United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 264: Hockridge's renewed motion for judgment of acquittal (2025-07-28)

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A renewed motion for judgment of acquittal, Document 264 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 July 28, 2025, under Federal Rule of Criminal Procedure 29(a) on Count One of the Superseding Indictment. The motion states that the jury acquitted Hockridge of every count except Count One, conspiracy to commit wire fraud. It argues that the Government failed to prove that Hockridge knowingly agreed to join a conspiracy, that the evidence did not establish the single conspiracy alleged in Count One, and that the Government failed to prove venue by a preponderance of the evidence. It bears the signature text /s/ Richard E. Finneran.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 264: Hockridge's renewed motion for judgment of acquittal (2025-07-28).” 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-264-ca982a7a33/, SHA-256 f11f817fa84413d8683f6075b4579cdd9f5130ea8cb72317036734af1dbe24c0.

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Case 4:24-cr-00287-O Document 264 Filed 07/28/25 Page 1 of 6 PageID 5411

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
RENEWED MOTION FOR JUDGMENT OF ACQUITTAL

COMES NOW Defendant Stephanie Hockridge, by and through the undersigned counsel,

and, pursuant to Federal Rule of Criminal Procedure 29(a), files this renewed motion for a

judgment of acquittal on Count One of the Superseding Indictment. In support of the Motion, and

as explained more fully in the contemporaneously filed memorandum of law in support of this

Motion, Ms. Hockridge respectfully states:

1. The Superseding Indictment (Doc. #163) alleged five counts against Ms.

Hockridge: conspiracy to commit wire fraud (Count One) and wire fraud under 18 U.S.C. § 1343

(Counts Two through Five) related to her business of processing loan applications under the

Paycheck Protection Program (PPP). The jury acquitted Ms. Hockridge of every count except

Count One. Such an inconsistent result demands “judicial skepticism.” United States v. Caro, 569

F.2d 411, 418 (5th Cir. 1978) (reversing and remanding with directions to enter a judgment of

acquittal); see also United States v. Peterson, 488 F.2d 645, 651 (5th Cir. 1974).

2. Under Rule 29, “the [C]ourt on the defendant’s motion must enter a judgment of

acquittal on any offense for which evidence is insufficient to sustain a conviction.” Fed. R. Crim.

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P. 29(a). In determining the sufficiency of the evidence, the “relevant question” is not merely

whether the Government has produced some evidence of the elements of its case, but instead

“whether, after viewing the evidence in the light most favorable to the prosecution, any rational

trier of fact could have found the essential elements of a crime beyond a reasonable doubt.” United

States v. Xu, 599 F.3d 452, 453 (5th Cir. 2010) (cleaned up) (emphasis added).

3. Given the absence of reliable evidence supporting multiple elements of conspiracy

under 18 U.S.C. § 1349, no rational factfinder could find Ms. Hockridge guilty beyond a

reasonable doubt on Count One. Instead, the jury’s sole guilty verdict on that count improperly

relied on “mere suspicion, speculation, or conjecture, or an overly attenuated piling of inference

upon inference,” which is improper as a matter of law. United States v. Ganji, 880 F.3d 760, 767

(5th Cir. 2018) (cleaned up).

4. First, Ms. Hockridge is entitled to an acquittal on Count One because the

Government failed to prove beyond a reasonable doubt that she knowingly agreed to join any

conspiracy at all. Instead, the trial evidence, as a whole, exculpated Ms. Hockridge not only of

wire fraud, but of conspiracy as well. Indeed, the jury’s acquittal on the wire fraud charges itself

shows that the Government failed to prove elements of its the conspiracy charge beyond a

reasonable doubt, for multiple reasons:

• According to the Superseding Indictment upon which Ms. Hockridge was tried,
the scheme to commit wire fraud embraced in Counts Two through Five
represented the very same course of conduct as the conspiracy. Superseding
Indictment (Doc. #163) ¶ 19 (referencing ¶¶ 15–17). Because the jury acquitted
on the wire fraud counts, its verdict reflects a finding that the Government had
failed to carry its burden to prove her involvement in that course of conduct
beyond a reasonable doubt.

• Moreover, the Court issued both a Pinkerton charge and an aiding and abetting
charge that would have permitted the jury to convict Ms. Hockridge on the
substantive counts of the Superseding Indictment if it found beyond a
reasonable doubt that Ms. Hockridge’s coconspirators either committed or

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assisted in the commission of those offenses. Jury Charge (Doc. #222) at 18–
19. Yet the jury acquitted on those charges. Those acquittals are irreconcilable
with the jury’s guilty verdict on the conspiracy charge. See id. Instead, the most
plausible explanation of the jury’s guilty verdict on Count One is that it simply
misunderstood what was required for Ms. Hockridge to be found guilty of that
charge.

5. A rational jury should have concluded that the Government failed to demonstrate

beyond a reasonable doubt that Ms. Hockridge engaged in the course of conduct representing the

alleged conspiracy (as well as representing the scheme embodied in the wire fraud counts, as the

jury did here). The evidence at trial showed that Ms. Hockridge was consistently kept at a distance

from discussions among the alleged coconspirators concerning fraud; that she was excluded from

discussions of fraudulent alterations to borrower applications; that she actively worked against the

goals of the alleged conspiracy by taking steps to root out fraud; and that Ms. Hockridge relied in

good faith on the accuracy of borrower certifications, as the Small Business Administration’s own

guidance permitted (and encouraged) Ms. Hockridge to do. For each of those reasons, Ms.

Hockridge is entitled to acquittal on Count One.

6. Although the Government attempted to stretch the available evidence at trial to

connect Ms. Hockridge to the fraud, the Government in fact failed to do so beyond a reasonable

doubt, in several important respects:

• Although the Government introduced evidence that Ms. Hockridge was
associated with other people who may have committed fraud, or that she was
around fraud, neither suffices to prove beyond a reasonable doubt that she
agreed to join a criminal conspiracy. “A conspiracy may not be shown . . . by
evidence that merely places the defendant in a climate of activity that reeks of
something foul.” United States v. Boyd, 478 F. App’x 826, 829 (5th Cir. 2012)
(cleaned up). And more to the point, it “is not enough that the Government
proves that the defendant knew something criminal was afoot.” Ganji, 880 F.3d
at 766.

• The principal evidence the Government attempted to introduce to demonstrate
Ms. Hockridge’s knowing participation in any conspiracy was the testimony of
its star witness—Eric Karnezis—a proven, prolific liar, whose claims were

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flatly contradicted by the written record of communications between himself
and Ms. Hockridge.

• The Government similarly failed to prove beyond a reasonable doubt that Ms.
Hockridge submitted any false loan application for Body Politix LLC. (Indeed,
the jury acquitted her of submitting such an application in 2021.)

• Though the Government attempted to prove a pattern of fraudulent applications
so pervasive that Ms. Hockridge must have known about, and joined, a
conspiracy, the Government repeatedly failed to demonstrate that the
applications were fraudulent—especially materially so—or that Ms. Hockridge
knew about any fraudulent application before it was submitted, rather than after
the fact.

• The Government failed to prove beyond a reasonable doubt that Ms. Hockridge
intended to do anything illegal by accepting agent fees from borrowers, which
were legally permitted.

7. Second, although the Government may have produced “some evidence” of a

criminal conspiracy, the evidence at trial did not establish the single, unified conspiracy to commit

wire fraud alleged in Count One. Superseding Indictment (Doc. #163) ¶ 14. At best, the

Government demonstrated two separate courses of conduct divided by separate PPP rounds—if

not a series of separate conspiracies for several borrowers, none of which were interdependent.

The Government’s failure to present evidence of such a single conspiracy constitutes a constructive

amendment to (or fatal variance from) the Superseding Indictment, in violation of the Fifth

Amendment.

8. Third, the Government failed to prove by a preponderance of the evidence that

venue was proper for the conspiracy charge. The Government failed to prove that any

conspiratorial agreement was formed, or that any coconspirator committed an overt act in

furtherance of the conspiracy, in the Northern District of Texas. The Government asserted venue

based on wires issued from this District—but the jury acquitted Ms. Hockridge of causing wire

transfers to be initiated from this District. Nor do such acts constitute overt acts in the district by a

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coconspirator, as the Government belatedly admitted was required the morning of closing

arguments at Ms. Hockridge’s trial.

9. For each of those reasons and others described in the memorandum of law

supporting this motion, this Court should enter a judgment of acquittal on the sole count of the

Superseding Indictment on which the jury returned a guilty verdict.

WHEREFORE Defendant Stephanie Hockridge prays that the Court grant her Renewed

Motion for Judgment of Acquittal on Count One and grant such other and further relief as the

Court deems just and proper.

Dated: July 28, 2025 Respectfully submitted,

BRYAN CAVE LEIGHTON PAISNER LLP

/s/ Richard E. Finneran
RICHARD E. FINNERAN
MARK A. SRERE
KEVIN H. JENCO
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
Tel: (314) 259-2000
Fax: (314) 259-2020
richard.finneran@bclplaw.com
mark.srere@bclplaw.com
kevin.jenco@bclplaw.com

Attorneys for Defendant Stephanie Hockridge
Attorneys for Defendant Stephanie Hockridge

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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

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