Transcript of Motion to Suppress Hearing — United States v. Delson Marc (Document 239, entered July 21, 2022)
Summary
A transcript of the November 2, 2018, motion to suppress hearing before United States District Judge William P. Dimitrouleas in United States v. Delson Marc, Case No. 18-80153-CR-WPD, in the U.S. District Court for the Southern District of Florida, Document 239, entered on the docket July 21, 2022. The government offers by stipulation a lease agreement as Government's Exhibit 1, a search warrant as Government's Exhibit 2 and a second search warrant as Government's Exhibit 3, and calls Detective Corey Oliver of the Palm Beach County Sheriff's Office. He testifies about a follow-up investigation at a storage lot for trailers, a search of a white recreational vehicle under a state search warrant, and a second search warrant. He describes finding a firearm, ammunition and approximately 40 capsules of suspected heroin in a green shopping bag.
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“Transcript of Motion to Suppress Hearing — United States v. Delson Marc (Document 239, entered July 21, 2022).”
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Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 1 of 41
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
FORT LAUDERDALE DIVISION
CASE NO. 18-80153-CR-WPD
UNITED STATES OF AMERICA, .
.
Plaintiff, . Fort Lauderdale, Florida
. November 2, 2018
v. . 10:59 a.m.
.
DELSON MARC, .
.
Defendant. .
. . . . . . . . . . . . . . . . .
- - - - -
Transcript of Motion to Suppress Hearing had
before the Honorable William P. Dimitrouleas,
United States District Judge.
- - - - -
Proceedings recorded by mechanical stenography, transcript
produced by computer.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 2 of 41
2
APPEARANCES:
For the Government: Rinku T. Tribuiani
Assistant U.S. Attorney
Unite States Attorney's Office
500 S. Australian Avenue
Suite 400
West Palm Beach, Florida 33401
and
John J. Parnofiello
State Attorney's Office
401 N. Dixie Highway
West Palm Beach, Florida 33401
For the Defendant: Robert C. Buschel, Esq.
Buschel Gibbons, P.A.
100 S.E. 3rd Avenue
Suite 1300
Fort Lauderdale, Florida 33394
Court Reporter: Francine C. Salopek, RMR, CRR
Official Court Reporter
United States District Court
299 E. Broward Blvd., Room 207
Fort Lauderdale, Florida 33301
(305)301-3276
- - - - -
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 3 of 41
3
1 FRIDAY, NOVEMBER 2, 2018, 10:59 A.M.
2 (The Judge entered the courtroom)
3 THE COURT: Please be seated.
4 United States vs. Delson Marc.
5 If counsel would announce their appearances for the
6 record.
7 MS. TRIBUIANI: Rinku Tribuiani and John Parnofiello
8 on behalf of the United States. Good morning, Your Honor.
9 MR. PARNOFIELLO: Good morning, Judge.
10 MR. BUSCHEL: Good morning, Judge. Robert Buschel on
11 behalf of Delson Marc, who is seated in this courtroom.
12 THE COURT: All right. We're here for a motion to
13 suppress. Both sides ready to proceed?
14 MS. TRIBUIANI: Yes, Your Honor.
15 MR. BUSCHEL: Yes, sir.
16 THE COURT: The government may call its first witness.
17 MS. TRIBUIANI: Your Honor, by stipulation, the
18 government would start by offering into evidence a lease
19 agreement executed by Defendant Delson Marc.
20 (Government's Exhibit Number 1 marked for
21 identification)
22 THE COURT: All right. So is that Government's
23 Exhibit 1?
24 MS. TRIBUIANI: Yes, it is.
25 THE COURT: All right. That will be received.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 4 of 41
4
OLIVER - DIRECT/TRIBUIANI
1 (Government's Exhibit Number 1 admitted into evidence)
2 MS. TRIBUIANI: Your Honor, the government calls
3 Detective Corey Oliver.
4 ROOM CLERK: Please raise your right hand.
5 (COREY OLIVER, GOVERNMENT'S WITNESS, WAS SWORN)
6 ROOM CLERK: Thank you. You may be seated.
7 THE WITNESS: Thank you.
8 THE COURT: Please state your name. Please spell your
9 name for the record.
10 THE WITNESS: Detective Corey Oliver, O-L-I-V-E-R.
11 DIRECT EXAMINATION
12 BY MS. TRIBUIANI:
13 Q. Sir, what is your occupation?
14 A. I work for the Palm Beach County Sheriff's Office.
15 Q. How long have you been with the Palm Beach County Sheriff's
16 Office?
17 A. Twelve years.
18 Q. What is your current assignment?
19 A. I work for the violent crimes gang unit division.
20 Q. Back on July 13th, 2018, were you also in the gang unit?
21 A. Yes.
22 Q. And on that day, sir, were you conducting a follow-up
23 investigation at a tractor-trailer lot?
24 A. Yes.
25 Q. Specifically, where were you?
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 5 of 41
5
OLIVER - DIRECT/TRIBUIANI
1 A. 759 Benoist Farms Road, Doerr's storage lot.
2 Q. Is that a facility named Doerr's Trailers?
3 A. Yes.
4 Q. Were you at that time assisted by other agents?
5 A. At that time, I was with Detective Drummin and Agent Combs.
6 Q. And specifically, who is Agent Combs?
7 A. He is a certified canine handler.
8 Q. And what was your assignment that day at Doerr's Trailers
9 on July 13th?
10 A. I was conducting a follow-up investigation that -- that
11 occurred the day prior, when Delson Marc was apprehended at
12 that location.
13 Q. So Delson Marc was arrested at Doerr's Trailers on
14 July 13th?
15 A. Yes.
16 Q. And what was your assignment on July -- excuse me -- he was
17 arrested on July 12th. What was your assignment on July 13th?
18 A. To conduct a follow-up into his storage facility at that
19 location.
20 Q. Now, Doerr's Trailers, that area, is it open to the public?
21 A. Yes.
22 Q. Is it accessible to the public?
23 A. Yes.
24 Q. Can anyone from the public walk into that open space?
25 A. Yes.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 6 of 41
6
OLIVER - DIRECT/TRIBUIANI
1 Q. Were people required to check in with the management before
2 they walked into the open space?
3 A. No.
4 Q. What kind of business is Doerr's Trailers?
5 A. It's a storage lot, I guess, liking a parking storage lot
6 for trailers, containers, recreational vehicles, things like
7 that.
8 Q. When I hear parking spot or parking lots, I think of
9 clearly marked demarcated lines separating spots. Is that the
10 kind of features that Doerr's Trailers had?
11 A. No.
12 Q. Describe the area.
13 A. A lot of the area is basically just dirt. There's some
14 shell rocks. There's certain areas of concrete there.
15 Q. Now, you've testified that the area is open and accessible
16 to the public, and despite that, did you still speak to the
17 property manager in order to gain their permission to access
18 the open space tow yard?
19 A. Yes, I did.
20 Q. Did the manager give you permission to access the entire
21 open space tow yard?
22 A. Yes, he did.
23 Q. Did you then approach Delson Marc's white RV?
24 A. Yes, I did.
25 Q. And how did you know that this was Delson Marc's white RV?
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 7 of 41
7
OLIVER - DIRECT/TRIBUIANI
1 A. I -- they're identified by his -- the lot itself is
2 identified by his business. And also, the management verified
3 that those were his items.
4 Q. Was the area surrounding Delson Marc's RV exposed and
5 accessible to the public?
6 A. Yes, it was.
7 Q. Was there any enclosure surrounding Delson Marc's RV?
8 A. No.
9 Q. Did the area immediately around Delson's RV look like the
10 rest of the open area?
11 A. Yes.
12 Q. Describe the condition of the RV from the exterior.
13 A. It appeared that it hadn't been utilized in years. There
14 was some overgrown shrubbery along the south side of it. The
15 windows were boarded up on the east side of the recreational
16 vehicle. Like I said, it appeared that it hadn't been utilized
17 in years. The grass, there was, like, plants growing around it
18 also on the north side of it.
19 Q. Did the RV have a license plate?
20 A. Yes.
21 Q. Did it have a VIN number?
22 A. Yes.
23 Q. From the exterior of the RV, could you tell if it had
24 access to running water?
25 A. From the outside of it? It didn't appear that it had
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 8 of 41
8
OLIVER - DIRECT/TRIBUIANI
1 access to running water.
2 Q. Was there any indication to you that anybody was living in
3 the RV?
4 A. No.
5 Q. Did Detective Combs deploy his certified canine, Kaya?
6 A. Yes, he did.
7 Q. And did Kaya alert towards the RV indicating that she was
8 detecting the odor that she was trained to detect?
9 A. Yes.
10 Q. As a result, did you apply for and receive a state search
11 warrant?
12 A. Yes, I did.
13 MS. TRIBUIANI: Your Honor, by stipulation, at this
14 time, I would offer Government's Exhibit 2, a search warrant,
15 into evidence.
16 (Government's Exhibit Number 2 marked for
17 identification)
18 THE COURT: Okay. Two will be received.
19 (Government's Exhibit Number 2 admitted into evidence)
20 BY MS. TRIBUIANI:
21 Q. All right, sir, you've got Government's 2 there in front of
22 you, and what is this?
23 A. That's the search warrant that I applied for.
24 Q. Okay. And what time did you receive that search warrant?
25 A. That was signed at -- right here it says 1440 hours, it
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 9 of 41
9
OLIVER - DIRECT/TRIBUIANI
1 looks like.
2 Q. After you received the search warrant, did you then begin
3 to search the RV?
4 A. Yes. After the search warrant was signed by the judge,
5 uhm, I began to conduct our -- or furthering our investigation
6 into searching the recreational vehicle.
7 Q. How did you make entry?
8 A. We had to pry the -- it's like an access door on the side,
9 the main door, we had to pry it open.
10 Q. During the course of your search, in general terms, what
11 did you find?
12 A. As soon as we began searching -- Detective Hermanson was
13 also assisting with the search of that recreational vehicle.
14 There was a cabinet area immediately to the left when you walk
15 in up on the top shelf that had a green shopping bag.
16 Inside of the green shopping bag were several items,
17 which included a firearm, a black handgun, a -- it was like a
18 pouch, like a cigar pouch that contained approximately 40
19 capsules of suspected heroin, ammunition, magazines for
20 firearms, and some other weapon accessories.
21 Q. After you discovered the firearm and ammunition, what did
22 you do?
23 A. As soon as these items were located, I backed out of the
24 location and applied for another search warrant.
25 Q. Why?
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 10 of 41
10
OLIVER - DIRECT/TRIBUIANI
1 A. Because on the initial search warrant, I did not have
2 firearms listed on it.
3 (Discussion had off the record between counsel)
4 MS. TRIBUIANI: Your Honor, at this time, I would move
5 Government's Exhibit 3 into evidence by stipulation, a second
6 search warrant.
7 (Government's Exhibit Number 3 marked for
8 identification)
9 THE COURT: All right. Three will be received.
10 (Government's Exhibit Number 3 admitted into evidence)
11 BY MS. TRIBUIANI:
12 Q. All right, sir, you've got Government's Exhibit 3 in front
13 of you. What is this?
14 A. That's the second search warrant that I applied for.
15 Q. Now, during the course of your search, were photographs
16 taken of the exterior and the interior of the RV?
17 A. Yes.
18 MS. TRIBUIANI: Your Honor, I would move Government's
19 Exhibit 4A through 4Q, a composite exhibit, into evidence by
20 stipulation.
21 (Government's Exhibit Numbers 4A through 4Q marked for
22 identification)
23 THE COURT: All right. There being no objection, 4
24 will be received.
25 (Government's Exhibit Number 4 admitted into evidence)
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 11 of 41
11
OLIVER - DIRECT/TRIBUIANI
1 THE WITNESS: Thank you.
2 BY MS. TRIBUIANI:
3 Q. All right, sir, let's go through these photographs starting
4 with 4A. And if you could just tell us what each photograph
5 shows.
6 A. All right. The 4A photograph is the white recreational
7 vehicle. There's also an Astro van there, but the white
8 recreational vehicle, that's the vehicle that we're talking
9 about.
10 Q. Okay. And 4B?
11 A. That's the white recreational vehicle with the door open.
12 Q. 4C?
13 A. That's the rear of the recreational vehicle, which was
14 facing the east.
15 Q. And does that photograph depict the license plate of the
16 vehicle?
17 A. Yeah, you can partially see it.
18 Q. 4D?
19 A. That's the front -- I'm sorry -- that's the front of the
20 recreational vehicle with the door open.
21 Q. 4E?
22 A. That's a picture of the door.
23 Q. And is that the door that was breached to make entry?
24 A. Yes, ma'am.
25 Q. 4F.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 12 of 41
12
OLIVER - DIRECT/TRIBUIANI
1 A. That's the initial view when you open the entry door that
2 we had to gain access to. As soon as you walk in, that's what
3 you see.
4 Q. 4G.
5 A. This is inside of the rec -- or recreational vehicle. This
6 is -- if you were to walk in through the front door, you'd look
7 to the left, and this is the area, this is the floor area.
8 Q. And, sir, just to be clear, the photograph 4G shows what
9 appears to be quite a bit of trash on the floor. Was this
10 photograph taken before your search or after your search?
11 A. This is how it looked before our search.
12 Q. 4H?
13 A. That's just another photograph of the area inside the
14 recreational vehicle.
15 Q. 4I.
16 A. In this photograph, if you look up to the top left portion,
17 there's like a cabinet area with no doors on it. You can see
18 the green bag. That's the green bag that the firearm and
19 suspected narcotics and ammunition was located in.
20 Q. And then towards the back of 4I, you can see a partial
21 window. Is the rest of that window boarded up?
22 A. Yes.
23 Q. 4J?
24 A. That's a -- it's kind of like a homemade table, I guess,
25 that's underneath the cabinet. It was like a packaging station
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 13 of 41
13
OLIVER - DIRECT/TRIBUIANI
1 kind of, I guess you could say. There's some gloves there with
2 a -- like a white plate with some unknown suspected -- or
3 unknown suspected packaging substance inside that bag, white
4 powder.
5 Q. And is there also a box of baking soda?
6 A. Yes.
7 Q. 4K?
8 A. That's just another view of the inside of the recreational
9 vehicle.
10 Q. 4L?
11 A. That's a closer view of the green bag that contained the
12 firearm, ammunition, and suspected narcotics.
13 Q. 4M?
14 A. That's another view of the green bag that contained those
15 items.
16 Q. 4N?
17 A. That's an up-close view of the green bag that contained the
18 firearm, ammunition, and suspected narcotics.
19 Q. 4O?
20 A. That's another close view of it.
21 Q. 4P.
22 A. This is a picture of the driver compartment. Uhm,
23 basically, if you come in through the main door that we made
24 entry into, if you were to look to the right, this is what you
25 would see. Above the two seats, there's a shelf there.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 14 of 41
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OLIVER - DIRECT/TRIBUIANI
1 Q. 4Q.
2 A. On top of this -- on top of this shelf, there was --
3 there's a metal bowl there, there's some packaging materials
4 that are consistent with narcotics sales, clear baggies,
5 there's latex gloves. There was a scale, I believe.
6 Q. Sir, inside the defendant's RV, was there a kitchen?
7 A. No.
8 Q. Was there a stove?
9 A. No.
10 Q. A bathroom?
11 A. No.
12 Q. Any toiletries?
13 A. No.
14 Q. Any evidence that anybody was living there?
15 A. No.
16 MS. TRIBUIANI: May I have a moment, Judge?
17 THE COURT: Cross-examination.
18 MS. TRIBUIANI: Just one moment, your Honor? One
19 moment?
20 THE COURT: Oh, I thought -- go ahead.
21 (Discussion had off the record between counsel)
22 MS. TRIBUIANI: I tender the witness.
23 THE COURT: Cross-examination.
24 MR. BUSCHEL: Thank you, Judge.
25
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 15 of 41
15
OLIVER - CROSS/BUSCHEL
1 CROSS-EXAMINATION
2 BY MR. BUSCHEL:
3 Q. Detective, you didn't have keys to the RV?
4 A. No, not that day, I did not.
5 Q. Did it require keys to open the RV?
6 A. Yes.
7 Q. Okay. And you got that from? You didn't have it that day.
8 You all pried open the door, correct?
9 A. That day we pried open the door.
10 Q. Any keys to start the RV?
11 A. No.
12 Q. Did the manager provide keys to open the RV?
13 A. No.
14 Q. To start the RV?
15 A. No.
16 Q. Do you remember the name of the manager or landlord?
17 A. It's a -- I think it's Braswell (phonetic) or something. I
18 have the name in the paperwork. I forgot what it is.
19 Q. Did he walk around the lot with you? Was he with you
20 during the search, particularly the dog, when the dog was doing
21 the search?
22 A. Not the initial search. He basically came over and he
23 verified which items -- which area was Mr. Marc's in his lease
24 agreement and which items were his on that property.
25 Q. Okay. In the warrant, you talked about this RV. Was it --
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 16 of 41
16
OLIVER - CROSS/BUSCHEL
1 you testified on direct that this didn't appear to work or
2 drive.
3 A. No.
4 Q. Meaning you agree?
5 A. (No response)
6 Q. You agree that it does not operate?
7 A. Oh, I agree that it does not, yes.
8 Q. Okay. And the license plate, it was expired? The tag?
9 A. Yes.
10 Q. Okay. Are you aware of any pole camera that was there as
11 pursuant to the -- an investigation by you all?
12 A. Yes.
13 Q. Okay. And it was of the lot, correct?
14 A. I believe it was on another portion of the lot. But I
15 don't -- I don't have that -- I was not part of that
16 investigation.
17 Q. Okay. Were you there for the dog sniff?
18 A. Yes.
19 Q. Okay. This dog, Kaya, the warrant says that the dog
20 sniffed, quote/unquote, the cabin entrance, correct?
21 A. Yes.
22 Q. Okay. You want the dog -- the dog should smell inside,
23 sniff inside the RV, not the surrounding area, correct?
24 A. I wouldn't be able to answer that question, because I'm not
25 a -- I'm not certified to handle narcotics -- a narcotics
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 17 of 41
17
OLIVER - REDIRECT/TRIBUIANI
1 canine, let alone a canine in general.
2 Q. But the dog seems to be putting its nose, as you indicated
3 in your application, up against the door --
4 A. Yes.
5 Q. -- to smell inside.
6 A. And that's what Agent Combs relayed to me.
7 Q. Okay. Very good.
8 MR. BUSCHEL: Thank you, Judge.
9 THE COURT: Redirect?
10 REDIRECT EXAMINATION
11 BY MS. TRIBUIANI:
12 Q. Sir, just to be clear -- and feel free to turn to your
13 affidavit if you need to refresh your memory -- did the dog
14 sniff the air around the RV?
15 A. (No response)
16 Q. I'm looking at the bottom of page 5 of 12 in your second
17 search warrant, Government's 3.
18 A. The second one?
19 Wait. I gotta find it.
20 Are you talking about where it says:
21 "Kaya began sniffing the cabin entrance door to
22 the white RV, and Agent Combs observed a behavior
23 change and heard an audible respiratory change. Kaya
24 pushed her nose hard against the bottom side of the
25 door and sniffed more frantic. Kaya then began to
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 18 of 41
18
1 bracket back and forth between the RV camper and the
2 white van. Kaya then spun, placed her nose hard
3 against the RV door. Kaya came to a final response
4 alert, indicating that she was detecting the odors
5 which she is trained to detect."
6 Q. The bottom of page 5, the last sentence there? Did Kaya
7 first begin sniffing the free air around Marc's assigned
8 parking spots?
9 A. Yes.
10 Q. Okay. And then after that sniff, did Kaya make her way
11 towards each one of those structures?
12 A. Yes.
13 Q. Was Kaya ever inside Marc's RV, or was she sniffing the
14 exterior of Marc's RV?
15 A. The exterior. She never went in.
16 MS. TRIBUIANI: Nothing further.
17 THE COURT: Thank you, Detective. You may step down.
18 You're excused.
19 THE WITNESS: Thank you.
20 (Witness excused)
21 THE COURT: The government may call its next witness.
22 MS. TRIBUIANI: The government rests.
23 THE COURT: Mr. Buschel?
24 MR. BUSCHEL: Nothing for Mr. Marc. Argument?
25 THE COURT: And Mr. Marc understands he has a
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 19 of 41
19
1 constitutional right to testify?
2 (Discussion had off the record between counsel and
3 client)
4 MR. BUSCHEL: He understands, Judge.
5 THE COURT: Any objection to my having a colloquy with
6 him?
7 (Discussion had off the record between counsel and
8 client)
9 THE DEFENDANT: Excuse me, sir?
10 THE COURT: You understand you have a constitutional
11 right to testify?
12 THE DEFENDANT: Yes, sir.
13 THE COURT: You have a constitutional right not to
14 testify. Do you understand that?
15 THE DEFENDANT: Yes, sir.
16 THE COURT: And there may be strategy reasons for or
17 against your testifying. Do you understand that?
18 THE DEFENDANT: Yes, sir.
19 THE COURT: Your lawyer's been to law school, he's
20 tried a lot of cases, he gives you the benefit of his legal
21 advice, but it's your life; you don't have to follow the
22 advice. Do you understand that?
23 THE DEFENDANT: Yes, sir.
24 THE COURT: And whatever decision you make, you're
25 going to be stuck with that decision. Do you understand that?
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 20 of 41
20
1 THE DEFENDANT: Um-hum.
2 THE COURT: You have to answer yes or no.
3 MR. BUSCHEL: Answer yes.
4 THE DEFENDANT: Yes, sir.
5 THE COURT: For example, if you decided to testify,
6 and if you turned out to be a lousy witness, and I denied the
7 motion to suppress, you can't complain about that, because you
8 decided to testify. Do you understand that?
9 THE DEFENDANT: Yes, sir.
10 THE COURT: On the other hand, if you decide not to
11 testify, and if I deny the motion to suppress, you can't come
12 back later on and say, "Oh, Judge, if you would have just heard
13 my testimony, you would have granted the motion to suppress."
14 Do you understand that?
15 THE DEFENDANT: Yes, sir.
16 THE COURT: And have you had enough time to think
17 about this and talk about it with your lawyer?
18 THE DEFENDANT: Yes, sir.
19 THE COURT: And do you agree with the strategy of not
20 testifying in the motion to suppress?
21 THE DEFENDANT: Yes, sir.
22 THE COURT: Argument, Mr. Buschel?
23 MR. BUSCHEL: Thank you, Judge.
24 (Discussion had off the record between counsel and
25 client)
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 21 of 41
21
1 MR. BUSCHEL: Judge, the motion to suppress should be
2 granted for the following reasons: The law on the matter is
3 this. A dog sniff is a search, and the Court must consider the
4 four corners of the search warrant affidavit. If the car is
5 not movable, which seems to be the unrefutable (sic) testimony,
6 the RV is not movable, then it is a structure, and the Court
7 should consider it a structure.
8 I will deal with the lease, which we didn't talk about
9 during the cross-examination. But -- I'm sorry -- first, I
10 want to say that the warrant itself actually says:
11 "Kaya pushed her nose hard against the bottom
12 side of the door and sniffed more frantic. Kaya then
13 began to bracket back and forth between the RV camper
14 and the white van."
15 And that's critical, because if it's not smelling
16 inside the van, I don't think that -- or the RV, then there is
17 no probable cause to put in the warrant. Without the dog
18 sniff, there is no warrant -- there is no probable cause to
19 support the warrant. And I think that's abundantly clear from
20 the affidavit itself.
21 The government and I agreed to put in the lease. The
22 lease agreement does prove standing of the actual lot, and we
23 know that the RV is owned by Mr. Marc.
24 The lease itself says that there is some type of
25 inspection that's granted to the landlord. The landlord wasn't
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22
1 present; it seemed to be a manager. The lease was there to --
2 purpose of this inspection is to stop by there to make sure
3 that no one's making repairs -- or to make repairs, according
4 to the lease. If the lot itself is not -- if -- but the tenant
5 is not allowed to make repairs.
6 So I'm saying that the lease itself says the
7 landlord's allowed to make repairs, but the tenant is not
8 allowed to make repairs, change oil, change tires, do anything
9 there. What I'm suggesting is that the lot is a leased lot,
10 and it belongs to Mr. Marc. Therefore, there needed to be
11 probable cause for the police to come upon that lot.
12 If the RV is a structure, now there is a curtilage.
13 And so now we have the Collins case, which the United States
14 Supreme Court recently ruled upon, saying a motorcycle
15 underneath a tarp in a curtilage, the officer can't just lift
16 up the tarp and look underneath it. That is a search within
17 the curtilage.
18 Here we --
19 THE COURT: Curtilage of a residence or curtilage of a
20 structure?
21 MR. BUSCHEL: Curtilage of a residence in that
22 situation.
23 THE COURT: What's the law on whether structures have
24 curtilage? I thought a curtilage would just apply to a
25 residence.
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1 MR. BUSCHEL: I put in my memo -- I cite to the
2 Florida burglary statute. It defines curtilage. It applies to
3 both structure and dwelling. And I believe that you can have a
4 curtilage to a structure as well.
5 The key here is -- the key here, the case law I cited
6 clearly says, if the car is not mobile, it becomes a -- it's a
7 structure. We know an RV can be used for a structure.
8 THE COURT: Well, is there a difference between what a
9 Florida statute defines as curtilage and what is curtilage for
10 the Fourth Amendment to the United States Constitution?
11 MR. BUSCHEL: There could -- sure -- there could be.
12 I don't think there is. I give it as something that we all --
13 that police, detectives, particularly state police detectives
14 would -- should consider when thinking about a structure and
15 curtilage.
16 The point is also --
17 THE COURT: If a police officer thought that a
18 curtilage would only apply to a residence, why wouldn't the
19 good-faith exception to the search warrant requirement allow
20 this search?
21 MR. BUSCHEL: I would also concede -- I'm not prepared
22 to concede that this wouldn't be a residence. An RV is built
23 for that purpose, and the only reason they know that it wasn't
24 that purpose is once they opened the door and saw that it was
25 disheveled and that it would be uninhabitable. Certainly
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1 someone could sleep in there. Granted, there's no running
2 water, et cetera. I concede that. But when you look at an RV,
3 when you look at this type of camper, you don't presume it
4 doesn't -- it isn't a residence; you presume the purpose of it
5 is that someone can sleep there overnight, and so there's an
6 expectation of privacy.
7 And if we get to the point where you're saying, well,
8 what's the good faith of the detective, the good faith default
9 should be, this a recreational vehicle that people sleep in;
10 therefore, I should presume it's a residence before I just
11 conclude it's uninhabitable to sleep in.
12 THE COURT: Any further argument?
13 MR. BUSCHEL: No. Thank you, Judge.
14 THE COURT: Ms. Tribuiani.
15 MS. TRIBUIANI: Your Honor, Delson Marc's recreational
16 vehicle is not a home. Marc was prevented by the terms of the
17 lease agreement, Government's Exhibit 1, from residing in his
18 RV. Page 2 of that document, number 2 specifically states:
19 "Tenant agrees to use the premise exclusively for
20 the storage of customer-owned truck and/or trailer."
21 This area was not zoned residential; it was a
22 commercial area.
23 Further, Government's 1, page 2, number 3 of the lease
24 agreement states:
25 "Tenant understands and agrees that the use of
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1 electricity is not allowed."
2 So not only did this structure not have running water,
3 it was also not permitted to have electricity.
4 THE COURT: Isn't there a propane tank outside of it,
5 though?
6 MS. TRIBUIANI: There may have been, your Honor. I
7 don't know what it was used for. And considering the
8 delapidated nature of the RV, it could have just been junk. We
9 don't know whether it was filled or its purpose.
10 Now, the photographs of the RV, again, show its
11 condition. It was used for storage. And in this case, it was
12 used for Mr. Marc to store his firearm and his ammunition.
13 Because the RV is not a home, it does not have any
14 curtilage. Mr. Marc did not have a right to exclude anybody
15 from that open accessible area.
16 The case that the defense cites, Florida vs. Jardines,
17 clearly applies to a home. Again, an uninhabited RV is not a
18 home.
19 I also have some additional cases for Your Honor that
20 I'd like to pass up. And defense counsel has a copy of these
21 as well.
22 Your Honor, beginning with the Supreme Court's
23 decision in United States vs. Dunn -- I'm sure the Court's
24 familiar with this case -- the Court came up with basically a
25 four-factor test to determine whether a particular area
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1 qualifies as curtilage.
2 Number one, the proximity of the area claimed to be
3 curtilage to the home; two, whether the area is included within
4 an enclosure surrounding the home; three, the nature of the
5 uses to which the area is put; and, four, the steps taken by
6 the resident to protect the area from observation by people
7 passing by.
8 Again, the underlying premise of Dunn is that
9 curtilage applies to a home. And even using Mr. Buschel's
10 definition of home or residence, the defense still does not
11 meet these four factors set forth in Dunn. The testimony is
12 that Mr. Marc took absolutely no steps, no precautions to
13 protect the area surrounding his home from observation by
14 people passing by. And, again, that's if the Court is inclined
15 to believe the defense's theory in this case.
16 Next, in United States vs. Perilla -- I understand
17 it's a district court case, but it gets to the very heart of
18 the question that the Court first asked. And that is, the
19 Court determined that an area surrounding a business has never
20 been considered part of the business itself, and the concept of
21 curtilage is limited to the home.
22 So if the Court finds, again, that this RV is not a
23 home, that ends the inquiry.
24 Lastly, United States vs. Wymer is also a district
25 court case. And this is a case that actually involved an RV.
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1 And in this case, the testimony was that the defendant actually
2 lived in his RV for part of the year. But, again, the Court
3 determined that a government intrusion that amounts to a
4 search, if conducted in or around a home, does not necessarily
5 constitute a search if conducted on commercial property. There
6 is a diminished expectation of privacy in those activities.
7 And the Court, most importantly, went on to say that:
8 "Even assuming the RV was Wymer's primary
9 residence from August to December, Wymer made no
10 showing that the area immediately surrounding the RV
11 qualified as curtilage. Living in an RV parked on
12 commercial premises does not automatically convert
13 some portion of those premises into an area so
14 intimately tied to the home itself that it should be
15 placed under the home's umbrella of the Fourth
16 Amendment protection."
17 Lastly, Your Honor, I just want to point out that
18 although the lease agreement lists some parking spaces for
19 Mr. Marc, the Court will notice that those spaces are not --
20 there's no dimensions given for those spaces. What that, in
21 essence, means is that Doerr's Trailers is literally leasing
22 the space underneath a vehicle. And if a vehicle parks a few
23 feet away from another vehicle, it's only because the driver
24 does not want to have an accident, not because there's any
25 curtilage surrounding a vehicle.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
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1 Lastly, your Honor, again, I would rely for appellate
2 purposes on Leon. The officers here clearly acted in good
3 faith. They did everything they were supposed to do, including
4 acquiring two different search warrants for the property.
5 THE COURT: Anything further, Mr. Buschel?
6 MR. BUSCHEL: If I may, just a few.
7 The one point I do want to make to the Court is, even
8 if there is no curtilage around the RV, the dog's invasive
9 sniff into the RV is a search pursuant to Jardines.
10 THE COURT: Well, I mean, isn't that the case on any
11 traffic stop, when a narcotics canine dog alerts to a car, the
12 dog is smelling the odors that are coming out of the car? But
13 Jardines, it seems to me, you know, said that you can't use a
14 dog to smell what's coming out of a home. I don't know that
15 you can't use a dog to smell what's coming out of a car.
16 MR. BUSCHEL: A car is different, Judge. You have the
17 automobile exception. If the Court accepts that it's a car,
18 then police are allowed to have permission during a traffic
19 stop due to the movement of the car.
20 THE COURT: The Carroll Doctrine only says they don't
21 have to get a warrant. To me, there's no difference between a
22 search of a car based on the Carroll Doctrine and the search of
23 a car based on a search warrant. They both require probable
24 cause. And I don't see the difference between the Carroll
25 Doctrine basis for a search and a search that is based on a
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1 canine alerting to a car that's put in a search warrant. To
2 me, the Carroll Doctrine says because the car's movable, they
3 don't have to go get a warrant.
4 MR. BUSCHEL: Right.
5 THE COURT: But the same principle applies, and that
6 is, they have to have probable cause in either situation to
7 believe that there's a crime being committed or evidence of a
8 crime in there.
9 MR. BUSCHEL: Right. But, again, I think there's a
10 distinction between the car and a structure. We know this must
11 be a structure. You get some increased sense of expectation of
12 privacy in a structure or a residence versus a car.
13 THE COURT: How about a homeless person that's living
14 in their car? I mean, does that mean that because the homeless
15 person's living in the car, and that's their residence, that
16 police can't use a canine dog to effectuate a Carroll Doctrine
17 search?
18 MR. BUSCHEL: I think it really does come down to that
19 the automobile -- whether some of this stuff is bleeding into
20 whether one has to get a warrant, and whether officers need to
21 get a warrant or not is determinative of that. So if you were
22 living in a structure, in the shed, are they allowed to just
23 come up to someone's shed if there's reason to believe that
24 this shed is being used -- could be used for a residence, for
25 someone to stay there?
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1 THE COURT: Well, if it's a gray area, if the police
2 aren't sure whether or not they can do a Carroll Doctrine
3 search of a car that's being used by a homeless person, but in
4 an abundance of caution, they go and they get a search warrant
5 for it, why wouldn't Leon say that the magistrate was justified
6 in relying on the police officer's belief that that search was
7 okay?
8 MR. BUSCHEL: I think because circum-- well, the -- if
9 the officers didn't express, articulate that there's a reason
10 to believe that a homeless person was living in their car and,
11 indeed, that was their residence, I might be having the same
12 conversation with the Court, saying they should have, even
13 though they went to get a warrant.
14 Here you have something by design, a recreational
15 vehicle, by design. It's meant to house people for albeit
16 short periods of time or for trips. And we have a particular
17 unique circumstance where the evidence is this RV didn't move.
18 And so the Supreme Court says we shouldn't make distinctions
19 based on monetary or financial, whether it's a glorious house
20 that has curtilage, a large curtilage, or whether somebody is
21 living in an RV.
22 THE COURT: I mean, it would seem to me that the judge
23 in the Northern District of Ohio, if he denied the motion to
24 suppress on that RV, he would certainly deny it on this case,
25 don't you think?
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1 MR. BUSCHEL: Probably. But we're in the Southern
2 District of Florida.
3 THE COURT: It's only persuasive on me.
4 MR. BUSCHEL: Yes.
5 THE COURT: All right. I'm going to deny the motion
6 to suppress. I'll enter a written order as soon as I can get
7 around to it.
8 The defense filed a motion for Brady and Giglio.
9 What's the government's position on that?
10 MS. TRIBUIANI: Your Honor, I'm aware of my Giglio
11 obligations. And if, in fact, the CI does testify at trial, we
12 will certainly turn over all of the relevant material.
13 Now, the defense is asking for a laundry list of
14 items, including tax returns and other cases in which the CI
15 was involved. They're not entitled to that information at all.
16 But I will certainly turn over and disclose any criminal
17 history for the CI, along with receipts of any payments or
18 instructions that he was given by his handlers in this case.
19 THE COURT: Mr. Buschel?
20 MR. BUSCHEL: That's sufficient, Judge. I just wanted
21 to cover Mr. Marc's interests.
22 THE COURT: All right. So I'll grant the motion to
23 compel if the CI testifies.
24 Anything else we need to discuss?
25 MR. BUSCHEL: Yes, Judge.
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1 The Court yesterday indicated we may or may not be
2 going to trial on Monday based upon a civil case that you were
3 going to hear about this morning.
4 THE COURT: They announced ready. And what I told
5 them was that we would pick the jury on the criminal case
6 first, then pick a jury in the civil case, and then recess that
7 civil case until the next week. So what I would plan on doing
8 is bringing in 46 or so jurors and picking a jury on Mr. Marc's
9 case, excuse that jury till Tuesday, and then we would resume
10 Mr. Marc's case on Tuesday, and then hopefully finish it next
11 week. And I'll have the civil jury come back -- normally it
12 would be Monday, but Monday's a holiday, so come back the next
13 Tuesday to finish their trial.
14 So it really doesn't impact you at all, because the
15 jury that is being selected for Mr. Marc won't even know
16 anything about the civil case. They may know that when we get
17 done with the criminal case, they're going to -- the remnants
18 are going to stick around and get picked for the civil case,
19 but the 12 jurors and the two alternates on Mr. Marc's case
20 will be excused until the next day.
21 So that's my preference as to how we handle it. And
22 then that kind of gets the civil case's foot in the door, so if
23 there's another criminal case next week, then they get to
24 finish their case first before the criminal case goes.
25 Otherwise, the criminal case could bump them.
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
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1 Any other questions?
2 MS. TRIBUIANI: Your Honor, as a housekeeping matter,
3 I've got a proposed letter that allows my agents to bring in
4 the firearm and ammunition and drugs. May I pass that up to
5 the Court?
6 THE COURT: Okay.
7 And, Mr. Buschel, did you have a chance to talk
8 Mr. Marc to see if he wants to have the challenges at sidebar
9 without him being present or the challenges in open court so he
10 can hear what's going on?
11 MR. BUSCHEL: I haven't, Judge, and I apologize.
12 We'll see him, I guess this evening, since that's when I'm told
13 he'll be transferred back to his facility in Pompano.
14 THE COURT: All right. So just let me know Monday.
15 And what do we have Monday? We've got two --
16 ROOM CLERK: Just the change of plea, if it goes. Two
17 changes of plea on Monday at nine.
18 THE COURT: Right.
19 I asked the civil lawyers to come at nine o'clock.
20 I've got a change of plea that's set for nine o'clock on
21 Monday. But the defense attorney's in trial in Ft. Pierce in
22 front of Judge Cohn. And I talked to Judge Cohn yesterday at
23 the magistrate's investiture ceremony, and he doesn't know for
24 sure whether the case is going to finish today.
25 So if Judge Cohn's Ft. Pierce case doesn't finish
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1 today, then they're going to finish on Monday, and the lawyer
2 won't be here, so I won't be able to do the change of plea on
3 Monday.
4 So what I told the civil lawyers, what I'm telling you
5 guys, is come at nine o'clock, and if Judge Cohn finished the
6 case, then I'll be taking the change of plea for half an hour.
7 We'll start at 9:30. If Judge Cohn didn't finish the case,
8 then the lawyer's in Ft. Pierce, and I'll take the change of
9 plea on Tuesday, and we'll start at nine o'clock.
10 MS. TRIBUIANI: Yes, sir.
11 THE COURT: Anything else we need to discuss?
12 MR. BUSCHEL: No. Thank you, Judge.
13 THE COURT: Let me go ahead and sign this letter for
14 Ms. Tribuiani.
15 MS. TRIBUIANI: So, Your Honor, just to confirm then,
16 we don't need to have any witnesses here on Monday. We will
17 start on Tuesday.
18 THE COURT: Correct.
19 MS. TRIBUIANI: All right.
20 THE COURT: And that assumes that the civil case
21 doesn't settle this afternoon. But I don't think they're going
22 to settle, so I think we're safe in assuming that.
23 And we'll be in recess.
24 ROOM CLERK: All rise.
25 (The Judge exited the courtroom)
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
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1 (Proceedings concluded at 11:43 a.m.)
2 - - - - -
3
4
5
6 INDEX OF WITNESSES
7 GOVERNMENT'S WITNESS PAGE
8 Corey Oliver
Direct by Ms. Tribuiani 4
9 Cross by Mr. Buschel 15
Redirect by Ms. Tribuiani 17
10
11 - - - - -
12 INDEX OF EXHIBITS
13 GOVERNMENT'S EXHIBITS MARKED ADMITTED
14 1 3 4
2 8 8
15 3 10 10
4A through 4Q 10 10
16
17 - - - - -
18 C E R T I F I C A T E
19 I hereby certify that pursuant to Section 753,
20 Title 28, United States Code, the foregoing is a true and
21 correct transcript from the record of proceedings in the
22 above-entitled matter.
23
____/s/Francine C. Salopek ____________ 7-21-2022 ___
24 Francine C. Salopek, RMR-CRR Date
Official Court Reporter
25
FRANCINE C. SALOPEK, OFFICIAL COURT REPORTER
(305)301-3276
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4P [1] 13/21 application [1] 17/3
4Q [4] 10/19 10/21 14/1 35/15 applied [3] 8/23 9/24 10/14
MR. BUSCHEL: [26]
applies [4] 23/2 25/17 26/9 29/5
MR. PARNOFIELLO: [1] 3/9 5 apply [3] 8/10 22/24 23/18
MS. TRIBUIANI: [20]
500 [1] 2/3 apprehended [1] 5/11
ROOM CLERK: [4] 4/4 4/6 33/16
approach [1] 6/23
34/24 7 approximately [1] 9/18
THE COURT: [55] 7-21-2022 [1] 35/23 area [27]
THE DEFENDANT: [11] 753 [1] 35/19 areas [1] 6/14
THE WITNESS: [4] 4/7 4/10 11/1 759 [1] 5/1 aren't [1] 30/2
18/19
argument [3] 18/24 20/22 24/12
9
/ arrested [2] 5/13 5/17
9:30 [1] 34/7 articulate [1] 30/9
/s/Francine [1] 35/23
assigned [1] 18/7
A
1 assignment [4] 4/18 5/8 5/16 5/17
a.m [3] 1/8 3/1 35/1 Assistant [1] 2/2
10 [4] 35/15 35/15 35/15 35/15 above [2] 13/25 35/22
100 [1] 2/9 assisted [1] 5/4
above-entitled [1] 35/22 assisting [1] 9/13
10:59 [2] 1/8 3/1 absolutely [1] 26/12
11:43 [1] 35/1 assumes [1] 34/20
abundance [1] 30/4 assuming [2] 27/8 34/22
12 [2] 17/16 32/19 abundantly [1] 21/19
12th [1] 5/17 Astro [1] 11/7
accepts [1] 28/17 Attorney [1] 2/2
1300 [1] 2/9 access [6] 6/17 6/20 7/24 8/1 9/8 12/2 attorney's [3] 2/3 2/6 33/21
13th [4] 4/20 5/9 5/14 5/17 accessible [4] 5/22 6/15 7/5 25/15
1440 hours [1] 8/25 audible [1] 17/23
accessories [1] 9/20 August [1] 27/9
15 [1] 35/9 accident [1] 27/24
17 [1] 35/9 Australian [1] 2/3
according [1] 22/3 automatically [1] 27/12
18-80153-CR-WPD [1] 1/4 acquiring [1] 28/4 automobile [2] 28/17 29/19
2 acted [1] 28/2 Avenue [2] 2/3 2/9
activities [1] 27/6 aware [2] 16/10 31/10
2018 [3] 1/7 3/1 4/20
admitted [5] 4/1 8/19 10/10 10/25
2022 [1] 35/23 B
35/13
207 [1] 2/12
advice [2] 19/21 19/22 bag [8]
28 [1] 35/20
affidavit [3] 17/13 21/4 21/20 baggies [1] 14/4
299 [1] 2/12
afternoon [1] 34/21 baking [1] 13/5
3 Agent [4] 5/5 5/6 17/6 17/22 basis [1] 28/25
Agent Combs [4] 5/5 5/6 17/6 17/22 bathroom [1] 14/10
301-3276 [1] 2/13
agents [2] 5/4 33/3 Beach [4] 2/4 2/7 4/14 4/15
305 [1] 2/13
agree [4] 16/4 16/6 16/7 20/19 becomes [1] 23/6
3276 [1] 2/13
agreement [6] 3/19 15/24 21/22 24/17 began [5] 9/5 9/12 17/21 17/25 21/13
33301 [1] 2/13
24/24 27/18 begin [2] 9/2 18/7
33394 [1] 2/10
agrees [2] 24/19 24/25 beginning [1] 25/22
33401 [2] 2/4 2/7
air [2] 17/14 18/7 behavior [1] 17/22
3rd [1] 2/9
albeit [1] 30/15 belief [1] 30/6
4 alert [2] 8/7 18/4 believe [7] 14/5 16/14 23/3 26/15 29/7
40 [1] 9/18 alerting [1] 29/1 29/23 30/10
400 [1] 2/4 alerts [1] 28/11 belongs [1] 22/10
401 [1] 2/6 allow [1] 23/19 benefit [1] 19/20
46 [1] 32/8 allowed [6] 22/5 22/7 22/8 25/1 28/18 Benoist [1] 5/1
4A [5] 10/19 10/21 11/4 11/6 35/15 29/22 black [1] 9/17
4B [1] 11/10 allows [1] 33/3 bleeding [1] 29/19
4C [1] 11/12 alone [1] 17/1 Blvd [1] 2/12
4D [1] 11/18 alternates [1] 32/19 boarded [2] 7/15 12/21
4E [1] 11/21 although [1] 27/18 bottom [4] 17/16 17/24 18/6 21/11
4F [1] 11/25 Amendment [2] 23/10 27/16 bowl [1] 14/3
4G [2] 12/4 12/8 AMERICA [1] 1/6 box [1] 13/5
4H [1] 12/12 ammunition [7] 9/19 9/21 12/19 13/12 bracket [2] 18/1 21/13
4I [2] 12/15 12/20 13/18 25/12 33/4 Brady [1] 31/8
4J [1] 12/23 amounts [1] 27/3 Braswell [1] 15/17
4K [1] 13/7 announce [1] 3/5 breached [1] 11/23
4L [1] 13/10 announced [1] 32/4 Broward [1] 2/12
4M [1] 13/13 answer [3] 16/24 20/2 20/3 built [1] 23/22
4N [1] 13/16 apologize [1] 33/11 bump [1] 32/25
4O [1] 13/19 appearances [2] 2/1 3/5 burglary [1] 23/2
appellate [1] 28/1 Buschel [10]
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 37 of 41
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B confirm [1] 34/15 determinative [1] 29/21
consistent [1] 14/4 determine [1] 25/25
Buschel's [1] 26/9
constitute [1] 27/5 determined [2] 26/19 27/3
business [4] 6/4 7/2 26/19 26/20
Constitution [1] 23/10 difference [3] 23/8 28/21 28/24
C constitutional [3] 19/1 19/10 19/13 dimensions [1] 27/20
cabin [2] 16/20 17/21 contained [4] 9/18 13/11 13/14 13/17 diminished [1] 27/6
cabinet [3] 9/14 12/17 12/25 containers [1] 6/6 Dimitrouleas [1] 1/14
call [2] 3/16 18/21 conversation [1] 30/12 direct [3] 4/11 16/1 35/8
calls [1] 4/2 convert [1] 27/12 dirt [1] 6/13
camera [1] 16/10 copy [1] 25/20 disclose [1] 31/16
camper [3] 18/1 21/13 24/3 Corey [4] 4/3 4/5 4/10 35/8 discovered [1] 9/21
canine [7] 5/7 8/5 17/1 17/1 28/11 corners [1] 21/4 discuss [2] 31/24 34/11
29/1 29/16 counsel [7] 3/5 10/3 14/21 19/2 19/7 Discussion [5] 10/3 14/21 19/2 19/7
capsules [1] 9/19 20/24 25/20 20/24
car [17] County [2] 4/14 4/15 disheveled [1] 23/25
car's [1] 29/2 court [25] distinction [1] 29/10
Carroll [6] 28/20 28/22 28/24 29/2 Court's [2] 25/22 25/23 distinctions [1] 30/18
29/16 30/2 courtroom [3] 3/2 3/11 34/25 district [8]
case's [1] 32/22 cover [1] 31/21 division [2] 1/3 4/19
cause [5] 21/17 21/18 22/11 28/24 CR [1] 1/4 Dixie [1] 2/6
29/6 crime [2] 29/7 29/8 Doctrine [6] 28/20 28/22 28/25 29/2
caution [1] 30/4 crimes [1] 4/19 29/16 30/2
ceremony [1] 33/23 criminal [6] 31/16 32/5 32/17 32/23 document [1] 24/18
certified [3] 5/7 8/5 16/25 32/24 32/25 Doerr's [8]
certify [1] 35/19 critical [1] 21/15 dog [16]
cetera [1] 24/2 cross [5] 14/17 14/23 14/25 21/9 35/9 dog's [1] 28/8
challenges [2] 33/8 33/9 cross-examination [4] 14/17 14/23 door [18]
chance [1] 33/7 14/25 21/9 doors [1] 12/17
check [1] 6/1 CRR [2] 2/11 35/24 drive [1] 16/2
CI [4] 31/11 31/14 31/17 31/23 curtilage [24] driver [2] 13/22 27/23
cigar [1] 9/18 customer [1] 24/20 drugs [1] 33/4
circum [1] 30/8 customer-owned [1] 24/20 Drummin [1] 5/5
circumstance [1] 30/17 Dunn [3] 25/23 26/8 26/11
D dwelling [1] 23/3
cite [1] 23/1
Date [1] 35/24
cited [1] 23/5 E
December [1] 27/9
cites [1] 25/16
decide [1] 20/10 east [2] 7/15 11/14
civil [10]
decided [2] 20/5 20/8 effectuate [1] 29/16
claimed [1] 26/2
decision [3] 19/24 19/25 25/23 electricity [2] 25/1 25/3
clear [4] 12/8 14/4 17/12 21/19
default [1] 24/8 enclosure [2] 7/7 26/4
client [3] 19/3 19/8 20/25
defendant [4] 1/10 2/8 3/19 27/1 enter [1] 31/6
close [2] 13/17 13/20
defendant's [1] 14/6 entitled [2] 31/15 35/22
closer [1] 13/11
defense [6] 25/16 25/20 26/10 31/8 entrance [2] 16/20 17/21
Code [1] 35/20
31/13 33/21 entry [4] 9/7 11/23 12/1 13/24
Cohn [4] 33/22 33/22 34/5 34/7
defense's [1] 26/15 Esq [1] 2/8
Cohn's [1] 33/25
definition [1] 26/10 essence [1] 27/21
Collins [1] 22/13
delapidated [1] 25/8 et [1] 24/2
colloquy [1] 19/5
DELSON [11] et cetera [1] 24/2
Combs [5] 5/5 5/6 8/5 17/6 17/22
Delson's [1] 7/9 evening [1] 33/12
commercial [3] 24/22 27/5 27/12
demarcated [1] 6/9 evidence [11]
committed [1] 29/7
denied [2] 20/6 30/23 examination [6] 4/11 14/17 14/23
compartment [1] 13/22
deny [3] 20/11 30/24 31/5 14/25 17/10 21/9
compel [1] 31/23
depict [1] 11/15 exception [2] 23/19 28/17
complain [1] 20/7
deploy [1] 8/5 exclude [1] 25/14
composite [1] 10/19
Describe [2] 6/12 7/12 exclusively [1] 24/19
computer [1] 1/24
design [2] 30/14 30/15 excuse [3] 5/16 19/9 32/9
concede [3] 23/21 23/22 24/2
despite [1] 6/16 excused [3] 18/18 18/20 32/20
concept [1] 26/20
detect [2] 8/8 18/5 executed [1] 3/19
conclude [1] 24/11
detecting [2] 8/8 18/4 exhibit [15]
concluded [1] 35/1
detective [8] Exhibit 1 [2] 3/23 24/17
concrete [1] 6/14
Detective Combs [1] 8/5 Exhibit 2 [1] 8/14
condition [2] 7/12 25/11
Detective Corey [2] 4/3 4/10 Exhibit 3 [2] 10/5 10/12
conduct [2] 5/18 9/5
Detective Drummin [1] 5/5 Exhibit 4A [1] 10/19
conducted [2] 27/4 27/5
Detective Hermanson [1] 9/12 EXHIBITS [2] 35/12 35/13
conducting [2] 4/22 5/10
detectives [2] 23/13 23/13 exited [1] 34/25
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 38 of 41
38
E grant [1] 31/22 intrusion [1] 27/3
granted [4] 20/13 21/2 21/25 24/1 invasive [1] 28/8
expectation [3] 24/6 27/6 29/11
grass [1] 7/17 investigation [5] 4/23 5/10 9/5 16/11
expired [1] 16/8
gray [1] 30/1 16/16
exposed [1] 7/4
green [7] 9/15 9/16 12/18 12/18 13/11 investiture [1] 33/23
express [1] 30/9
13/14 13/17 items [7] 7/3 9/16 9/23 13/15 15/23
exterior [5] 7/12 7/23 10/16 18/14
growing [1] 7/17 15/24 31/14
18/15
F H J
half [1] 34/6 Jardines [3] 25/16 28/9 28/13
facility [3] 5/2 5/18 33/13
hand [2] 4/4 20/10 John [2] 2/5 3/7
facing [1] 11/14
handgun [1] 9/17 judge [25]
fact [1] 31/11
handle [2] 16/25 32/21 Judge Cohn [4] 33/22 33/22 34/5 34/7
factor [1] 25/25
handler [1] 5/7 Judge Cohn's [1] 33/25
factors [1] 26/11
handlers [1] 31/18 July [6] 4/20 5/9 5/14 5/16 5/17 5/17
faith [4] 23/19 24/8 24/8 28/3
he'll [1] 33/13 July 12th [1] 5/17
Farms [1] 5/1
hear [3] 6/8 32/3 33/10 July 13th [4] 4/20 5/9 5/14 5/17
features [1] 6/10
heard [2] 17/23 20/12 junk [1] 25/8
filed [1] 31/8
Hearing [1] 1/13 jurors [2] 32/8 32/19
filled [1] 25/9
heart [1] 26/17 jury [6] 32/5 32/6 32/8 32/9 32/11
final [1] 18/3
hereby [1] 35/19 32/15
financial [1] 30/19
Hermanson [1] 9/12 justified [1] 30/5
finish [7] 32/10 32/13 32/24 33/24
heroin [1] 9/19
33/25 34/1 34/7 K
Highway [1] 2/6
finished [1] 34/5
history [1] 31/17 Kaya [13]
firearm [7] 9/17 9/21 12/18 13/12
holiday [1] 32/12 key [2] 23/5 23/5
13/18 25/12 33/4
home [14] keys [4] 15/3 15/5 15/10 15/12
firearms [2] 9/20 10/2
home's [1] 27/15 kitchen [1] 14/6
floor [2] 12/7 12/9
homeless [4] 29/13 29/14 30/3 30/10
FLORIDA [10]
homemade [1] 12/24 L
Florida vs. Jardines [1] 25/16 landlord [3] 15/16 21/25 21/25
Honor [17]
follow-up [3] 4/22 5/10 5/18 landlord's [1] 22/7
Honorable [1] 1/14
foot [1] 32/22 large [1] 30/20
hopefully [1] 32/10
foregoing [1] 35/20 Lastly [3] 26/24 27/17 28/1
hour [1] 34/6
forgot [1] 15/18 latex [1] 14/5
hours [1] 8/25
FORT [4] 1/3 1/7 2/10 2/13 LAUDERDALE [4] 1/3 1/7 2/10 2/13
house [2] 30/15 30/19
four-factor [1] 25/25 laundry [1] 31/13
housekeeping [1] 33/2
Fourth [2] 23/10 27/15 law [4] 19/19 21/2 22/23 23/5
hum [1] 20/1
Francine [3] 2/11 35/23 35/24 lawyer [2] 20/17 34/1
frantic [2] 17/25 21/12 I lawyer's [2] 19/19 34/8
free [2] 17/12 18/7 lawyers [2] 33/19 34/4
I'd [1] 25/20
FRIDAY [1] 2/15 lease [12]
I'll [5] 31/6 31/22 32/11 34/6 34/8
front [6] 8/21 10/12 11/19 11/19 12/6 leased [1] 22/9
I'm [13]
33/22 leasing [1] 27/21
I've [2] 33/3 33/20
Ft. [3] 33/21 33/25 34/8
identification [4] 3/21 8/17 10/8 10/22 legal [1] 19/20
Ft. Pierce [3] 33/21 33/25 34/8 Leon [2] 28/2 30/5
identified [2] 7/1 7/2
furthering [1] 9/5 letter [2] 33/3 34/13
immediately [3] 7/9 9/14 27/10
G impact [1] 32/14 license [3] 7/19 11/15 16/8
inclined [1] 26/14 life [1] 19/21
gain [2] 6/17 12/2
included [2] 9/17 26/3 lift [1] 22/15
gang [2] 4/19 4/20
including [2] 28/3 31/14 liking [1] 6/5
general [2] 9/10 17/1
increased [1] 29/11 limited [1] 26/21
gets [2] 26/17 32/22
indeed [1] 30/11 lines [1] 6/9
Gibbons [1] 2/8
INDEX [2] 35/6 35/12 list [1] 31/13
Giglio [2] 31/8 31/10
indicated [2] 17/2 32/1 lists [1] 27/18
gives [1] 19/20
indicating [2] 8/7 18/4 literally [1] 27/21
glorious [1] 30/19
indication [1] 8/2 location [3] 5/12 5/19 9/24
gloves [2] 13/1 14/5
information [1] 31/15 lousy [1] 20/6
good-faith [1] 23/19
initial [3] 10/1 12/1 15/22
gotta [1] 17/19
inquiry [1] 26/23 M
government [8] magazines [1] 9/19
inspection [2] 21/25 22/2
government's [21] magistrate [1] 30/5
instructions [1] 31/18
Government's 1 [1] 24/23 magistrate's [1] 33/23
interests [1] 31/21
Government's 2 [1] 8/21 main [2] 9/9 13/23
interior [1] 10/16
Government's 3 [1] 17/17 management [2] 6/1 7/2
intimately [1] 27/14
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 39 of 41
39
M O-L-I-V-E-R [1] 4/10 plate [4] 7/19 11/15 13/2 16/8
objection [2] 10/23 19/5 plea [6] 33/16 33/17 33/20 34/2 34/6
manager [5] 6/17 6/20 15/12 15/16
obligations [1] 31/11 34/9
22/1
observation [2] 26/6 26/13 point [4] 23/16 24/7 27/17 28/7
MARC [17]
observed [1] 17/22 pole [1] 16/10
Marc's [13]
occupation [1] 4/13 police [8]
marked [6] 3/20 6/9 8/16 10/7 10/21
odor [1] 8/8 Pompano [1] 33/13
35/13
odors [2] 18/4 28/12 portion [3] 12/16 16/14 27/13
material [1] 31/12
offer [1] 8/14 position [1] 31/9
materials [1] 14/3
offering [1] 3/18 pouch [2] 9/18 9/18
matter [3] 21/2 33/2 35/22
Office [4] 2/3 2/6 4/14 4/16 powder [1] 13/4
mean [4] 28/10 29/14 29/14 30/22
officer [2] 22/15 23/17 precautions [1] 26/12
Meaning [1] 16/4
officer's [1] 30/6 preference [1] 32/21
means [1] 27/21
officers [3] 28/2 29/20 30/9 premise [2] 24/19 26/8
meant [1] 30/15
Official [2] 2/11 35/24 premises [2] 27/12 27/13
mechanical [1] 1/24
Oh [3] 14/20 16/7 20/12 prepared [1] 23/21
meet [1] 26/11
Ohio [1] 30/23 present [2] 22/1 33/9
memo [1] 23/1
oil [1] 22/8 presume [3] 24/3 24/4 24/10
memory [1] 17/13
Oliver [4] 4/3 4/5 4/10 35/8 prevented [1] 24/16
metal [1] 14/3
one's [1] 22/3 pried [2] 15/8 15/9
mobile [1] 23/6
open [17] primary [1] 27/8
moment [3] 14/16 14/18 14/19
operate [1] 16/6 principle [1] 29/5
Monday [9]
order [2] 6/17 31/6 privacy [3] 24/6 27/6 29/12
Monday's [1] 32/12
overgrown [1] 7/14 probable [5] 21/17 21/18 22/11 28/23
monetary [1] 30/19
overnight [1] 24/5 29/6
morning [4] 3/8 3/9 3/10 32/3
owned [2] 21/23 24/20 proceed [1] 3/13
motion [11]
proceedings [3] 1/24 35/1 35/21
motorcycle [1] 22/14 P produced [1] 1/24
movable [3] 21/5 21/6 29/2
P.A [1] 2/8 propane [1] 25/4
move [3] 10/4 10/18 30/17
packaging [3] 12/25 13/3 14/3 property [4] 6/17 15/24 27/5 28/4
movement [1] 28/19
page [5] 17/16 18/6 24/18 24/23 35/7 proposed [1] 33/3
MR [2] 15/2 35/9
page 2 [2] 24/18 24/23 protect [2] 26/6 26/13
Mr. [21]
page 5 [2] 17/16 18/6 protection [1] 27/16
Mr. Buschel [5] 18/23 20/22 28/5
Palm [4] 2/4 2/7 4/14 4/15 prove [1] 21/22
31/19 33/7
paperwork [1] 15/18 provide [1] 15/12
Mr. Buschel's [1] 26/9
parked [1] 27/11 proximity [1] 26/2
Mr. Marc [10]
parking [5] 6/5 6/8 6/8 18/8 27/18 pry [2] 9/8 9/9
Mr. Marc's [5] 15/23 31/21 32/8 32/10
parks [1] 27/22 public [5] 5/20 5/22 5/24 6/16 7/5
32/19
Parnofiello [2] 2/5 3/7 purposes [1] 28/2
MS [7] 4/12 8/20 10/11 11/2 17/11
part [3] 16/15 26/20 27/2 pursuant [3] 16/11 28/9 35/19
35/8 35/9
partial [1] 12/20 pushed [2] 17/24 21/11
Ms. [2] 24/14 34/14
partially [1] 11/17
Ms. Tribuiani [2] 24/14 34/14 Q
pass [2] 25/20 33/4
N passing [2] 26/7 26/14 qualified [1] 27/11
payments [1] 31/17 qualifies [1] 26/1
name [4] 4/8 4/9 15/16 15/18
people [5] 6/1 24/9 26/6 26/14 30/15 question [2] 16/24 26/18
named [1] 5/2
Perilla [1] 26/16 questions [1] 33/1
narcotics [7] 12/19 13/12 13/18 14/4
periods [1] 30/16 quote [1] 16/20
16/25 16/25 28/11
permission [3] 6/17 6/20 28/18 quote/unquote [1] 16/20
nature [2] 25/8 26/4
permitted [1] 25/3
nine [5] 33/17 33/19 33/20 34/5 34/9 R
person [3] 29/13 30/3 30/10
nine o'clock [4] 33/19 33/20 34/5 34/9
person's [1] 29/15 raise [1] 4/4
normally [1] 32/11
persuasive [1] 31/3 ready [2] 3/13 32/4
north [1] 7/18
phonetic [1] 15/17 rear [1] 11/13
Northern [1] 30/23
photograph [7] 11/4 11/6 11/15 12/8 reasons [2] 19/16 21/2
nose [4] 17/2 17/24 18/2 21/11
12/10 12/13 12/16 rec [1] 12/5
notice [1] 27/19
photographs [3] 10/15 11/3 25/10 receipts [1] 31/17
November [2] 1/7 3/1
pick [2] 32/5 32/6 receive [2] 8/10 8/24
number [11]
picked [1] 32/18 received [5] 3/25 8/18 9/2 10/9 10/24
number 2 [1] 24/18
picking [1] 32/8 recently [1] 22/14
number 3 [1] 24/23
picture [2] 11/22 13/22 recess [2] 32/6 34/23
Numbers [1] 10/21
Pierce [3] 33/21 33/25 34/8 record [8]
O Plaintiff [1] 1/7 recorded [1] 1/24
plan [1] 32/7 recreational [15]
o'clock [4] 33/19 33/20 34/5 34/9
plants [1] 7/17 Redirect [3] 17/9 17/10 35/9
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 40 of 41
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R signed [2] 8/25 9/4 talking [2] 11/8 17/20
situation [2] 22/22 29/6 tank [1] 25/4
refresh [1] 17/13
sleep [4] 24/1 24/5 24/9 24/11 tarp [2] 22/15 22/16
relayed [1] 17/6
smell [4] 16/22 17/5 28/14 28/15 tax [1] 31/14
relevant [1] 31/12
smelling [2] 21/15 28/12 tell [2] 7/23 11/4
rely [1] 28/1
sniff [7] 16/17 16/23 17/14 18/10 21/3 telling [1] 34/4
relying [1] 30/6
21/18 28/9 tenant [4] 22/4 22/7 24/19 24/25
remember [1] 15/16
sniffed [3] 16/20 17/25 21/12 tender [1] 14/22
remnants [1] 32/17
sniffing [3] 17/21 18/7 18/13 terms [2] 9/10 24/16
repairs [5] 22/3 22/3 22/5 22/7 22/8
soda [1] 13/5 test [1] 25/25
Reporter [3] 2/11 2/11 35/24
someone's [1] 29/23 testified [2] 6/15 16/1
required [1] 6/1
soon [4] 9/12 9/23 12/2 31/6 testifies [1] 31/23
requirement [1] 23/19
south [1] 7/14 testify [7] 19/1 19/11 19/14 20/5 20/8
residence [13]
SOUTHERN [2] 1/2 31/1 20/11 31/11
resident [1] 26/6
space [5] 5/24 6/2 6/18 6/21 27/22 testifying [2] 19/17 20/20
residential [1] 24/21
spaces [3] 27/18 27/19 27/20 testimony [4] 20/13 21/5 26/11 27/1
residing [1] 24/17
spell [1] 4/8 Thank [10]
respiratory [1] 17/23
spot [1] 6/8 theory [1] 26/15
response [3] 16/5 17/15 18/3
spots [2] 6/9 18/8 think [12]
rest [2] 7/10 12/21
spun [1] 18/2 thinking [1] 23/14
rests [1] 18/22
standing [1] 21/22 thought [3] 14/20 22/24 23/17
result [1] 8/10
starting [1] 11/3 tied [1] 27/14
resume [1] 32/9
state [4] 2/6 4/8 8/10 23/13 till [1] 32/9
returns [1] 31/14
states [15] time [7] 5/4 5/5 8/14 8/24 10/4 20/16
Rinku [2] 2/2 3/7
States vs [1] 3/4 30/16
rise [1] 34/24
States vs. Dunn [1] 25/23 tires [1] 22/8
RMR [2] 2/11 35/24
States vs. Perilla [1] 26/16 Title [1] 35/20
RMR-CRR [1] 35/24
States vs. Wymer [1] 26/24 toiletries [1] 14/12
Road [1] 5/1
station [1] 12/25 top [4] 9/15 12/16 14/2 14/2
Robert [2] 2/8 3/10
statute [2] 23/2 23/9 tow [2] 6/18 6/21
rocks [1] 6/14
stay [1] 29/25 towards [3] 8/7 12/20 18/11
Room [1] 2/12
stenography [1] 1/24 tractor [1] 4/23
ruled [1] 22/14
step [1] 18/17 tractor-trailer [1] 4/23
RV [50]
steps [2] 26/5 26/12 traffic [2] 28/11 28/18
S stick [1] 32/18 trailer [2] 4/23 24/20
S.E [1] 2/9 stipulation [4] 3/17 8/13 10/5 10/20 trailers [8]
safe [1] 34/22 stop [3] 22/2 28/11 28/19 trained [2] 8/8 18/5
sales [1] 14/4 storage [6] 5/1 5/18 6/5 6/5 24/20 transcript [3] 1/13 1/24 35/21
Salopek [3] 2/11 35/23 35/24 25/11 transferred [1] 33/13
saw [1] 23/24 store [1] 25/12 trash [1] 12/9
scale [1] 14/5 stove [1] 14/8 trial [4] 31/11 32/2 32/13 33/21
school [1] 19/19 strategy [2] 19/16 20/19 Tribuiani [11]
search [40] structure [14] trips [1] 30/16
searching [2] 9/6 9/12 structures [2] 18/11 22/23 truck [1] 24/20
seats [1] 13/25 stuck [1] 19/25 true [1] 35/20
second [4] 10/5 10/14 17/16 17/18 stuff [1] 29/19 Tuesday [5] 32/9 32/10 32/13 34/9
Section [1] 35/19 substance [1] 13/3 34/17
selected [1] 32/15 sufficient [1] 31/20 Twelve [1] 4/17
sense [1] 29/11 suggesting [1] 22/9 Twelve years [1] 4/17
sentence [1] 18/6 Suite [2] 2/4 2/9
support [1] 21/19 U
settle [2] 34/21 34/22
suppress [9] U.S [1] 2/2
shed [3] 29/22 29/23 29/24
Supreme [3] 22/14 25/22 30/18 uhm [2] 9/5 13/22
shelf [3] 9/15 13/25 14/2
surrounding [8] Um [1] 20/1
shell [1] 6/14
suspected [6] 9/19 12/19 13/2 13/3 Um-hum [1] 20/1
Sheriff's [2] 4/14 4/15
13/12 13/18 umbrella [1] 27/15
shopping [2] 9/15 9/16
SWORN [1] 4/5 underlying [1] 26/8
short [1] 30/16
underneath [4] 12/25 22/15 22/16
shrubbery [1] 7/14 T 27/22
sic [1] 21/5
table [1] 12/24 understand [8]
side [6] 7/14 7/15 7/18 9/8 17/24
tag [1] 16/8 understands [3] 18/25 19/4 24/25
21/12
take [1] 34/8 uninhabitable [2] 23/25 24/11
sidebar [1] 33/8
taken [3] 10/16 12/10 26/5 uninhabited [1] 25/17
sides [1] 3/13
talk [3] 20/17 21/8 33/7 unique [1] 30/17
sign [1] 34/13
talked [2] 15/25 33/22 unit [2] 4/19 4/20
Case 9:18-cr-80153-WPD Document 239 Entered on FLSD Docket 07/21/2022 Page 41 of 41
41
U
Unite [1] 2/3
UNITED [12]
unknown [2] 13/2 13/3
unquote [1] 16/20
unrefutable [1] 21/5
up-close [1] 13/17
us [1] 11/4
utilized [2] 7/13 7/16
V
van [4] 11/7 18/2 21/14 21/16
vehicle [20]
vehicles [1] 6/6
verified [2] 7/2 15/23
versus [1] 29/12
view [6] 12/1 13/8 13/11 13/14 13/17
13/20
VIN [1] 7/21
violent [1] 4/19
vs. [4] 25/16 25/23 26/16 26/24
W
Wait [1] 17/19
walk [5] 5/24 9/14 12/2 12/6 15/19
walked [1] 6/2
warrant [27]
warrants [1] 28/4
water [4] 7/24 8/1 24/2 25/2
weapon [1] 9/20
week [3] 32/7 32/11 32/23
West [2] 2/4 2/7
white [10]
William [1] 1/14
window [2] 12/21 12/21
windows [1] 7/15
witness [7] 3/16 4/5 14/22 18/20
18/21 20/6 35/7
witnesses [2] 34/16 35/6
work [3] 4/14 4/19 16/1
WPD [1] 1/4
written [1] 31/6
Wymer [2] 26/24 27/9
Wymer's [1] 27/8
Y
yard [2] 6/18 6/21
you'd [1] 12/6
Z
zoned [1] 24/21
File and source
- File
- 239.pdf
- Size
- 205,139 bytes
- SHA-256
- 4679ebf5d59a471322b6eb48fae5817b415321d961ae60af314f3bb762b66de5
- Our copy
- 239.pdf
- Original
- No public link identified.