or would counsel presenting arguments three please approach introduce yourselves for the record and spell your last n of beds she received sentences of seventy eight months sixteen months some thirty six months as to each of those i would like to focus today on the insufficiency of the evidence as to every element of the charges and as our position they did not in particular as to the element which was underlying both up charges that the defendant knew that the defendant intended to prominent deprive the victim of the use and benefit of the property the case relates to fifteen contracts that were issued between the county and certain that there is that's the money some contract cases right rev stand in which it it's clear that if something happens in the middle of a contract and the services are not provided that may be a civil matter but it's not a from out that the it was intended that the work not be done would have to look at it in contacts no more and everyone into it is that a reasonable inference though that if nobody it if people generally get paid until they do work it you might infer there's something maybe perhaps it proper about giving facts out for twenty five under just under twenty five thousand  for work we haven't even because i certainly would think improper it is a possible implant but not to prove that the work was not going to be done and i think the context of this is number one ok i take it this is kind of a several were created within days and actually many of them feel just stopped functioning so is that another ignorance of some kind of impropriety we'll call it that there was no evidence  knowledge and that's what you're trying to emphasize she gets now again now it's like intent is something that most often is never direct it's the or it's it's based on inferences that are their the letter and that letter says certain things about this company and why it was the only company that could do that if that person didn't take any i didn't consider what they were doing when they with their name on it to request that contract be given i actually i do not think that's necessarily in front because of the it when you put your name on a letter that you have some semblance of knowledge of what you're doing and i mean isn't that just and it piece that may be a better approach and a standard but i don't believe that is the way the evidence indicates that this this this signing of of the writers worked muskogee up to it the testimony of these individuals saying well this is how we did it we just two companies that have she had  when we talk about whether the defendant intended to work would be done those were companies so how could we conclude from that that there's no evidence that she intended that the work it was to people from we would be performing if you're expecting  look up and there was evidence that she there were could come to us from a financial group there was no evidence that she was involved in monitoring the real work done by those companies by any of these companies that was being done by m being done under those contracts there wasn't there was evidence that she had financial that there was financial going into accounts that she had but that she was on a day to day monitoring what that one hundred thousand in fields there was no allegation of what the money was worth the funds that would be wanted that's what the the the just a money laundering is the financial transaction itself right and the only  all these contracts sole source for the specific purpose of taking that money it had to be placed somewhere and placing it in work races that came out of nowhere in a day did these transactions were done my way i'm so nice i can't absolutely no connection talk are the ones in his those that went into his house but before they got to that account there was a disguised them into these other corporations sufficient because she knew it was about those transactions right yeah that's it and she prepared and some went to trial and there right yes but what the state is arguing now is not that it is that the words that five thousand dollars mattered more whether she knew about it we can have a different discussion but would you admit that much is it was money from it if there's a finding of staff transaction would be among the tr one hundred thousand dollars tony money using illegitimate bender they say her conduct was it they say her conduct was initiat were set up or take in all this to write on lawful money for example the woman who was a caterer who was suddenly a corporation to do he our work that's their position this started it wasn't a bunch of money being bubble later it started at the very beginning the plan from the beginning was to  all this money and then it had to go somewhere it had to be placed somewhere and therefore it was wandered through the only company that's their position now how do you respond to that argument  she initiated she participated she conducted because she was the one of the originators if you will so i don't think the staff to can be the same thing to someone you want to think the money laundering g off and then except the money and the vendors never did work so there is the there are all these inferences about how this money was being laundered because no the  intent know experience in p r one was either or there was and then there's these letters saying all these people are really qualified they should be the only ones doing this this is the sole source and she's the one that put her put her name on all the letters so i mean it's kind of a big thing but that's their argument in the brief is that the wandering started at the very beginning with the theft of the money that the money that was still had to be laundered somewhere being expecting kickback wells as as i understand judgment few things for contracts went to trial harris and at the back end she got some money from one of trial harris's companies and he viewed that i believe as f t p that is he took that as maybe not that it is a kickback but she was getting some money in exchange for doing that so even if she may not have directed the attorney graham's and isaac in exactly how to move what money to what it kelps wasn't she expecting to get some money concealed as that which intimate business transaction on the it did she immediately then said those proceedings so she could get several bids under the twenty five thousand dollars again she did not make that decision that decision would hear this as i believe it's  into a letter that you want it to be sole source for the specific purpose oh boy doing the bidding you have to do that more than once is that what you're saying when you have a straight or is it just one single contraire would was it says it was for the purpose of updating right in the first line but the way it was done was to split them up into the eight from the two that are the one that was two hundred thousand down to the two that  twenty five thousand dollars county funds she collaborated with other individuals to obtain an unheard of scope and level of authority and she didn't use that authority to facilitate contracts to sham companies that she used as fronts for her theft no forwarding was granted to her and to her alone and every step of the way she funnel b s county funds to accounts controlled by herself as well as her complex as always ensuring attempting to shield her criminal activities from county authorities is the is the offense of money laundering supposed to be supplanting after or is it a separate charge that requires that the money be disguised while transfer a different house they're tied together factually but it is a separate charge we have charges of theft two of them to fight deception and use that but the money laundering was separately charged because of the way the money was handled once it was stolen as well or better than money laundering  specifically challenge how it's how it's worded and as to the wording of of the financial transactions discussed several transactions of the money and how it's handled where it's moved to it specifically states that the money was placed in different the circumstantial evidence definitely indicates that she was aware of what was happening because the person who was instructing mr isaac on the transaction the person who is telling him what to do with every single track according to his drives its own testimony  happen with the money because the money came back to her which is a key factor the fact that she was dealing on five thousand dollar deposit into early company that's the one that we don't pay because it was a check but there were also cash deposits and made it to her company correct to see to see his company when the time as to the exact number i don't have the exact number but there were several cast deposits in the amount of thousands of dollars that were made these after these checks were distributed around the same time that all this money that's been cited through the attorney suddenly is appearing via cash payments into her own company it's really not functioning very well it goes business transaction when really it was just a pale and so they did it by funneling money through companies but when you see as you see it is is it one of the vendors whether they should have been or not that's your theft argument they get this money and then whatever they do with it the deposit to be an initial criminal act that's part of why it defendant first contested in her second to sure she said she and i did not sufficiently specify the financial transaction that was being used as the basis for the money laundering so the financial transaction sole source of a spending number one does both you have to have both together so if a contract a sole source you can tell the defendant that you have to charge what you're suggesting you could have slowly just avoiding board divide the contracts and the one hundred thousand dollars each into eight contracts each worth over twenty four thousand nine hundred dollars but under twenty five thousand and for the purpose of doing so was to evade the requirements of the twenty five thousand dollars but there is direct evidence as to who wrote or who signed the justification letters who created the that these contracts  this is what these companies are capable of doing this is what their experience in doing this is what the company that can do this if a contract and now is the defendant so she's the only person who we have evidence of for justified these to be sole source which is how they had to be dotted and had to have a justification letter who is the only signature on them now so there is evidence that the defendant played a role in an sourcing but when you indicted her you said that she violated the bitstream statute by virtue of how they  constitute a crime and she did argue i agree with you she did not move to dismiss the indictment ok sure you probably did that's fine but now here we are if a directed verdict stage at trial and an appeal she keeps jumping up and down saying that's not a things that circumstantially offense defendants intent to commit fact here to steal the over three hundred twenty almost three hundred twenty five thousand dollars from the county as to the vendors there were seven stipulated vendors and there was some discussion as to whether or not they claim to do any work on the seven stipulated binders only four were claimed to do anything well as unclean told me attend a couple of meetings to send his wife to a couple of others on three of them claim to do actual work in the sense that one said he once they got there where all the evidence showed that she wrote these justification letters when she was the one making the representations to the county that the companies were built qualified and experienced ideas showed they were neither ok they were not intended that they were not going to do the work or say god well i'm still working do it right correct you can't she was making false representations from the get go representations they were experience sure the company she wanted to get into right and i think that part of that showed her intention to obtain the money without any sort of work for honesty in these contracts whatsoever i think it influences directly her intent her intent to get the money as quickly as possible into the hands of herself and the people she wanted it to go to and to hide that activity well was there evidence in the record that basically they have jury of them never did there prosecution that's because that's part of the standard as well so we look at rather a rational trier of fact put a found that she was that the evidence proved beyond a reasonable doubt that she was guilty of these crimes she had the intent of cetera and then inferences have to be resolved in favor of the saying that the proof in this case was always that these just patient letters were sent out for the purpose of baiting it right i would say both getting hired and asked him not only about it being order a few but they talked specifically about sole source contracts and justification letters and how those could be expedited so there was direct evidence from mr abbas that he worked with the fund and on on how to get how to get these contracts to be that combination of both one hundred twenty five thousand and so suggestions that there were cash deposits kickbacks there was absolutely no evidence that any deposit were chalk was a kickbacks the only evidence as to kickbacks stipulations of the problem i mean she signs a letter saying these people because yes you need skill to do this contract that requires unique skill and she didn't even know who these companies were and she relied on straw man ones and now was the procedure that everyone testified w issue that that was the fact was never disputed that that in fact these going through going to be needed within a short period of time that wasn't a disputed factual issue so based on th politically it's offensive is running a business ok i think anyone would look at it would be offended that's why we have a ructions to get people out of executive positions to spend money in a way we don't want