United States v. Roberson, E.D. La. No. 2:25-cr-210, Doc. 61: Order on the government's motion in limine to deem business records authentic (Aug. 12, 2026)

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An Order, Document 61, filed 08/12/26 in United States v. Cherikah Roberson, Case 2:25-cr-00210-ASJ-MBN (Criminal Action No. 25-210), in the U.S. District Court for the Eastern District of Louisiana. The order states that Roberson was indicted on August 14, 2025, for conspiracy to commit wire fraud, wire fraud, false statements, and theft of government funds, and that Roberson has not filed a response. The court grants the government's Motion in Limine to Deem Authentic and Admissible Business Records, as amended, and makes preliminary determinations under Federal Rule of Evidence 104(a) for records from entities including Harvest Small Business Finance, LLC and South Louisiana Bank. Its signature block names Anna St. John, United States District Judge.

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“United States v. Roberson, E.D. La. No. 2:25-cr-210, Doc. 61: Order on the government's motion in limine to deem business records authentic (Aug. 12, 2026).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-roberson-e-d-la-no-2-25-cr-210-doc-61-order-on-the-gov-fff0b1be28/, SHA-256 57491834b2badc4eecc4df4312bdc42154b0f5b18ff320a9f40e3973da749f2e.

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Case 2:25-cr-00210-ASJ-MBN Document 61 Filed 08/12/26 Page 1 of 5

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

UNITED STATES OF AMERICA CRIMINAL ACTION

VERSUS NO. 25-210

CHERIKAH ROBERSON SECTION: N

ORDER

Before the Court are the government’s Motion in Limine to Deem Authentic

and Admissible Business Records1 and an amended motion in which the government

provides an amended chart of records subject to its motion. 2 The Court heard

argument on the motion on July 28, 2026, and ordered 3 that any response by

Defendant Cherikah Roberson be filed by Friday, August 7, 2026. Roberson has not

filed a response. After careful consideration of the government’s memoranda, the

parties’ oral arguments, the record, and the applicable law, the Court GRANTS the

motion as amended.

I. FACTUAL AND PROCEDURAL BACKGROUND

Defendant Cherikah Roberson was indicted on August 14, 2025, for conspiracy

to commit wire fraud, wire fraud, false statements, and theft of government funds

arising out of alleged schemes to defraud the Small Business Administration and

other financial institutions supporting the Paycheck Protection Program, Kentucky’s

Office of Unemployment Insurance, and the Federal Emergency Management

1 Rec. Doc. 50.
2 Rec. Doc. 59.
3 Rec. Doc. 60.
Case 2:25-cr-00210-ASJ-MBN Document 61 Filed 08/12/26 Page 2 of 5

Agency.4 As permitted by Federal Rule of Evidence 104, the government requests a

preliminary determination that certain records are admissible as business records

under the exception to hearsay set forth in Rule 803(6).5 Subject to the motion are

documents provided by various financial institutions and a social media platform,

among other business entities, that the government anticipates introducing at trial.6

With its motion, the government provided certifications from custodians of these

records, filed under seal, and provided copies of the records to the Court and

defendant.7

II. LEGAL STANDARD

A. Authenticity via Certifications

Rule 803 of the Federal Rules of Evidence sets forth a number of exceptions to

the evidentiary rule against hearsay that apply “regardless of whether the declarant

is available as a witness.” Under Rule 803(6), a “record of an act, event, condition,

opinion, or diagnosis” is not excluded if

(A) the record was made at or near the time by — or from information
transmitted by — someone with knowledge;
(B) the record was kept in the course of a regularly conducted activity of
a business, organization, occupation, or calling, whether or not for profit;
(C) making the record was a regular practice of that activity;
(D) all these conditions are shown by the testimony of the custodian or
another qualified witness, or by a certification that complies with Rule
902(11) or (12) or with a statute permitting certification; and
(E) the opponent does not show that the source of information or the
method or circumstances of preparation indicate a lack of
trustworthiness.

4 Rec. Doc. 1.
5 Rec. Doc. 50-1 at p.1; Rec. Doc. 59 at p. 1.
6 Rec. Doc. 59-1 at p.1.
7 Rec. Doc. 51-2.
Case 2:25-cr-00210-ASJ-MBN Document 61 Filed 08/12/26 Page 3 of 5

Further, Rule 902 enumerates items of evidence that are “self-authenticating”

and thus “require no extrinsic evidence of authenticity in order to be admitted.”8 Such

items include certified domestic records of a regularly conducted activity, certified

records generated by an electronic process or system, and certified data copied from

an electronic device, storage medium, or file. 9 The introduction of these types of

records require a “certification of the custodian or another qualified person,” and “the

proponent must give an adverse party reasonable written notice of the intent to offer

the record — and must make the record and certification available for inspection —

so that the party has a fair opportunity to challenge them.”10 The records must also

meet the requirements of Rule 803(6)(A)-(C). Once these requirements are met, “valid

902(11) certificates are sufficient for admissibility” without additional

authentication.11

III. ANALYSIS

The government seeks a determination that the following are authentic and

admissible business records: records from Harvest Small Business Finance, LLC,

South Louisiana Bank, Bank of America, Blueacorn, Block, Liberty SBF Holdings,

LLC, Stride Bank, Current, T-Mobile, Google, Yahoo, Facebook, and the Louisiana

Secretary of State.12 The government filed a certificate of authenticity from each of

these custodians for the records subject to its motion.13

8 Fed. R. Evid. 902.
9 See, e.g., Fed. R. Evid. 902(11), (13), (14).
10 Fed. R. Evid. 902(11). See also Fed. R. Evid. 902(13), (14).
11 United States v. Age, 136 F. 4th 193, 226 (5th Cir. 2025).
12 Rec. Doc. 50.
13 Id.
Case 2:25-cr-00210-ASJ-MBN Document 61 Filed 08/12/26 Page 4 of 5

Because the records constitute self-authenticating records under Rule 902(11)

and the certificates meet the requirements of Rule 803(6), the Court finds that the

records are authentic and admissible.14

IV. CONCLUSION

IT IS ORDERED that the Motion in Limine to Deem Authentic and

Admissible Business Records, as amended,15 is GRANTED. The Court makes the

following preliminary determinations of admissibility regarding authenticity and

hearsay pursuant to Federal Rule of Evidence 104(a). Any proponent must

nevertheless establish the relevance of any document before it is admitted, and all

parties reserve objections under Federal Rule of Evidence 403.

IT IS FURTHER ORDERED that the original Motion in Limine to

Authenticate and Deem Admissible Business Records by the Government 16 is

GRANTED.

IT IS FURTHER ORDERED that records from the following entities are

deemed authentic and admissible as records of regularly conducted activity. See Fed.

R. Evid. 803(6), 902(11). Those entities and records are:

Exhibit Source Entity Bates Number
Number
Harvest Small Business Finance, LLC 002915 – 003034;
1
006599 – 006600

2 South Louisiana Bank 005968 – 006230

3 Bank of America 000002 – 000186

14 Rec. Doc. 59.
15 Rec. Doc. 59.
16 Rec. Doc. 50.
Case 2:25-cr-00210-ASJ-MBN Document 61 Filed 08/12/26 Page 5 of 5

4 Blueacorn 000285 – 000859

5 Block 000187 – 000284

Liberty SBF Holdings, LLC 003090 – 003148;
6 006715 – 006717;
006718 – 006719

7 Stride Bank 006704 – 006712

Current 000879 – 000896;
8
006597 – 006598

9 T-Mobile 006231 – 006295

10 Google 002892 – 002914

11 Yahoo 006575 – 006596

12 Facebook 000001; 006601

13 Louisiana Secretary of State 006695 – 006703

New Orleans, Louisiana, August 12, 2026.

______________________________
ANNA ST. JOHN
UNITED STATES DISTRICT JUDGE

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