UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-20326-CR-MOORE

UNITED STATES OF AMERICA,

v. 

ANDRE LORQUET, 

Defendant.

___________________________/ 

UNITED STATES OF AMERICA’S NOTICE OF INTENT TO ADMIT EVIDENCE 

PURSUANT TO FEDERAL RULES OF EVIDENCE 902(11) AND 803(6)

The United States of America, by and through the undersigned Assistant United States 

Attorney, hereby files this notice of intent to admit evidence through Federal Rules of Evidence 

(“FRE”) 902(11) and 803(6), and states the following in support thereof: 

At the trial of the instant cause, the United States intends to admit business records through 

Federal Rule of Evidence 902(11) and 803(6), which provide for the admissibility and authenticity 

of business records via certifications provided by a records custodian. 

Pursuant to Federal Rule of Evidence 902(11), 

A party intending to offer a record into evidence under this paragraph must provide 

written notice of that intention to all adverse parties, and must make the record and 

declaration available for inspection sufficiently in advance of their offer into 

evidence to provide an adverse party with a fair opportunity to challenge them. 

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Pursuant to Federal Rule of Evidence 803(6),

The following [is] not excluded by the rule against hearsay, regardless of whether 

the declarant is available as a witness: . . . A record of an act, event, condition, 

opinion, or diagnosis 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.

The certifications are attached to this notice. Below are the document control numbers 

corresponding with each certification:

CN_005 TD Bank

CN_010 American Lending Center

CN_011 BlueVine

CN_012 Celtic Bank

CN_013 Florida Department of Revenue

CN_017 Comcast

CN_020 TD Bank

CN_022 Comast

CN_027 Celtic Bank

CN_028 Cross River Bank

CN_032 Florida Department of Revenue

CN_033 Google

CN_033a Google

CN_034 Comcast

CN_035 Craig Zinn

CN_039 TMobile

CN_043 Comcast

CN_045 TMobile

507900896 Facebook (Meta)

27146730 Google (Gmail)

243881117 Instagram (Meta)

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This filing is intended to provide the defense with the required notice under Federal Rule 

of Evidence 902(11). The above certifications and corresponding business records have been 

produced to the defense. 

 Respectfully submitted,

 

 JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY

 BY: Jonathan Bailyn 

 Jonathan R. Bailyn, AUSA 

Court ID No. A5502602 

99 Northeast Fourth Street, 6th Floor 

Miami, Florida 33132-2111 

Phone: (305) 961-9071 

jonathan.bailyn@usdoj.gov 

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