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United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 199: Hockridge's supplemental brief on excluding 'good act' evidence (June 9, 2025)

Summary

A supplemental brief of Defendant Stephanie Hockridge in opposition to the Government's motion in limine regarding “good acts” evidence, Document 199 in United States v. Stephanie Hockridge, No. 4:24-cr-00287-O, in the United States District Court for the Northern District of Texas, Fort Worth Division, filed June 9, 2025. The brief states that Hockridge plans to introduce evidence of specific acts under Rules 402, 404(b), and 406 to show good faith during the course of conduct the Government contends was a criminal conspiracy, not to prove character. It states that the Government alleges that VIPPP, a referral network led by Hockridge, was a manner and means of a conspiracy to solicit and facilitate fraudulent PPP loan applications. The signature block shows /s/ Richard E. Finneran as attorney for Defendant Stephanie Hockridge.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 199: Hockridge's supplemental brief on excluding 'good act' evidence (June 9, 2025).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-reis-and-hockridge-n-d-tex-no-4-24-cr-00287-o-doc-199-e602a99206/, SHA-256 447090e57968c24f7a881c8d772a1fa0a2145de9ade140698a2f0585bf301c81.

Full text

Case 4:24-cr-00287-O                       Document 199                   Filed 06/09/25               Page 1 of 14               PageID 2184



                                     IN THE UNITED STATES DISTRICT COURT
                                     FOR THE NORTHERN DISTRICT OF TEXAS
                                             FORT WORTH DIVISION

 UNITED STATES OF AMERICA,                                            §
                                                                      §
                         Plaintiff,                                   §
                                                                      §
 v.                                                                   §           Case No. 4:24 CR-00287-O
                                                                      §
 STEPHANIE HOCKRIDGE, a/k/a                                           §           (02)
 STEPHANIE REIS,                                                      §
                                                                      §
                         Defendant.                                   §

                   DEFENDANT STEPHANIE HOCKRIDGE’S
               SUPPLEMENTAL BRIEF IN OPPOSITION TO THE
      GOVERNMENT’S MOTION IN LIMINE REGARDING “GOOD ACTS” EVIDENCE


                                                           TABLE OF CONTENTS

 Table of Authorities ........................................................................................................................ ii
 Summary and Introduction ............................................................................................................. 3
 Discussion ....................................................................................................................................... 5
      I.   Fifth Circuit Law Does Not Prevent a Defendant Charged with Conspiracy from Offering
      Evidence, for a Non-Character Purpose, of “Other” Acts Performed During the Alleged
      Conspiracy ................................................................................................................................... 5
      II. Ms. Hockridge’s Evidence Is Not Offered to Prove Her Character; It Is Offered to
      Directly Refute Elements of the Charged Offenses..................................................................... 8
      III.   Ms. Hockridge Must Be Permitted to Rebut the Government’s Allegations of a
      Conspiracy and Scheme to Defraud .......................................................................................... 11




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Case 4:24-cr-00287-O                     Document 199                 Filed 06/09/25                Page 2 of 14              PageID 2185



                                                      TABLE OF AUTHORITIES

                                                                                                                                       Page(s)
 Cases

 United States v. Akers,
  7:19-cr-7-REW-BEA, 2019 WL 4934948 (E.D. Ky. Oct. 7, 2019) .................................. 8, 9, 12
 United States v. Ali,
  870 F. Supp. 2d 10 (D.D.C. 2012) ......................................................................................... 9, 12
 United States v. Grimm,
  568 F.2d 1136 (5th Cir. 1978) ................................................................................................. 7, 8
 United States v. Hayes,
  219 F. App’x (3d Cir. 2007) .................................................................................................. 8, 12
 United States v. Jackson,
  544 F. App’x 380 (5th Cir. 2013) .............................................................................................. 11
 United States v. Marrero,
  904 F.2d 251, 253–54 (5th Cir. 1990) ..................................................................................... 7, 8
 United States v. Nguyen,
  504 F.3d 561 (5th Cir. 2007) ..................................................................................................... 12
 United States v. Rubin/Chambers,
  828 F. Supp. 2d 698 (S.D.N.Y. 2011) ................................................................................... 9, 13
 United States v. Santos,
  201 F.3d 953 (7th Cir. 2000) ..................................................................................................... 12
 United States v. Spayd,
  2022 WL 4367621 (D. Ala. Sept. 20, 2022).......................................................................... 9, 12

 Rules

 Fed. R. Evid. 401 ...................................................................................................................... 6, 12
 Rule 404(b) ....................................................................................................................... 6. 7, 8, 11
 Rule 406 ............................................................................................................................ 6, 7, 8, 11




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                                   SUMMARY AND INTRODUCTION

         Ms. Hockridge, through her undersigned counsel, files this supplemental brief in further

 opposition to the Government’s motion in limine regarding so-called “good acts” evidence. See

 Mot. (Doc. #76). Ms. Hockridge thanks the Court for the opportunity to submit supplemental

 briefing on such a critical issue to her defense.

         Ms. Hockridge plans to introduce evidence of her specific acts under Rules 402, 404(b),

 and 406 not to prove her “good” or “law-abiding” character, but to show that she acted in good

 faith during the very course of conduct the Government contends was a criminal conspiracy. Ms.

 Hockridge plans to introduce that evidence to refute charges explicitly present on the face of the

 Superseding Indictment. The Government alleges that VIPPP, a referral network led by Ms.

 Hockridge, was itself a manner and means of a conspiracy to solicit and facilitate fraudulent PPP

 loan applications. Superseding Indictment (Doc. #163) ¶ 16(e). To rebut that charge, Ms.

 Hockridge intends to introduce evidence that she encouraged the staff at VIPPP to be vigilant in

 attempting to detect and prevent fraud, including paying bonuses for flagging suspicious loan

 applications. That evidence is admissible—not because it shows Ms. Hockridge is a person of

 “law-abiding” or “good” character—but because it directly rebuts the charge in the Superseding

 Indictment that she intentionally devised a plan to use VIPPP to further a fraudulent conspiracy.

 Indeed, as Ms. Hockridge will show, her implementation of multiple fraud-detection measures

 flatly contradicts that claim.

         Similarly, the Government has alleged that Ms. Hockridge conspired with Eric Karnezis to

 submit fraudulent loan applications through VIPPP, based almost entirely on a purported

 conversation where Ms. Hockridge allegedly instructed Mr. Karnezis on how to commit fraud. To

 rebut the claim that there was any such agreement with Mr. Karnezis, Ms. Hockridge intends to



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 offer evidence of how she handled applications submitted through Mr. Karnezis’s VIPPP referral

 channel—including rejecting numerous loans submitted by Mr. Karnezis that Ms. Hockridge

 suspected to be fraudulent.

        Again, that evidence is admissible, not to show her good character, but because it directly

 rebuts the Government’s claims that she entered a conspiracy or scheme with Mr. Karnezis, that

 she knew Mr. Karnezis was intentionally submitting fraudulent applications, or that she had any

 plan or intent to push through such fraudulent applications. The evidence makes a fact of enormous

 consequence—i.e. whether there was an unlawful agreement—far less likely, thereby making it

 plainly relevant evidence. Put simply, evidence that Ms. Hockridge rejected suspicious loans that

 were submitted through Mr. Karnezis’s channel is probative of whether Ms. Hockridge conspired

 with Mr. Karnezis to submit fraudulent loan applications. A reasonable jury could conclude that if

 there was a conspiracy, Ms. Hockridge would have pushed through loans she suspected were

 fraudulent, not rejected them. Importantly, no appeal to Ms. Hockridge’s “character” is necessary

 to draw such an inference.

        The Government has charged Ms. Hockridge with conspiracy to commit wire fraud from

 approximately April 2020 through May 2021. The Government alleges that Ms. Hockridge worked

 with several individuals to commit fraud. To support their argument, Ms. Hockridge anticipates

 that the Government’s case-in-chief will consist of a number of hand-picked loans and testimony

 by alleged coconspirators. Faced with such allegations, Ms. Hockridge is entitled to produce

 evidence that directly refutes their claims. To challenge the testimony of the alleged coconspirators,

 she is entitled to introduce evidence that is directly probative of her intent. Having charged Ms.

 Hockridge with conspiracy to commit wire fraud that allegedly lasted more than a year, the




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 Government cannot fairly seek to exclude evidence that shows that no conspiracy existed during

 that same time period.

           Denying Ms. Hockridge the right to introduce such evidence would be a gravely prejudicial

 error. The Government intends to introduce evidence of numerous loan applications not identified

 in the Superseding Indictment to establish the existence of a scheme and a conspiracy. Ms.

 Hockridge must be able to refute that claim by showing that the manner in which VIPPP operated

 was not consistent with any such scheme or conspiracy and, in fact, establishes that her intent was

 entirely to the contrary. 1 The jury must decide what weight to give the competing evidence.

 Otherwise, the jury will be told just one side of the story, without the context needed to assess

 whether the Government’s allegations of fraudulent intent are true or false.

                                             DISCUSSION

 I.       Fifth Circuit Law Does Not Prevent a Defendant Charged with Conspiracy from
          Offering Evidence, for a Non-Character Purpose, of “Other” Acts Performed During
          the Alleged Conspiracy

           Rules 404 and 405 prohibit a defendant from offering evidence of “other . . . act[s]” to

 prove or disprove her good character. But Ms. Hockridge does not seek to offer evidence regarding

 her management, supervision, and performance in the VIPPP program as evidence of her good

 character. She instead seeks to introduce it as evidence directly relevant to her lack of intent to




      1
         At this Court’s recent hearing, the Government seized upon Ms. Hockridge’s counsel’s use
 of the word “inconsistent” to describe the relevance of the “good acts” evidence the Government
 seeks to exclude. But Rules 404 and 405 prohibit evidence being used to show that the Defendant’s
 character is inconsistent with her being a criminal actor, not from its being used as direct evidence
 to show that her conduct in the particular circumstances of the case are inconsistent with the
 Government’s allegations of knowledge, intent, plan, conspiracy, and scheme. Indeed, that is the
 nature of all evidence presented by any defendant: to demonstrate that the evidence introduced in
 support of her defense is “inconsistent” with—and thereby creates a reasonable doubt regarding—
 the Government’s allegations.
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 commit fraud, which is expressly permitted under Federal Rules of Evidence 402, 404(b)(2), and

 406.

         Rule 404(b)(2) permits the introduction of “other . . . act[s]” evidence not as character

 evidence, but for any other admissible purpose, such as proving (or, in Ms. Hockridge’s case,

 disproving) plan, knowledge, and intent—each of which are elements of the charged offenses. See

 Proposed Instr. (Doc. #143) No. 37 (stating that a conspiracy charge requires proof that the

 defendant “knew” the unlawful purpose of the agreement and joined it “willfully” (emphasis

 added)); id. No. 40 (stating that the Government must prove that Ms. Hockridge “knowingly

 devised or intended to devise a scheme” (i.e., a plan) to defraud (emphasis added)). Likewise,

 Rule 406 permits the introduction of such evidence to establish Ms. Hockridge’s habit and routine

 practice of instructing her staff and affiliates on how to review applications and what to do when

 they suspected fraud. See Fed. R. Evid. 406.

         Such evidence is relevant and admissible because it makes multiple “fact[s] of consequence”

 more or less likely. Fed. R. Evid. 401(b). The evidence is probative of (1) whether Ms. Hockridge

 in fact had an agreement with any of her alleged coconspirators to commit fraud (she did not); (2)

 whether she devised a scheme to commit fraud through her supervision and operation of the VIPPP

 program (she did not); and (3) whether she joined any such agreement or scheme with knowledge

 of its illegal purpose (she did not).

         At its June 4, 2025 hearing, the Court questioned both parties on whether the Government’s

 cited authorities would preclude certain kinds of evidence that Ms. Hockridge might offer at trial

 regarding the manner in which she operated the very program that the Government claims was at

 the center of the conspiracy and scheme alleged in the Superseding Indictment. None of the

 Government’s cited authorities prevent Ms. Hockridge from introducing such exculpatory,



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 “other . . . act[s]” evidence not as character evidence, but for permissible reasons, including those

 outlined in Rule 404(b) and 406.

        In United States v. Marrero, for example, the defendant was charged not with conspiracy,

 but with presenting false claims to a government agency. 904 F.2d 251, 253–54 (5th Cir. 1990)

 (noting that Marrero was charged with “seventeen counts of presenting false claims to an agency

 of the United States and on twenty counts of theft of government property”). The defendant sought

 to introduce evidence under Rule 405 that she sometimes underbilled clients—not to disprove

 intent to join a conspiracy under Rule 404(b), since none was charged—but rather, under Rule 405,

 to “prove that her good character was inconsistent with criminal intent.” Id. at 21 (emphasis

 added). In other words, she sought to introduce such evidence as character evidence. The court

 held that such evidence is not admissible to prove character under “Rule 405(b)” (emphasis added);

 it did not address whether “other . . . act[s]” evidence is admissible under Rule 404(b) to disprove

 criminal intent, a scheme or plan, the defendant’s knowledge, or conspiratorial agreement. Id. at

 260.

        In United States v. Grimm (a 47-year-old, two-page opinion), a case about fraudulent bank

 drafts, the defendant sought to introduce evidence of non-fraudulent drafts. 568 F.2d 1136, 1138

 (5th Cir. 1978). The Fifth Circuit held that the trial court had discretion to exclude that evidence

 because it was “cumulative of . . . undisputed testimony that [a defendant] had paid other drafts”—

 meaning that the trial court had already admitted “other . . . act[s]” evidence that tended to rebut

 the Government’s charges. Id. at 1138 (emphasis added). The court also held that evidence of

 noncriminal conduct is “generally” irrelevant to negate an inference of criminal conduct. Id. But

 that means only that a good act does not erase a bad act, which Ms. Hockridge does not dispute.




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        This case is fundamentally different from Marrero and Grimm. Unlike in Marrero, Ms.

 Hockridge does not seek to introduce character evidence under Rule 405 to prove her good

 character. Marrero, 904 F.2d at 259. She instead seeks to introduce “other . . . act[s]” evidence

 under Rules 402, 404(b), and 406—i.e, evidence of her direct efforts to detect and prevent fraud,

 and evidence of rejections of fraudulent loan applications—for the permissible purpose of showing

 that she did not intend to join a criminal conspiracy and did not plan a scheme to defraud.

        Further distinguishing Grimm, this is not a case where Ms. Hockridge seeks to introduce

 evidence that is overly cumulative of other admitted evidence; indeed, the Government seeks to

 exclude such evidence altogether. Cf. Grimm, 568 F.2d at 1138 (excluding evidence because it

 was “simply cumulative” and risked “confus[ing] the jury”). Nor is this a case where Ms.

 Hockridge is simply arguing that one good act (like a good loan) negates another bad act (like a

 bad loan)—or even in which she is pointing to evidence “of prior non-criminal acts [] to

 demonstrate that [she] did not act criminally on an unrelated occasion.” United States v. Akers, No.

 7:19-cr-7-REW-BEA, 2019 WL 4934948, at *9 (E.D. Ky. Oct. 7, 2019). Instead, Ms. Hockridge

 seeks to introduce evidence that directly refutes allegations that she knowingly and intentionally

 joined a criminal scheme or conspiracy. See id. (holding that, though non-criminal acts are not

 admissible to show a general “propensity for legality,” non-criminal acts are admissible to show

 an “overall course of” conduct relevant to rebut allegations of a conspiracy).

 II.   Ms. Hockridge’s Evidence Is Not Offered to Prove Her Character; It Is Offered to
       Directly Refute Elements of the Charged Offenses

        As explained above, evidence of specific “other . . . act[s]” is admissible under Rule 404(b)

 to disprove an intent to join a criminal conspiracy. See, e.g., United States v. Hayes, 219 F. App’x

 219, 117 (3d Cir. 2007) (evidence was admissible when it was “not offered to prove [the

 defendant’s] character” but instead “to show that [the defendant’s] actions were inconsistent with


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Case 4:24-cr-00287-O          Document 199         Filed 06/09/25       Page 9 of 14       PageID 2192



 conspiring to fabricate test results” (emphasis added)); Akers, 2019 WL 4934948, at *9 (“[T]o

 the extent the Government’s theory of the conspiracy rests on a common pattern of illicit

 prescribing . . . Akers may present evidence regarding his care of the relevant patient class in order

 to present a full picture of the care he provided to this class of patients.”); United States v. Ali, 870

 F. Supp. 2d 10, 22 (D.D.C. 2012) (“The Court further concludes that although this evidence

 pertains to Ali’s ‘other act[s],’ it is nonetheless ‘admissible’ for the ‘purpose’ of negating the

 government’s showing of Ali’s ‘intent.’”); United States v. Rubin/Chambers, 828 F. Supp. 2d 698,

 708 (S.D.N.Y. 2011) (“If an Uncharged Transaction shared the same objective characteristics as

 an Overt Act Transaction, but the bidding outcome differed, the Uncharged Transaction could be

 relevant to undermine the Government’s position that Defendants possessed the intent to

 manipulate the bidding process.”); cf. United States v. Spayd, No. 3:19-cr-0111-JMK, 2022 WL

 4367621, at *2 (D. Ala. Sept. 20, 2022) (“Specific acts of Ms. Spayd’s good conduct therefore is

 relevant to rebut the proposition that Ms. Spayd maintained her practice for the purpose of illegally

 distributing drugs.”). Here, Ms. Hockridge plans to introduce contemporaneous communications

 and other evidence that directly refute the Government’s allegations that she intended to join a

 conspiracy and planned a scheme to solicit and facilitate fraudulent PPP loan applications. Two

 examples demonstrate the point.

         The first example involves Eric and Anthony Karnezis, alleged coconspirators who have

 pleaded guilty to submitting fraudulent PPP loan applications, and whom the Government intends

 to call at trial. The Karnezises submitted almost 200 fraudulent loan applications from one of their

 referral agents, who (unbeknownst to Ms. Hockridge) was using the false name “Rick Diamond.”

 A contemporaneous communication shows that, as Ms. Hockridge had instructed him to do, one

 of her VIPPP team members flagged those applications as potentially fraudulent:



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        Rob: “Hey Stephanie, Talked with Andrew yesterday and he said I should bring
        this up to you. Nearly every single one of the remaining unassigned loans are from
        [Eric and Anthony Karnezis] – and they are all California sole props with between
        9 and 13 employees, every single one of them with a payroll between $625k and
        $695k (often either $644 or $674), and some of them with multiple names on
        payroll that have applied for a lot of their own, also almost identical loans. . . .”

 Ex. A (message from R. Warzel to S. Hockridge). Rather than wave the suspicious applications

 through, Ms. Hockridge then investigated the situation and, as a result, caused the applications to

 be withdrawn. See Ex. B (“Team: The ‘Rick Diamond Situation’ has been resolved in Salesforce.

 The flagged applications have been marked as ‘Withdrawn.’”). The evidence also demonstrates

 that Mr. Karnezis lied to the VIPPP team about his knowledge of the falsehoods in those

 applications, falsely asserting that he did not want to have anything to do with Rick Diamond:

        Eric: “Withdraw anything related to Rick diamond. I don’t want anything to do with
        fraudsters. / If they are legit that’s too bad… they should have chosen better friends”
        Rob: “Haha Fair enough. Gilda and Kenneth Ramcharan being withdrawn.”
        Eric: “I hate losing money but I feel like it’s prudent of us to stay away from that energy”

 Ex. C (messages between E. Karnezis and R. Warzel) at 2. This evidence, which directly bears on

 the existence of the conspiracy alleged in the Superseding Indictment, is not character evidence

 about Ms. Hockridge. It is direct evidence contradicting the Government’s allegations of a

 conspiracy between Ms. Hockridge and the Karnezises to facilitate fraudulent PPP loans.2

        In another instance, suspicions were raised regarding a number of loan applications

 submitted through Blueacorn by an individual named Z.S. To separate the fraudulent applications

 from the genuine ones, Blueacorn called in Ms. Hockridge to review the 350 potentially fraudulent

 applications that had been placed on hold. For those submitted by Z.S., Blueacorn and Ms.

 Hockridge developed a plan to “require [the applicants] to provide additional documents & []

 handle each on a case-by-case” basis. See Ex. D (email from A. Frank regarding process for


    2
       This particular instance is also admissible for the separate purpose of impeaching Mr.
 Karnezis’s testimony regarding the existence of a conspiracy between him and Ms. Hockridge.
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 addressing suspicious loan applications) at 2. Again, this is not mere character evidence. This is

 evidence rebutting the charge in the Superseding Indictment that Blueacorn was an instrument of

 a fraudulent conspiracy. Superseding Indictment (Doc. #163) ¶¶ 16(b), (d).

        There are many such examples of Ms. Hockridge identifying suspicious applications and

 providing correct advice (or at least, advice she believed in good faith to be correct) to borrowers

 as to what they could and could not do in order to qualify for a loan under the PPP. Taken together,

 those examples dwarf the Government’s evidence of any knowing scheme or conspiracy

 participated in by Ms. Hockridge, nearly all of which is circumstantial and based on insinuation.

 Ms. Hockridge must have the ability to refute those claims—not by proving that she is a person of

 “good” or “law-abiding” character—but by showing the jury that she engaged in conduct that

 contradicts the Government’s allegation that she knowingly and intentionally entered into the

 conspiracy and scheme alleged in the Superseding Indictment.

 III.   Ms. Hockridge Must Be Permitted to Rebut the Government’s Allegations of a
        Conspiracy and Scheme to Defraud

        Ms. Hockridge anticipates that the Government will introduce evidence of a group of

 fraudulent loan applications that were submitted through VIPPP or Blueacorn—including loans

 not alleged in the Superseding Indictment—in order to prove the existence of a fraudulent scheme

 and conspiracy. As courts uniformly recognize, such evidence is admissible, not because it is

 evidence of Ms. Hockridge’s character, but because it is direct evidence of the existence of a

 scheme or conspiracy, and is thereby admissible. See, e.g., United States v. Jackson, 544 F. App’x

 380, 383 (5th Cir. 2013) (“Jackson also argues that the district court erred in permitting the

 introduction of evidence of other similar crimes that occurred prior to the dates alleged in the

 indictment, in violation of Federal Rule of Evidence 404(b). Because the evidence established that

 the conspiracy continued through the time stated in the indictment, the district court did not err in


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 admitting it.”); United States v. Nguyen, 504 F.3d 561, 574 (5th Cir. 2007) (holding that evidence

 relating to two fraudulent property transactions that were not charged in the indictment was

 relevant to defendant’s knowledge and intent in engaging in the similar property transactions

 charged in the indictment).

         What’s good for the goose is good for the gander. If the Government is permitted to

 introduce evidence of Ms. Hockridge’s purported “other acts” to prove that a conspiracy and

 scheme existed, then she is entitled to introduce evidence of her “other acts” during the same period

 and under the same program to dispute the Government’s allegations. Spayd, 2022 WL 4367621,

 at *2 (“The Government may not seek to introduce prior bad acts evidence with the argument that

 it tends to prove the continuous nature of Count 10, while simultaneously seeking to preclude Ms.

 Spayd from offering prior good act evidence to undermine this theory of guilt.”); Akers, 2019 WL

 4934948, at *9 (“[T]o the extent the Government’s theory of the conspiracy rests on a common

 pattern of illicit prescribing . . . Akers may present evidence regarding his care of the relevant

 patient class in order to present a full picture of the care he provided to this class of patients.”); see

 generally United States v. Santos, 201 F.3d 953, 962 (7th Cir. 2000) (Posner, J.) (“[I]t is improper

 to prevent a party from countering possibly false testimony favorable to his opponent even if that

 testimony should not have been admitted.”). And like the Government, she is not using such

 evidence to prove her character, but because it is direct evidence that tends to make the existence

 of a scheme or conspiracy less likely. See Fed R. Evid. 401(b). See Hayes, 219 F. App’x at 117

 (“The government introduced specific instances of Hayes pressuring employees to ignore company

 policy and fabricate test results. The evidence Hayes wanted to introduce is no less relevant merely

 because it is exculpatory and undermines Hayes’s participation in the alleged conspiracy.”); Ali,

 870 F. Supp. 2d at 22 (“The Court further concludes that although this evidence pertains to Ali’s



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 ‘other act[s],’ it is nonetheless ‘admissible’ for the ‘purpose’ of negating the government’s

 showing of Ali’s ‘intent.’”); Rubin/Chambers, 828 F. Supp. 2d at 708. Simply put, if bad loans

 tend to prove the existence of a conspiracy, then specific actions taken to prevent bad loans tend

 to disprove it. That makes them admissible, relevant evidence under Rules 402, 404(b), and 406.

                                            CONCLUSION

        Acceding to the Government’s request would work a grave injustice. The Government has

 charged Ms. Hockridge with a wide-ranging conspiracy to solicit and facilitate fraudulent PPP

 loan applications. Although it has unfairly attempted to confine its proof at trial to only a handful

 of loans in order to limit Ms. Hockridge’s ability to put on evidence of her good faith, the charges

 in the Superseding Indictment are not nearly so narrow. By excluding powerful evidence of her

 good faith from the jury’s consideration, the Government evidently hopes to convince the jury of

 Ms. Hockridge’s guilt by depriving them of the needed context to understand both the framework

 of the PPP and the significant efforts she made to root out fraud when suspicions were raised. That

 is not evidence of her good character; it is direct evidence of her lack of fraudulent intent, lack of

 knowledge, and lack of plan to commit fraud, all of which tend to make the existence of any

 conspiracy or scheme substantially less likely. Such evidence is therefore plainly relevant and must

 be admitted for those non-character purposes. Any other ruling would unfairly handicap Ms.

 Hockridge’s ability to defend herself against the Government’s serious charges.




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   Dated: June 9, 2025                           Respectfully submitted,

                                                 BRYAN CAVE LEIGHTON PAISNER LLP

                                                 /s/ Richard E. Finneran
                                                 RICHARD E. FINNERAN
                                                 211 North Broadway, Suite 3600
                                                 St. Louis, Missouri 63102
                                                 Tel: (314) 259-2000
                                                 Fax: (314) 259-2020
                                                 richard.finneran@bryancave.com

                                                 Attorneys for Defendant Stephanie Hockridge

                                                 GALLIAN FIRM

                                                 /s/ Gregg Gallian
                                                 Gregg Gallian, TX Bar: 24085952
                                                 3500 Maple Avenue, Suite 1150
                                                 Dallas, Texas 75219
                                                 Tel: (214) 432-8860
                                                 Fax: (972) 433-5835
                                                 gregg@gallianfirm.com

                                                 Attorneys for Defendant Stephanie Hockridge




                                 CERTIFICATE OF SERVICE

        I hereby certify that a true and correct copy of the foregoing document was served on all
 counsel of record by operation of the Court’s CM/ECF system.


                                                     /s/ Richard Finneran
                                                     RICHARD E. FINNERAN




                                                14


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