UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-80144-CR-Smith/Maynard(s)(s)

UNITED STATES OF AMERICA

v.

JOFF STENN WROY PHILOSSAINT,

MARIEL TOLLINCHI,

REGINE MARIE RENE,

BRIANNA MONIQUE GAYLE,

MAURICE SHAZIER, and

ROBENSON LAUVINCE,

Defendants.

GOVERNMENT’S SECOND NOTICE OF INTENT TO OFFER RECORDS

OF REGULARLY CONDUCTED ACTIVITY BY CERTIFICATION

The United States respectfully notifies the defense that it intends to introduce domestic 

records of regularly conducted activity that meet the requirements of Federal Rule of Criminal 

Procedure 803(6)(A)–(C), as shown by a certification of a custodian or another qualified person that 

complies with Federal Rules of Criminal Procedure 803(6)(D) and 902(11).

The records to be introduced and the corresponding certifications are as follows:

Records Certification

Location* Records of File† p.‡

HD\010_Bank of America Bank of 

America

221114.zip\Bank of America _ 

Declaration.pdf

* All records were disclosed by USAfx except where the location of the records begins with 

‘HD’, in which case the records were provided to defense counsel on a hard drive at the beginning 

of the case, as discussed in the government’s initial discovery responses (D.E. 44, 87, 134).

† All certifications were provided by USAfx. If the file name is blank, the certification is 

found in the same file that also contains the records. If a filename is given without a folder path, 

then the file containing the certification is found in the same folder as the records. If a path and 

filename are given, the file is found at the location specified.

‡ If the page number is blank, the entire file constitutes the certification.

Case 9:22-cr-80144-RS Document 136 Entered on FLSD Docket 01/01/2023 Page 1 of 2
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Records Certification

Location* Records of File† p.‡

\221114.zip\Itria Gayle loan file Itria Certificate of Authenticity- Brianna 

Gayle.pdf

\221114.zip\Itria Cinda loan file Itria Certificate of Authenticity- Cinda 

Foundation INC.pdf

\221116\Chase April-May 2022.zip Chase SB1379601-F1_SCD_1.PDF

\221116.zip\048 PNC PNC 048_PNCCertification.pdf 2

\221119\076_NFCU.zip Navy Federal 

Credit Union

Certification.pdf

\221119\PNC_5131.zip PNC PNC5131_CERT.pdf

\221201\Comcast_Trial_Subpoena_Resp

onse.pdf

Comcast Comcast_Trial_Subpoena_Response.pdf 2

\221201\079_CHASE Chase SB1384937-F1_SCD_1.PDF 2

\221202\029_POPULAR BANK Popular Bank 029_Certification.pdf

\221202\030_CHASE Chase SB1357096-F1_SCD_1.PDF 2-3

\221202\031_SYNOVUS Synovus Certification-S22-0830.pdf

\221205\Ferro's PPP loan file Itria certification.pdf

\221214\032_AMEX.zip American 

Express

AMEX_Return Certification Password 

Docs.pdf

3

\221219.zip\Clear Shot property records 

221130.pdf

GP 1-2

\221219.zip\Clear Shot property records 

221205.pdf

GP 1

221223.zip Discover Discover Certification Document.pdf

221228.zip MidFirst Bank Affidavit & Appendix.pdf

WHEREFORE, the government respectfully notifies the defense that it intends to introduce 

records of regularly conducted activity by certification.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: s/ Marc Osborne

Assistant United States Attorney

Court ID# A5500796

500 S. Australian Avenue, Suite 400

West Palm Beach, Florida 33401

Tel: (561) 209-1014

marc.osborne@usdoj.gov

Case 9:22-cr-80144-RS Document 136 Entered on FLSD Docket 01/01/2023 Page 2 of 2