Change of Plea Hearing Transcript — United States v. Jerel Andre Williams (E.D. Pa.)

Record facts

U.S. District Court for the Eastern District of Pennsylvania · No. 2:20-cr-00143-JMG · Doc. 56 · 2022-06-29 · Docket on CourtListener

Full text

Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 1 of 39
1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA,.
.
Plaintiff,
.
.
v.
.
.
JEREL ANDRE WILLIAMS,
.
.
Defendant.
.
.
. . . . . . . . . . . . ..

Case No. 2:20-cr-00143-JMG
Edward N. Cahn U.S.
Courthouse & Federal Building
504 W. Hamilton Street
Allentown, PA 18101
June 29, 2022
2:39 p.m.

TRANSCRIPT OF CHANGE OF PLEA HEARING
BEFORE HONORABLE JOHN M. GALLAGHER
UNITED STATES DISTRICT COURT JUDGE
APPEARANCES:
For the Government:

MICHAEL S. LOWE, ESQ.
U.S. ATTORNEY'S OFFICE
EASTERN DISTRICT OF PENNSYLVANIA
615 Chestnut Street, Suite 1250
Philadelphia, PA 19106

For the Defendant:

NATASHA TAYLOR-SMITH, ESQ.
FEDERAL COMMUNITY DEFENDER OFFICE
FOR THE EASTERN DISTRICT OF
PENNSYLVANIA
601 Walnut Street, Suite 545 West
Philadelphia, PA 19106

Audio Operator:

CHRISTINE C. STEIN

TRANSCRIBED BY:

Marie A. Doroff

Proceedings recorded by electronic sound
recording, transcript produced by transcription service.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 2 of 39

2
1

THE CLERK:

All rise. The United States District

2

Court for the Eastern District of Pennsylvania is now in

3

session, Judge John M. Gallagher presiding.

4
5

THE COURT:
be seated.

Welcome to Allentown, everybody.

Please

Make yourself comfortable.

6

MR. LOWE:

7

MS. TAYLOR-SMITH:

8

THE COURT:

9

Ladies and gentlemen, we're here this afternoon on

10

the matter of United States vs. Jerel Andre Williams. That's

11

criminal docket number 20-143.

12

Good afternoon, Your Honor.
Good afternoon, Your Honor.

Good afternoon.

Good afternoon.

Counsel, I understand that we're here for the purpose

13

of entering a guilty plea.

14

MS. TAYLOR-SMITH:

15

THE COURT:

That's correct, Your Honor.

Terrific.

16

the Government.

Welcome back.

17

Attorney Michael Lowe.

Okay.

So, we'll start with

This is the United States

18

MR. LOWE:

Thank you, Your Honor.

19

THE COURT:

Will you introduce us to your colleagues?

20

MR. LOWE:

Your Honor, I'm here with Special Agent

21

Richard Martin of the Internal Revenue Service Criminal

22

Investigation Division.

23

THE COURT:

Welcome.

24

MR. MARTIN:

Hi.

25

MR. LOWE:

And FBI Special Agent Sean Norman on the


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 3 of 39

3
1

far end.

2

THE COURT:

3

And then, we have Attorney Taylor-Smith.

4

7
8

MS. TAYLOR-SMITH:
Honor.

Thank you.

THE COURT:

Nice to see you as well, Your

And we also have your client,

Mr. Williams.
MS. TAYLOR-SMITH:

10

THE COURT:

That's correct.

Mr. Williams, welcome.

MR. WILLIAMS:

13

THE COURT:

Nice to meet you.

All right.

So, folks, there's a number

14

of things that we have to do today.

15

of questions that I have to ask Mr. Williams.

16

to have to put him under oath, okay?

18
19

It's good to make

your acquaintance.

12

17

It's nice

Good afternoon.

9

11

Good to see you.

to see you again.

5
6

Agent Norman, welcome.

And there'll be a number
So we're going

Ms. Stein, would you do that?
JEREL ANDRE WILLIAMS, DEFENDANT, SWORN
THE COURT:

Thank you, sir.

And I neglected to

20

introduce -- or welcome, at least -- James Stroup from United

21

States Pretrial Services.

22

MR. STROUP:

Good afternoon, Your Honor.

23

THE COURT:

Good to see you again, and thank you for

24

the information you've been providing us in this case.

25

appreciated, so --

Much


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 4 of 39

4
1
2
3

Mr. Williams, Ms. Stein just administered the oath to
you.

Let's -- I just want to take a moment to discuss that.
An oath is a very serious promise you're making.

4

promise that you're going to tell the truth.

5

consequences.

6

here today falsely, then there could be significant negative

7

consequences for you.

8

even be prosecuted for making false statements in this

9

proceeding.

10

understand the seriousness and the consequences of the oath?

You

And there are

If you answer any of the questions I have in

Including, you could be -- you could

You could be prosecuted for perjury.

11

THE WITNESS:

12

THE COURT:

So you

Yes.
If there's any time, sir, that you don't

13

understand anything that I'm saying or if I can clarify

14

something for you or I'm speaking too softly or too quickly,

15

please, just let me know.

16

to explain what I'm saying.

17

critical that I make sure that you understand everything that

18

we're discussing in here today.

19

THE WITNESS:

20

THE COURT:

Raise your hand, and I'll be happy
And I -- it's just -- it's

Does that sound fair?

Yes.
And of course, if at any time you need to

21

speak to Attorney Taylor-Smith, just let me know that too.

22

That's your absolute right.

23

the opportunity to speak in private, and you can make that

24

request at any time.

25

THE WITNESS:

We'll take a break.

Sound good?
Sounds good.

You'll have


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 5 of 39

5
1

THE COURT:

Okay.

Attorney Lowe, I looked at the

2

bail paperwork here, and it might be a matter of the -- this

3

case was initially before a magistrate judge before all the

4

rules of -- Criminal Procedure Rule 5(f) and the Due Process

5

Protection Act came in because I didn't see an indication.

6

So anyway, in an abundance of caution, as I know you

7

understand from your many years' experience, but it must be

8

said that the Government is obligated, pursuant to United

9

States Supreme Court case law such as Brady vs. Maryland and

10

Giglio vs. The United States and the other cases as well as

11

statutes, to timely disclose information that's favorable to

12

the defense as to criminal liability on the charged offenses or

13

on potential mitigation of any punishment that may be imposed.

14

Such favorable information includes information that may cast

15

doubt on the credibility of Government witnesses.

16

United States complied with these obligations?

Has the

17

MR. LOWE:

Yes, Your Honor.

18

THE COURT:

And I know I've asked you this before,

19

Attorney Lowe, that you understand that there are potential

20

serious consequences for the Government in -- for violating

21

these obligations.

22

evidence, the dismissal of charges, contempt proceedings,

23

disciplinary referrals, and any other relief authorized by law

24

of an unpleasant nature.

25

MR. LOWE:

It could result in the exclusion of

Yes, Your Honor.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 6 of 39

6
1
2

THE COURT:

Okay.

And you're aware of that, and you

understand your obligations are ongoing.

3

MR. LOWE:

Yes, Your Honor.

4

THE COURT:

Okay.

5

And Attorney Lowe, is there any victims that need to

6

be notified and have indicated that they would like to attend

7

here at today's proceeding?

8

MR. LOWE:

Thank you very much.

No, Your Honor.

The primary victim here

9

is Cisco Systems Inc.

They're aware of the proceedings.

10

have no interest in sending anyone to today's proceeding.

They

11

THE COURT:

Very good, very good.

12

Mr. Williams, I'm going to talk to you for a couple

13

minutes now.

I need to be sure that your guilty plea today is

14

knowing, intelligent, and voluntary, and that the decision to

15

plead guilty is your decision and your decision alone, and it

16

is because you are truly guilty.

17

THE WITNESS:

18

THE COURT:

Do you understand that?

Yes.
So, if you would -- I do know the answers

19

to a lot of these questions, but we have to have a dialogue

20

again so that I can be comfortable that you understand all of

21

today's proceedings.

Sound fair?

22

THE WITNESS:

23

THE COURT:

24

name for the record.

25

Sounds fair.

THE WITNESS:

So if you would, please state your full

Jerel Andre Williams, Sr.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 7 of 39

7
1

THE COURT:

2

THE WITNESS:

3

THE COURT:

4

And, Mr. Williams, how old are you?
Forty-nine.
Can you read, write, and speak the

English language?

5

THE WITNESS:

6

THE COURT:

7

THE WITNESS:

8

THE COURT:

9

Yes.
And how far did you go in school?
Three years of college.
Have you ever been or are you now being

treated for a drug or alcohol addiction?

10

THE WITNESS:

11

THE COURT:

12

No.
Have you taken any drugs or alcohol today

or yesterday or this week?

13

THE WITNESS:

14

THE COURT:

15

No.
Are you currently taking any prescription

medications?

16

THE WITNESS:

17

THE COURT:

18

No.
Have you ever been treated for or

diagnosed with any type of mental illness?

19

THE WITNESS:

No.

20

THE COURT: Have you, sir, spoken with your attorney,

21

and has she fully explained to you your trial rights?

22

when you're charged with a crime, you have a right to plead not

23

guilty and to go to trial. And then you would have certain

24

rights at trial.

25

That is,

Have you discussed this with your counsel?

THE WITNESS:

Yes.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 8 of 39

8
1
2

THE COURT:

Have you discussed with her the charges

against you?

3

THE WITNESS:

4

THE COURT:

Yes.
And in your discussions -- and I don't

5

want you to get too particular, but have you and your lawyer

6

discussed any possible defenses that you might have to the

7

charges?

8

THE WITNESS:

9

THE COURT:

Yes.
So are you comfortable, Mr. Williams,

10

that you've had enough time to discuss this matter with

11

Attorney Taylor-Smith?

12

THE WITNESS:

13

THE COURT:

Yes.
And are you fully satisfied with the

14

representation and advice that have been given to you by

15

Attorney Taylor-Smith?

16

THE WITNESS:

17

THE COURT:

Yes.
And Attorney Taylor-Smith, from your

18

perspective, have you had enough time to discuss this matter

19

with Mr. Williams?

20

MS. TAYLOR-SMITH:

21

THE COURT:

Thank you so much.

22

a guilty plea agreement.

23

there was a brief amendment.

24

parties.

25

I have, Your Honor.
I understand there's

I have the copy here.

I note that

It appears to be signed by both

That's on page 9 of the agreement.
MR. LOWE:

Your Honor, that's actually on the guilty


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 9 of 39

9
1

plea memo.

2

THE COURT:

Oh, that's a change in plea memo.

3

Very good.

I stand corrected.

4

agreement has no amendments.

5

MR. LOWE:

That's correct, Your Honor.

6

THE COURT:

Okay.

Okay.

So -- the guilty plea

Very good.

And does -- I have a

7

copy of the executed guilty plea agreement.

8

have one?

9

MS. TAYLOR-SMITH:

10

MR. LOWE:

Yes, Your Honor.

11

THE COURT:

Okay.

Does each side

Yes, Your Honor.

So, Mr. Williams, I'd like you to

12

keep a copy of that guilty plea agreement in front of you so we

13

can discuss it.

14

gone over the charges that you are facing, correct?

You had stated that Attorney Taylor-Smith had

15

THE WITNESS:

16

THE COURT:

17

agreement with her?

Correct.

18

THE WITNESS:

19

THE COURT:

And you also reviewed the guilty plea

Yes.
And on page 12 of the guilty plea

20

agreement, if you would go there. There are a number of

21

signatures here including signatures that look to be from the

22

United States Attorney, from Attorney Taylor-Smith, and then

23

the top-left signature appears to be yours.

24

signature?

25

THE WITNESS:

Yes.

Is that your


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 10 of 39

10
1
2

THE COURT:

And did you voluntarily sign this guilty

plea agreement?

3

THE WITNESS:

4

THE COURT:

Yes.
Then there -- following that page,

5

there's a three-page acknowledgement of rights.

6

review that with Attorney Taylor-Smith?

7

THE WITNESS:

8

THE COURT:

9

signed.

10

Taylor-Smith.

Yes, sir.
And you see that there?

That is also

It appears to be signed by you and Attorney

11

THE WITNESS:

12

THE COURT:

13

THE WITNESS:

14

THE COURT:

15

Did you also

Yes.
And you did sign that, correct?
Yes, I did.
And did you voluntarily sign this

acknowledgment of rights?

16

THE WITNESS:

17

THE COURT:

Yes, I did.
And again, did you read and discuss the

18

guilty plea agreement and the acknowledgement of rights with

19

Attorney Taylor-Smith before signing it?

20

THE WITNESS:

21

THE COURT:

Yes, I did.
And so as -- just to -- sorry if I'm

22

repeating myself -- Attorney Taylor-Smith fully explained the

23

written plea agreement and the acknowledgement of rights to

24

you.

25

Is that correct?
THE WITNESS:

Yes.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 11 of 39

11
1

THE COURT:

And are you comfortable -- sir, you

2

understand the terms of the guilty plea agreement and the

3

acknowledgement of rights?

4

THE WITNESS:

5

THE COURT:

Yes, I know.
And in your discussions with Attorney

6

Taylor-Smith, did you discuss the maximum possible punishment

7

that you can receive for the offenses for which you are

8

pleading guilty?

9

THE WITNESS:

10

THE COURT:

Yes, I am.
And does the guilty plea agreement in

11

front of you represent, in its entirety, any understanding that

12

you have with the Government?

13

THE WITNESS:

14

THE COURT:

Excuse me?
Is this written guilty plea agreement --

15

does it represent, in its entirety, any understanding that you

16

have with the government?

17

THE WITNESS:

18

THE COURT:

Yes.
Assistant US Attorney Lowe, I'm going to

19

ask now, at this time, that you summarize the terms of the

20

guilty plea agreement.

21

to summarize the facts that the Government indicates it could

22

prove if this case went to trial, but for now, please just

23

summarize the terms of the plea agreement as have been reached

24

by the two sides in this case.

25

MR. LOWE:

I'm going to ask you in a few minutes

Yes, Your Honor.

The Defendant is


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 12 of 39

12
1

agreeing to plead guilty to counts 7, 8, and 10 of the

2

Superseding Indictment in this case.

3

this, I just want to put on the record the procedural posture

4

here so that it's very clear.

5

And while I get into

Initially, the Defendant was charged by way of

6

information, and that was, I think, before COVID.

7

COVID, the intended resolution that, at that time, did not

8

happen, and so we had to charge the Defendant by an indictment.

9

At the time we charged him by indictment, we labeled that the

10

Superseding Indictment.

11

And after

So right now, on the docket, there should be an

12

Original Information and a Superseding Indictment.

13

pleading guilty to counts 7, 8, and 10 of the Superseding

14

Indictment in this case.

15

THE COURT:

And then, that raises a good point.

16

appreciate that, Counsel.

17

Superseding Indictment?

18
19

MR. LOWE:

He's

I

Do we need to arraign him on the

No. He's been arraigned on that before,

Your Honor.

20

THE COURT:

Okay.

All right.

Thank you.

21

MR. LOWE:

So in terms of the plea agreement, counts

22

7 and 8 of the Superseding Indictment charge him with mail

23

fraud in violation of 18 USC Section 1341.

24

charges him with filing a false tax return in violation of 26

25

USC Section 72061.

And count 10

He also agrees not to contest forfeiture,


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 13 of 39

13
1

as set forth in the notice of forfeiture in this case. And the

2

Government is agreeing to dismiss counts 1 through 6, count 9,

3

and count 11 at the time of sentencing, provided that the

4

Defendant complies with his obligations under the plea

5

agreement.

6

The Defendant also agrees to waive any objection to

7

venue and consents to the filing and disposition of the charges

8

in this case in the Eastern District of Pennsylvania.

9

understands that, absent his waiver of venue, venue for the

10

three counts to which he's pleading guilty would likely reside

11

in the Northern District of Texas, the District of Delaware,

12

and/or the District of Nevada.

13

He

At the time of sentencing, provided that the

14

Defendant comply with all of his obligations, as I've stated,

15

the Government will move to dismiss counts 1 through 6, 9, and

16

11.

17

limitations as to any of those dismissed counts and agrees that

18

if he were to withdraw from or successfully challenge the plea

19

agreement or the guilty plea entered in the case, or if the

20

counts were otherwise reinstated somehow, the statute of

21

limitations and the double jeopardy clause would not bar

22

prosecution on those dismissed counts.

23

The Defendant is agreeing to waive the statute of

The Government has the right to make a sentencing

24

recommendation that it deems appropriate, comment on the

25

evidence, bring any relevant facts to the Court's attention,


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 14 of 39

14
1

respond to any questions he raises, or any potential factual

2

inaccuracies also can be corrected.

3

nothing in the agreement limits the Government's ability to

4

respond to post-sentencing matters.

5

It should be clear that

There is a financial obligation section.

That's

6

paragraph 6 of the plea agreement.

The Defendant is agreeing

7

to fully disclose all his income, assets, liabilities, and

8

financial interests.

9

statement to the US Attorney's office within 14 days, and I

10

believe he's been provided a copy of that statement.

11

hasn't, we'll get it to him.

12

obtain a credit report on him.

13

financial deposition or interview if we so request.

14

not to transfer, assign, expose, remove, conceal, pledge as

15

collateral, waste, or destroy any property he has with the

16

effect of hindering, delaying, or defrauding the United States

17

or the victim in this case.

18

any property he has that's worth more than $1,000 prior to

19

sentencing without the Government's approval.

He agrees to submit a completed financial

If he

He authorizes our office to
He agrees to submit to a
He agrees

And he also agrees not to devalue

20

He agrees to execute any documents that we ask him to

21

to help facilitate the transfer of any payments of monetary --

22

of money towards the monetary penalties that will be ultimately

23

imposed in this case.

24

comply with the financial obligations in paragraph 6, that

25

would amount to a breach of the plea agreement and then the

He understands that if he fails to


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 15 of 39

15
1

Government has different options.

2

We could void the agreement.

We could argue that he

3

is not entitled to a downward adjustment for acceptance of

4

responsibility.

5

portion of the agreement and seek a trial on the forfeiture

6

count before this court.

7

waive any right to jury trial on the forfeiture issues.

We could seek to void just the forfeiture

And if that happened, he agreed to

8

He also agrees to fully cooperate with the IRS and

9

that that requires him to pay restitution as directed to the

10

IRS by this court in the amount of the determined total tax

11

loss plus interest and penalties.

12

outstanding taxes and interest and penalties within the period

13

of supervised release in the event of custodial sentence or

14

within the period of probation if it's a non-custodial

15

sentence.

16

that he has due and owing for those years during the period of

17

supervision.

He agrees to pay any

And he also agrees to pay any state and local taxes

18

He agrees to execute and deliver various forms that

19

are set forth in sub-paragraph C of that paragraph and make a

20

full disclosure -- financial disclosure to the IRS.

21

to provide any written documents to the IRS for the purpose of

22

a civil audit and to sign any IRS forms necessary to -- for

23

them to make an assessment of the taxes that he has due and

24

owing.

25

He agrees

He agrees to sign a particular form IRS -- Bless you.
MS. TAYLOR-SMITH:

Thank you.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 16 of 39

16
1

MR. LOWE:

-- IRS form 8821 at any time requested

2

until his term of supervision is finished.

He agrees not to

3

file any claim for refunds of taxes, penalties, or interest for

4

tax years 2015 and 2016 or any other amounts paid pursuant to

5

this agreement.

6

that I just went through relating to the IRS portion of the

7

plea agreement are appropriate conditions of his supervision.

8

He agrees not to make any objection to the entry of

9

an order under Rule 6(d) permitting the IRS to disclose to the

10

collections division of the IRS the documents that were

11

obtained as part of this criminal investigation.

12

to pay a fine and make restitution as directed by this court.

13

He agrees that any amounts that he were to pay prior to

14

sentencing would not be considered extraordinary acceptance of

15

responsibility entitling him to any variance or downward

16

departure.

17

prior to sentencing.

And he understands that all of those terms

He does agree

He agrees to pay the special assessment of $300

18

He agrees that, with respect to the forfeiture of

19

assets as set forth in paragraph 11, that he'll forfeit his

20

right, title, and interest in the proceeds of the scheme to

21

defraud as charged in counts 7 and 8 of the Superseding

22

indictment.

23

that amount that's determined by the Court.

24

entry of a preliminary order of forfeiture as soon as possible

25

after the guilty plea, and he understands that forfeiture is

And he agrees to the entry of a money judgment in
He agrees to the


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 17 of 39

17
1

part of the sentence in this case.

2

constitutional or statutory or other challenges to the

3

forfeiture.

4

He agrees to waive any

He understands that he cannot withdraw his guilty

5

plea if the Court declines to follow any of the recommendations

6

or stipulations or motions that might be filed or that are

7

otherwise part of this agreement.

8

one has promised him what sentence the Court will impose.

9

And he understands that no

If he commits any other crimes between the date of

10

this agreement and sentencing or if he violates any other

11

provision of the plea agreement, the Government can declare the

12

agreement breached.

13

one of those, that we could prosecute him for any crime that we

14

otherwise could, including but not limited to perjury or

15

obstruction of justice, and we can use any of the information

16

he gave us during the investigation in this prosecution.

17

could reinstate and try any counts that we had agreed to

18

dismiss.

19

sentencing stipulations or other stipulations in the plea

20

agreement.

21

have sole discretion as to whether to declare a breach and what

22

remedy we want to seek.

23

provision in paragraph 14, which I know the Court will go

24

through.

25

And then, we would have various options;

We

We could be relieved of our obligations regarding any

And the Government would be the entity that would

THE COURT:

There is a standard appellate waiver

I will.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 18 of 39

18
1

MR. LOWE:

And he also is waiving his claims under

2

the Hyde Amendment because prior to Ms. Taylor-Smith

3

representing him, the Defendant did have obtained counsel. And

4

so he's waiving any claims under the Hyde Amendment for

5

attorney's fees and other litigation expenses arising out of

6

the investigation or prosecution of this case.

7

He's also waving his rights to obtain any records of

8

the investigation or prosecution of this case, whether under

9

the Freedom of Information Act or the Privacy Act.

10

the salient terms of the plea agreement, Your Honor.

11
12

THE COURT:

Thank you for that summary,

Attorney Lowe.

13
14

Those are

Mr. Williams, did you completely understand
Mr. Lowe's summary of the guilty plea agreement?

15

THE WITNESS:

16

THE COURT:

Yes, I did.
And did the Government correctly and

17

completely summarize the terms of the guilty plea agreement as

18

you understand them?

19

THE WITNESS:

Yes.

20

THE COURT:

21

of the guilty plea agreement?

22

THE WITNESS:

23

THE COURT:

And so, do you agree to all of the terms

Yes, I do.
Attorney Taylor-Smith, did the Government

24

correctly and completely summarize the terms of the guilty plea

25

agreement?


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 19 of 39

19
1

MS. TAYLOR-SMITH:

2

THE COURT:

3

They did, Your Honor.

And, Counsel, did you convey all formal

plea offers from the Government to your client?

4

MS. TAYLOR-SMITH:

5

THE COURT:

I did, Your Honor.

Thank you so much.

Mr. Williams, other

6

than the terms of the guilty plea agreement, did anyone promise

7

or offer you anything else to get you to plead guilty?

8

THE WITNESS:

9

THE COURT:

10

No.
Did anyone use force, violence, or

threats to get you to plead guilty?

11

THE WITNESS:

No.

12

THE COURT:

13

will because you are guilty?

14

THE WITNESS:

15

THE COURT:

So are you doing this of your own free

16

Yes.
And did anyone tell you what to say today

or put words in your mouth?

17

THE WITNESS:

18

THE COURT:

No, sir.
Okay.

Sir, do you understand that you're

19

entering a plea to a felony, and if your plea is accepted, you

20

will be then judged guilty of a felony, which may deprive you

21

of valuable rights including the right to vote, hold public

22

office, serve on a jury, possess a firearm, or hold a

23

professional license?

24

THE WITNESS:

25

THE COURT:

Yes.
Sir, are you a United States citizen?


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 20 of 39

20
1

THE WITNESS:

2

THE COURT:

Yes.
I have no reason to disbelieve that, but

3

if for any reason you were not a United States citizen, do you

4

understand that as a result of your guilty plea, you could be

5

removed from the United States, you could be denied

6

citizenship, and you could be denied admission to the United

7

States in the future?

8

THE WITNESS:

9

THE COURT:

Yes.
Have you ever been on supervision for a

10

crime before, such as probation, parole, supervised release, or

11

accelerated rehabilitative disposition?

12

THE WITNESS:

13

THE COURT:

Yes, I have.
Do you understand, sir, that if you were

14

on supervision when you committed the offenses to which you're

15

pleading guilty, your guilty plea would be an admission that

16

you violated that supervision?

17

THE WITNESS:

18

THE COURT:

19

Yes.
And do you understand that a prior

conviction can also affect your sentencing guideline range?

20

THE WITNESS:

21

THE COURT:

Yes, I have.
Mr. Williams, I'm going to now advise you

22

of the maximum penalties you could receive from the Court in

23

connection to the offenses to which you are pleading guilty.

24

As to each of counts 7 and 8 charging mail fraud in

25

violation of Title 18 United States Code Section 1341, the


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 21 of 39

21
1

maximum sentence is 20 years imprisonment, a three-year period

2

of supervised release, a $250,000 fine, and a $100 special

3

assessment.

4

in violation of Title 26 United States Code Section 7206 Sub-

5

section 1, the maximum sentence is three years imprisonment, a

6

one-year period of supervised release, a $250,000 fine, and a

7

$100 special assessment fee.

As to Count 10 charging filing a false tax return

8

Therefore, the total maximum punishment is 43 years

9

imprisonment with a three-year period of supervised release, a

10

$750,000 fine, a $300 total special assessment fee, and full

11

restitution.

12

may also be ordered.

13
14

Forfeiture from the proceeds from the offenses

Mr. Williams, do you understand the maximum possible
punishment in connection with your guilty plea?

15

THE WITNESS:

16

THE COURT:

Yes, I do.
And do you understand that here in the

17

Federal system, there's no parole, and you must serve the whole

18

time of any imprisonment you are sentenced to?

19

THE WITNESS:

20

THE COURT:

Yes.
Do you understand that if conditions of

21

supervised release are imposed and you violate those

22

conditions, the original term of imprisonment may be increased

23

by up to two years on each of counts 7 and 8 and by one year on

24

count 10, thereby making it possible that you will serve the

25

original sentence plus additional time in prison without credit


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 22 of 39

22
1

for time already spent on supervised release?

2

THE WITNESS:

3

THE COURT:

Yes.
Sir, this guilty plea also requires you

4

to forfeit certain property to the Government.

5

means that the Government wants to take and keep, sell, or

6

destroy property they claim was used to help commit the

7

offenses in this case or which was derived from the offenses.

8

Do you understand this?

9

THE WITNESS:

10

THE COURT:

11

Yes, I do.
And do you understand that the Court may

also order you to pay any applicable restitution?

12

THE WITNESS:

13

THE COURT:

14

Forfeiture just

Yes.
Mr. Williams, do you understand that no

one can guarantee you what sentence you will get from me?

15

THE WITNESS:

16

THE COURT:

Yes.
At this point, sir, I do not know what

17

sentence I am going to give you because I have not yet ordered

18

or read a presentence report in your case.

19

the sentencing hearing.

20

THE WITNESS:

21

THE COURT:

22

Do you understand?
Yes.

Did anyone promise you or suggest to you

what sentence you would receive from me?

23

THE WITNESS:

24

THE COURT:

25

And we have not had

No.
And, sir, do you understand that the

offenses to which you are pleading guilty are covered by the


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 23 of 39

23
1

advisory sentencing guidelines?

2

THE WITNESS:

3

THE COURT:

Yes.
And have you and Attorney Taylor-Smith

4

discussed how the advisory sentencing guidelines might apply to

5

your case?

6

THE WITNESS:

7

THE COURT:

Yes.
So do you understand that I am required

8

to calculate the sentencing guidelines and to consider those

9

guidelines in determining whether to follow the recommended

10

sentence; however, under the law, I'm not required to follow

11

the sentencing guidelines because they are advisory and not

12

mandatory?

13

THE WITNESS:

14

THE COURT:

Yes.
In addition to the guidelines, I must

15

also consider the sentencing factors enumerated in the United

16

States Sentencing law that refer to as Title 18 United States

17

Code Section 3553(a).

18

not limited to the nature and the circumstances of the offenses

19

that you committed, your personal history and characteristics,

20

the need for the sentence to reflect the seriousness of your

21

offenses, the need for the sentence to promote respect for the

22

law, and the need for the sentence to provide just punishment

23

for the offenses.

These sentencing factors include but are

Do you understand this?

24

THE WITNESS:

25

THE COURT:

Yes, I do.
And, sir, I will also consider a


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 24 of 39

24
1

presentence report that a probation officer will prepare which

2

will calculate your sentencing guideline range.

3

will tell me certain things about you and your background.

4

you disagree with any of the information in a presentence

5

report, you can contest the presentence report by objecting to

6

it with the probation officer who prepared it.

7

can contest the presentence report by objecting to it before

8

me, if necessary.

9

Do you understand this?

The report
If

After that, you

The Government may also contest the report.

10

THE WITNESS:

11

THE COURT:

Yes, I do.
And do you understand that your attorney

12

and the Government can agree on facts and make recommendations,

13

motions, and requests at sentencing, but I do not have to do

14

what they ask me to do?

15

THE WITNESS:

16

THE COURT:

Yes, I do.
And do you understand that this guilty

17

plea remains binding on you whether or not I agree with their

18

facts and recommendations and whether or not I grant their

19

motions and requests?

20

THE WITNESS:

21

THE COURT:

Yes.
All defendants, sir, have certain

22

constitutional rights.

I'm going to explain to you those

23

constitutional rights, and I'm also going to explain which of

24

those constitutional rights you will be giving up by pleading

25

guilty.

Do you understand this?


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 25 of 39

25
1

THE WITNESS:

2

THE COURT:

3

Yes.
Mr. Williams, you have the right to plead

not guilty and to persist in that plea.

4

THE WITNESS:

5

THE COURT:

Do you understand?

Yes, I do.
You have the right to a trial by a judge

6

or a jury.

If a trial by jury, your jury would consist of 12

7

members and possibly some alternates drawn from the residents

8

of this district, the Eastern District of Pennsylvania.

9

and your attorney would be permitted to participate in the jury

10

selection and be present while the jurors are questioned about

11

their potential jury service by the judge or by the lawyers.

12

Sir, you would have the right to challenge, without

13

limitation, any jurors who are not legally qualified to serve

14

on your jury or any jurors who are prejudiced or incapable of

15

fair judgment in your case.

16

strike a certain number of jurors without stating a reason.

17

The verdict of the jury would have to be unanimous.

18

that all 12 jurors would have to find you guilty for you to be

19

convicted.

20

described them to you?

21

THE WITNESS:

22

THE COURT:

You

You would also have the right to

That means

Do you understand these trial rights as I've

Yes, I do.
Sir, if you went to trial, you would be

23

presumed innocent and the burden would be on the Government to

24

prove your guilt beyond a reasonable doubt.

25

to prove your innocence or prove anything at your trial.

You would not have
Do


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 26 of 39

26
1

you understand this?

2

THE WITNESS:

3

THE COURT:

Yes.
And, sir, you would have the right to be

4

represented by a lawyer at your trial and at all critical

5

stages of your proceedings, both before and after trial.

6

you could not afford a lawyer, one would be appointed for you.

7

Do you understand?

8

THE WITNESS:

9

THE COURT:

If

Yes.
You would have the right to obtain a

10

subpoena or a court order to make witnesses come to court to

11

testify on your behalf.

12

THE WITNESS:

13

THE COURT:

Do you understand this?
Yes, I do.

At trial, you would have the right to

14

confront and cross-examine witnesses.

That is the right to be

15

in the courtroom and see, hear, and question the Government's

16

witnesses against you.

17

THE WITNESS:

18

THE COURT:

Do you understand this?
Yes.

You would have the right to challenge the

19

admissibility of the Government's evidence.

20

the Court to keep out any evidence that violates the United

21

State Constitution, your rights, or the rules of evidence or

22

the rules of criminal procedure.

23

THE WITNESS:

24

THE COURT:

25

That is, to ask

Do you understand this?

Yes.
At trial, you could present evidence, and

you alone would decide whether or not to testify as a witness.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 27 of 39

27
1

Do you understand?

2

THE WITNESS:

3

THE COURT:

Yes.
If you were to choose to exercise your

4

constitutional right not to testify or if you were to choose to

5

exercise your right not to present evidence or witnesses, no

6

unfavorable inference can be drawn from that from the jury.

7

you understand this?

8

THE WITNESS:

9

THE COURT:

Do

Yes.
If you plead guilty, sir, there will be

10

no trial, and therefore you will not have any of these rights

11

except that you will still have the right to an attorney.

12

you understand?

13

THE WITNESS:

14

THE COURT:

Do

Yes.
Mr. Williams, if you were found guilty at

15

trial, you could appeal such a finding to a higher court that

16

could set aside or modify the finding of guilt or give you a

17

new trial.

18

would have to file an appeal or seek collateral review.

19

There would be a time limitation under which you

However, sir, by signing the guilty plea agreement

20

and by entering a plea of guilty, you are voluntarily and

21

expressly waiving all rights to appeal or collaterally attack

22

your conviction, sentence, or any other matters related to this

23

prosecution.

24

waiving the right to argue that the statutes to which you are

25

pleading guilty are unconstitutional and that the admitted

As a part of this waiver, you are expressly


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 28 of 39

28
1

conduct does not fall within the scope of this statute.

2

waiver applies if I accept the recommended sentence and also in

3

the event that I do not accept any recommended sentence, but

4

you still agree to plead guilty.

5

This

Notwithstanding this waiver, if the Government

6

appeals from the sentence, then you, sir, you may file a direct

7

appeal of your sentence.

8

the sentence, there are very few issues that you may raise a

9

direct appeal or collateral attack.

10

But if the Government does not appeal

You would be able to argue that your sentence exceeds

11

the statutory maximum of the offenses.

You may challenge a

12

decision by me to impose an upward departure pursuant to the

13

sentencing guideline or an upward variance above the final

14

sentencing guideline range determined by me, and you may argue

15

that your lawyer did not provide effective assistance of

16

counsel to you.

17

collateral attack waiver under the guilty plea agreement?

Do you understand, sir, this appeal and

18

THE WITNESS:

19

THE COURT:

Yes.
Sir, in order to prove you guilty of the

20

offenses to which you are pleading guilty, the Government would

21

have to prove beyond a reasonable doubt each of the elements of

22

the offenses to which you are pleading guilty.

23

to advise you of those elements.

I'm now going

24

As to counts 7 and 8, to establish mail fraud, the

25

Government must prove beyond a reasonable doubt the following


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 29 of 39

29
1

elements: 1, that you, the Defendant, knowingly devised a

2

scheme to defraud, that is, to deprive another of money or

3

property by fraud including by false or fraudulent pretenses,

4

representations or promises, or omissions concerning material

5

fact; 2, that you, the Defendant, did so with the intent to

6

defraud; and 3, that in advancing, furthering, or carrying out

7

this scheme, you used the mails or caused the mails to be used.

8

As to count 10, to establish filing a false income

9

tax return, the Government must prove beyond a reasonable doubt

10

the following five elements: 1, that you, the Defendant, made

11

or subscribed an income tax return or other document; 2, that

12

the tax return contained a written declaration that is made

13

under the penalties of perjury; 3, that the tax return was

14

false regarding a material matter; 4, that you, the Defendant,

15

did not believe the tax return was true and correct as to every

16

material matter; and 5, that you, the Defendant, acted

17

willfully.

18
19

Mr. Williams, do you understand the elements and the
offenses as I have explained them to you?

20

THE WITNESS:

21

THE COURT:

22

Yes, I do.
And sir, do these elements correctly

describe what you did on the occasion of these offenses?

23

THE WITNESS:

24

THE COURT:

25

Yes, Your Honor.
Sir, at this point, I'm going to ask

Assistant to the United States Attorney Lowe to summarize the


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 30 of 39

30
1

facts that the Government could prove if this case were to go

2

to trial.

3

Mr. Williams, would you please do so at this time?
MR. LOWE:

Your Honor, the guilty plea memorandum

4

that we filed -- as Your Honor pointed out earlier, we had

5

amended it, both parties, at page 9.

6

starts at page 4, and it proceeds through page 9.

7

paragraph of the factual basis is on page 9.

8

sentence that started with the words "as a result."

So the factual basis
And the last

We struck the

9

So with that striking, the entire factual basis now

10

of this guilty plea memo, I ask that it be incorporated, both

11

the factual basis itself and the guilty plea memo itself, into

12

this proceeding.

13

proceed in this manner rather than just reading the entire

14

factual basis.

15

Ms. Taylor-Smith had asked me if we could

It is my understanding that the Defendant has

16

thoroughly read the factual basis that I just mentioned and

17

agrees to admit that we could prove those facts and that they

18

are true and correct.

19

THE COURT:

20

Attorney Lowe.

21

things.

22

Taylor-Smith.

23

And I'm willing to do that,

Let me just check with Mr. Williams on a couple

You -- I'm sorry.

MS. TAYLOR-SMITH:

I didn't see you stand Attorney

That's okay, Your Honor.

I was

24

just going to agree with Mr. Lowe that, in fact, we went over

25

the factual basis and there was a change made as a result of


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 31 of 39

31
1
2
3
4
5
6

that after conferring with Mr. Williams.
THE COURT:

And there's initials on the original.

Whose initials are those?
MS. TAYLOR-SMITH:

Those initials would be Mr. Lowe's

initials and my initials.
THE COURT:

And your initials.

And, Mr. Williams,

7

were you privy to that change where they struck that sentence

8

from the factual basis for the guilty plea agreement?

9

THE WITNESS:

10

THE COURT:

11

THE WITNESS:

12

THE COURT:

Yes.
And you agreed with that?
Yes.
And, sir, frequently, at guilty plea

13

agreements, we would read these five pages into the record.

14

It's my understanding that you have read these yourself and

15

with your counsel, these pages, correct?

16

THE WITNESS:

17

THE COURT:

18

THE WITNESS:

19

THE COURT:

Yes.
Is that fair to say?
Yes.
And you're satisfied if we don't read

20

them aloud but I just incorporate what is in the guilty plea

21

agreement and the guilty plea memo, including the facts that

22

have been stated or listed in that memo?

23

THE WITNESS:

24

THE COURT:

25

Yes.
Okay.

Attorney Taylor-Smith?

And you're also fine with that,


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 32 of 39

32
1

MS. TAYLOR-SMITH:

Yes, Your Honor.

I would just

2

like to point out my client has admitted or, when the Court

3

formally takes a plea, will have admitted to the facts in those

4

cases.

5

There is going to be an issue, however, at sentencing

6

as to the loss amount.

7

its presentation, and I will be making my presentation as to

8

that.

9
10

THE COURT:

And so, the Government will be making

And I anticipated that because I could

see the line that was struck out dealt with that very issue.

11

MS. TAYLOR-SMITH:

12

MR. LOWE:

That's correct.

And Your Honor, I would just ask that the

13

Court inquire of Mr. Williams if he admits to the factual basis

14

that's stated herein.

15

Smith that loss will be contested.

16

concerted effort, particularly with respect to the fraud

17

counts, to not include loss figures because I know Mr. Williams

18

is going to make a presentation on what he thinks the loss

19

amount is, and we will do the same.

20

anything in there obligates him to any loss figures with

21

respect to Cisco.

And I would also agree with Ms. Taylor-

22

MS. TAYLOR-SMITH:

23

THE COURT:

And I also made a very

So, I don't believe

That's correct, Your Honor.

All right.

Thank you.

And I'm --

24

Mr. Williams, you understand that -- what Mr. Lowe said that

25

you are preserving certain arguments for the time of


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 33 of 39

33
1

sentencing?

2

THE WITNESS:

3

THE COURT:

Yes.
However, with the -- with that

4

qualification and with the language stricken from the guilty

5

plea memo, do you fully admit to the facts that remain in that

6

memo?

7

THE WITNESS:

8

THE COURT:

Yes.
Okay.

And so, sir, at this time, is it

9

your wish to formally enter a plea of guilty to counts 7, 8,

10

and 10 of the Superseding Indictment?

11

THE WITNESS:

12

THE COURT:

Yes, Your Honor.
And sir, are you pleading guilty because

13

you admit that you are actually guilty of committing the

14

offenses listed in counts 7, 8, and 10 of the Superseding

15

Indictment?

16

THE WITNESS:

17

THE COURT:

Yes, Your Honor.
On either side, Counsel, are there any

18

requests for any changes or any additions to our guilty plea

19

colloquy this afternoon?

20

MR. LOWE:

21

MS. TAYLOR-SMITH:

22

THE COURT:

23
24
25

Not from the Government, Your Honor.
Not from the Defense.

Thank you, Counsel.

Ms. Stein, would you

please take the defendant's plea?
THE CLERK:

Jerel Andre Williams, you have been

charged in Superseding Indictment No. 20-143 charging you in


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 34 of 39

34
1

counts 7 and 8 with mail fraud in violation of Title 18 United

2

States Code Section 1341 and in count 10 with filing false tax

3

return in violation of Title 26 United States Code Section

4

72061.

5

guilty?

How do you plead now to these charges, guilty or not

6

THE WITNESS:

Guilty.

7

THE CLERK:

Thank you.

8

THE COURT:

The Court makes the following findings:

Please be seated.

9

the Defendant, Mr. Williams, is fully alert, competent, and

10

capable of entering an informed plea, and this plea is a

11

knowing and voluntary plea supported by an independent basis in

12

fact, containing each of the essential elements of the offenses

13

to which the Defendant has pled guilty.

14

guilty is therefore accepted, and he is now judged guilty of

15

these offenses.

16

Mr. Williams's plea of

As I mentioned a few minutes ago, a presentence

17

report will be prepared by a United States probation officer,

18

and Mr. Williams will be required to provide information to

19

assist that officer.

20

while answering questions from the probation officer.

21

presentence report is complete, both the Defendant and his

22

counsel shall review it together.

23

immediately notify his counsel of any objections that he may

24

have to the presentence report, and counsel shall notify the

25

probation officer of any such objections within 14 days of

Mr. Williams may have a lawyer present
When the

Mr. Williams shall


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 35 of 39

35
1

receipt of the report as required under the rules of criminal

2

procedure.

Do you understand this, Mr. Williams?

3

THE WITNESS:

4

THE COURT:

Yes, I do.
And Attorney Taylor-Smith, will you meet

5

with your client to review the presentence report once it is

6

complete?

7

MS. TAYLOR-SMITH:

8

THE COURT:

Yes, Your Honor.

We have set -- scheduled sentencing for

9

Tuesday, November 1, 2022, 9:30 in the morning in this

10

courtroom.

11

supporting memoranda must be filed at least 14 days prior to

12

the sentencing date, and any responses thereto must be filed at

13

least seven days before the sentencing date.

14

from counsel that we may be getting those types of motions

15

prior to sentencing in this case.

16

exclusive of motions, must be filed at least seven days prior

17

to our sentencing date, and any responses thereto must be filed

18

at least three days prior to the sentencing date.

19

shall serve a copy of all sentencing motions and sentencing

20

memoranda on the United States probation office.

21
22
23

Counsel are advised that any sentencing motions and

It does sound

All sentencing memoranda,

Counsel

Attorney Lowe, I understand that the Government is
not seeking detention at this time.
MR. LOWE:

That's correct, Your Honor.

He's been

24

fully compliant with his release conditions.

We have no

25

objection to him remaining on bond pending sentencing.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 36 of 39

36
1

THE COURT:

And that's consistent with my review of

2

the pretrial services report.

3

Mr. Stroup.

And again, I thank you for that,

That was very helpful for us.

4

MR. STROUP:

Yes, Your Honor.

5

THE COURT:

I also note, and please correct me if I'm

6

wrong, that Mr. Williams walked in voluntarily through the

7

front door of this courtroom, in fact after significant travel

8

to get to this courthouse.

9

is a risk of danger to the community, nor does he pose a

10

significant risk of nonappearance.

11

should walk out the same door that he walked in here today.

And I do not see any reason that he

So I also agree that he

12

So, Mr. Williams, to ensure the safety of the

13

community and your appearance at sentencing, you will remain on

14

the $50,000 own recognizance bond that has been previously set,

15

and so the same conditions remain in effect.

16

to go through those, and Ms. Stein, my deputy, will have some

17

documents for you to sign.

18

continue to do so as you've been doing, to the United States

19

pretrial services.

20

that for the time being, or if you do not have one, you may not

21

now apply for one until these proceedings have been completed.

22

Do you understand these conditions?

But you are to report as directed,

If you have a passport, you must surrender

23

THE WITNESS:

24

THE COURT:

25

Though I do want

Yes.
Your travel is restricted to the Eastern

District of Pennsylvania and the state of Texas.

Any other


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 37 of 39

37
1

travel is possible, but it must be approved in advance by

2

pretrial services.

Do you understand?

3

THE WITNESS:

4

THE COURT:

Yes.
Do you understand that you must surrender

5

any firearms or dangerous weapons and must not possess any

6

firearms or dangerous weapons as a strict condition of your

7

release?

8

THE WITNESS:

9

THE COURT:

Yes.
You are not to have contact with any

10

individuals engaged in any criminal activity.

11

have contact with any of the victims, witnesses, or co-

12

defendants in the case.

13

victim, witness, or co-defendant, please consult with Attorney

14

Taylor-Smith.

If you're unsure whether someone is a

Do you understand?

15

THE WITNESS:

16

THE COURT:

17

gainful employment.

Yes.
You must maintain or actively seek

Do you understand this?

18

THE WITNESS:

19

THE COURT:

20

You are not to

Yes.

Do you have any questions, sir, about the

conditions upon which you're being released?

21

THE WITNESS:

22

THE COURT:

No, I do not.
Sir, I have to advise you, and it's very

23

important, that the penalties for violating any of the

24

conditions of bail can be severe.

25

required for sentencing is itself a criminal offense for which

And a failure to appear as


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 38 of 39

38
1

you could be sentenced to imprisonment.

2

sir?

3

THE WITNESS:

4

THE COURT:

5

You understand that,

Yes, I do.
Is there anything else to come before the

Court this afternoon before we adjourn in this matter?

6

MR. LOWE:

Not from the Government, Your Honor.

7

MS. TAYLOR-SMITH:

Not from the Defense.

8

THE COURT:

Well, thank you, counsel, agents.

Okay.

9

Thank you, Mr. Williams.

10

least as for now.

11
12

We'll see you again in November.

THE WITNESS:
`

I wish you a safe return trip, at

MR. LOWE:

Thank you.

Thank you, Your Honor.

13

MS. TAYLOR-SMITH:

14

THE COURT:

Thank you, everybody.

15

THE CLERK:

Court is adjourned.

16

Thank you.

* * * * *

Okay.


Case 2:20-cr-00143-JMG Document 56 Filed 11/22/22 Page 39 of 39

C E R T I F I C A T E

*  DPVSU BQQSPWFE USBOTDSJCFS  DFSUJGZ UIBU
UIF GPSFHPJOH JT B USVF BOE BDDVSBUF DPNQMFUF
USBOTDSJQU

GSPN

UIF

PGGJDJBM

FMFDUSPOJD

TPVOE

SFDPSEJOH PG UIF QSPDFFEJOHT JO UIF BCPWFFOUJUMFE
NBUUFS

----------------------1HDO5*URVV

November 22, 2022

1($/5*5266
(202) 234-4433

COURT REPORTERS AND TRANSCRIBERS
17+67, N.W.67(
WASHINGTON, D.C. 2000

www.nealrgross.com

File and source

File

paed.569219.56.0.pdf

Size

198,317 bytes

SHA-256

67fad223252176ffd4e656936ee6e7e11f1846355007479c216e8b4ab13dd8fa

Our copy

paed.569219.56.0.pdf

Original

No public link identified.