to prove by a
preponderance of the evidence -- that means more likely than
not -- that you are the same Sniders Jean-Jacques that the
grand jury indicted in the District of Massachusetts.
Do you understand that you have that right?
THE DEFENDANT: Yes, your Honor.
THE COURT: Okay. And have you had sufficient time to
discuss with your lawyer whether you'd like to waive your right
to an identity hearing?
THE DEFENDANT: Yes, your Honor.
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THE COURT: And would you like to waive that right?
THE DEFENDANT: Yes, your Honor.
THE COURT: Okay. And your lawyer has passed up two
documents. That's a waiver of Rule 5 and 5.1, removal/identity
hearing, where it indicates you'd like to waive that hearing.
These are -- there's one in Criminal Case 26-2277-MJ-Elfenbein
and the other one is in 26-2278-MJ-Elfenbein. Did you sign
both of these forms here in court?
THE DEFENDANT: Yes, your Honor.
THE COURT: Okay. All right. Well, having had the
benefit of counsel and having colloquied you, I'm going to find
that you have made a knowing and voluntary waiver of your right
to an identity hearing done with the advice of counsel, and I
will accept the waiver.
Okay. So, folks, my courtroom deputy has just reminded
me that I neglected on the last case to go over the probable
cause waiver with our last defendant. So I'm so sorry, but
before -- that way, Mr. Fleischman doesn't have to wait this
whole detention hearing for that.
I'm going to re-call that case briefly and then we're
going to have your detention hearing. Okay, Mr. Jean-Jacques?
(Pause in the audio recording.)
THE COURTROOM DEPUTY: Re-calling Page 6 of 7, Case No.
26-MJ-2277-Judge Elfenbein and -- sorry -- 278 -- Sniders
Jean-Jacques.
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Counsels, state your name for the record, beginning
with the Government.
MS. GUZMAN: Yes, your Honor. Maria Guzman on behalf
of the United States on both matters.
THE COURT: Thank you, Ms. Guzman.
And I see Mr. Beaton is back along with
Mr. Jean-Jacques.
So now we've handled the identity hearing. The only
matter that remains is the detention hearing.
Are the parties ready to proceed?
MS. GUZMAN: The United States is ready, your Honor.
MR. BEATON: Yes, your Honor.
THE COURT: Okay. I'll be taking judicial notice of
the Pretrial Services report as well as I've taken judicial
notice of the indictments in both matters in the District of
Massachusetts -- the indictments in -- let's see -- 20-MJ-2217
and the indictment in 26-2278-MJ.
Okay. Does the Government have an agent available for
cross-examination?
MS. GUZMAN: We do, your Honor. We would like to
proceed on testimonial evidence before the Court and also, if
the Court will permit us, argument with regards to that
testimony and then the Bail Reform Act.
THE COURT: Oh, are you going to call him as a witness,
not a proffer?
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MS. GUZMAN: No. I'm going to call him as a witness.
THE COURT: I guess in the Middle District of Florida,
is that how it was done?
MS. GUZMAN: Sometimes.
THE COURT: Okay. All right. I'm not used to any
AUSAs proceeding by testimonial evidence. Well, you're welcome
to do so. You don't have to proceed by proffer. But go ahead.
However you wish to proceed.
MS. GUZMAN: Just for purposes of the record, I know
this is probably established, but we're pursuing detention in
this case pursuant to Title 18, 3142, indicating to the Court
that we believe the Defendant is both a flight risk and a
danger to the community with regards to both matters before the
Court.
Also, also, before I put on a witness, I would like the
Court to know that I have inquired of any potential Jencks
evidence that we would be turning over to the Defendant and
defense counsel prior to this hearing. There is none. So with
regards to our responsibilities under the Federal Rule of
Criminal Procedure 26.2 and Title 18, 3500, I would advise the
Court that there are no such materials in existence to provide
to counsel.
THE COURT: Okay. And tell me -- a couple of things
that I ask on a preliminary basis before the AUSAs dive into
their proffer.
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If you could tell me whether there's a mandatory
minimum, which I don't think would be on these charges; what
the stat max is; and if there's any calculation as to what the
guidelines would be.
MS. GUZMAN: Yes, your Honor.
MR. BEATON: Your Honor, can we sit down? We got the
permission from the marshals.
THE COURT: Yes. Certainly. Yes. I know that
Mr. Jean-Jacques has an issue with standing on his feet. So
certainly.
MS. GUZMAN: So, your Honor, with regards to the first
question, the indictment charges the Defendant pursuant to
Title 18, Section 1349, which is a conspiracy to commit wire
fraud, the wire fraud would have a 20-year statutory maximum.
In the indictment, it appears that they also include
bank fraud. As the Court is aware, under that statute, there
is a provision that if there is a financial institution that is
involved, the statutory maximum can be increased to 30 years.
So I believe that the way that the District of
Massachusetts pled it, it's a 30-year statutory maximum.
THE COURT: Okay. And do you have any preliminary
estimate of what his guidelines would be?
MS. GUZMAN: Yes. The preliminary estimate provided to
me by the District of Massachusetts based on his total offense
level, which of course would be based on the total loss and his
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criminal history, would be somewhere around the range of 121 to
151 months.
THE COURT: Is that before acceptance?
MS. GUZMAN: Before acceptance. That's correct.
THE COURT: Okay. All right. Well, at this point, if
you're ready to call your agent, you may do so.
MS. GUZMAN: Thank you, your Honor.
The United States would call Agent Nelson Muñiz.
THE COURT: Nelson Muñiz? That's his name?
MS. GUZMAN: Yes.
THE COURT: All right. Come on up, Agent Muñiz.
MR. BEATON: Your Honor, while Agent Muñiz is doing
that, the only thing that I will note for the record is that I
would have an objection to testimony or argument on danger to
the community. I believe this Court granted the hearing simply
based on risk of flight, which was the Government's
representation when we were before you initially.
THE COURT: I'll look at the docket.
The Government sought -- requested a hearing based on
serious risk of flight, is what my notes are -- what the minute
order reflects from his initial appearance two days ago.
So, Ms. Guzman, is the Government proceeding only in
that case on -- based on risk of flight?
MS. GUZMAN: If that was the representation that was
made to the Court at a prior hearing, and obviously the defense
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relied on that representation to prepare for today's hearing, I
would proceed only, then, on the issue of flight risk.
THE COURT: Okay. And that is consistent with my
recollection. I remember that I heard Mr. Ustynoski give me a
preliminary proffer on serious risk of flight, and there was no
discussion of danger. So that is consistent with my
recollection, too. But I just wanted to double-check the
minute order, and the minute order reflects that as well.
MS. GUZMAN: Yes, your Honor.
THE COURT: Okay. So in that case, we'll be proceeding
under risk of flight today.
Go ahead.
MS. GUZMAN: Thank you, your Honor.
May I approach the podium or --
THE COURT: Wherever you feel most comfortable. You
can use the lectern; you can stay there.
MS. GUZMAN: Okay.
THE COURT: It's up to you.
MS. GUZMAN: All right. Thank you, your Honor.
THE COURTROOM DEPUTY: Sir, please raise your right
hand to be sworn.
NELSON MUNIZ, GOVERNMENT WITNESS, SWORN.
THE COURTROOM DEPUTY: Can you state your name for the
record and spell your first and last name?
THE WITNESS: Nelson Muñiz. First name is N-E-L-S-O-N.
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Last name is M-U-N-I-Z.
MS. GUZMAN: May I proceed, your Honor?
THE COURT: Yes. Go ahead.
MS. GUZMAN: Thank you.
DIRECT EXAMINATION
BY MS. GUZMAN:
Q.
Agent Muñiz, thank you. Good morning.
A.
Good morning.
Q.
Are you familiar with the facts involving an indictment out
of the District of Massachusetts involving an individual by the
name of Sniders Jean-Jacques?
A.
Yes.
Q.
First of all, how are you currently employed?
A.
I'm a special agent with the Federal Housing Finance Agency
Office of Inspector General.
Q.
And are you based out of South Florida or are you based out
of Massachusetts?
A.
I'm based out of South Florida.
Q.
You are, however -- let me ask you this: Are you aware of
the indictment that was returned by the District of
Massachusetts against this Defendant?
A.
Yes.
Q.
And are you aware of the facts underlying that particular
indictment in the District of Massachusetts?
A.
Yes.
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Q.
Okay. With regards to just the facts briefly in that
matter, what is essentially the role of the Defendant in the
indictment -- as illustrated in the indictment?
A.
The Defendant coordinated a conspiracy to defraud banks by
arranging fraudulent employment, income and documentation
created to induce banks to issue loans and also for the purpose
of leasing apartments.
Q.
And with regards to -- I think you used the word
"coordinated." Is that correct?
A.
Yes.
Q.
There are other individuals listed in the indictment; is
that correct?
A.
Correct.
Q.
When you refer to others, are you referring to the
individuals noted in the indictment?
A.
Yes.
Q.
Is it your understanding that Mr. Jean-Jacques held
somewhat of a management or supervisor role with regards to
these other Defendants?
A.
Yes.
Q.
Now, with regards to the amount of this potential loss, do
you have a figure that is estimated?
A.
There are two indictments. There was a PPP loan indictment
and a mortgage and apartment indictment. The one with the
mortgages, I believe the original intended amounts were about
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6 million, and maybe three-point-something million was actually
obtained. The PPP one I am not familiar with.
Q.
Now, with regards to this case in the District of
Massachusetts, was the Defendant in control or a proprietor of
a business or establishment that was conducting or assisting in
the fraud?
A.
Yes.
Q.
And what type of business was that?
A.
The name of the business was Black Market Luxury. And it
was his company.
Q.
Is that company still open?
A.
It's currently inactive, according to the Division of
Corporations.
Q.
Are you aware of whether or not Mr. Jean-Jacques had a
prior criminal history?
A.
Yes, he did.
Q.
And what type of criminal history are you aware of that he
had in Massachusetts -- or that he had?
A.
It was another financial fraud. I believe it was around
2013 or 2014.
Q.
Now, with regards to that particular matter and the current
matter, do you know if there was any overlap between the period
of the prior offense and the period during which, as you
suggest, this fraudulent activity occurred?
A.
I believe the -- for the prior offense, the supervised
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release ended at the end of 2018, December 2018, I believe.
And for this indictment, the conspiracy started in May of 2018.
Q.
Now, are you familiar with Mr. Jean-Jacques's personal
history?
A.
(No audible response.)
Q.
Is he a United States citizen? Do you know? If you know.
A.
I believe he is. I'm not sure. I believe he is.
Q.
All right. Were you involved or do you have knowledge of
the events surrounding his detention to be brought over to
federal court?
A.
I'm sorry. Can you ask that again?
Q.
Now, he was detained a few days ago -- is that correct? --
to be brought to federal court?
A.
Yes. Sure.
Q.
Were you involved in that arrest or detention?
A.
I was involved in one of the other Defendants on the
indictment.
Q.
With regards to Mr. Jean-Jacques, had you become aware of
the facts or instances involving his arrest?
A.
Yes.
Q.
Is it your understanding based on your review of other --
and speaking, I assume, to other agents -- whether this
Defendant was cooperative at the time of his arrest?
A.
No, not initially.
Q.
Could you please explain that to the Court?
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A.
The arrest team originally went to the address shown on his
driver's license, and he was not present. They discovered
where he may actually have been. They went to that residence.
And that is where he was. But he initially refused to come
out.
Q.
Now, when you indicate to the Court that he initially
refused to come out, what happened when he refused to come out?
A.
It took about 15 minutes before finally he presented
himself, whatever, to the agents. That's a long time when
you're trying to arrest somebody.
Q.
Okay. So you've indicated that you did not believe he was
cooperative, at least at that point?
A.
Correct.
Q.
With regards to this particular case in the District of
Massachusetts, have these other individuals that are noted in
the indictment also been arrested?
A.
Yes.
Q.
Were they all arrested the same day?
A.
Yes.
Q.
And are they all pending transfer to the District of
Massachusetts at this time?
A.
Yes.
Q.
I'm not going to go through the specifics of the
indictment. The Court has that. However, you indicated that
at least during the course of the conspiracy -- which took
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place from, I believe, 2018, May of 2018, and then on or about
June of 2025. Is that correct?
A.
Yes.
Q.
So that was somewhat of a long period of time; is that
correct?
A.
Correct.
Q.
Now, during that time period, is it your understanding
based on your knowledge of this case that Mr. Jean-Jacques
continued to -- with regards to the other Defendants, what was
it that Mr. Jean-Jacques was doing or suggesting to the other
Defendants?
A.
There was -- one of the other Defendants would take
individuals recruited by Jean-Jacques and connect their
identities to people with good credit to help bolster their
credit. One of the other Defendants, Mr. Jean-Jacques would
coordinate with him on the creation of -- for altering actual
bank statements to make fraudulent bank statements showing
higher assets than they actually had, to make them appear more
creditworthy, and then with a mortgage broker who would
actually do the rest of the work of getting the loan issued by
the bank.
Q.
And I think you had stated this was all fraudulent
activity; is that correct?
A.
Correct.
Q.
And when you suggest to the Court that Mr. Jean-Jacques
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recruited the other Co-Defendants, what exactly do you mean by
that?
A.
I mean that they worked together. He communicated with
them, provided them with actual documentation, received
fraudulent documentation in return, which was used for the bank
fraud.
Q.
And are you aware what happened with the funds that were
obtained as a result of this fraudulent activity?
A.
No. I don't have that knowledge.
Q.
With regards to this investigation, were you the main case
agent or were you an assistant to the case agents in the
District of Massachusetts?
A.
No. I was helping the case agent in Massachusetts.
MS. GUZMAN: Your Honor, I have no further questions of
this witness with regards to the issue of flight risk.
THE COURT: Are you going to have other questions for
this witness on another issue?
MS. GUZMAN: No, your Honor. With regards to flight
risk, I am relying on the bail report to the Court and base my
argument on that, since we have limited it to only the issue of
flight risk.
THE COURT: Okay. So in that case, you tender the
witness?
MS. GUZMAN: I do.
THE COURT: Okay. Great.
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Mr. Beaton, cross-examination.
MR. BEATON: Thank you, your Honor.
CROSS-EXAMINATION
BY MR. BEATON:
Q.
Good morning, Agent Muñiz. How are you?
A.
Good morning.
Q.
You and I have never met before?
A.
No.
Q.
We said hello to each other at the beginning of today's
court session. This is the first time that we've met?
A.
Yes.
Q.
Agent Muñiz, did you do any substantive work in either one
of these cases? And here's what I mean, just to get -- cut to
the point. Did you interview witnesses, pull documents,
execute subpoenas as part of the investigation in this case?
A.
As to Jean-Jacques, no.
Q.
And because this is a case that originates in Boston,
you're standing in for [inaudible]?
A.
Correct.
Q.
So a lot of what underpins the indictment in terms of
documents, records and interviews, you do not have personal
knowledge of?
A.
Other than reviewing the documentation, no.
Q.
And when you have reviewed documentation, have you reviewed
reports?
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A.
Yes.
Q.
Have you reviewed anything else?
A.
I've reviewed text message conversations between
Jean-Jacques and other Defendants.
Q.
And by whom were those provided to you?
A.
By the agents in Massachusetts.
Q.
So your colleagues sent you reports and some text messages
to get you caught up to speed?
A.
Yes.
Q.
Other than what was sent to you, you have no personal
knowledge of what happened in this case. Is that fair?
A.
Yes, sir.
Q.
And you're saying that I think your investigative agency is
not involved in the PPP fraud case? That's a different agency?
A.
Correct.
Q.
You definitely don't have any personal knowledge on the PPP
fraud case?
A.
No.
Q.
So let's talk about 26-Criminal-10030, which is the case
that you testified about.
So Ms. Guzman made the point that in the indictment,
Paragraph 19, it lists the conspiracy dates as May 2018 through
June of 2025.
Do you remember that?
A.
Yes.
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Q.
Do you have a copy of the indictment with you?
A.
No.
MR. BEATON: Can I borrow yours?
MS. GUZMAN: Sure.
Your Honor, for purposes of the hearing, I would be
happy to provide the witness with a copy of the indictment.
May I approach the witness?
THE COURT: Sure.
BY MR. BEATON:
Q.
So if you need to refer to it, I want you to have it there
and I want to move things along.
Would you agree with me that all of the acts in furtherance
of the conspiracy identify dates in 2018, 2020, 2021 and two in
2023, but nothing else?
A.
So 2024 and 2025 are nowhere to be found in the acts in
furtherance of the conspiracy. Right. Correct.
Q.
So that May '18 through June of 2025 indication is
internally inconsistent with what's in the document.
A.
What's in the document, yes.
Q.
With regards to this case, you used the word "coordinated"
as to Mr. Jean-Jacques. And I'm going to point you to, for
example, Page 4, Paragraph 19-B. And you'll see where it says:
On or about December 5th, 2020, Jean-Jacques instructed Pierre
in substance to provide an apartment complex with a phone
number for a fraudulent applicant.
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Do you see that? At the bottom of the page.
A.
Yes.
Q.
We're going to do this. Do you have -- can you tell us
what that substance is, what words were used?
A.
No. I can't tell you what words were used.
Q.
So let's move quickly. If you'll go with me to Page 6. Do
you see Paragraph 5 at the top of the page, "in substance"?
You see the same phrase, right?
A.
Yes.
Q.
Paragraph L, you'll see "in substance." Right?
A.
Yes.
Q.
Paragraph N, "in substance"?
A.
Correct.
Q.
And those are talking about messages attributed to
Mr. Jean-Jacques.
You don't have any information about what the substance of
that is, right?
A.
The specific wording used, no.
Q.
And I want you to look at Paragraph K. So the paragraph
says: On or about June 13th, 2018, Kelly Michelle messaged
Jean-Jacques at, quote, "All trade lines have closed in Boston,
period," end quote.
You see that, right?
A.
Yes.
Q.
So you'll agree with me that when the language is quoted in
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there, those are the actual words that were used. Right?
A.
Probably. Most likely. Yes.
Q.
And so the indictment does state what certain messages are
word for word. Right?
A.
Correct.
Q.
But in most all other instances, it qualifies it with the
"in substance" language. Right?
A.
Yes.
Q.
And you'll agree with me that "in substance" means, In
summary, my summary of what this message said is XYZ. Right?
A.
Correct. You take it into context with other
communication.
Q.
And the indictment in this case alleges that certain folks
who are characterized as Borrowers 1 and 2 and Employees 1 and
2 submitted applications either for rents or for mortgages.
That's one of the acts in furtherance. Correct?
A.
Yes.
Q.
There's no instance where Mr. Jean-Jacques submitted a
mortgage application. You'll agree with me. Right?
A.
Where he personally submitted? I don't know.
Q.
And you'll agree with me that there's no instance where
Mr. Jean-Jacques submitted a rental application. Right?
A.
Submitted? No.
Q.
The allegation is that essentially, in substance, to use
the word that you guys used in the indictment, he assisted, you
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guys are claiming, folks with these applications. Right?
A.
Correct. He caused them to be submitted.
Q.
And I see that word a lot. You took the next word. "He
caused them to be submitted." And so we just talked about the
fact that he didn't press any buttons to submit them. Right?
A.
Not that I know of.
Q.
He didn't walk over to any agency to turn them in. Right?
A.
Not that I'm aware of.
Q.
Okay. He didn't force anybody either by threat, coercion,
depriving anything for them to submit these applications.
Right?
A.
Not that I know of.
Q.
So your allegation is that Mr. Jean-Jacques helped or
someone -- guided someone in the participation of these
applications. That's the substance of the allegation. Right?
A.
Yes. That he coordinated it and he provided the use of his
business in order to further the conspiracy.
Q.
And there's allegations in here as to another Co-Defendant
about falsifying documents. Right? About actually taking, for
example, bank statements and then switching them up. Right?
A.
Yes. Yes.
Q.
That's not Mr. Jean-Jacques. Right?
A.
No. He provided the actual bank statements to that
Defendant and then received the fraudulent ones in return.
Q.
Well --
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A.
And he asked the Defendant that the bank statement had to
show a certain minimum balance, which is what was returned to
him.
Q.
And that kind of conversation is another "in substance."
What words did Mr. Jean-Jacques use to say, "Here's the
original one. Give me back a fake one"?
A.
I don't remember the exact amount. But it was a text
message. And he said, "The balance has to show at least around
somewhere around $69,000." I remember he said that.
Q.
So you're aware that Mr. Jean-Jacques -- one of the things
that he does is he's a tax preparer. He has a tax preparation
business. Right?
A.
Yes.
Q.
And so he assists some of those clients in some financial
advice, as you understand it. Right?
A.
Yes. He was a tax preparer. He does not have an active
[inaudible], so he cannot prepare taxes anymore.
Q.
Got it.
So you understand that certain mortgage companies have
underwriting standards. Right?
A.
Yes.
Q.
And there are people that get hired to understand those
underwriting standards. Right?
A.
Yes.
Q.
And one of those underwriting standards that the mortgage
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companies have is an approximation of how much cash on hand you
have. Correct?
A.
Correct.
Q.
So telling someone that, "Hey, bank XYZ is going to need
you to have, you know, at least 70 grand if you want to
qualify," that's kind of accurate advice. And I'm not saying
that that may be clear, because I don't know what the number
is. I have no idea what the numbers are. But that type of
advice is things that mortgage brokers tell their clients all
day.
A.
Yes. But not when you provide somebody's actual bank
statements that show a significantly lower balance and then
receive altered bank statements in return reflecting the
balance that was requested.
Q.
I -- you're connecting dots that sort of just in
isolation -- so giving someone advice based on an inadequacy
that you see, there's nothing wrong with that statement.
"You're never going to qualify." There's nothing wrong with
that. Right?
A.
That's right.
Q.
And if somebody finds mom, dad, uncle, aunt to give them,
you know, 50 grand or whatever -- I haven't bought a house for
a million years, so I don't remember how this works. But they
can submit the application when they think they're going to
qualify. Right?
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A.
Yes.
Q.
And there's no evidence that you have that Mr. Jean-Jacques
went to a program, a computer, that he switched the numbers.
Right? There's no evidence of that?
A.
Somebody else did that for him.
Q.
So the answer to my question -- and my question is:
There's no evidence that he went to a program and that he
changed those things himself. Right?
A.
Not that I know of.
Q.
So this -- this intended loss of 6 million and loss of 3.7
million, so I see that the indictment that you're responsible
for -- I'm not going to ask you about the PPP fraud, because
that's not yours.
That -- I see that we're talking about literally two
borrowers and that we're talking about timeframes that span
from -- as to Borrower 1, which is how the indictment is broken
down, you're talking January 2021 through May, June; there's
some dates in July; and then in September of 2021 as to
Borrower 1. And then Borrower 2 is October 2021 through kind
of August of 2021. It goes to August of 2022. And those are
the only two borrowers that I see. So I have a hard time
understanding where the $3.7 million number comes from. Can
you explain?
A.
I believe the $6 million would be the original intended
amounts, all applications submitted. And the 3.7 is what was
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actually issued.
Q.
So, I mean, as to Employee 1, for example, we're talking
about submitting an application for renting an apartment in
Wynwood. As to Employee 2, we're talking about something that
is sort of related to Social Security and proof of employment
and has to do with another rental.
And then it's Borrowers 1 and 2 that we're talking about.
So, I mean, these are the only two applications that are
mentioned in acts in furtherance. Are you saying that
collectively those two applications add up to $3.7 million --
A.
No.
Q.
-- in fraudulent proceeds?
A.
No.
Q.
So there's others that are not listed in the indictment?
A.
That are part of the overall conspiracy, yes.
Q.
So who are they? What evidence? Tell us what -- because
the judge has to find by a preponderance of the evidence. It's
a low standard, but it's not a no standard. Right?
So we don't have any evidence. We have Borrower 1. You
have Borrower 2. The numbers we're talking about are
balances -- I mean, you know, you're looking at probably, you
know, $70,000 to $90,000 in a bank account. They're not buying
$2 or $3 million homes. So putting those two aside, what
others and what amounts are you talking about?
A.
I don't have that information.
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Q.
So the only information that we have right now is what's in
the indictment?
A.
Yes.
Q.
The last thing I want to ask you about is the circumstances
of Mr. Jean-Jacques's arrest.
You said an arrest team went to execute the arrest to the
original location and the second location. Were you a part of
that arrest team?
A.
No.
Q.
You said based on what you've been told it took him about
15 minutes to come out?
A.
Yes.
Q.
Just so the Court's clear and we have it on the record, an
arrest team is somebody who, at least generally speaking, they
go knock on the door, say, Hey -- you know, they identify
themselves as law enforcement, say who they're looking for,
come out. Right?
A.
Correct.
Q.
And you weren't able to testify certainly to your personal
knowledge, but you don't know what Mr. Jean-Jacques heard or
saw inside the home. Right?
A.
No.
Q.
And the best estimate that you've been given is 15 minutes.
Right?
A.
Yes.
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Q.
And when law enforcement comes knocking on your door, would
you agree with me that it's not an unreasonable thing to do to
call, let's say, an attorney and ask for advice?
MS. GUZMAN: Objection to speculation on that question.
THE COURT: Overruled. He can answer.
THE WITNESS: I think you should open the door when the
[inaudible].
BY MR. BEATON:
Q.
I appreciate it. I'm sure you guys would prefer that. But
you'll agree with me it's not an unreasonable thing to do for
someone that has law enforcement at the door so they can't come
out to call their attorney. It's not unreasonable?
A.
You can call them afterwards.
Q.
But my question is, it's not unreasonable? That's the only
thing I'm asking.
A.
I think it's unreasonable.
Q.
You think it's unreasonable?
A.
Yes.
MR. BEATON: Give me one second, your Honor.
THE COURT: Go ahead.
BY MR. BEATON:
Q.
I appreciate you stepping in. I know you were put on the
spot.
MR. BEATON: I have nothing further, your Honor.
THE COURT: All right. Any redirect?
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MS. GUZMAN: No, your Honor. Just argument.
THE COURT: All right. So, Agent Muñiz, you may step
down. Thank you, sir.
THE WITNESS: Thank you.
(Witness excused.)
THE COURT: All right. Ms. Guzman, does the Government
have any other evidence it wishes to either proffer or any
other witnesses it wishes to call?
MS. GUZMAN: No, your Honor. Just argument.
Essentially --
THE COURT: Hold on. Before I get to that, let me turn
to defense counsel to see if he wants to proffer anything or if
he has any witnesses he wants to call.
MR. BEATON: No, your Honor. I'll proceed by argument.
It's half proffer, half argument. But there's just
some facts, most of which are contained in the Pretrial
Services report.
THE COURT: All right. Are you going to offer anything
that's not in the Pretrial Services report? Only because I
want to make sure that Ms. Guzman has an opportunity to respond
to anything that's, like, outside the record that she might not
know.
MR. BEATON: No. She has everything.
THE COURT: Okay. Great. So let's proceed to
argument.
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Go ahead, Ms. Guzman.
MS. GUZMAN: Thank you, your Honor.
Obviously, the one issue before the Court is the issue
of the Defendant's potential flight risk. Under Title 18,
3142, we're not proceeding on danger to the community. So I'll
narrow my arguments to that particular issue.
In this particular case, the Court -- the Defendant was
charged by an indictment. These are indicted cases that were
presented to a federal grand jury.
The Defendant is facing a potential maximum of 20 years
on a conspiracy to commit wire fraud, potentially up to 30
years on the issue of whether a financial institution was used
during the commission of the conspiracy to commit wire fraud.
So the statutory maximums are significant for this
Defendant. I believe that the fine amounts for Title 18, 1349,
are somewhere in the range of a million dollars. So they are
significant penalties that the Defendant is facing.
The Defendant is a recidivist. So with regards to his
potential to flee, not only is he facing significant penalties
if convicted, but he's also a recidivist, as the Court note --
heard, not only in the testimony of the agent, that the
Defendant had supervision on a prior case that was discharged
in December of 2018, which would have been during the timeframe
of the conspiracy.
But moreover, the charge itself, which is on Page 4 of
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the Pretrial Services report, was a charge out of Boston where
the Defendant was convicted of theft of public money.
The Defendant received a sentence on those two counts
of 24 months' imprisonment and three years of supervised
release and a $200 special assessment. Again, as noted, his
supervision was discharged in 2018 after the time period
commenced in the indictment.
It is safe to suggest that that prior criminal history
is also going to affect his potential guidelines and obviously
an additional incentive for him to flee.
As is noted in the Pretrial Services report --
THE COURT: You're saying because he's not a Criminal
History Category I, but he's going to have three points, and so
he'll be Criminal History Category II?
MS. GUZMAN: Correct.
THE COURT: Okay.
MS. GUZMAN: He's going to have an enhanced penalty
range than just a Criminal History Category I, which means that
that will obviously elevate his guidelines potentially even
more.
THE COURT: But the estimate that you gave me, the 121
to 151 months, that accounts for Criminal History Category II,
does it not?
MS. GUZMAN: I believe it does.
THE COURT: Okay.
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MS. GUZMAN: I do believe it does. I think that that
was taken into account by the District of Massachusetts when
they came up with their guidelines.
I would also note with regards to the flight risk
issue, which is the only issue before the Court, in the
Pretrial Services report, the person that was contacted to
corroborate the Defendant's personal history was his brother,
Christopher Johnson. He indicated that he was not willing to
cosign a bond. Although he was contacted by Pretrial Services,
he indicated he was not willing to cosign a bond. There are
several instances during the course of the report where he
indicates that he couldn't corroborate information. He just
didn't know the information.
So it appears that there's just a lot of gaps and a lot
of unverified, uncorroborated information in the Pretrial
Services report, which is worrisome.
The Defendant also --
THE COURT: Like what?
MS. GUZMAN: Well, foreign travel. The Defendant
indicated that he had a valid United States passport and that
the Defendant himself declined to provide any of his foreign
travel history.
THE COURT: So does he have foreign travel that you
want to proffer to me?
MS. GUZMAN: I do not know whether he does or does not.
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THE COURT: Wouldn't that burden be on the Government
to come here and show me that he has ties outside of the
district in foreign travel?
MS. GUZMAN: I can only say that he declined to provide
that information. I cannot say whether he traveled. I can
only say that in the Pretrial Services report he declined to
provide that information.
I note that also, which is worrisome, the Defendant
indicated that he has had mental health issues as reflected on
Page 3, that he had admitted himself to a local Miami hospital
sometime in August of 2025, that he was diagnosed with anxiety
and he is being prescribed medication.
There are other issues here, I think, that relate more
to the Defendant's danger to the community, but I'm not going
to address those, because those are not, obviously, before the
Court.
The Defendant, as is reported here in the Pretrial
Services report, apparently has -- by his own account has
family in Haiti, has contacts to Haiti, which -- he is an
American citizen. He was born in Haiti, became a United States
citizen. However, he indicates that, you know, obviously,
there is information in the Pretrial Services report that he
still has ties to the country of Haiti.
And as the Pretrial Services report indicated itself, I
think, when assessing their concern with regards to the flight
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risk issue, there was the offense charged, which is why I
briefly put the agent on. I think it was important for the
Court to hear from the agent and the circumstances of his
arrest. Whether the Court deems that cooperative or not
cooperative, that's for the Court to determine. However, I
thought it was important that the Court hear that in fact the
Defendant didn't simply just surrender when approached by law
enforcement.
Obviously, as the Court knows, he does have possession
of travel documents. He has the family in Haiti; he has the
ties to Haiti, the mental health history.
And then the two most important ones for purposes of
the Court determining whether or not he's a flight risk, again,
his criminal history and then he has a prior failure to appear.
It appears that in -- with regard at least to one case in 2006,
as reflected on Page 4, he had a failure to appear --
THE COURT: Well, but the disposition in that case is
unknown.
MS. GUZMAN: Correct.
THE COURT: So we don't know. He could have been
acquitted of that. It's an accusation; it's not a conviction
for failure to appear.
MS. GUZMAN: Correct. And I'm not -- I am not asking
the Court, quite frankly, to look at the first three, because
the first three all appear to be unknown. So with regards to
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his prior criminal history, the one concern -- and whether I
deem or term him as a recidivist, it is only based on the 2014
offense.
THE COURT: Well, but let me ask you, the 2014 case,
did he have a bond? Did he violate the bond? Or was he
detained pretrial?
MS. GUZMAN: I do not have that information, your
Honor.
THE COURT: Okay.
MS. GUZMAN: I do not have that information.
So with regards to this case, again, being limited only
to the flight risk issue, I think those are the pertinent
issues that I would suggest to the Court, that the nature of
the offense, his ties to other countries, his possession of
travel documents would be something that the Court should look
at, address and deny him conditions of release on that issue,
since I'm not in a position to argue the danger to the
community.
THE COURT: Okay. All right. Mr. Beaton?
MR. BEATON: Thank you, your Honor.
First of all, obviously, Mr. Jean-Jacques is a United
States citizen. He has resided in Miami since 2006. He has
significant family ties, including his father, his mother,
several siblings and four children.
As the Court is --
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THE COURT: All residing in Miami. Correct?
MR. BEATON: They do reside in Miami.
As the Court is aware, the burden that the Government
must carry under 3142 --
THE COURT: Is preponderance.
MR. BEATON: -- is preponderance. But it's a
preponderance that there are no conditions or combination of
conditions that will reasonably secure his appearance.
THE COURT: Correct.
MR. BEATON: So they must exclude all conditions or
combination of conditions.
And notably, Pretrial Services did recommend a bond in
this case with conditions that your Honor and other courts in
our district commonly impose, report to Pretrial Services to
surrender -- as directed, surrender passports, continue with
current mental health provider, avoid contact with
Co-Defendants. And you'll see the list there. I'm not going
to read it out for the Court.
And the Court, I think, had its finger on the right
questions. I'm asking the Court not to consider any of those
priors identified in the Pretrial Services report. There is no
evidence of what they are. There's not even case numbers with
which to verify them.
And I will also note, as the Court noted, that there
were no violations in the 2014 case. Also, the --
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THE COURT: Do you know if your client was out on bond
during that 2014 case prior to trial?
MR. BEATON: I don't know.
(Confers with the Defendant privately.)
What I'm understanding from Mr. Jean-Jacques is that he
waived the pretrial detention hearing in that case and the case
was resolved relatively [inaudible].
THE COURT: Okay.
MR. BEATON: But yeah. So --
THE COURT: When you say no violations, there was no
petition to revoke his supervised release while he was on
supervised release in the 2014 case. Is that what you mean?
MR. BEATON: That's correct. And I apologize.
THE COURT: Okay.
MR. BEATON: So -- and, your Honor, as to the weight of
the evidence -- and I think the weight of the evidence is one
of those factors that is not at the top of the list -- the
evidence on this record is that -- there's almost no proof of
the loss amount. There's no proof as to Mr. Jean-Jacques, of
things that he said or did. There's characterizations, and I
think that's what the record establishes.
With regards to coming to the door, 15 minutes is --
and I respect law enforcement's perspective. I have law
enforcement in my family. They prefer everybody come to the
door. But I know what I tell my clients, is if that happens,
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call me. And so the fact that there's a 15-minute delay while
someone does that internally is not unreasonable, and I don't
think it suggests risk of flight.
I think there is a bond that the Court can impose with
other conditions, maybe electronic monitoring, that would help
assure the Defendant's appearance as required.
And that's it, your Honor.
THE COURT: Okay. Rebuttal?
MS. GUZMAN: Your Honor, I have no additional rebuttal.
I obviously have made my argument to the Court with regards to
our position as to, again, only flight risk. And I don't have
anything else to add.
THE COURT: Okay. Mr. Beaton, I neglected to ask
before when you were discussing proposed bond conditions, is
there a cosigner who is willing to cosign on a bond for him?
MR. BEATON: So I have -- I have been in some
communication with the family. I've spoken with one brother.
They weren't here this morning because we had anticipated not
proceeding this morning on it. I cannot confirm for the Court
that I have spoken with someone that is willing to cosign.
Mr. Jean-Jacques has indicated to me, however, that he
spoke with his mother last night, who did tell him that she
would agree to cosign the bond.
THE COURT: Okay. But you anticipated that you were
not going to have this detention hearing this morning, that it
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was going to be held in the District of Massachusetts, and you
didn't make the phone calls to find out before today's hearing?
Is that what I understand?
MR. BEATON: That is -- yes, Judge.
THE COURT: Okay. And if he were released on bond,
Mr. Beaton, where would he live?
MR. BEATON: He would live with his mother, your Honor.
THE COURT: Okay. All right. The Court must determine
whether the Government has met its burden of proving that no
condition or combination of conditions will reasonably assure
the Defendant's appearance as required. As to appearance in
court, the Government's burden is by a preponderance of the
evidence, meaning that it is more likely than not.
The Court first assesses the extent of any risk and
then turns to whether any condition or combination of
conditions would reasonably mitigate that risk.
Looking to the nature and circumstances of the offenses
here, other than what is alleged in the indictment involving
the PPP loan, we know other information has been proffered to
me as to the -- or provided through testimony or evidence as to
the circumstances involving that criminal conduct. And as it
relates to the -- what I'll call the mortgage fraud indictment,
there was certainly more information that was proffered. And
certainly both offenses are serious offenses.
But I will note that a mortgage fraud -- the overt acts
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seem to be older conduct, although the conspiracy does range
through 2025.
And looking at the weight of the evidence against the
Defendant, there was really very little outside of what's in
the indictment that was actually proffered here in court.
It's very difficult for the Court to assess based on
the current record established here in court whether or not the
weight of the evidence against this particular Defendant is
strong.
Certainly I think on cross-examination, there were some
points that were brought out as to indicate that perhaps this
is a case where it is a defensible case. And there wasn't
anything outside of, really, the four corners of the indictment
that was presented here to me to indicate whether or not this
is a -- it's uncharacteristic for a detention hearing to
proceed in this manner. I'm used to this proceeding by proffer
where the Government provides a ton of details about the
investigation. But this is not a case where we see a ton of
details about the investigation to really understand how strong
the Government's case is or not.
So on that particular -- in that regard, I find that
the evidence is not particularly strong and that factor does
not particularly weigh in favor of finding that he will not
abide by the terms of any bond that I could impose.
Turning to his history and characteristics, I actually
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find the Defendant has mitigating factors as well as factors
that weigh against him in his personal history and
characteristics. Certainly he has a prior conviction for theft
of public funds that is 12 years old for which he was convicted
and he served 24 months' imprisonment. And that is a
significant factor to consider.
He was on three years of supervised release, that he
was not -- Probation did not seek to violate him for that
period -- during his period of supervised release.
Nonetheless, I do recognize that there are allegations
here from the Government that at least in the last seven months
or so of his supervised release he was already engaging in this
conspiracy.
And so those factors do weigh against the Defendant.
Looking to his family ties to the community, though, I
do find that there are many mitigating factors here. You know,
he's a United States citizen. He's been a naturalized citizen
since 2016. Although he was born in Haiti, his roots here in
this country date back to, according to the Pretrial Services
report, 1996. So he's actually lived in the United States for
30 of his 38 years.
And he's been rooted here in Miami since 2006. That's
20 years that he's been rooted here in Miami. And he has a lot
of family ties here in Miami. His mother lives here and owns a
residence here; his father lives here; he has multiple siblings
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who live here; and he's got his children who live here as well
in Miami.
So I recognize that he has significant family ties here
in this jurisdiction, even though he does have some family
located in Haiti.
I have considered the Government's proffer and
testimony related to his 15-minute delay in coming to the door.
And while that is a delay, he didn't immediately present
himself to law enforcement is an indication that perhaps he was
not immediately cooperative. This is not a situation as far as
the evidence I was presented where he barricaded himself in or
law enforcement had to go in and get him, where he took off
from the residence and tried to flee from law enforcement.
So I don't think that a 15-minute delay in coming to
the door is particularly concerning as to whether or not he's
going to appear here in court.
With regard to his foreign travel, although the
Government pointed out that he declined to provide information
about his foreign travel, the burden here is not on the
Defendant. The burden here is on the Government to provide me
evidence. And the Government had the opportunity and could
have pulled his travel records and told me anything about his
foreign travel.
Based on the current record, I don't have any
information that he's traveled in the last ten years out of the
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United States. And the burden's on the Government to do so.
Now, on balance here, based on the current record, I
think there are bond conditions that I can impose in this case
that can reasonably assure his appearance in court and that he
will appear in the District of Massachusetts.
But I recognize that his brother for whatever reason
indicated that he was not willing to be a cosigner, but
Mr. Beaton has indicated to me that his mother is willing to
serve as a cosigner. And the Pretrial Services report reflects
that the brother did report that the mother would possibly be
willing to be a cosigner, and that is consistent with what
Mr. Beaton has proffered here in court.
I would like, however, Mr. Beaton, to get the mother on
the phone so that I can colloquy her and make sure that she
understands what she'd be agreeing to by being a cosigner.
So, Mr. Beaton, can you please get her on the phone?
MR. BEATON: I can try.
(Pause in the audio recording.)
MR. BEATON: As the Court heard, it went to voicemail.
THE COURT: Okay. Well, here's what we're going to do:
I'm going to require that the mother be a cosigner or another
person who is acceptable to the Government, where he will not
be able to bond out until he has the cosigner who has signed.
Typically, I have the cosigner here in court. I
understand that there was a belief that you were not going to
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have this hearing here this morning, and that's why family
members were not here in court, according to Mr. Beaton.
But I'm going to require that the mother, Nirva
Jean-Jacques, be a cosigner; or alternatively, if for whatever
reason she's not willing to be a cosigner, that another family
member cosign on the loan. But the Government must agree to
the alternative cosigner.
Okay. So let's talk about bond conditions in this
case. And, Ms. Guzman, let me hear from you as far as what are
bond conditions that the Government would like me to consider.
Would you like me to -- are you asking me to consider the
possibility of a percentage bond versus a personal surety bond?
Let me hear from you on that.
MS. GUZMAN: I am not --
THE COURT: And then we'll talk about special
conditions, too. Right now, I'm just talking about the actual
bond itself.
MS. GUZMAN: I'm not asking for a surety bond. I don't
know that the Defendant has the resources for an actual surety
bond. It looks like --
THE COURT: No. A personal surety bond. So in our
district -- I know the Middle District does it differently -- a
personal surety bond is, I think, maybe what you all call an
unsecured bond.
MS. GUZMAN: Oh, okay.
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THE COURT: A [inaudible] bond.
MS. GUZMAN: Yes. I'm sorry.
THE COURT: This is a percentage bond.
MS. GUZMAN: Correct.
I think probably something along the lines, because of
the loss amount, if the Court would consider at least a $25,000
surety bond.
THE COURT: Personal surety?
MS. GUZMAN: Personal surety. Correct.
THE COURT: Oh, it's going to make -- it's going to be
more than 25,000.
MS. GUZMAN: Okay. At least 25,000, based on the loss.
We would also suggest to the Court that perhaps some
kind of -- I don't know if it's termed "electronic monitoring"
here in the Southern District of Florida, but some type of
electronic monitoring perhaps would be appropriate in this
case.
He apparently is currently seeing a mental health
provider. Probation -- Pretrial recommends that he continue
seeing his mental health provider. I think that that would be
an appropriate condition for the Court to consider.
Obviously, surrender all passports, if he has a U.S.
passport, to surrender his passport during the pendency of this
matter. And obviously, not obtain any additional travel
documents during the pendency of this matter.
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One of the conditions suggested by Pretrial that I
would certainly urge the Court to consider is that he not be
employed where there's access to credit cards or where the
Defendant has any type of PII, or any type of personal
identifying information, available.
Obviously, there are Co-Defendants in this case. So
any -- to avoid any contact with additional Co-Defendants
during the course of this case, except through counsel.
Obviously, there may be meetings with counsel for other
matters.
They've also indicated here to refrain from possessing
a firearm, destructive device or other dangerous weapon. He's
not charged with a violent offense in this case. However, that
would not be a bad condition.
There is a restraining order, as the Court noted -- as
I note in the Pretrial Services report. We didn't argue it,
because we weren't arguing danger. But there is apparently an
existing restraining order that was filed by a girlfriend and
that applies to the girlfriend and his child that I think is
still applicable.
So I think a condition that he refrain from any
firearms or destructive devices or dangerous weapons would be
an appropriate condition.
And then of course travel. If the Court would restrict
his travel from the Southern District of Florida to the
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District of Massachusetts. I don't know exactly how the Court
would do that in the Southern District of Florida. I mean,
obviously, he's going to have to appear for court appearances
in Boston in the District of Massachusetts, so he's going to
have to travel there either by vehicle or plane.
THE COURT: What it typically is is that you restrict
their travel, but -- to go to court up in Massachusetts. But
obviously, the plane has to fly from here to Massachusetts.
MS. GUZMAN: Right.
THE COURT: Well, he's allowed to --
MS. GUZMAN: Right.
THE COURT: -- to cover all those jurisdictions by
plane or by rail or by car, however he gets there. But it's
only going to be for driving from here to Massachusetts to go
to court and then back.
MS. GUZMAN: Yes, your Honor. Thank you.
And that would be another condition that we would think
would be appropriate in this case.
THE COURT: Okay.
MS. GUZMAN: Other than that, and as the Court has
noted, a co-signature with either his mother or another
individual that would be appropriate, I think is also an
appropriate condition.
THE COURT: All right. And the electronic monitoring
request, is that -- are you asking for him to have a curfew or
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any restrictions that are tied to the electronic monitoring?
MS. GUZMAN: I mean, I think that a curfew would be
appropriate. I don't know, again -- please excuse, your Honor,
because in the Middle District of Florida usually Pretrial
Services is at the hearings and they advise the Court.
THE COURT: They are here.
MS. GUZMAN: Oh, they are here.
THE COURT: Officer García is here.
MS. GUZMAN: I did not know. Thank you. I'm sorry.
Whether any type of electronic monitoring would be
feasible or appropriate in this case. I mean, it would add an
additional layer to the Defendant remaining within the
jurisdiction and not traveling, unless it's obviously to go to
court. We would urge the Court to consider that, if feasible,
and something that is feasible with U.S. Pretrial.
If not, then certainly at least a curfew would be
something that we would urge the Court to include in his
conditions.
THE COURT: Okay.
MS. GUZMAN: Other than that, I think I have covered
pretty much the conditions we think that would be appropriate
and also mirror what U.S. Pretrial has suggested in the
Pretrial Services report.
THE COURT: All right. Mr. Beaton, let me hear from
you on any proposed bond conditions.
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MR. BEATON: It is interesting how just a district away
that things are so different.
THE COURT: Yes.
MR. BEATON: And I do get a chance to practice in other
places, and it's almost a different language.
So what we would propose is a $100,000 personal surety
bond, cosigned by the mother or by some other person that is
acceptable to the Government.
When I heard the Government say travel restrictions
between the Southern District and the District of
Massachusetts, fair. Surrender travel documents, fair.
Continue mental health treatment, appropriate.
But I think the Court wanted to address now the meat of
the monetary amount. And if you have any other questions, I'm
happy to answer them.
THE COURT: Sure. Was there anything else you wanted
to address with regard to the bond?
MR. BEATON: In terms of bond amount, I think that's
it. If the Court is inclined to impose electronic monitoring,
I'm happy to address that.
THE COURT: Yes. You actually proposed electronic
monitoring when you were --
MR. BEATON: I did.
THE COURT: -- in your argument.
MR. BEATON: So if you're going to accept our proposal,
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then what has worked with Pretrial Services -- and Officer
Garcia is the best person to speak to this -- but there is a
monitoring that leaves it to their discretion on the technology
to be used. And to the extent the Court is going to impose
electronic monitoring, that's what I would propose.
THE COURT: Okay. Officer García, let me hear from you
on the electronic monitoring issue. Obviously, I know that's
not something that Pretrial Services recommended in their
report. But it is something that I'm inclined to order in this
case in light of the fact that, you know, the brother seemed
hesitant about cosigning on a bond, and so that gives me a
little bit of pause. And I would like a little bit more
assurances and -- in light of the fact that he does have the
prior federal conviction.
So -- but I do want to hear from Pretrial Services in
terms of what they would recommend for electronic monitoring
for him.
THE PRETRIAL SERVICES OFFICER: Judge, we're not
recommending any type of electronic monitoring. But we would
like a cosigner to execute the bond prior to release.
Now, that's our position. And it is -- to answer the
Government's question, it is feasible. We handle location
monitoring, we call it, or electronic monitoring in cases all
the time. So we can do that if the Court does order it.
But that's not our recommendation. But we would like a
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cosigner.
THE COURT: Yes. No. There's definitely going to be a
cosigner.
THE PRETRIAL SERVICES OFFICER: Absolutely.
THE COURT: But my question about electronic
monitoring -- I'm going to impose it. So my question is: I
know typically you don't do standalone electronic monitoring,
because usually it's tethered to a curfew or some other
conditions.
THE PRETRIAL SERVICES OFFICER: Right.
THE COURT: So what would your recommendation,
practical recommendation, be in that regard?
THE PRETRIAL SERVICES OFFICER: Your Honor, actually,
the bond papers in the Southern District were recently changed
in the past couple of years. And it does include now
standalone monitoring. So basically, standalone monitoring is
no restrictions other than the fact that we could track if he
were to flee the district. That's really the only
restrictions. No real restriction.
So in that case, if you were -- if the Court were
asking what type of monitoring, I would say standalone
monitoring with the technology to be determined by us. And
that recommendation is coming from the fact that we frankly
didn't recommend the monitoring, but I was glad to answer the
Court's question.
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THE COURT: Okay. All right. Well, thank you. I
appreciate that. And I understand that that wasn't one of the
recommendations. That is something that I am recommending to
myself.
So here's what the bond is going to be: It's going to
be a $100,000 personal surety bond. I do think that that is an
appropriate amount for a personal surety bond in this case.
Given the potential exposure in this case with the guideline
range, I think it's important that there be a more substantive
bond in the amount of $100,000 in this case.
Also, for further assurances that he will appear in
court as required, I'm going to require that his mother be the
cosigner unless for whatever reason she cannot cosign. Then
there's going to be another family member that will be
acceptable to the Government.
So, Mr. Beaton, obviously, you'll have to talk to the
mom first. And if for whatever reason, you can talk to one of
the other siblings or family members and check with the AUSA
and make sure that that is acceptable.
He will not be able to bond out, though, until the bond
paperwork is returned with the signatures of the cosigners.
So, Mr. Jean-Jacques, I want you to listen closely to
what your standard conditions of your bond and your special
conditions are to make sure you don't violate any of them.
All right. So first of all, standard conditions of
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your bond: You are not to violate any state, local or federal
laws while you are out on bond.
If DNA collection is required by law, you are to
participate in DNA collection.
You must -- you will be living at -- let me ask you
this. The address is on the Pretrial report, 801 Northeast
156th Terrace. Is that your mom's house or is that a different
location?
THE DEFENDANT: That's my mama. That's my location.
Yes.
THE COURT: That's your mother's house?
THE DEFENDANT: Yes.
THE COURT: Okay. So then you will continue residing
at that address that is on the Pretrial report while you are
out on bond.
Also, I need to advise you that if you fail to appear
at any required court appearances, that is a separate federal
offense for failure to appear and it is punishable by up to
five years in prison and a fine of up to $250,000.
Now let's go over the special conditions of your bond.
You are to report to Pretrial Services as often as the officer
directs you to report. You are to surrender your passport. So
that U.S. passport that you have, you need to turn it over to
the Pretrial Services officer. And while you are out on bond,
you cannot apply for any other travel documents. Do not apply
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for any passports, visas or anything while you are out on this
bond.
You are also to participate in a mental health
assessment and treatment, if necessary, or continue
participating in that treatment.
With regard to employment, I'm going to give you an
employment restriction. You may continue working. However,
you cannot have any jobs where you have access to credit cards
or the personal identification information of other
individuals.
You are to avoid having contact with the Co-Defendants
for both cases. Right? Because I think you have different
Co-Defendants in each case. So in one case, let me see -- yes.
You have different Co-Defendants in your cases. So you cannot
have any contact with any of the Co-Defendants either in
Criminal Case 26-MJ-2277 or in 26-MJ-2278.
You are to refrain from possessing a firearm or any
other dangerous device. So to the extent that you have any
kind of device like that, you need to make sure that you --
make sure it is not in the home where you reside.
Also, none of -- whoever the cosigner is on the bond
cannot encumber, mortgage or hypothecate in any way any real
property that they own. So if your mom is the cosigner and
your mom owns her house, which according to the Pretrial
Services report she does, your mom cannot get a second mortgage
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on the home; she cannot sell the home or cannot do anything to
encumber the title on that home, as would be true for any other
cosigner who may be -- cosign your bond in lieu of your mother.
Your travel also is going to be restricted from the
Southern District of Florida to the District of Massachusetts.
And you can only travel to the District of Massachusetts for
the purpose of appearing in court. And you'll have to notify
your Pretrial Services officer anytime you're going to leave
the district to go to Massachusetts for court. If you have any
questions about what the geographic boundaries are of the
Southern District of Florida, ask your Pretrial Services
officer to make sure you don't go outside the boundaries of the
Southern District of Florida.
And then the last requirement that I'm going to impose
is that you have standalone electronic monitoring. And the
standalone electronic monitoring is going to be determined,
the -- the technology will be determined by the Pretrial
Services officer, which means you're going to have some kind of
GPS or ankle monitor that's going to monitor your whereabouts
at all times.
But you will not have a curfew or other restriction as
to what time you need to be back at your mother's residence.
All right. Ms. Guzman, did I leave out any other
conditions?
MS. GUZMAN: No, your Honor.
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THE COURT: Okay. Mr. Beaton, anything further on the
subject of bond?
MR. BEATON: No, your Honor.
THE COURT: Okay.
MR. BEATON: And did I hear you say to report to
Pretrial Services as directed?
THE COURT: As directed. Correct.
MR. BEATON: Okay.
THE COURT: And, Officer García, did I leave anything
out?
THE PRETRIAL SERVICES OFFICER: Did the Court order him
to appear in the District of Massachusetts?
THE COURT: Oh, yes. He would have to appear -- but
let me ask Ms. Guzman, do we have any information about when he
has an initial appearance?
MS. GUZMAN: Your Honor, I do not. I did not get that
from the assistant United States attorney in Boston. I did
ask. She did not have it.
And perhaps this is not the appropriate time, but she
also asked that if the Court did consider conditions of release
in this case, whether the Court would consider a one-week stay
for her to appeal to the district court in Boston. That was
her request.
THE COURT: So is she -- well, is she intending to
appeal?
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MS. GUZMAN: She indicated to me that if the Defendant
were to receive conditions of release, which she understood
could happen if he had a hearing, that she was requesting that
the Court consider a one-week stay because she intended to
appeal it to the Court in the District of Massachusetts.
THE COURT: Well, I'm not -- we don't give a one-week
in this district.
MS. GUZMAN: Okay.
THE COURT: She can have until close of business on
Tuesday to file that notice of appeal. And if she doesn't file
it by close of business on Tuesday, then we'll assume that the
District of Massachusetts has chosen not to appeal the ruling
and the decision to grant the Defendant a bond.
So at that point in time -- and in either event, we're
going to be waiting for the cosigner to sign the paperwork.
But -- well, hold on. Today's Friday. Monday's a
holiday. She has until close of business on Wednesday. I'm
sorry. I usually give -- I give two business days for it. So
it will be stayed until close of business on Wednesday, which
is February 18th.
MS. GUZMAN: Thank you.
THE COURT: Okay. February 18th. Yes.
All right. So, Mr. Jean-Jacques, what that means for
you is that the Government is considering appealing my ruling,
which they'll have to do in the District of Massachusetts. My
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ruling is going to be stayed from now until Wednesday at 5:00
p.m. If the Government appeals me, then the District of
Massachusetts will have to take up the decision. If the
Government chooses not to appeal me, then your bond will go
into effect; and as long as you satisfy all the bond conditions
and you have the cosigners, under those circumstances you would
be able to bond out. Okay?
You will be required, if you are able -- if -- assuming
they don't appeal me and my order stands, you're going to be
required to appear in court in Massachusetts. Right now, we
don't have a date for that. So the United States is going to
have to be in contact with your attorney and Pretrial Services
to notify them of when you need to appear in court in
Massachusetts for your initial appearance. Okay?
All right. Mr. Beaton, make sure -- we're going to
need one bond for each case. So make sure you have two bond
forms prepared.
MR. BEATON: I'm doing that now.
And this may not be the appropriate venue in which to
ask, but it raises an issue for me that if the Government does
appeal, I am appointed under a magistrate number by you for
purposes of this removal hearing. I continue on that
representation on that appeal or do I -- or does someone in
Massachusetts take over that representation? And by -- I don't
know the answer either.
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THE COURT: I don't know the answer to that, because
you're here as CJA.
Officer García, you're nodding your head. Do you know
the answer?
THE PRETRIAL SERVICES OFFICER: No, Judge. I was
saying, good point. I've never seen this before.
THE COURT: You know what? We're going to have to find
out. I don't know if your appointment here would include the
appeal to the District of Massachusetts, because you're also --
I don't know if -- are you barred up there? Can you even
appeal up there?
MR. BEATON: I'm not, but I mean, I'm pro hac vice in
other places. So it creates -- it creates a little bit of a
conundrum.
THE COURT: Here's what I suggest. It does happen.
I've never had -- I haven't had it happen before me. My
suggestion is perhaps inquire over at the Federal Public
Defender who's in charge of the CJA panel, and I'm sure they
have seen this come up. I just don't know what the answer
is --
MR. BEATON: I don't either.
THE COURT: -- to tell you right now.
MR. BEATON: I know that is an issue, and I wanted to
make sure that Mr. Jean-Jacques had somebody to help him in the
event that --
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THE COURT: Yes. Yes. Certainly. That is important.
He needs to have counsel. But I'm sure that the folks who
oversee the CJA have seen this come up and can immediately give
you the answer to that. But we will need to make sure that he
has representation should an appeal be filed. Yes.
MR. BEATON: Yes, ma'am.
THE COURT: Okay. All right. Is there anything
further before we recess?
MS. GUZMAN: No, your Honor. Thank you.
THE COURT: All right. So can I enter the order of
removal now or do I need to wait until after with regard to if
they're going to file the appeal? I should probably wait.
THE COURTROOM DEPUTY: [Inaudible] hold off.
THE COURT: Okay. So I'm not going to enter the
removal order just yet. I'm going to wait until close of
business on Wednesday to enter the removal order, because after
that we lose jurisdiction over the case and I'm staying my
order. So I'm going to hold on to entering the order of
removal until that happens and until I get the bond paperwork
so that I can continue to have jurisdiction over this case.
Okay, folks?
MS. GUZMAN: Yes, your Honor.
THE COURT: And as soon as I see whether or not the
Government is appealing my ruling, then I'll make sure that I
sign the removal order, and that way they can -- the whole case
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can be transferred up to Massachusetts, and that way the judge
in Massachusetts can do whatever he or she is going to do with
regard to the ruling.
Okay, folks. Well, thank you so much. Have a lovely
weekend. We'll be in recess.
MS. GUZMAN: Thank you.
THE COURTROOM DEPUTY: All rise. Court is adjourned.
(Proceedings concluded.)
C E R T I F I C A T E
I hereby certify that the foregoing is an
accurate transcription of the proceedings in the
above-entitled matter produced to the best of my ability.
____________
/s/Lisa Edwards
DATE
LISA EDWARDS, RDR, CRR
(305) 439-7168
Reporterlisaedwards@gmail.com
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 65 of 76
$
$100,000 [3] - 52:6,
55:6, 55:10
$200 [1] - 34:5
$25,000 [1] - 48:6
$250,000 [1] - 56:19
$69,000 [1] - 26:9
$70,000 [1] - 29:22
$90,000 [1] - 29:22
'
'18 [1] - 22:17
/
/s/Lisa [1] - 64:20
1
1 [8] - 1:8, 24:14,
28:16, 28:19, 29:2,
29:7, 29:19
11:25 [1] - 1:6
12 [1] - 44:4
121 [2] - 11:1, 34:21
13 [1] - 1:5
1349 [2] - 10:13,
33:15
13th [1] - 23:20
15 [4] - 17:8, 30:11,
30:23, 40:22
15-minute [3] - 41:1,
45:7, 45:14
150 [1] - 1:19
151 [2] - 11:2, 34:22
156th [1] - 56:7
18 [5] - 9:11, 9:20,
10:13, 33:4, 33:15
18th [2] - 60:20,
60:22
19 [1] - 21:22
19-B [1] - 22:22
1996 [1] - 44:20
2
2 [7] - 24:14, 24:15,
28:19, 29:4, 29:7,
29:20, 29:23
20 [2] - 33:10, 44:23
20-MJ-2217 [1] - 8:16
20-year [1] - 10:14
2006 [3] - 37:15,
38:22, 44:22
2013 [1] - 15:20
2014 [6] - 15:20,
38:2, 38:4, 39:25,
40:2, 40:12
2016 [1] - 44:18
2018 [10] - 16:1,
16:2, 18:1, 21:22,
22:13, 23:20, 33:23,
34:6
2020 [2] - 22:13,
22:23
2021 [5] - 22:13,
28:17, 28:18, 28:19,
28:20
2022 [1] - 28:20
2023 [1] - 22:14
2024 [1] - 22:15
2025 [6] - 18:2,
21:23, 22:15, 22:17,
36:11, 43:2
2026 [1] - 1:5
2278-Elfenbein [1] -
2:2
24 [3] - 5:22, 34:4,
44:5
25,000 [2] - 48:11,
48:12
26 [1] - 5:3
26-2277-MJ-
Elfenbein [1] - 7:6
26-2278-MJ [1] - 8:17
26-2278-MJ-
Elfenbein [1] - 7:7
26-Criminal-10030
[1] - 21:19
26-MJ-02277 [1] - 1:2
26-MJ-02278-
CRIMINAL-
ELFENBEIN [1] - 1:2
26-MJ-2277 [2] - 2:2,
57:16
26-MJ-2277-Judge
[1] - 7:24
26-MJ-2278 [1] -
57:16
26.2 [1] - 9:20
278 [1] - 7:24
3
3 [2] - 29:23, 36:10
3.7 [4] - 28:10, 28:22,
28:25, 29:10
30 [3] - 10:18, 33:11,
44:21
30-year [1] - 10:20
305 [2] - 1:22, 64:21
3142 [3] - 9:11, 33:5,
39:4
33130 [1] - 1:19
33132 [1] - 1:16
3500 [1] - 9:20
38 [2] - 4:24, 44:21
4
4 [3] - 22:22, 33:25,
37:16
439-7168 [2] - 1:22,
64:21
5
5 [2] - 7:4, 23:7
5.1 [1] - 7:4
50 [1] - 27:22
5:00 [1] - 61:1
5th [1] - 22:23
6
6 [6] - 2:1, 7:23, 15:1,
23:6, 28:10, 28:24
7
7 [2] - 2:1, 7:23
70 [1] - 27:5
8
801 [1] - 56:6
9
99 [1] - 1:16
A
A-track [1] - 5:4
a.m [1] - 1:6
abide [1] - 43:24
ability [2] - 6:9,
64:18
able [6] - 5:5, 30:19,
46:23, 55:20, 61:7,
61:8
above-entitled [1] -
64:18
absolutely [1] - 54:4
accept [2] - 7:14,
52:25
acceptable [4] -
46:22, 52:8, 55:15,
55:19
acceptance [2] -
11:3, 11:4
access [2] - 49:3,
57:8
according [4] -
15:12, 44:19, 47:2,
57:24
account [3] - 29:22,
35:2, 36:18
accounts [1] - 34:22
accurate [2] - 27:6,
64:17
accusation [1] -
37:21
acquitted [1] - 37:21
Act [1] - 8:23
active [1] - 26:16
activity [3] - 15:24,
18:23, 19:8
acts [5] - 22:12,
22:15, 24:16, 29:9,
42:25
actual [7] - 18:16,
19:4, 24:1, 25:23,
27:11, 47:16, 47:19
add [3] - 29:10,
41:12, 51:11
addiction [1] - 5:10
additional [5] -
34:10, 41:9, 48:24,
49:7, 51:12
address [8] - 17:1,
36:15, 38:16, 52:13,
52:17, 52:20, 56:6,
56:14
adjourned [1] - 64:7
admitted [1] - 36:10
advice [6] - 7:13,
26:15, 27:6, 27:9,
27:16, 31:3
advise [3] - 9:20,
51:5, 56:16
affect [1] - 34:9
afterwards [1] -
31:13
Agency [1] - 13:14
agency [3] - 21:13,
21:14, 25:7
Agent [7] - 11:8,
11:11, 11:12, 13:7,
20:5, 20:12, 32:2
agent [8] - 8:18,
11:6, 13:14, 19:11,
19:13, 33:21, 37:2,
37:3
agents [4] - 16:22,
17:9, 19:11, 21:6
ago [2] - 11:21,
16:12
65
agree [9] - 22:12,
23:25, 24:9, 24:19,
24:21, 31:2, 31:10,
41:23, 47:6
agreeing [1] - 46:15
ahead [5] - 9:7,
12:12, 13:3, 31:20,
33:1
allegation [3] -
24:24, 25:13, 25:15
allegations [2] -
25:18, 44:10
alleged [1] - 42:18
alleges [1] - 24:13
allowed [1] - 50:10
almost [2] - 40:18,
52:5
altered [1] - 27:13
altering [1] - 18:16
alternative [1] - 47:7
alternatively [1] -
47:4
America [1] - 2:3
AMERICA [1] - 1:4
American [1] - 36:20
amount [8] - 14:21,
26:7, 40:19, 48:6,
52:14, 52:18, 55:7,
55:10
amounts [4] - 14:25,
28:25, 29:24, 33:15
ankle [1] - 58:19
answer [11] - 4:17,
28:6, 31:5, 52:15,
53:21, 54:24, 61:25,
62:1, 62:4, 62:19,
63:4
anticipated [2] -
41:18, 41:24
anxiety [3] - 5:17,
5:19, 36:11
anytime [1] - 58:8
apartment [3] -
14:24, 22:24, 29:3
apartments [1] -
14:7
apologize [1] - 40:13
appeal [13] - 59:22,
59:25, 60:5, 60:10,
60:12, 61:4, 61:9,
61:21, 61:23, 62:9,
62:11, 63:5, 63:12
appealing [2] -
60:24, 63:24
appeals [1] - 61:2
appear [15] - 18:18,
37:14, 37:16, 37:22,
37:25, 45:16, 46:5,
50:3, 55:11, 56:16,
56:18, 59:12, 59:13,
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 66 of 76
61:10, 61:13
appearance [8] -
11:21, 39:8, 41:6,
42:11, 46:4, 59:15,
61:14
appearances [2] -
50:3, 56:17
APPEARANCES [1] -
1:13
appearing [1] - 58:7
applicable [1] -
49:20
applicant [1] - 22:25
application [4] -
24:19, 24:22, 27:24,
29:3
applications [7] -
24:15, 25:1, 25:10,
25:15, 28:25, 29:8,
29:10
applies [1] - 49:19
apply [2] - 56:25
appointed [1] - 61:21
appointment [1] -
62:8
appreciate [3] - 31:9,
31:22, 55:2
approach [2] - 12:14,
22:7
approached [1] -
37:7
appropriate [13] -
48:16, 48:21, 49:23,
50:18, 50:22, 50:23,
51:3, 51:11, 51:21,
52:12, 55:7, 59:19,
61:19
approximation [1] -
27:1
argue [2] - 38:17,
49:16
arguing [1] - 49:17
argument [10] - 8:22,
11:14, 19:20, 32:1,
32:9, 32:14, 32:15,
32:25, 41:10, 52:24
arguments [1] - 33:6
arranging [1] - 14:5
arrest [11] - 16:15,
16:19, 16:23, 17:1,
17:10, 30:5, 30:6,
30:8, 30:14, 37:4
arrested [2] - 17:16,
17:18
aside [1] - 29:23
assess [1] - 43:6
assesses [1] - 42:14
assessing [1] -
36:25
assessment [2] -
34:5, 57:4
assets [1] - 18:18
ASSISTANT [2] -
1:15, 1:18
assistant [2] - 19:11,
59:17
assisted [1] - 24:25
assisting [1] - 15:5
assists [1] - 26:14
associate [1] - 5:2
assume [2] - 16:22,
60:11
assuming [1] - 61:8
assurances [2] -
53:13, 55:11
assure [3] - 41:6,
42:10, 46:4
attorney [4] - 31:3,
31:12, 59:17, 61:12
ATTORNEY [1] -
1:15
attributed [1] - 23:14
audible [1] - 16:5
audio [2] - 7:22,
46:18
AUDIO [1] - 1:10
August [3] - 28:20,
36:11
aunt [1] - 27:21
AUSA [1] - 55:18
AUSAs [2] - 9:6, 9:24
available [2] - 8:18,
49:5
avoid [3] - 39:16,
49:7, 57:11
aware [10] - 10:16,
13:19, 13:23, 15:14,
15:17, 16:18, 19:7,
25:8, 26:10, 39:3
B
bad [1] - 49:14
Bail [1] - 8:23
bail [2] - 3:13, 19:19
balance [5] - 26:2,
26:8, 27:12, 27:14,
46:2
balances [1] - 29:21
bank [12] - 10:16,
18:17, 18:21, 19:5,
25:20, 25:23, 26:1,
27:4, 27:11, 27:13,
29:22
banks [2] - 14:4,
14:6
barred [1] - 62:10
barricaded [1] -
45:11
base [1] - 19:19
based [17] - 10:24,
10:25, 11:16, 11:19,
11:23, 13:16, 13:18,
16:21, 18:8, 27:16,
30:10, 38:2, 43:6,
45:24, 46:2, 48:12
basis [1] - 9:24
Beaton [18] - 2:10,
2:12, 2:18, 3:6, 8:6,
20:1, 38:19, 41:13,
42:6, 46:8, 46:12,
46:13, 46:16, 47:2,
51:24, 55:16, 59:1,
61:15
BEATON [46] - 1:18,
2:9, 2:19, 3:8, 3:12,
3:19, 4:1, 8:12, 10:6,
11:12, 20:2, 20:4,
22:3, 22:9, 31:8,
31:19, 31:21, 31:24,
32:14, 32:23, 38:20,
39:2, 39:6, 39:10,
40:3, 40:9, 40:13,
40:15, 41:16, 42:4,
42:7, 46:17, 46:19,
52:1, 52:4, 52:18,
52:23, 52:25, 59:3,
59:5, 59:8, 61:18,
62:12, 62:21, 62:23,
63:6
became [1] - 36:20
become [1] - 16:18
BEFORE [1] - 1:11
beginning [3] - 2:5,
8:1, 20:9
behalf [3] - 2:7, 2:10,
8:3
belief [1] - 46:25
benefit [1] - 7:11
best [3] - 30:23,
53:2, 64:18
between [3] - 15:22,
21:3, 52:10
bit [3] - 53:12, 62:13
Black [1] - 15:9
bolster [1] - 18:14
bond [57] - 35:9,
35:10, 38:5, 39:12,
40:1, 41:4, 41:14,
41:15, 41:23, 42:5,
43:24, 46:3, 46:23,
47:8, 47:10, 47:12,
47:17, 47:18, 47:20,
47:21, 47:23, 47:24,
48:1, 48:3, 48:7,
51:25, 52:7, 52:17,
52:18, 53:11, 53:20,
54:14, 55:5, 55:6,
55:7, 55:10, 55:20,
55:23, 56:1, 56:2,
56:15, 56:20, 56:24,
57:2, 57:21, 58:3,
59:2, 60:13, 61:4,
61:5, 61:7, 61:16,
63:19
born [2] - 36:20,
44:18
borrow [1] - 22:3
Borrower [5] - 28:16,
28:19, 29:19, 29:20
Borrowers [2] -
24:14, 29:7
borrowers [2] -
28:15, 28:21
Boston [6] - 20:17,
23:21, 34:1, 50:4,
59:17, 59:22
bottom [1] - 23:1
bought [1] - 27:22
boundaries [2] -
58:10, 58:12
briefly [3] - 7:20,
14:1, 37:2
broken [1] - 28:16
broker [1] - 18:19
brokers [1] - 27:9
brother [5] - 35:7,
41:17, 46:6, 46:10,
53:10
brought [3] - 16:9,
16:13, 43:11
burden [6] - 36:1,
39:3, 42:9, 42:12,
45:19, 45:20
burden's [1] - 46:1
business [11] - 15:5,
15:8, 15:9, 25:17,
26:12, 60:9, 60:11,
60:17, 60:18, 60:19,
63:16
buttons [1] - 25:5
buying [1] - 29:22
BY [6] - 1:21, 13:6,
20:4, 22:9, 31:8,
31:21
C
calculation [1] - 10:3
calendar [1] - 2:16
cannot [11] - 26:17,
36:5, 41:19, 55:13,
56:25, 57:8, 57:14,
57:22, 57:25, 58:1
car [1] - 50:13
cards [2] - 49:3, 57:8
carry [1] - 39:4
Case [4] - 2:2, 7:6,
66
7:23, 57:16
CASE [1] - 1:2
case [61] - 2:21,
3:14, 3:24, 3:25, 7:16,
7:20, 9:11, 11:23,
12:10, 15:3, 17:14,
18:8, 19:10, 19:11,
19:13, 19:22, 20:15,
20:17, 21:11, 21:14,
21:17, 21:19, 22:20,
24:13, 33:7, 33:22,
37:15, 37:17, 38:4,
38:11, 39:13, 39:22,
39:25, 40:2, 40:6,
40:12, 43:12, 43:18,
43:20, 46:3, 47:9,
48:17, 49:6, 49:8,
49:13, 50:18, 51:11,
53:10, 54:20, 55:7,
55:8, 55:10, 57:13,
59:21, 61:16, 63:17,
63:20, 63:25
cases [5] - 20:13,
33:8, 53:23, 57:12,
57:14
cash [1] - 27:1
Category [4] - 34:13,
34:14, 34:18, 34:22
caught [1] - 21:8
caused [2] - 25:2,
25:4
certain [4] - 24:3,
24:13, 26:2, 26:19
certainly [10] - 10:8,
10:10, 30:19, 42:23,
42:24, 43:10, 44:3,
49:2, 51:16, 63:1
certificates [1] - 5:3
certify [1] - 64:16
chance [1] - 52:4
changed [2] - 28:8,
54:14
characteristics [2] -
43:25, 44:3
characterizations
[1] - 40:20
characterized [1] -
24:14
charge [3] - 33:25,
34:1, 62:18
charged [3] - 33:8,
37:1, 49:13
charges [3] - 3:5,
10:2, 10:12
check [2] - 12:7,
55:18
child [1] - 49:19
children [2] - 38:24,
45:1
chooses [1] - 61:4
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 67 of 76
chosen [1] - 60:12
Christopher [1] -
35:8
circumstances [5] -
30:4, 37:3, 42:17,
42:21, 61:6
citizen [6] - 16:6,
36:20, 36:21, 38:22,
44:17
CJA [3] - 62:2, 62:18,
63:3
claiming [1] - 25:1
clear [2] - 27:7,
30:13
clearly [1] - 6:12
client [2] - 3:7, 40:1
clients [3] - 26:14,
27:9, 40:25
close [5] - 60:9,
60:11, 60:17, 60:19,
63:15
closed [1] - 23:21
closely [1] - 55:22
co [1] - 50:21
Co [9] - 19:1, 25:18,
39:17, 49:6, 49:7,
57:11, 57:13, 57:14,
57:15
Co-Defendant [1] -
25:18
Co-Defendants [8] -
19:1, 39:17, 49:6,
49:7, 57:11, 57:13,
57:14, 57:15
co-signature [1] -
50:21
coercion [1] - 25:9
colleagues [1] - 21:7
collection [2] - 56:3,
56:4
collectively [1] -
29:10
college [2] - 5:1, 5:3
colloquied [1] - 7:11
colloquy [1] - 46:14
combination [4] -
39:7, 39:11, 42:10,
42:15
comfortable [1] -
12:15
coming [4] - 40:22,
45:7, 45:14, 54:23
commenced [1] -
34:7
commission [1] -
33:13
commit [3] - 10:13,
33:11, 33:13
commonly [1] -
39:14
communicated [1] -
19:3
communication [2] -
24:12, 41:17
community [6] -
9:13, 11:15, 33:5,
36:14, 38:18, 44:15
companies [2] -
26:19, 27:1
company [2] - 15:10,
15:11
complex [1] - 22:24
computer [1] - 28:3
concern [2] - 36:25,
38:1
concerning [1] -
45:15
concluded [1] - 64:8
condition [8] - 42:10,
42:15, 48:21, 49:14,
49:21, 49:23, 50:17,
50:23
conditions [27] -
38:16, 39:7, 39:8,
39:10, 39:11, 39:13,
41:5, 41:14, 42:10,
42:16, 46:3, 47:8,
47:10, 47:16, 49:1,
51:18, 51:21, 51:25,
54:9, 55:23, 55:24,
55:25, 56:20, 58:24,
59:20, 60:2, 61:5
conduct [2] - 42:21,
43:1
conducting [1] -
15:5
confers [2] - 4:2,
40:4
confirm [1] - 41:19
connect [1] - 18:13
connecting [1] -
27:15
consider [11] -
39:20, 44:6, 47:10,
47:11, 48:6, 48:21,
49:2, 51:14, 59:20,
59:21, 60:4
considered [1] - 45:6
considering [1] -
60:24
consistent [3] - 12:3,
12:6, 46:11
conspiracy [14] -
10:13, 14:4, 16:2,
17:25, 21:22, 22:13,
22:16, 25:17, 29:15,
33:11, 33:13, 33:24,
43:1, 44:13
contact [5] - 39:16,
49:7, 57:11, 57:15,
61:12
contacted [2] - 35:6,
35:9
contacts [1] - 36:19
contained [1] - 32:16
contemplating [1] -
3:3
contested [1] - 3:15
context [1] - 24:11
continue [8] - 39:15,
48:19, 52:12, 56:13,
57:4, 57:7, 61:22,
63:20
continued [1] - 18:9
control [1] - 15:4
conundrum [1] -
62:14
conversation [1] -
26:4
conversations [1] -
21:3
convicted [3] -
33:20, 34:2, 44:4
conviction [3] -
37:21, 44:3, 53:14
cooperative [5] -
16:23, 17:12, 37:4,
37:5, 45:10
coordinate [1] -
18:16
coordinated [4] -
14:4, 14:9, 22:20,
25:16
copy [2] - 22:1, 22:6
corners [1] - 43:13
Corporations [1] -
15:13
correct [32] - 2:18,
11:4, 14:9, 14:12,
14:13, 16:12, 17:13,
18:2, 18:5, 18:6,
18:23, 18:24, 20:19,
21:15, 22:16, 23:13,
24:5, 24:11, 24:16,
25:2, 27:2, 27:3,
30:18, 34:15, 37:19,
37:23, 39:1, 39:9,
40:13, 48:4, 48:9,
59:7
corroborate [2] -
35:7, 35:12
cosign [8] - 35:9,
35:10, 41:15, 41:20,
41:23, 47:6, 55:13,
58:3
cosigned [1] - 52:7
cosigner [19] -
41:15, 46:7, 46:9,
46:11, 46:15, 46:21,
46:23, 46:24, 47:4,
47:5, 47:7, 53:20,
54:1, 54:3, 55:13,
57:21, 57:23, 58:3,
60:15
cosigners [2] -
55:21, 61:6
cosigning [1] - 53:11
counsel [9] - 2:4,
7:11, 7:13, 9:18, 9:22,
32:12, 49:8, 49:9,
63:2
counsels [1] - 8:1
countries [1] - 38:14
country [2] - 36:23,
44:19
counts [1] - 34:3
couple [2] - 9:23,
54:15
course [5] - 10:25,
17:25, 35:11, 49:8,
49:24
Court [63] - 4:4, 8:21,
8:22, 9:11, 9:14, 9:16,
9:21, 10:16, 11:15,
11:25, 16:25, 17:6,
17:24, 18:25, 19:19,
33:3, 33:7, 33:20,
35:5, 36:16, 37:3,
37:4, 37:5, 37:6, 37:9,
37:13, 37:24, 38:13,
38:15, 38:25, 39:3,
39:18, 39:19, 39:20,
39:24, 41:4, 41:10,
41:19, 42:8, 42:14,
43:6, 46:19, 48:6,
48:13, 48:21, 49:2,
49:15, 49:24, 50:1,
50:20, 51:5, 51:14,
51:17, 52:13, 52:19,
53:4, 53:24, 54:20,
59:11, 59:20, 59:21,
60:4, 60:5
court [25] - 6:10, 7:8,
16:10, 16:13, 20:10,
42:12, 43:5, 43:7,
45:16, 46:4, 46:12,
46:24, 47:2, 50:3,
50:7, 50:15, 51:14,
55:12, 56:17, 58:7,
58:9, 59:22, 61:10,
61:13, 64:7
COURT [126] - 1:1,
2:8, 2:12, 2:20, 3:11,
3:14, 3:20, 3:23, 4:5,
4:7, 4:15, 4:22, 4:25,
5:5, 5:8, 5:13, 5:18,
5:21, 5:25, 6:5, 6:8,
6:12, 6:15, 6:22, 7:1,
7:3, 7:10, 8:5, 8:13,
8:24, 9:2, 9:5, 9:23,
67
10:8, 10:21, 11:3,
11:5, 11:9, 11:11,
11:18, 12:3, 12:10,
12:15, 12:18, 13:3,
19:16, 19:22, 19:25,
22:8, 31:5, 31:20,
31:25, 32:2, 32:6,
32:11, 32:18, 32:24,
34:12, 34:16, 34:21,
34:25, 35:18, 35:23,
36:1, 37:17, 37:20,
38:4, 38:9, 38:19,
39:1, 39:5, 39:9, 40:1,
40:8, 40:10, 40:14,
41:8, 41:13, 41:24,
42:5, 42:8, 46:20,
47:15, 47:21, 48:1,
48:3, 48:8, 48:10,
50:6, 50:10, 50:12,
50:19, 50:24, 51:6,
51:8, 51:19, 51:24,
52:3, 52:16, 52:21,
52:24, 53:6, 54:2,
54:5, 54:11, 55:1,
56:11, 56:13, 59:1,
59:4, 59:7, 59:9,
59:13, 59:24, 60:6,
60:9, 60:22, 62:1,
62:7, 62:15, 62:22,
63:1, 63:7, 63:10,
63:14, 63:23
Court's [2] - 30:13,
54:25
courtroom [2] - 3:23,
7:15
COURTROOM [9] -
2:1, 3:22, 4:11, 4:14,
7:23, 12:20, 12:23,
63:13, 64:7
courts [1] - 39:13
cover [1] - 50:12
covered [1] - 51:20
created [1] - 14:6
creates [2] - 62:13
creation [1] - 18:16
credit [4] - 18:14,
18:15, 49:3, 57:8
creditworthy [1] -
18:19
crime [2] - 4:18
criminal [7] - 11:1,
15:15, 15:17, 34:8,
37:14, 38:1, 42:21
Criminal [7] - 7:6,
9:20, 34:12, 34:14,
34:18, 34:22, 57:16
CROSS [1] - 20:3
cross [3] - 8:19,
20:1, 43:10
CROSS-
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 68 of 76
EXAMINATION [1] -
20:3
cross-examination
[3] - 8:19, 20:1, 43:10
CRR [2] - 1:21, 64:21
curfew [5] - 50:25,
51:2, 51:16, 54:8,
58:21
current [5] - 15:21,
39:16, 43:7, 45:24,
46:2
cut [1] - 20:13
D
dad [1] - 27:21
danger [7] - 9:13,
11:14, 12:6, 33:5,
36:14, 38:17, 49:17
dangerous [3] -
49:12, 49:22, 57:18
DATE [1] - 64:21
date [2] - 44:19,
61:11
dates [3] - 21:22,
22:13, 28:18
days [3] - 11:21,
16:12, 60:18
December [3] - 16:1,
22:23, 33:23
decision [3] - 4:8,
60:13, 61:3
declined [4] - 35:21,
36:4, 36:6, 45:18
deem [1] - 38:2
deems [1] - 37:4
defendant [2] - 1:8,
7:17
Defendant [38] - 4:2,
4:13, 9:12, 9:17,
10:12, 13:21, 14:2,
14:4, 15:4, 16:23,
25:18, 25:24, 26:1,
33:7, 33:10, 33:15,
33:17, 33:18, 33:22,
34:2, 34:3, 35:17,
35:19, 35:21, 36:8,
36:17, 37:7, 40:4,
43:4, 43:8, 44:1,
44:14, 45:20, 47:19,
49:4, 51:12, 60:1,
60:13
DEFENDANT [20] -
1:18, 4:6, 4:21, 4:24,
5:1, 5:7, 5:11, 5:15,
5:20, 5:23, 6:2, 6:6,
6:11, 6:14, 6:21, 6:25,
7:2, 7:9, 56:9, 56:12
Defendant's [5] -
33:4, 35:7, 36:14,
41:6, 42:11
Defendants [15] -
14:19, 16:16, 18:9,
18:11, 18:12, 18:15,
19:1, 21:4, 39:17,
49:6, 49:7, 57:11,
57:13, 57:14, 57:15
DEFENDER [1] -
1:18
Defender [1] - 62:18
defense [3] - 9:18,
11:25, 32:12
defensible [1] -
43:12
definitely [2] - 21:16,
54:2
defraud [1] - 14:4
delay [4] - 41:1, 45:7,
45:8, 45:14
deny [1] - 38:16
depriving [1] - 25:10
deputy [2] - 3:23,
7:15
DEPUTY [9] - 2:1,
3:22, 4:11, 4:14, 7:23,
12:20, 12:23, 63:13,
64:7
destructive [2] -
49:12, 49:22
details [2] - 43:17,
43:19
detained [2] - 16:12,
38:6
DETENTION [1] -
1:10
detention [13] - 3:1,
3:9, 3:13, 3:16, 7:19,
7:21, 8:9, 9:10, 16:9,
16:15, 40:6, 41:25,
43:15
determine [2] - 37:5,
42:8
determined [3] -
54:22, 58:16, 58:17
determining [1] -
37:13
device [3] - 49:12,
57:18, 57:19
devices [1] - 49:22
diagnosed [2] - 5:9,
36:11
different [6] - 21:14,
52:2, 52:5, 56:7,
57:12, 57:14
differently [1] -
47:22
difficult [1] - 43:6
DIGITAL [1] - 1:10
DIRECT [1] - 13:5
directed [3] - 39:15,
59:6, 59:7
directs [1] - 56:22
discharged [2] -
33:22, 34:6
discovered [1] - 17:2
discretion [1] - 53:3
discuss [1] - 6:23
discussing [1] -
41:14
discussion [1] - 12:6
disposition [1] -
37:17
District [37] - 3:5,
6:19, 8:15, 9:2, 10:19,
10:24, 13:10, 13:20,
13:24, 15:3, 17:14,
17:20, 19:12, 35:2,
42:1, 46:5, 47:22,
48:15, 49:25, 50:1,
50:2, 50:4, 51:4,
52:10, 54:14, 58:5,
58:6, 58:11, 58:13,
59:12, 60:5, 60:12,
60:25, 61:2, 62:9
district [8] - 36:3,
39:14, 47:22, 52:1,
54:18, 58:9, 59:22,
60:7
DISTRICT [2] - 1:1,
1:1
dive [1] - 9:24
Division [1] - 15:12
DIVISION [1] - 1:2
DNA [2] - 56:3, 56:4
docket [1] - 11:18
document [3] - 3:25,
22:18, 22:19
documentation [5] -
14:5, 19:4, 19:5,
20:23, 20:24
documents [9] - 7:4,
20:14, 20:21, 25:19,
37:10, 38:15, 48:25,
52:11, 56:25
dollars [1] - 33:16
done [2] - 7:13, 9:3
door [8] - 30:15,
31:1, 31:6, 31:11,
40:22, 40:25, 45:7,
45:15
dots [1] - 27:15
double [1] - 12:7
double-check [1] -
12:7
down [4] - 4:14,
10:6, 28:17, 32:3
driver's [1] - 17:2
driving [1] - 50:14
duly [1] - 4:13
during [11] - 15:23,
17:25, 18:7, 33:13,
33:23, 35:11, 40:2,
44:9, 48:23, 48:25,
49:8
E
EDWARDS [2] -
1:21, 64:21
Edwards [1] - 64:20
effect [1] - 61:5
effects [1] - 5:16
either [12] - 5:25,
6:8, 20:12, 24:15,
25:9, 32:7, 50:5,
50:21, 57:15, 60:14,
61:25, 62:21
electronic [17] -
41:5, 48:14, 48:16,
50:24, 51:1, 51:10,
52:19, 52:21, 53:5,
53:7, 53:16, 53:19,
53:23, 54:5, 54:7,
58:15, 58:16
elevate [1] - 34:19
ELFENBEIN [1] -
1:11
Elfenbein [1] - 7:24
employed [2] -
13:13, 49:3
Employee [2] - 29:2,
29:4
Employees [1] -
24:14
employment [4] -
14:5, 29:5, 57:6, 57:7
encumber [2] -
57:22, 58:2
end [2] - 16:1, 23:22
ended [1] - 16:1
enforcement [8] -
30:16, 31:1, 31:11,
37:8, 40:24, 45:9,
45:12, 45:13
enforcement's [1] -
40:23
engaging [1] - 44:12
English [2] - 2:18,
5:6
enhanced [1] - 34:17
enter [3] - 63:10,
63:14, 63:16
entering [1] - 63:18
entitled [1] - 64:18
ESQ [2] - 1:15, 1:18
essentially [3] -
14:2, 24:24, 32:10
established [2] -
68
9:10, 43:7
establishes [1] -
40:21
establishment [1] -
15:5
estimate [4] - 10:22,
10:23, 30:23, 34:21
estimated [1] - 14:22
event [2] - 60:14,
62:25
events [1] - 16:9
evidence [22] - 6:17,
8:21, 9:6, 9:17, 28:2,
28:4, 28:7, 29:16,
29:17, 29:19, 32:7,
39:22, 40:16, 40:18,
42:13, 42:20, 43:3,
43:8, 43:22, 45:11,
45:21
exact [1] - 26:7
exactly [2] - 19:1,
50:1
examination [3] -
8:19, 20:1, 43:10
EXAMINATION [2] -
13:5, 20:3
example [3] - 22:22,
25:20, 29:2
except [1] - 49:8
exclude [1] - 39:10
excuse [1] - 51:3
excused [2] - 2:21,
32:5
execute [3] - 20:15,
30:6, 53:20
existence [1] - 9:21
existing [1] - 49:18
explain [2] - 16:25,
28:23
exposure [1] - 55:8
extent [3] - 42:14,
53:4, 57:18
F
facing [3] - 33:10,
33:17, 33:19
fact [7] - 25:5, 37:6,
41:1, 53:10, 53:13,
54:17, 54:23
factor [2] - 43:22,
44:6
factors [5] - 40:17,
44:1, 44:14, 44:16
facts [5] - 13:9,
13:23, 14:1, 16:19,
32:16
fail [1] - 56:16
failure [4] - 37:14,
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 69 of 76
37:16, 37:22, 56:18
fair [3] - 21:11, 52:11
fake [1] - 26:6
falsely [1] - 4:18
falsifying [1] - 25:19
familiar [3] - 13:9,
15:2, 16:3
family [13] - 36:19,
37:10, 38:23, 40:24,
41:17, 44:15, 44:24,
45:3, 45:4, 47:1, 47:5,
55:14, 55:18
far [3] - 4:25, 45:10,
47:9
father [2] - 38:23,
44:25
favor [1] - 43:23
feasible [4] - 51:11,
51:14, 51:15, 53:22
February [3] - 1:5,
60:20, 60:22
Federal [3] - 9:19,
13:14, 62:17
FEDERAL [1] - 1:18
federal [6] - 16:10,
16:13, 33:9, 53:14,
56:1, 56:17
feet [1] - 10:9
few [1] - 16:12
figure [1] - 14:22
figured [1] - 2:23
file [3] - 60:10, 63:12
filed [2] - 49:18, 63:5
filled [2] - 3:18, 3:24
finally [1] - 17:8
Finance [1] - 13:14
financial [4] - 10:17,
15:19, 26:14, 33:12
fine [2] - 33:15,
56:19
finger [1] - 39:19
firearm [2] - 49:12,
57:17
firearms [1] - 49:22
first [12] - 3:16,
10:11, 12:24, 12:25,
13:13, 20:10, 37:24,
37:25, 38:21, 42:14,
55:17, 55:25
five [2] - 4:19, 56:19
Flagler [1] - 1:19
flee [4] - 33:19,
34:10, 45:13, 54:18
Fleischman [1] -
7:18
flight [17] - 9:12,
11:16, 11:20, 11:23,
12:2, 12:5, 12:11,
19:15, 19:18, 19:21,
33:4, 35:4, 36:25,
37:13, 38:12, 41:3,
41:11
FLORIDA [1] - 1:1
Florida [13] - 1:4,
1:16, 1:19, 9:2, 13:16,
13:18, 48:15, 49:25,
50:2, 51:4, 58:5,
58:11, 58:13
fluent [1] - 2:17
fly [1] - 50:8
folks [7] - 2:25, 7:15,
24:13, 25:1, 63:2,
63:21, 64:4
FOR [2] - 1:15, 1:18
force [2] - 6:16, 25:9
foregoing [1] - 64:16
foreign [7] - 35:19,
35:21, 35:23, 36:3,
45:17, 45:19, 45:23
form [1] - 3:20
forms [2] - 7:8, 61:17
forward [2] - 2:14,
3:6
four [2] - 38:24,
43:13
Fourth [1] - 1:16
frankly [2] - 37:24,
54:23
fraud [13] - 10:14,
10:16, 15:6, 15:19,
19:6, 21:14, 21:17,
28:12, 33:11, 33:13,
42:22, 42:25
fraudulent [9] - 14:5,
15:24, 18:17, 18:22,
19:5, 19:8, 22:25,
25:24, 29:12
Friday [1] - 60:16
FROM [1] - 1:10
FULGUEIRA [1] -
1:11
funds [2] - 19:7, 44:4
furtherance [4] -
22:12, 22:16, 24:16,
29:9
G
gaps [1] - 35:14
Garcia [1] - 53:2
García [4] - 51:8,
53:6, 59:9, 62:3
General [1] - 13:15
generally [1] - 30:14
geographic [1] -
58:10
girlfriend [2] - 49:18,
49:19
given [2] - 30:23,
55:8
glad [1] - 54:24
GOVERNMENT [2] -
1:15, 12:22
Government [27] -
2:5, 6:16, 8:2, 8:18,
11:19, 11:22, 32:6,
36:1, 39:3, 42:9,
43:17, 44:11, 45:18,
45:20, 45:21, 46:1,
46:22, 47:6, 47:10,
52:8, 52:9, 55:15,
60:24, 61:2, 61:4,
61:20, 63:24
Government's [5] -
11:16, 42:12, 43:20,
45:6, 53:22
GPS [1] - 58:19
grand [4] - 6:19,
27:5, 27:22, 33:9
grant [1] - 60:13
granted [1] - 11:15
great [3] - 2:20,
19:25, 32:24
guess [1] - 9:2
guided [1] - 25:14
guideline [1] - 55:8
guidelines [5] - 10:4,
10:22, 34:9, 34:19,
35:3
guys [3] - 24:25,
25:1, 31:9
Guzman [12] - 2:7,
2:8, 8:3, 8:5, 11:22,
21:21, 32:6, 32:20,
33:1, 47:9, 58:23,
59:14
GUZMAN [65] - 1:15,
2:6, 8:3, 8:11, 8:20,
9:1, 9:4, 9:9, 10:5,
10:11, 10:23, 11:4,
11:7, 11:10, 11:24,
12:9, 12:13, 12:17,
12:19, 13:2, 13:4,
13:6, 19:14, 19:18,
19:24, 22:4, 31:4,
32:1, 32:9, 33:2,
34:15, 34:17, 34:24,
35:1, 35:19, 35:25,
36:4, 37:19, 37:23,
38:7, 38:10, 41:9,
47:14, 47:18, 47:25,
48:2, 48:4, 48:9,
48:12, 50:9, 50:11,
50:16, 50:20, 51:2,
51:7, 51:9, 51:20,
58:25, 59:16, 60:1,
60:8, 60:21, 63:9,
63:22, 64:6
H
hac [1] - 62:12
Haiti [8] - 36:19,
36:20, 36:23, 37:10,
37:11, 44:18, 45:5
half [2] - 32:15
hand [6] - 4:3, 4:11,
4:14, 6:3, 12:21, 27:1
handle [1] - 53:22
handled [1] - 8:8
happy [3] - 22:6,
52:15, 52:20
hard [1] - 28:21
head [1] - 62:3
health [7] - 36:9,
37:11, 39:16, 48:18,
48:20, 52:12, 57:3
hear [8] - 37:3, 37:6,
47:9, 47:13, 51:24,
53:6, 53:15, 59:5
heard [5] - 12:4,
30:20, 33:21, 46:19,
52:9
hearing [30] - 2:22,
3:1, 3:6, 3:9, 3:13,
3:16, 3:18, 4:9, 6:24,
7:5, 7:13, 7:19, 7:21,
8:8, 8:9, 9:18, 11:15,
11:19, 11:25, 12:1,
22:5, 40:6, 41:25,
42:2, 43:15, 47:1,
60:3, 61:22
HEARING [1] - 1:10
hearings [1] - 51:5
held [2] - 14:17, 42:1
hello [1] - 20:9
help [3] - 18:14,
41:5, 62:24
helped [1] - 25:13
helping [1] - 19:13
hereby [1] - 64:16
hesitant [1] - 53:11
higher [1] - 18:18
himself [6] - 17:9,
28:8, 35:21, 36:10,
45:9, 45:11
hired [1] - 26:22
history [12] - 11:1,
15:15, 15:17, 16:4,
34:8, 35:7, 35:22,
37:11, 37:14, 38:1,
43:25, 44:2
History [4] - 34:13,
34:14, 34:18, 34:22
hold [4] - 32:11,
60:16, 63:13, 63:18
holiday [1] - 60:17
home [5] - 30:21,
69
57:20, 58:1, 58:2
homes [1] - 29:23
Honor [50] - 2:6, 2:9,
4:6, 4:21, 5:3, 5:11,
6:11, 6:14, 6:21, 6:25,
7:2, 7:9, 8:3, 8:11,
8:12, 8:20, 10:5, 10:6,
10:11, 11:7, 11:12,
12:9, 12:13, 12:19,
13:2, 19:14, 19:18,
20:2, 22:5, 31:19,
31:24, 32:1, 32:9,
32:14, 33:2, 38:8,
38:20, 39:13, 40:15,
41:7, 41:9, 42:7,
50:16, 51:3, 54:13,
58:25, 59:3, 59:16,
63:9, 63:22
HONORABLE [1] -
1:11
hospital [1] - 36:10
hours [1] - 5:22
house [4] - 27:22,
56:7, 56:11, 57:24
Housing [1] - 13:14
hypothecate [1] -
57:22
I
idea [1] - 27:8
identification [1] -
57:9
identified [1] - 39:21
identify [2] - 22:13,
30:15
identifying [1] - 49:5
identities [1] - 18:14
identity [6] - 3:18,
3:19, 4:8, 6:24, 7:13,
8:8
II [2] - 34:14, 34:22
illness [1] - 5:9
illustrated [1] - 14:3
immediately [3] -
45:8, 45:10, 63:3
impact [1] - 6:9
important [5] - 37:2,
37:6, 37:12, 55:9,
63:1
impose [8] - 39:14,
41:4, 43:24, 46:3,
52:19, 53:4, 54:6,
58:14
imprisonment [2] -
34:4, 44:5
inactive [1] - 15:12
inadequacy [1] -
27:16
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 70 of 76
inaudible [7] - 3:21,
4:10, 5:1, 20:18,
26:17, 48:1, 63:13
inaudible] [3] - 5:2,
31:7, 40:7
incentive [1] - 34:10
inclined [2] - 52:19,
53:9
include [4] - 10:15,
51:17, 54:15, 62:8
including [1] - 38:23
income [1] - 14:5
inconsistent [1] -
22:18
increased [1] - 10:18
indicate [3] - 17:6,
43:11, 43:14
indicated [12] -
17:11, 17:24, 35:8,
35:10, 35:20, 36:9,
36:24, 41:21, 46:7,
46:8, 49:11, 60:1
indicates [3] - 7:5,
35:12, 36:21
indicating [1] - 9:11
indication [2] -
22:17, 45:9
indicted [2] - 6:19,
33:8
indictment [33] -
8:17, 10:12, 10:15,
13:9, 13:20, 13:24,
14:3, 14:11, 14:15,
14:23, 14:24, 16:2,
16:17, 17:16, 17:24,
20:20, 21:21, 22:1,
22:6, 24:3, 24:13,
24:25, 28:11, 28:16,
29:14, 30:2, 33:8,
34:7, 42:18, 42:22,
43:5, 43:13
indictments [3] -
8:15, 8:16, 14:23
individual [2] -
13:10, 50:22
individuals [5] -
14:11, 14:15, 17:15,
18:13, 57:10
induce [1] - 14:6
information [18] -
23:16, 29:25, 30:1,
35:12, 35:13, 35:15,
36:5, 36:7, 36:22,
38:7, 38:10, 42:19,
42:23, 45:18, 45:25,
49:5, 57:9, 59:14
informed [1] - 3:8
initial [3] - 11:21,
59:15, 61:14
inquire [1] - 62:17
inquired [1] - 9:16
inside [1] - 30:21
Inspector [1] - 13:15
instance [2] - 24:18,
24:21
instances [3] -
16:19, 24:6, 35:11
institution [2] -
10:17, 33:12
instructed [1] -
22:23
intended [4] - 14:25,
28:10, 28:24, 60:4
intending [1] - 59:24
intentionally [1] -
4:17
interesting [1] - 52:1
internally [2] - 22:18,
41:2
interpreter [2] - 2:15,
2:19
Interpreter [1] - 2:21
interview [1] - 20:14
interviews [1] -
20:21
investigation [4] -
19:10, 20:15, 43:18,
43:19
investigative [1] -
21:13
involved [5] - 10:18,
16:8, 16:15, 16:16,
21:14
involving [5] - 13:9,
13:10, 16:19, 42:18,
42:21
isolation [1] - 27:16
issue [18] - 10:9,
12:2, 14:6, 19:15,
19:17, 19:20, 33:3,
33:6, 33:12, 35:5,
37:1, 38:12, 38:16,
53:7, 61:20, 62:23
issued [2] - 18:20,
29:1
issues [3] - 36:9,
36:13, 38:13
itself [3] - 33:25,
36:24, 47:17
J
JACQUES [1] - 1:7
Jacques [44] - 2:3,
2:10, 2:13, 2:17, 3:2,
3:8, 4:3, 4:15, 6:18,
7:21, 7:25, 8:7, 10:9,
13:11, 14:17, 15:14,
16:18, 18:8, 18:10,
18:13, 18:15, 18:25,
20:16, 21:4, 22:21,
22:23, 23:15, 23:21,
24:18, 24:22, 25:13,
25:22, 26:5, 26:10,
28:2, 30:20, 38:21,
40:5, 40:19, 41:21,
47:4, 55:22, 60:23,
62:24
Jacques's [2] - 16:3,
30:5
January [1] - 28:17
JEAN [1] - 1:7
Jean [46] - 2:3, 2:10,
2:13, 2:17, 3:2, 3:8,
4:3, 4:15, 6:18, 7:21,
7:25, 8:7, 10:9, 13:11,
14:17, 15:14, 16:3,
16:18, 18:8, 18:10,
18:13, 18:15, 18:25,
20:16, 21:4, 22:21,
22:23, 23:15, 23:21,
24:18, 24:22, 25:13,
25:22, 26:5, 26:10,
28:2, 30:5, 30:20,
38:21, 40:5, 40:19,
41:21, 47:4, 55:22,
60:23, 62:24
JEAN-JACQUES [1]
- 1:7
Jean-Jacques [44] -
2:3, 2:10, 2:13, 2:17,
3:2, 3:8, 4:3, 4:15,
6:18, 7:21, 7:25, 8:7,
10:9, 13:11, 14:17,
15:14, 16:18, 18:8,
18:10, 18:13, 18:15,
18:25, 20:16, 21:4,
22:21, 22:23, 23:15,
23:21, 24:18, 24:22,
25:13, 25:22, 26:5,
26:10, 28:2, 30:20,
38:21, 40:5, 40:19,
41:21, 47:4, 55:22,
60:23, 62:24
Jean-Jacques's [2] -
16:3, 30:5
Jencks [1] - 9:16
jobs [1] - 57:8
Johnson [1] - 35:8
Judge [2] - 42:4,
62:5
judge [3] - 29:17,
53:18, 64:1
JUDGE [1] - 1:11
judicial [2] - 8:13,
8:14
July [1] - 28:18
June [5] - 18:2,
21:23, 22:17, 23:20,
28:17
jurisdiction [4] -
45:4, 51:13, 63:17,
63:20
jurisdictions [1] -
50:12
jury [2] - 6:19, 33:9
K
Kelly [1] - 23:20
Keppra [2] - 6:3
kind [6] - 26:4, 27:6,
28:19, 48:14, 57:19,
58:18
knock [1] - 30:15
knocking [1] - 31:1
knowing [1] - 7:12
knowledge [7] -
16:8, 18:8, 19:9,
20:22, 21:11, 21:16,
30:20
knows [1] - 37:9
L
language [3] - 23:25,
24:7, 52:5
languages [1] - 5:7
last [12] - 2:22, 5:22,
5:23, 7:16, 7:17,
12:24, 13:1, 30:4,
41:22, 44:11, 45:25,
58:14
law [10] - 30:16,
31:1, 31:11, 37:7,
40:23, 45:9, 45:12,
45:13, 56:3
laws [1] - 56:2
lawyer [2] - 6:23, 7:3
layer [1] - 51:12
leasing [1] - 14:7
least [10] - 17:12,
17:25, 26:8, 27:5,
30:14, 37:15, 44:11,
48:6, 48:12, 51:16
leave [3] - 58:8,
58:23, 59:9
leaves [1] - 53:3
lectern [1] - 12:16
level [1] - 10:25
license [1] - 17:2
lieu [1] - 58:3
light [2] - 53:10,
53:13
likely [3] - 6:17, 24:2,
42:13
limited [2] - 19:20,
70
38:11
lines [2] - 23:21, 48:5
LISA [2] - 1:21, 64:21
list [2] - 39:17, 40:17
listed [2] - 14:11,
29:14
listen [1] - 55:22
lists [1] - 21:22
literally [1] - 28:14
live [4] - 42:6, 42:7,
45:1
lived [1] - 44:20
lives [2] - 44:24,
44:25
living [1] - 56:5
loan [4] - 14:23,
18:20, 42:19, 47:6
loans [1] - 14:6
local [2] - 36:10, 56:1
located [1] - 45:5
location [5] - 30:7,
53:22, 56:8, 56:9
look [5] - 3:23,
11:18, 23:19, 37:24,
38:15
looked [1] - 2:22
looking [5] - 29:21,
30:16, 42:17, 43:3,
44:15
looks [1] - 47:20
lose [1] - 63:17
loss [7] - 10:25,
14:21, 28:10, 40:19,
48:6, 48:12
lovely [1] - 64:4
low [1] - 29:18
lower [1] - 27:12
Luxury [1] - 15:9
M
M-U-N-I-Z [1] - 13:1
ma'am [2] - 6:7, 63:6
Madam [1] - 2:21
magistrate [1] -
61:21
MAGISTRATE [1] -
1:11
main [1] - 19:10
mama [1] - 56:9
management [1] -
14:18
mandatory [1] - 10:1
manner [1] - 43:16
MARCOS [1] - 1:18
Marcos [1] - 2:9
MARIA [1] - 1:15
Maria [2] - 2:6, 8:3
Market [1] - 15:9
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 71 of 76
marshals [1] - 10:7
MARTY [1] - 1:11
Massachusetts [39] -
3:5, 6:19, 8:16, 10:20,
10:24, 13:10, 13:17,
13:21, 13:24, 15:4,
15:18, 17:15, 17:21,
19:12, 19:13, 21:6,
35:2, 42:1, 46:5, 50:1,
50:4, 50:7, 50:8,
50:14, 52:11, 58:5,
58:6, 58:9, 59:12,
60:5, 60:12, 60:25,
61:3, 61:10, 61:14,
61:24, 62:9, 64:1,
64:2
materials [1] - 9:21
matter [8] - 3:15, 8:9,
14:2, 15:21, 15:22,
48:24, 48:25, 64:18
matters [4] - 8:4,
8:15, 9:13, 49:10
max [1] - 10:3
maximum [4] -
10:14, 10:18, 10:20,
33:10
maximums [1] -
33:14
mean [11] - 19:1,
19:3, 20:13, 29:2,
29:8, 29:21, 40:12,
50:2, 51:2, 51:11,
62:12
meaning [1] - 42:13
means [5] - 6:17,
24:9, 34:18, 58:18,
60:23
meat [1] - 52:13
medication [4] -
5:12, 5:16, 5:17,
36:12
medications [3] -
5:21, 6:1, 6:8
meetings [1] - 49:9
member [2] - 47:6,
55:14
members [2] - 47:2,
55:18
mental [8] - 5:9,
36:9, 37:11, 39:16,
48:18, 48:20, 52:12,
57:3
mentioned [1] - 29:9
message [3] - 21:3,
24:10, 26:8
messaged [1] -
23:20
messages [3] - 21:7,
23:14, 24:3
met [3] - 20:7, 20:10,
42:9
MIAMI [1] - 1:2
Miami [11] - 1:4,
1:16, 1:19, 36:10,
38:22, 39:1, 39:2,
44:22, 44:23, 44:24,
45:2
Michelle [1] - 23:20
Middle [3] - 9:2,
47:22, 51:4
might [1] - 32:21
million [10] - 15:1,
27:23, 28:10, 28:11,
28:22, 28:24, 29:10,
29:23, 33:16
minimum [2] - 10:2,
26:2
minute [3] - 11:20,
12:8
minutes [4] - 17:8,
30:11, 30:23, 40:22
mirror [1] - 51:22
mitigate [1] - 42:16
mitigating [2] - 44:1,
44:16
mom [5] - 27:21,
55:17, 57:23, 57:24,
57:25
mom's [1] - 56:7
Monday's [1] - 60:16
monetary [1] - 52:14
money [1] - 34:2
monitor [2] - 58:19
monitoring [24] -
41:5, 48:14, 48:16,
50:24, 51:1, 51:10,
52:19, 52:22, 53:3,
53:5, 53:7, 53:16,
53:19, 53:23, 54:6,
54:7, 54:16, 54:21,
54:22, 54:24, 58:15,
58:16
months [3] - 11:2,
34:22, 44:11
months' [2] - 34:4,
44:5
moreover [1] - 33:25
morning [19] - 2:6,
2:9, 2:12, 2:13, 2:16,
2:25, 3:8, 4:6, 4:7,
5:23, 6:13, 13:7, 13:8,
20:5, 20:6, 41:18,
41:19, 41:25, 47:1
mortgage [10] -
14:24, 18:19, 24:19,
26:19, 26:25, 27:9,
42:22, 42:25, 57:22,
57:25
mortgages [2] -
14:25, 24:15
most [5] - 12:15,
24:2, 24:6, 32:16,
37:12
mother [13] - 38:23,
41:22, 42:7, 44:24,
46:8, 46:10, 46:13,
46:21, 47:3, 50:21,
52:7, 55:12, 58:3
mother's [2] - 56:11,
58:22
move [2] - 22:11,
23:6
MR [45] - 2:9, 2:19,
3:8, 3:12, 3:19, 4:1,
8:12, 10:6, 11:12,
20:2, 20:4, 22:3, 22:9,
31:8, 31:19, 31:21,
31:24, 32:14, 32:23,
38:20, 39:2, 39:6,
39:10, 40:3, 40:9,
40:13, 40:15, 41:16,
42:4, 42:7, 46:17,
46:19, 52:1, 52:4,
52:18, 52:23, 52:25,
59:3, 59:5, 59:8,
61:18, 62:12, 62:21,
62:23, 63:6
MS [64] - 2:6, 8:3,
8:11, 8:20, 9:1, 9:4,
9:9, 10:5, 10:11,
10:23, 11:4, 11:7,
11:10, 11:24, 12:9,
12:13, 12:17, 12:19,
13:2, 13:4, 13:6,
19:14, 19:18, 19:24,
22:4, 31:4, 32:1, 32:9,
33:2, 34:15, 34:17,
34:24, 35:1, 35:19,
35:25, 36:4, 37:19,
37:23, 38:7, 38:10,
41:9, 47:14, 47:18,
47:25, 48:2, 48:4,
48:9, 48:12, 50:9,
50:11, 50:16, 50:20,
51:2, 51:7, 51:9,
51:20, 58:25, 59:16,
60:1, 60:8, 60:21,
63:9, 63:22, 64:6
multiple [1] - 44:25
MUNIZ [1] - 12:22
must [5] - 39:4,
39:10, 42:8, 47:6,
56:5
Muñiz [9] - 11:8,
11:9, 11:11, 11:12,
12:25, 13:7, 20:5,
20:12, 32:2
N
N-E-L-S-O-N [1] -
12:25
name [10] - 2:4, 6:1,
8:1, 11:9, 12:23,
12:24, 12:25, 13:1,
13:11, 15:9
narcotics [1] - 5:10
narrow [1] - 33:6
naturalized [1] -
44:17
nature [2] - 38:13,
42:17
necessary [1] - 57:4
need [13] - 2:16,
2:19, 3:25, 22:10,
27:4, 56:16, 56:23,
57:19, 58:22, 61:13,
61:16, 63:4, 63:11
needed [1] - 3:24
needs [1] - 63:2
neglected [2] - 7:16,
41:13
Nelson [3] - 11:8,
11:9, 12:25
NELSON [1] - 12:22
never [4] - 20:7,
27:18, 62:6, 62:16
next [3] - 2:11, 5:13,
25:3
night [2] - 5:23,
41:22
Nirva [1] - 47:3
none [2] - 9:18,
57:21
nonetheless [1] -
44:10
Northeast [2] - 1:16,
56:6
NOS [1] - 1:2
notably [1] - 39:12
note [7] - 11:13,
33:20, 35:4, 36:8,
39:24, 42:25, 49:16
noted [7] - 14:15,
17:15, 34:5, 34:11,
39:24, 49:15, 50:21
notes [1] - 11:20
nothing [4] - 22:14,
27:17, 27:18, 31:24
notice [3] - 8:13,
8:15, 60:10
noticing [1] - 2:15
notify [2] - 58:7,
61:13
nowhere [1] - 22:15
number [4] - 22:25,
27:7, 28:22, 61:21
71
numbers [4] - 27:8,
28:3, 29:20, 39:22
O
oath [3] - 4:10, 4:16,
4:17
objection [2] - 11:14,
31:4
obtain [1] - 48:24
obtained [2] - 15:2,
19:8
obviously [18] -
11:25, 33:3, 34:9,
34:19, 36:15, 36:21,
37:9, 38:21, 41:10,
48:22, 48:24, 49:6,
49:9, 50:3, 50:8,
51:13, 53:7, 55:16
occurred [1] - 15:24
October [1] - 28:19
OF [2] - 1:1, 1:4
offense [8] - 10:24,
15:23, 15:25, 37:1,
38:3, 38:14, 49:13,
56:18
offenses [3] - 42:17,
42:24
offer [1] - 32:18
Office [1] - 13:15
officer [8] - 51:8,
53:6, 56:21, 56:24,
58:8, 58:12, 58:18,
62:3
Officer [2] - 53:1,
59:9
OFFICER [6] - 53:18,
54:4, 54:10, 54:13,
59:11, 62:5
often [1] - 56:21
old [2] - 4:23, 44:4
older [1] - 43:1
one [36] - 3:15, 3:25,
5:16, 5:25, 6:2, 6:3,
6:6, 6:8, 7:6, 7:7,
14:24, 15:2, 16:16,
18:12, 18:15, 20:12,
24:16, 26:6, 26:10,
26:25, 31:19, 33:3,
37:15, 38:1, 40:16,
41:17, 49:1, 55:2,
55:17, 57:13, 59:21,
60:4, 60:6, 61:16
one-week [3] -
59:21, 60:4, 60:6
ones [2] - 25:24,
37:12
open [2] - 15:11,
31:6
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 72 of 76
opportunity [2] -
32:20, 45:21
order [16] - 11:21,
12:8, 25:17, 49:15,
49:18, 53:9, 53:24,
59:11, 61:9, 63:10,
63:15, 63:16, 63:18,
63:25
original [4] - 14:25,
26:6, 28:24, 30:7
originally [1] - 17:1
originates [1] - 20:17
outside [5] - 32:21,
36:2, 43:4, 43:13,
58:12
overall [1] - 29:15
overlap [1] - 15:22
overruled [1] - 31:5
oversee [1] - 63:3
overt [1] - 42:25
own [2] - 36:18,
57:23
owns [2] - 44:24,
57:24
P
p.m [1] - 61:2
page [2] - 23:1, 23:7
Page [8] - 2:1, 7:23,
22:22, 23:6, 33:25,
36:10, 37:16
Pages [1] - 1:8
panel [1] - 62:18
papers [1] - 54:14
paperwork [3] -
55:21, 60:15, 63:19
Paragraph [6] -
21:22, 22:22, 23:7,
23:10, 23:12, 23:19
paragraph [1] -
23:19
part [3] - 20:15,
29:15, 30:7
participate [2] - 56:4,
57:3
participating [1] -
57:5
participation [1] -
25:14
particular [7] -
13:23, 15:21, 17:14,
33:6, 33:7, 43:8,
43:21
particularly [3] -
43:22, 43:23, 45:15
parties [1] - 8:10
passed [1] - 7:3
passport [5] - 35:20,
48:23, 56:22, 56:23
passports [3] -
39:15, 48:22, 57:1
past [1] - 54:15
pause [3] - 7:22,
46:18, 53:12
penalties [2] - 33:17,
33:19
penalty [1] - 34:17
pendency [2] -
48:23, 48:25
pending [2] - 3:5,
17:20
people [2] - 18:14,
26:22
percentage [2] -
47:12, 48:3
perfect [1] - 5:8
perhaps [6] - 43:11,
45:9, 48:13, 48:16,
59:19, 62:17
period [8] - 15:22,
15:23, 18:4, 18:7,
23:22, 34:6, 44:9
perjury [1] - 4:19
permission [1] - 10:7
permit [1] - 8:22
person [4] - 35:6,
46:22, 52:7, 53:2
personal [17] - 16:3,
20:21, 21:10, 21:16,
30:19, 35:7, 44:2,
47:12, 47:21, 47:23,
48:8, 48:9, 49:4, 52:6,
55:6, 55:7, 57:9
personally [1] -
24:20
perspective [1] -
40:23
pertinent [1] - 38:12
petition [1] - 40:11
phone [4] - 22:24,
42:2, 46:14, 46:16
phrase [1] - 23:8
Pierre [1] - 22:23
PII [1] - 49:4
place [1] - 18:1
places [3] - 2:24,
52:5, 62:13
Plaintiff [1] - 1:5
plane [3] - 50:5,
50:8, 50:13
pled [1] - 10:20
podium [1] - 12:14
point [8] - 11:5, 15:1,
17:12, 20:14, 21:21,
22:21, 60:14, 62:6
pointed [1] - 45:18
points [2] - 34:13,
43:11
position [3] - 38:17,
41:11, 53:21
possessing [2] -
49:11, 57:17
possession [2] -
37:9, 38:14
possibility [2] - 3:3,
47:12
possibly [1] - 46:10
potential [7] - 9:16,
14:21, 33:4, 33:10,
33:19, 34:9, 55:8
potentially [2] -
33:11, 34:19
PPP [6] - 14:23, 15:2,
21:14, 21:16, 28:12,
42:19
practical [1] - 54:12
practice [1] - 52:4
pre [1] - 3:24
pre-filled [1] - 3:24
prefer [2] - 31:9,
40:24
preliminary [4] -
9:24, 10:21, 10:23,
12:5
preparation [1] -
26:11
prepare [2] - 12:1,
26:17
prepared [1] - 61:17
preparer [2] - 26:11,
26:16
preponderance [6] -
6:17, 29:17, 39:5,
39:6, 39:7, 42:12
prescribed [1] -
36:12
present [3] - 2:10,
17:2, 45:8
presented [4] - 17:8,
33:9, 43:14, 45:11
press [1] - 25:5
Pretrial [37] - 8:14,
32:16, 32:19, 34:1,
34:11, 35:6, 35:9,
35:15, 36:6, 36:17,
36:22, 36:24, 39:12,
39:14, 39:21, 44:19,
46:9, 48:19, 49:1,
49:16, 51:4, 51:15,
51:22, 51:23, 53:1,
53:8, 53:15, 56:6,
56:14, 56:21, 56:24,
57:24, 58:8, 58:11,
58:17, 59:6, 61:12
PRETRIAL [6] -
53:18, 54:4, 54:10,
54:13, 59:11, 62:5
pretrial [3] - 3:1,
38:6, 40:6
pretty [1] - 51:21
priors [1] - 39:21
prison [2] - 4:19,
56:19
privately [2] - 4:2,
40:4
pro [1] - 62:12
probable [1] - 7:16
Probation [2] - 44:8,
48:19
Procedure [1] - 9:20
proceed [10] - 3:9,
8:10, 8:21, 9:7, 9:8,
12:2, 13:2, 32:14,
32:24, 43:16
proceeding [6] - 9:6,
11:22, 12:10, 33:5,
41:19, 43:16
proceedings [3] -
3:4, 64:8, 64:17
proceeds [1] - 29:12
produced [1] - 64:18
proffer [10] - 8:25,
9:7, 9:25, 12:5, 32:7,
32:12, 32:15, 35:24,
43:16, 45:6
proffered [4] - 42:19,
42:23, 43:5, 46:12
program [2] - 28:3,
28:7
proof [3] - 29:5,
40:18, 40:19
property [1] - 57:23
proposal [1] - 52:25
propose [2] - 52:6,
53:5
proposed [3] -
41:14, 51:25, 52:21
proprietor [1] - 15:4
prove [1] - 6:16
provide [9] - 9:21,
22:6, 22:24, 27:11,
35:21, 36:4, 36:7,
45:18, 45:20
provided [6] - 10:23,
19:4, 21:5, 25:16,
25:23, 42:20
provider [3] - 39:16,
48:19, 48:20
provides [1] - 43:17
proving [1] - 42:9
provision [1] - 10:17
PUBLIC [1] - 1:18
public [2] - 34:2,
44:4
Public [1] - 62:17
pull [1] - 20:14
pulled [1] - 45:22
punishable [2] -
72
4:19, 56:18
purpose [2] - 14:6,
58:7
purposes [4] - 9:9,
22:5, 37:12, 61:22
pursuant [2] - 9:11,
10:12
pursuing [1] - 9:10
put [6] - 4:10, 4:14,
4:16, 9:15, 31:22,
37:2
putting [1] - 29:23
Q
qualifies [1] - 24:6
qualify [3] - 27:6,
27:18, 27:25
questions [8] - 3:17,
4:8, 4:18, 19:14,
19:16, 39:20, 52:14,
58:10
quickly [1] - 23:6
quite [1] - 37:24
quote [2] - 23:21,
23:22
quoted [1] - 23:25
R
rail [1] - 50:13
raise [2] - 4:11,
12:20
raises [1] - 61:20
range [5] - 11:1,
33:16, 34:18, 43:1,
55:9
RDR [2] - 1:21, 64:21
re [2] - 7:20, 7:23
re-call [1] - 7:20
re-calling [1] - 7:23
read [1] - 39:18
ready [3] - 8:10,
8:11, 11:6
real [2] - 54:19,
57:22
really [4] - 43:4,
43:13, 43:19, 54:18
reason [4] - 46:6,
47:5, 55:13, 55:17
reasonably [4] -
39:8, 42:10, 42:16,
46:4
rebuttal [2] - 41:8,
41:9
receive [2] - 27:13,
60:2
received [3] - 19:4,
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 73 of 76
25:24, 34:3
recently [1] - 54:14
recess [2] - 63:8,
64:5
recidivist [3] - 33:18,
33:20, 38:2
recognize [3] -
44:10, 45:3, 46:6
recollection [3] -
2:17, 12:4, 12:7
recommend [3] -
39:12, 53:16, 54:24
recommendation [4]
- 53:25, 54:11, 54:12,
54:23
recommendations
[1] - 55:3
recommended [1] -
53:8
recommending [2] -
53:19, 55:3
recommends [1] -
48:19
record [12] - 2:4, 8:1,
9:9, 11:13, 12:24,
30:13, 32:21, 40:18,
40:21, 43:7, 45:24,
46:2
RECORDING [1] -
1:10
recording [2] - 7:22,
46:18
records [2] - 20:21,
45:22
recruited [2] - 18:13,
19:1
redirect [1] - 31:25
refer [2] - 14:14,
22:10
referring [1] - 14:14
reflected [2] - 36:9,
37:16
reflecting [1] - 27:13
reflects [3] - 11:21,
12:8, 46:9
Reform [1] - 8:23
refrain [3] - 49:11,
49:21, 57:17
refused [3] - 17:4,
17:7
regard [8] - 37:15,
43:21, 45:17, 52:17,
54:12, 57:6, 63:11,
64:3
regards [24] - 8:22,
9:13, 9:19, 10:11,
14:1, 14:8, 14:18,
14:21, 15:3, 15:21,
16:18, 17:14, 18:9,
19:10, 19:15, 19:18,
22:20, 33:18, 35:4,
36:25, 37:25, 38:11,
40:22, 41:10
relate [1] - 36:13
related [2] - 29:5,
45:7
relates [1] - 42:22
relatively [1] - 40:7
release [11] - 16:1,
34:5, 38:16, 40:11,
40:12, 44:7, 44:9,
44:12, 53:20, 59:20,
60:2
released [1] - 42:5
relied [1] - 12:1
relying [1] - 19:19
remaining [1] - 51:12
remains [1] - 8:9
remember [6] - 6:3,
12:4, 21:24, 26:7,
26:9, 27:23
reminded [1] - 7:15
removal [8] - 3:1,
3:12, 61:22, 63:11,
63:15, 63:16, 63:19,
63:25
removal/identity [1]
- 7:4
rental [2] - 24:22,
29:6
renting [1] - 29:3
rents [1] - 24:15
report [27] - 8:14,
19:19, 32:17, 32:19,
34:1, 34:11, 35:6,
35:11, 35:16, 36:6,
36:18, 36:22, 36:24,
39:14, 39:21, 44:20,
46:9, 46:10, 49:16,
51:23, 53:9, 56:6,
56:14, 56:21, 56:22,
57:25, 59:5
reported [1] - 36:17
reporterlisaedward
s@gmail.com [1] -
1:21
Reporterlisaedwar
ds@gmail.com [1] -
64:22
reports [2] - 20:25,
21:7
representation [6] -
11:17, 11:24, 12:1,
61:23, 61:24, 63:5
request [2] - 50:25,
59:23
requested [2] -
11:19, 27:14
requesting [1] - 60:3
require [3] - 46:21,
47:3, 55:12
required [7] - 41:6,
42:11, 55:12, 56:3,
56:17, 61:8, 61:10
requirement [1] -
58:14
reside [2] - 39:2,
57:20
resided [1] - 38:22
residence [4] - 17:3,
44:25, 45:13, 58:22
residing [2] - 39:1,
56:13
resolved [1] - 40:7
resources [1] - 47:19
respect [1] - 40:23
respond [1] - 32:20
response [1] - 16:5
responsibilities [1] -
9:19
responsible [1] -
28:11
rest [1] - 18:20
restraining [2] -
49:15, 49:18
restrict [2] - 49:24,
50:6
restricted [1] - 58:4
restriction [3] -
54:19, 57:7, 58:21
restrictions [4] -
51:1, 52:9, 54:17,
54:19
result [1] - 19:8
return [3] - 19:5,
25:24, 27:13
returned [3] - 13:20,
26:2, 55:21
review [1] - 16:21
reviewed [4] - 20:24,
21:2, 21:3
reviewing [1] - 20:23
revoke [1] - 40:11
rise [1] - 64:7
risk [19] - 9:12,
11:16, 11:20, 11:23,
12:2, 12:5, 12:11,
19:15, 19:19, 19:21,
33:4, 35:4, 37:1,
37:13, 38:12, 41:3,
41:11, 42:14, 42:16
role [2] - 14:2, 14:18
rooted [2] - 44:22,
44:23
roots [1] - 44:18
Rule [2] - 7:4, 9:19
ruling [5] - 60:12,
60:24, 61:1, 63:24,
64:3
S
safe [1] - 34:8
satisfy [1] - 61:5
saw [2] - 2:23, 30:21
school [1] - 4:25
second [3] - 30:7,
31:19, 57:25
Section [1] - 10:13
secure [1] - 39:8
Security [1] - 29:5
see [19] - 2:14, 8:6,
8:16, 22:22, 23:1,
23:7, 23:8, 23:10,
23:23, 25:3, 27:17,
28:11, 28:14, 28:21,
32:12, 39:17, 43:18,
57:13, 63:23
seeing [2] - 48:18,
48:20
seek [1] - 44:8
seem [1] - 43:1
seizure [4] - 5:11,
5:15, 5:24, 6:4
seizures [1] - 5:18
sell [1] - 58:1
sent [2] - 21:7, 21:10
sentence [1] - 34:3
separate [2] - 4:18,
56:17
September [1] -
28:18
serious [3] - 11:20,
12:5, 42:24
serve [1] - 46:9
served [1] - 44:5
SERVICES [6] -
53:18, 54:4, 54:10,
54:13, 59:11, 62:5
Services [31] - 8:14,
32:17, 32:19, 34:1,
34:11, 35:6, 35:9,
35:16, 36:6, 36:18,
36:22, 36:24, 39:12,
39:14, 39:21, 44:19,
46:9, 49:16, 51:5,
51:23, 53:1, 53:8,
53:15, 56:21, 56:24,
57:25, 58:8, 58:11,
58:18, 59:6, 61:12
services [1] - 2:16
session [1] - 20:10
seven [2] - 5:7, 44:11
several [2] - 35:11,
38:24
show [4] - 26:2, 26:8,
27:12, 36:2
showing [1] - 18:17
shown [1] - 17:1
73
siblings [3] - 38:24,
44:25, 55:18
side [1] - 5:16
sign [3] - 7:7, 60:15,
63:25
signature [1] - 50:21
signatures [1] -
55:21
signed [2] - 4:3,
46:23
significant [6] -
33:14, 33:17, 33:19,
38:23, 44:6, 45:3
significantly [1] -
27:12
simply [2] - 11:15,
37:7
sit [1] - 10:6
situation [1] - 45:10
Sniders [4] - 2:3,
6:18, 7:24, 13:11
SNIDERS [1] - 1:7
Social [1] - 29:5
someone [8] - 25:14,
27:4, 27:16, 31:11,
41:2, 41:20, 61:23
sometime [1] - 36:11
sometimes [1] - 9:4
somewhat [2] -
14:18, 18:4
somewhere [3] -
11:1, 26:9, 33:16
soon [1] - 63:23
sorry [7] - 2:22, 7:17,
7:24, 16:11, 48:2,
51:9, 60:18
sort [2] - 27:15, 29:5
sought [1] - 11:19
South [2] - 13:16,
13:18
SOUTHERN [1] - 1:1
Southern [8] - 48:15,
49:25, 50:2, 52:10,
54:14, 58:5, 58:11,
58:13
span [1] - 28:15
speaking [2] - 16:22,
30:14
special [5] - 13:14,
34:5, 47:15, 55:23,
56:20
specific [1] - 23:18
specifics [1] - 17:23
speculation [1] -
31:4
speed [1] - 21:8
spell [1] - 12:24
spoken [2] - 41:17,
41:20
spot [1] - 31:23
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 74 of 76
standalone [6] -
54:7, 54:16, 54:21,
58:15, 58:16
standard [4] - 29:18,
55:23, 55:25
standards [3] -
26:20, 26:23, 26:25
standing [3] - 2:11,
10:9, 20:18
stands [1] - 61:9
start [1] - 4:22
started [1] - 16:2
stat [1] - 10:3
state [5] - 2:4, 8:1,
12:23, 24:3, 56:1
statement [2] - 26:1,
27:17
statements [6] -
18:17, 25:20, 25:23,
27:12, 27:13
STATES [4] - 1:1,
1:4, 1:11, 1:15
States [14] - 2:2, 2:7,
8:4, 8:11, 11:8, 16:6,
35:20, 36:20, 38:22,
44:17, 44:20, 46:1,
59:17, 61:11
statute [1] - 10:16
statutory [4] - 10:14,
10:18, 10:20, 33:14
stay [3] - 12:16,
59:21, 60:4
stayed [2] - 60:19,
61:1
staying [1] - 63:17
step [1] - 32:2
stepping [1] - 31:22
still [5] - 2:15, 3:3,
15:11, 36:23, 49:20
Street [2] - 1:16, 1:19
strong [3] - 43:9,
43:19, 43:22
subject [1] - 59:2
submit [3] - 25:5,
25:10, 27:24
submitted [8] -
24:15, 24:18, 24:20,
24:22, 24:23, 25:2,
25:4, 28:25
submitting [1] - 29:3
subpoenas [1] -
20:15
substance [11] -
22:24, 23:4, 23:7,
23:10, 23:12, 23:16,
24:7, 24:9, 24:24,
25:15, 26:4
substantive [2] -
20:12, 55:9
sufficient [1] - 6:22
suggest [6] - 15:24,
18:25, 34:8, 38:13,
48:13, 62:15
suggested [2] - 49:1,
51:22
suggesting [1] -
18:10
suggestion [1] -
62:17
suggests [1] - 41:3
summary [2] - 24:10
supervised [7] -
15:25, 34:4, 40:11,
40:12, 44:7, 44:9,
44:12
supervision [2] -
33:22, 34:6
supervisor [1] -
14:18
surety [11] - 47:12,
47:18, 47:19, 47:21,
47:23, 48:7, 48:8,
48:9, 52:6, 55:6, 55:7
surrender [7] - 37:7,
39:15, 48:22, 48:23,
52:11, 56:22
surrounding [1] -
16:9
switched [1] - 28:3
switching [1] - 25:20
sworn [3] - 4:12,
4:13, 12:21
SWORN [1] - 12:22
T
tax [3] - 26:11, 26:16
taxes [1] - 26:17
team [4] - 17:1, 30:6,
30:8, 30:14
technology [3] -
53:3, 54:22, 58:17
ten [1] - 45:25
tender [1] - 19:22
term [1] - 38:2
termed [1] - 48:14
terms [4] - 20:20,
43:24, 52:18, 53:16
Terrace [1] - 56:7
testified [1] - 21:20
testify [1] - 30:19
testimonial [2] -
8:21, 9:6
testimony [5] - 8:23,
11:14, 33:21, 42:20,
45:7
tethered [1] - 54:8
text [3] - 21:3, 21:7,
26:7
THE [166] - 1:10,
1:11, 1:15, 1:18, 2:1,
2:8, 2:12, 2:20, 3:11,
3:14, 3:20, 3:22, 3:23,
4:5, 4:6, 4:7, 4:11,
4:14, 4:15, 4:21, 4:22,
4:24, 4:25, 5:1, 5:5,
5:7, 5:8, 5:11, 5:13,
5:15, 5:18, 5:20, 5:21,
5:23, 5:25, 6:2, 6:5,
6:6, 6:8, 6:11, 6:12,
6:14, 6:15, 6:21, 6:22,
6:25, 7:1, 7:2, 7:3,
7:9, 7:10, 7:23, 8:5,
8:13, 8:24, 9:2, 9:5,
9:23, 10:8, 10:21,
11:3, 11:5, 11:9,
11:11, 11:18, 12:3,
12:10, 12:15, 12:18,
12:20, 12:23, 12:25,
13:3, 19:16, 19:22,
19:25, 22:8, 31:5,
31:6, 31:20, 31:25,
32:2, 32:4, 32:6,
32:11, 32:18, 32:24,
34:12, 34:16, 34:21,
34:25, 35:18, 35:23,
36:1, 37:17, 37:20,
38:4, 38:9, 38:19,
39:1, 39:5, 39:9, 40:1,
40:8, 40:10, 40:14,
41:8, 41:13, 41:24,
42:5, 42:8, 46:20,
47:15, 47:21, 48:1,
48:3, 48:8, 48:10,
50:6, 50:10, 50:12,
50:19, 50:24, 51:6,
51:8, 51:19, 51:24,
52:3, 52:16, 52:21,
52:24, 53:6, 53:18,
54:2, 54:4, 54:5,
54:10, 54:11, 54:13,
55:1, 56:9, 56:11,
56:12, 56:13, 59:1,
59:4, 59:7, 59:9,
59:11, 59:13, 59:24,
60:6, 60:9, 60:22,
62:1, 62:5, 62:7,
62:15, 62:22, 63:1,
63:7, 63:10, 63:13,
63:14, 63:23, 64:7
theft [2] - 34:2, 44:3
themselves [1] -
30:16
they've [1] - 49:11
thinking [1] - 6:12
threat [1] - 25:9
three [6] - 15:1, 34:4,
34:13, 37:24, 37:25,
44:7
three-point-
something [1] - 15:1
tied [1] - 51:1
ties [8] - 36:2, 36:23,
37:11, 38:14, 38:23,
44:15, 44:24, 45:3
timeframe [1] - 33:23
timeframes [1] -
28:15
Title [5] - 9:11, 9:20,
10:13, 33:4, 33:15
title [1] - 58:2
today [1] - 12:11
today's [4] - 12:1,
20:9, 42:2, 60:16
together [1] - 19:3
ton [2] - 43:17, 43:18
took [6] - 5:23, 17:8,
17:25, 25:3, 30:10,
45:12
top [3] - 6:2, 23:7,
40:17
total [2] - 10:24,
10:25
track [2] - 5:4, 54:17
trade [1] - 23:21
TRANSCRIBED [2] -
1:10, 1:21
transcription [1] -
64:17
transfer [1] - 17:20
transferred [1] - 64:1
travel [20] - 35:19,
35:22, 35:23, 36:3,
37:10, 38:15, 45:17,
45:19, 45:22, 45:23,
48:24, 49:24, 49:25,
50:5, 50:7, 52:9,
52:11, 56:25, 58:4,
58:6
traveled [2] - 36:5,
45:25
traveling [1] - 51:13
treatment [3] -
52:12, 57:4, 57:5
trial [1] - 40:2
tried [1] - 45:13
true [1] - 58:2
try [1] - 46:17
trying [1] - 17:10
Tuesday [2] - 60:10,
60:11
turn [3] - 25:7, 32:11,
56:23
turning [2] - 9:17,
43:25
turns [1] - 42:15
two [13] - 7:3, 11:21,
14:23, 22:13, 28:14,
28:21, 29:8, 29:10,
74
29:23, 34:3, 37:12,
60:18, 61:16
type [9] - 15:8,
15:17, 27:8, 48:15,
49:4, 51:10, 53:19,
54:21
typically [3] - 46:24,
50:6, 54:7
U
U.S [4] - 48:22,
51:15, 51:22, 56:23
uncharacteristic [1]
- 43:15
uncle [1] - 27:21
uncorroborated [1] -
35:15
under [10] - 4:10,
4:16, 4:17, 9:19,
10:16, 12:11, 33:4,
39:4, 61:6, 61:21
underlying [1] -
13:23
underpins [1] -
20:20
understood [1] -
60:2
underwriting [3] -
26:20, 26:23, 26:25
United [14] - 2:2, 2:7,
8:4, 8:11, 11:8, 16:6,
35:20, 36:20, 38:21,
44:17, 44:20, 46:1,
59:17, 61:11
UNITED [4] - 1:1,
1:4, 1:11, 1:15
unknown [2] - 37:18,
37:25
unless [2] - 51:13,
55:13
unreasonable [7] -
31:2, 31:10, 31:12,
31:14, 31:16, 31:17,
41:2
unsecured [1] -
47:24
unverified [1] - 35:15
up [21] - 3:14, 3:15,
3:21, 4:19, 7:3, 11:11,
12:18, 21:8, 25:20,
29:10, 33:11, 35:3,
50:7, 56:18, 56:19,
61:3, 62:10, 62:11,
62:19, 63:3, 64:1
urge [3] - 49:2,
51:14, 51:17
Ustynoski [1] - 12:4
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 75 of 76
V
valid [1] - 35:20
vehicle [1] - 50:5
venue [1] - 61:19
verify [1] - 39:23
versus [2] - 2:3,
47:12
vice [1] - 62:12
violate [4] - 38:5,
44:8, 55:24, 56:1
violations [2] -
39:25, 40:10
violent [1] - 49:13
visas [1] - 57:1
voicemail [1] - 46:19
voluntary [1] - 7:12
vs [1] - 1:6
W
wait [4] - 7:18, 63:11,
63:12, 63:15
waiting [1] - 60:15
waive [5] - 3:12, 4:8,
6:23, 7:1, 7:5
waived [1] - 40:6
waiver [5] - 3:18, 7:4,
7:12, 7:14, 7:17
walk [1] - 25:7
wants [2] - 32:12,
32:13
weapon [1] - 49:12
weapons [1] - 49:22
Wednesday [4] -
60:17, 60:19, 61:1,
63:16
week [4] - 3:3, 59:21,
60:4, 60:6
weekend [1] - 64:5
weigh [3] - 43:23,
44:2, 44:14
weight [4] - 40:15,
40:16, 43:3, 43:8
welcome [1] - 9:6
West [1] - 1:19
whereabouts [1] -
58:19
whole [2] - 7:19,
63:25
willing [8] - 35:8,
35:10, 41:15, 41:20,
46:7, 46:8, 46:11,
47:5
wire [4] - 10:13,
10:14, 33:11, 33:13
wish [1] - 9:8
wishes [2] - 32:7,
75
32:8
WITNESS [4] -
12:22, 12:25, 31:6,
32:4
witness [9] - 8:24,
9:1, 9:15, 19:15,
19:17, 19:23, 22:6,
22:7, 32:5
witnesses [3] -
20:14, 32:8, 32:13
word [7] - 14:8,
22:20, 24:4, 24:25,
25:3
wording [1] - 23:18
words [4] - 23:4,
23:5, 24:1, 26:5
works [1] - 27:23
worrisome [2] -
35:16, 36:8
Wynwood [1] - 29:4
X
XYZ [2] - 24:10, 27:4
Y
years [13] - 4:19,
10:18, 27:23, 33:10,
33:12, 34:4, 44:4,
44:7, 44:21, 44:23,
45:25, 54:15, 56:19
Case 1:26-cr-10031-RGS Document 46-1 Filed 04/04/26 Page 76 of 76File and source
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