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Home Source documents United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 222: Jury charge (Hockridge trial) (2025-06-20)

United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 222: Jury charge (Hockridge trial) (2025-06-20)

Summary

The court's jury charge, Document 222 in United States of America v. Stephanie Hockridge, a/k/a Stephanie Reis, Case No. 4:24-cr-00287-O (N.D. Tex., Fort Worth Division), filed 06/20/25. It instructs jurors on the presumption of innocence, the government's burden of proof beyond a reasonable doubt, direct and circumstantial evidence, and witness credibility. The charge states that witnesses Flores and Karnezis were convicted of conspiracy to commit wire fraud, and that testimony of alleged accomplices who entered plea agreements must be weighed with greater care and caution. It also covers opinion testimony from David Abshier concerning the PPP Program and when a statement is "material". The charge is signed June 20, 2025.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 222: Jury charge (Hockridge trial) (2025-06-20).” Original at storage.courtlistener.com. 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-222-176af2b985/, SHA-256 d065584ad0a924dcfe07473a092cb321ac50f4383f29423d0659191cb4ca1782.

Full text

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/ Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Pagelof21 PagelD 2508
/

IN THE UNITED STATES DISTRICT COURT.

FOR THE NORTHERN DISTRICT OF TEXAS,,,0 52588 T COURT vas
FORT WORTH DIVISION | FILL
UNITED STATES OF AMERICA, § j POMS
Plaintiff, § Bienen
§
V. § Case No. 4:24 CR-00287-O
§
STEPHANIE HOCKRIDGE, a/k/a § (02)
STEPHANIE REIS, §
§
Defendants. §
JURY CHARGE
Members of the Jury:

In any jury trial there are, in effect, two judges. I am one of the judges; the other is
the jury. It is my duty to preside over the trial and to decide what evidence is proper for
your consideration. It is also my duty at the end of the trial to explain to you the rules of
law that you must follow and apply in arriving at your verdict.

First, I will give you some general instructions which apply in every case, for
example, instructions about burden of proof and how to judge the believability of
witnesses. Then I will give you some specific rules of law about this particular case, and
finally I will explain to you the procedures you should follow in your deliberations.

You, as jurors, are the judges of the facts. But in determining what actually
happened—that is, in reaching your decision as to the facts—it is your sworn duty to follow

all of the rules of law as I explain them to you.
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page2of21 PagelD 2509

You have no right to disregard or give special attention to any one instruction, or to
question the wisdom or correctness of any rule I may state to you. You must not substitute
or follow your own notion or opinion as to what the law is or ought to be. It is your duty to
apply the law as I explain it to you, regardless of the consequences.

It is also your duty to base your verdict solely upon the evidence, without prejudice
or sympathy. That was the promise you made and the oath you took before being accepted
by the parties as jurors, and they have the right to expect nothing less.

The indictment or formal charge against a defendant is not evidence of guilt.
Indeed, the defendant is presumed by the law to be innocent. The defendant begins
with a clean slate. The law does not require a defendant to prove her innocence or
produce any evidence at all and no inference whatsoever may be drawn from the election
of a defendant not to testify.

The government has the burden of proving the defendant guilty beyond a
reasonable doubt, and if it fails to do so, you must acquit the defendant. While the
government’s burden of proof is a strict or heavy burden, it is not necessary that the
defendant’s guilt be proved beyond all possible doubt. It is only required that the
government’s proof exclude any “reasonable doubt” concerning the defendant’s guilt.

A “reasonable doubt” is a doubt based upon reason and common sense after careful
and impartial consideration of all the evidence in the case. Proof beyond a reasonable
doubt, therefore, is proof of such a convincing character that you would be willing to

rely and act upon it without hesitation in making the most important decisions of your own

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affairs.

As I told you earlier, it is your duty to determine the facts. To do so, you must
consider only the evidence presented during the trial. Evidence is the sworn
testimony of the witnesses, including stipulations, and the exhibits. The questions,
statements, objections, and arguments made by the lawyers are not evidence.

The function of the lawyers is to point out those things that are most significant
or most helpful to their side of the case, and in so doing to call your attention to certain
facts or inferences that might otherwise escape your notice. In the final analysis,
however, it is your own recollection and interpretation of the evidence that controls in
the case. What the lawyers say is not binding upon you.

During the trial I sustained objections to certain questions and exhibits. You
must disregard those questions and exhibits entirely. Do not speculate as to what the
witness would have said if permitted to answer the question or as to the contents of an
exhibit. Also, certain testimony or other evidence has been ordered removed or redacted
from the record and you have been instructed to disregard this evidence. Do not consider
any testimony or other evidence which has been removed from your consideration
in reaching your decision. Further, do not speculate about what information, if any, has
been redacted from exhibits admitted into evidence during trial. Your verdict must be
based solely on the legally admissible evidence and testimony.

Also, do not assume from anything I may have done or said during the trial that I

have any opinion concerning any of the issues in this case. Except for the instructions to

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you on the law, you should disregard anything I may have said during the trial in
arriving at your own verdict.

In considering the evidence, you are permitted to draw such reasonable inferences
from the testimony and exhibits as you feel are justified in the light of common experience.
In other words, you may make deductions and reach conclusions that reason and common
sense lead you to draw from the facts which have been established by the evidence.

Do not be concerned about whether evidence is “direct evidence” or “circumstantial
evidence.” You should consider and weigh all of the evidence that was presented to you.

“Direct evidence” is the testimony of one who asserts actual knowledge of a fact,
such as an eyewitness. “Circumstantial evidence” is proof of a chain of events and
circumstances indicating that something is or is not a fact.

The law makes no distinction between the weights to be given either direct or
circumstantial evidence. But the law requires that you, after weighing all of the evidence,
whether direct or circumstantial, be convinced of the guilt of the defendant beyond a
reasonable doubt before you can find her guilty.

I remind you that it is your job to decide whether the government has proved the
guilt of the defendant beyond a reasonable doubt. In doing so, you must consider all of the
evidence. This does not mean, however, that you must accept all of the evidence as true or
accurate.

You are the sole judges of the credibility or “believability” of each witness and the

weight to be given to the witness’s testimony. An important part of your job will be making

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judgments about the testimony of the witnesses who testified in this case. You should
decide whether you believe all, some part, or none of what each person had to say, and how
important that testimony was. In making that decision I suggest that you ask yourself a few
questions: Did the witness impress you as honest? Did the witness have any particular
reason not to tell the truth? Did the witness have a personal interest in the outcome of the
case or their own case? Did the witness have any relationship with either the government
or the defense? Did the witness seem to have a good memory? Did the witness clearly see
or hear the things about which he or she testified? Did the witness have the opportunity
and ability to understand the questions clearly and answer them directly? Did the witness’s
testimony differ from the testimony of other witnesses? These are a few of the
considerations that will help you determine the accuracy of what each witness said.

Your job is to think about the testimony of each witness you have heard and decide
how much you believe of what each witness had to say. In making up your mind and
reaching a verdict, do not make any decisions simply because there were more witnesses
on one side than on the other. Do not reach a conclusion on a particular point just because
there were more witnesses testifying for one side on that point. You will always bear in
mind that the law never imposes upon a defendant in a criminal case the burden or duty of
calling any witnesses or producing any evidence.

The testimony of a witness may be discredited by showing that the witness testified

falsely, or by evidence that at some other time the witness said or did something, or failed
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page6of21 PagelD 2513

to say or do something, which is inconsistent with the testimony the witness gave at this

trial.

Earlier statements of a witness were not admitted in evidence to prove that the
contents of those statements are true. You may not consider the earlier statements to prove
that the content of an earlier statement is true; you may only use earlier statements to
determine whether you think the earlier statements are consistent or inconsistent with the
trial testimony of the witness and therefore whether they affect the credibility of that
witness,

If you believe that a witness has been discredited in this manner, it is your exclusive
right to give the testimony of that witness whatever weight you think it deserves, or no
weight at all.

You have been told that witnesses Flores and Karnezis were convicted of conspiracy
to commit wire fraud. A conviction is a factor you may consider in deciding whether to
believe that witness, but it does not necessarily destroy the witness’s credibility. It has been
brought to your attention only because you may wish to consider it when you decide

whether you believe the witness’s testimony. It is not evidence of anything else.

The testimony of an alleged accomplice, and/or the testimony of one who provides
evidence against a defendant, for immunity from or reduction in punishment, or for
personal advantage or vindication, must always be examined and weighed by the jury with

greater care and caution than the testimony of ordinary witnesses. You, the jury, must
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page7of21 PagelD 2514

decide whether the witness’s testimony has been affected by these circumstances, by the
witness’s interest in the outcome of the case, by prejudice against the defendant, or by the
benefits that the witness has received or may expect or hope to receive, either financially
or as a result of being immunized from prosecution or having their own punishment
reduced. You should keep in mind that such testimony is always to be received with caution

and weighed with great care.

You should not convict any defendant upon the unsupported testimony of such a

witness unless you believe that testimony beyond a reasonable doubt.

In this case the government called as witnesses multiple alleged accomplices, with
whom the government has entered into plea agreements. These agreements provide that the
witnesses would each be charged with one count of conspiracy to commit wire fraud and
that the government would not bring any additional charges for conduct underlying and
relating to that conspiracy. In the case of Eric Karnezis and Jimmy Flores, the agreements
included a nonbinding recommendation to the judge to reduce their sentence. Such plea
bargaining, as it is called, has been approved as lawful and proper, and is expressly
provided for in the rules of this court.

An alleged accomplice, including one who has entered into a plea agreement with
the government, is not prohibited from testifying. On the contrary, the testimony of such a
witness may alone be of sufficient weight to sustain a verdict of guilty. You should keep

in mind that such testimony is always to be received with caution and weighed with great
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page8of21 PagelD 2515

care. You should never convict a defendant upon the unsupported testimony of an alleged
accomplice unless you believe that testimony beyond a reasonable doubt.
The fact that an accomplice has entered a plea of guilty to a similar offense is not

evidence of the guilt of any other person.

You should never convict any defendant upon the unsupported testimony of such a
witness unless you believe that testimony beyond a reasonable doubt.

During the trial you heard the testimony of David Abshier, who expressed opinions
concerning the PPP Program. If scientific, technical, or other specialized knowledge might
assist the jury in understanding the evidence or in determining a fact in issue, a witness
qualified by knowledge, skill, experience, training, or education may testify and state an
opinion concerning such matters,

Merely because such a witness has expressed an opinion does not mean, however,
that you must accept this opinion. You should judge such testimony like any other
testimony. You may accept it or reject it and give it as much weight as you think it deserves,
considering the witness’s education and experience, the soundness of the reasons given for

the opinion, and all other evidence in the case.

You will note that the Indictment charges that the offenses were committed “on or
about” or “in or about” a specified date. The government does not have to prove that the
crime was committed on that exact date, so long as the government proves beyond a

reasonable doubt that the defendant committed each crime on a date reasonably near the
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page9of21 PagelD 2516

date stated in the indictment.

You are here to decide whether the government has proved beyond a reasonable
doubt that the defendant is guilty of the crimes charged. The defendant is not on trial for
any act, conduct, or offense not alleged in the indictment. Neither are you called upon to
return a verdict as to the guilt of any other person or persons not on trial as a defendant in
this case.

Ifa defendant is found guilty, it will be my duty to decide what the punishment will
be. You should not be concerned with punishment in any way. It should not enter your
consideration or discussion.

A separate crime is charged in each count of the indictment. Each count, and the
evidence pertaining to it, should be considered separately. If you find the defendant guilty
or not guilty as to one of the crimes charged, that should not control your verdict as to any

other.

As used in these instructions, a representation or statement is “material” if it has a
natural tendency to influence, or is capable of influencing, the decision of the person or
entity to which it is addressed. The Government can prove materiality in either of two
ways. First, a representation or statement is “material” if a reasonable person would attach
importance to its existence or nonexistence in determining his choice of action in the

transaction in question. Second, a statement could be material, even though only an
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page10of21 PagelD 2517

unreasonable person would rely on it, if the person who made the statement knew or had
reason to know his victim was likely to rely on it.

In determining materiality, you should consider that naivety, carelessness,
negligence, or stupidity of a victim does not excuse criminal conduct, if any, on the part of
the defendant.

The word “knowingly,” as that term has been used from time to time in these
instructions, means that the act was done voluntarily and intentionally, not because of
mistake or accident.

You may find that a defendant had knowledge of a fact if you find that the defendant
deliberately closed her eyes to what would otherwise have been obvious to her. While
knowledge on the part of the defendant cannot be established merely by demonstrating that
the defendant was negligent, careless, or foolish, knowledge can be inferred if the
defendant deliberately blinded herself to the existence of a fact.

One of the issues in this case is whether the Defendant acted in good faith. Good
faith is a complete defense to the crime of wire fraud if the defendant did not act with the
intent to defraud, which is an element of the charge. The essence of the good faith defense
is that one who acts with honest intentions cannot be convicted of a crime requiring
fraudulent intent. The phrase ‘good faith’ includes, among other things, an opinion or belief
honestly held, even if the opinion is in error or the belief is mistaken. However, even though
a defendant held a certain opinion or belief, a defendant does not act in good faith if he or

she also knowingly made false or fraudulent representations or promises or otherwise acted

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with the intent to defraud or deceive another.

You have heard testimony in this case regarding various rules, regulations, and
guidance issued by the Small Business Administration, or “SBA,” under the Paycheck
Protection Program, or “PPP,” namely, related to the program’s purpose, loan
requirements, and how loan proceeds are disbursed. You have also heard testimony of
various tax laws and documents.

Ms. Hockridge is charged with conspiracy to commit wire fraud and wire fraud. She
is not charged in this case with violating any SBA rules, regulations, or guidance. She is
also not charged with violating any tax laws. It is your duty to determine if the government

has established her guilt to the crimes charged, not to any other matter.

The government has introduced audio recordings that have an accompanying
transcript of the oral conversation which can be heard on the audio recordings received in
evidence. The transcript also purports to identify the speakers engaged in such
conversation.

I have admitted the transcript for the limited and secondary purpose of aiding you
in following the content of the conversation as you listen to the tape recording, and also to
aid you in identifying the speakers.

You are specifically instructed that whether the transcript correctly or incorrectly
reflects the content of the conversation or the identity of the speakers is entirely for you to

determine based upon your own evaluation of the testimony you have heard concerning the

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preparation of the transcript, and from your own examination of the transcript in relation
to your hearing of the tape recording itself as the primary evidence of its own contents;
and, if you should determine that the transcript is in any respect incorrect or unreliable, you
should disregard it to that extent. It is what you hear on the tape that is evidence, not the
transcripts.

During the course of trial, you have heard evidence that law enforcement officers,
as part of their investigation, sought and obtained search warrants from judges. You may
not infer from the fact that these warrants were court-ordered that the defendant or any of
the alleged co-conspirators committed any of the offenses charged. That information was
provided to you solely for the purpose of informing you how the government obtained
certain evidence introduced in this case.

Certain charts and summaries have been shown to you solely as an aid to help
explain the facts disclosed by evidence (testimony, books, records, and other documents)
in the case. These charts and summaries are not admitted evidence or proof of any facts.

You should determine the facts from the evidence that has been admitted.

Certain charts and summaries of other records have been received into evidence.
They should be considered like any other evidence in the case. You should give them only

such weight as you think they deserve.

The charts and summaries include inferences or conclusions drawn from the records

underlying them. It is up to you to determine if these inferences or conclusions are accurate.

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The underlying records are the best evidence of what occurred.

Count One of the indictment charges the defendant with conspiracy in violation of
Title 18, United States Code, Section 1349.

Section 1349 makes it a crime for anyone to conspire with someone else to do
something which, if actually carried out, would be a violation of Title 18, United States
Code, Section 1343 (Wire Fraud).

A “conspiracy” is an agreement between two or more persons to join together to
accomplish some unlawful purpose. It is a kind of “partnership in crime” in which each
member becomes the agent of every other member.

For you to find the defendant guilty of this charge, you must be convinced that the
government has proved each of the following beyond a reasonable doubt:

First: That the defendant and at least one other person made an agreement to
commit the crime of wire fraud;

Second: That the defendant knew the unlawful purpose of the agreement; and

Third: That the defendant joined in the agreement willfully, that is, with the specific
intent to further the unlawful purpose.

I will separately instruct you on the elements of wire fraud, which is the object of
the conspiracy charged in the indictment.

One may become a member of a conspiracy without knowing all the details of the
unlawful scheme or the identities of all the other alleged conspirators. If a defendant

understands the unlawful nature of a plan or scheme and knowingly and intentionally joins

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in that plan or scheme on one occasion, that is sufficient to convict her for conspiracy even
though the defendant had not participated before and even though the defendant played
only a minor part.

The government need not prove that the alleged conspirators entered into any formal
written or oral agreement, nor that they directly stated between themselves all the details
of the scheme. Similarly, the government need not prove that all of the details of the scheme
alleged in the indictment were actually agreed upon or carried out. Nor must it prove that
all of the persons alleged to have been members of the conspiracy were such, or that the
alleged conspirators actually succeeded in accomplishing their unlawful objectives.

Mere presence at the scene of an event, even with knowledge that a crime is being
committed, or the mere fact that certain persons may have associated with each other, and
may have assembled together and discussed common aims and interests, does not
necessarily establish proof of the existence of a conspiracy. Merely being married to a
person who commits a crime does not support the inference that the spouse conspired to
commit a crime. You may, if you choose, consider the marriage as circumstantial evidence
of knowledge. Also, a person who has no knowledge of a conspiracy, but who happens to
act in a way which advances some purpose of a conspiracy, does not thereby become a
conspirator.

You must determine whether the conspiracy charged in the indictment existed, and,
if it did, whether the defendant was a member of it. If you find that the conspiracy charged

did not exist, then you must return a not guilty verdict, even though you find that some

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other conspiracy existed. If you find that a defendant was not a member of the conspiracy
charged in the indictment, then you must find that defendant not guilty, even though that
defendant may have been a member of some other conspiracy.

The events presented at trial happened in various places. There is no requirement
that the entire conspiracy take place in the Northern District of Texas, but in order for you
to return a guilty verdict, the government must prove by a preponderance of the evidence
that either the agreement or an overt act took place in this district, even if the defendant
never set foot in the district. An overt act is an act performed to affect the object of a
conspiracy, although it remains separate and distinct from the conspiracy itself. Though
the overt act need not be of criminal nature, it must be done in furtherance of the object of
the conspiracy.

Unlike the other elements of the offense, this is a fact that the government has to
prove only by a preponderance of the evidence. This means the government has to convince
you only that it is more likely than not that part of the conspiracy took place in the Northern
District of Texas, All other elements of the offense must be proved beyond a reasonable
doubt. You are instructed that Amarillo, Bedford, Dallas, and Tarrant County, Texas are

located in the Northern District of Texas.

Title 18, United States Code, Section 1343, makes it a crime for anyone to use

interstate wire communications in carrying out a scheme to defraud.

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For you to find the defendant guilty of this crime, you must be convinced that the
government has proved each of the following beyond a reasonable doubt:

First: That the defendant knowingly devised or intended to devise a scheme to
defraud, that is, the defendant and any coconspirator sought to unlawfully
enrich themselves by submitting and causing the submission of false and
fraudulent applications for forgivable Paycheck Protection Program loans;

Second: That the scheme to defraud employed false material representations;

Third: That the defendant caused to be transmitted by way of wire communications,
in interstate commerce, any writing, sign, or signal for the purpose of
executing such scheme; and

Fourth: That the defendant acted with a specific intent to defraud.

A “scheme to defraud” means any plan, pattern, or course of action intended to
deprive another of money or property or bring about some financial gain to the person
engaged in the scheme.

A “specific intent to defraud” means a conscious, knowing intent to deceive and
cheat someone.

A representation is “false” if it is known to be untrue or is made with reckless
indifference as to its truth or falsity. A representation would also be “false” if it constitutes
a half truth, or effectively omits or conceals a material fact, provided it is made with the

intent to defraud.

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A representation is “material” if it has a natural tendency to influence, or is capable
of influencing, the decision of the person or entity to which it is addressed.

It is not necessary that the government prove all of the details alleged in the
indictment concerning the precise nature and purpose of the scheme. What must be proved
beyond a reasonable doubt is that the defendant knowingly devised or intended to devise a
scheme to defraud by means of false or fraudulent pretenses, representations, or promises
that was substantially the same as the one alleged in the indictment.

It is also not necessary that the government prove that the material transmitted by
wire communications was itself false or fraudulent, or that the use of the interstate wire
communications facilities was intended as the specific or exclusive means of
accomplishing the alleged fraud. What must be proved beyond a reasonable doubt is that
the use of the interstate wire communications facilities was closely related to the scheme
because the defendant either wired something or caused it to be wired in interstate
commerce in an attempt to execute or carry out the scheme.

The alleged scheme need not actually succeed in defrauding anyone.

To “cause” interstate wire communications facilities to be used is to do an act with
knowledge that the use of the wire communications facilities will follow in the ordinary
course of business or where such use can reasonably be foreseen.

Each separate use of the interstate wire communications facilities in furtherance of
a scheme to defraud by means of false or fraudulent pretenses, representations, or promises

constitutes a separate offense.

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As to counts two to five, you are instructed that the guilt of a defendant in a criminal
case may be established without proof that the defendant personally did every act
constituting the offense alleged. The law recognizes that, ordinarily, anything a person can
do for himself or herself may also be accomplished by him or her through the direction of
another person as his or her agent, or by acting in concert with, or under the direction of
another person or persons in a joint effort or enterprise.

If another person is acting under the direction of the defendant or if the defendant
joins another person and performs acts with the intent to commit a crime, then the law
holds the defendant responsible for the acts and conduct of such other persons just as
though the defendant had committed the acts or engaged in such conduct.

Before any defendant may be held criminally responsible for the acts of others, it is
necessary that the accused deliberately associate herself in some way with the crime and
participate in it with the intent to bring about the crime.

Mere presence at the scene of a crime and knowledge that a crime is being
committed are not sufficient to establish that a defendant either directed or aided and
abetted the crime unless you find beyond a reasonable doubt that the defendant was a
participant and not merely a knowing spectator.

In other words, you may not find any defendant guilty unless you find beyond a
reasonable doubt that every element of the offense as defined in these instructions was
committed by some person or persons, and that the defendant voluntarily participated in its

commission with the intent to violate the law.

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A conspirator is responsible for offenses committed by another conspirator if the
conspirator was a member of the conspiracy when the offense was committed and if the
offense was committed in furtherance of, and as a foreseeable consequence of, the
conspiracy.

Therefore, if you have first found the defendant guilty of the conspiracy charged in
Count One and if you find beyond a reasonable doubt that during the time the defendant
was a member of that conspiracy, another conspirator committed the offenses in Counts
Two, Three, Four, or Five, both in furtherance of and as a foreseeable consequence of that
conspiracy, then you may find the defendant guilty of Counts Two, Three, Four, or Five,
even though the defendant may not have participated in any of the acts which constitute
the offense described in Count Two, Three, Four, or Five.

In order for you to return a guilty verdict as to Counts Two, Three, Four, or Five,
the government must prove by a preponderance of the evidence that a wire transmission in
furtherance of the scheme was begun, continued, completed, or was committed in the
Northern District of Texas. Unlike the other elements of the offense, this is a fact that the
government must prove only by a preponderance of the evidence. This means the
government must convince you only that it is more likely than not that the offense charged
was begun, continued, completed, or was committed in the Northern District of Texas. All
other elements of the offense must be proved beyond a reasonable doubt. You are instructed
that Amarillo, Bedford, Dallas, and Tarrant County, Texas are located in the Northern

District of Texas.

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To reach a verdict, whether it is guilty or not guilty, all of you must agree. Your
verdict must be unanimous on each count of the indictment.

It is your duty to consult with one another and to deliberate in an effort to reach
agreement if you can do so. Each of you must decide the case for yourself, but only after
an impartial consideration of the evidence with your fellow jurors. Do not let any bias,
sympathy, or prejudice that you may feel toward one side or the other influence your
decision in any way. In particular, do not let racial, ethnic, national origin, or other bias
influence your decision in any way. During your deliberations, do not hesitate to
reexamine your own opinions and change your mind if convinced that you were wrong.
But do not give up your honest beliefs as to the weight or effect of the evidence solely
because the opinion of your fellow jurors, or for the mere purpose of returning a verdict.

Remember at all times, you are judges—judges of the facts. Your duty is to
decide whether the government has proved the defendant guilty beyond a reasonable
doubt.

When you go to the jury room, the first thing that you should do is select one of
your number as your foreperson, who will help to guide your deliberations and will speak
for you here in the courtroom. A verdict form has been prepared for your convenience.

The foreperson will write the unanimous answer of the jury in the space provided
for each count of the indictment, either guilty or not guilty. At the conclusion of your
deliberations, the foreperson should date and sign the verdict.

If you need to communicate with me during your deliberations, the foreperson

20
Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page21of21 PagelD 2528

should write the message and give it to the court security office. I will either reply in
writing or bring you back into the court to answer your message.

Bear in mind that you are never to reveal to any person, not even to the court, how
the jury stands, numerically or otherwise, on any count of the indictment, until after you
have reached a unanimous verdict.

Signed this 20th day of June, 2025.

Reed O’ Connor é
UNITED STATED DISTRICT JUDGE

21


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