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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

UNITED STATES OF AMERICA, )

 )

 vs. ) Case No. 

 ) 2:16-cr-00160-MFK-2 

JAMES E. SNYDER, )

 )

 Defendant. )

____________________________ )

EXCERPT FROM JURY TRIAL 

CLOSING ARGUMENT BY THE GOVERNMENT MARCH 18, 2021

BEFORE THE HONORABLE MATTHEW F. KENNELLY

UNITED STATES DISTRICT COURT

APPEARANCES: 

FOR THE GOVERNMENT: JILL ROCHELLE KOSTER - AUSA 

 United States Attorney's Office 

 5400 Federal Plaza, Suite 1500 

 Hammond, Indiana 46320 

 219-937-5500 

 Fax: 219-852-2770 

 Email: Jill.Koster@usdoj.gov 

 ANKUR SRIVASTAVA - AUSA 

 United States Attorney's Office 

 219 South Dearborn, 5th Floor 

 Chicago, Illinois 60604-2029 

 312-353-3148 

 Email: Ankur.Srivastava@usdoj.gov 

FOR THE DEFENDANT: JACKIE M. BENNETT, JUNIOR 

 Taft Stettinius & Hollister LLP 

 One Indiana Square, Suite 3500 

 Indianapolis, Indiana 46204-2023 

 317-713-3500 

 Fax: 317-713-3699 

 Email: jbennett@taftlaw.com 

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

APPEARANCES (Continued): 

FOR THE DEFENDANT: VIVEK R. HADLEY 

 Taft Stettinius & Hollister LLP 

 One Indiana Square, Suite 3500 

 Indianapolis, Indiana 46204 

 317-713-3500 

 Fax: 317-713-3699 

 Email: vhadley@taftlaw.com 

ALSO PRESENT: Defendant, James E. Snyder 

OFFICIAL REPORTER: Angela Phipps, RMR, CRR, CSR 

 5400 Federal Plaza 

 Hammond, Indiana 46320 

 (219) 852-3616 

 angela_phipps@innd.uscourts.gov 

Proceedings reported by stenotype. Transcript produced by 

computer-aided transcription. 

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

(Whereupon, proceedings were had and reported, but not

made a part of this record.) 

* * * 

(Jury present.)

CLOSING ARGUMENT BY THE GOVERNMENT

MS. KOSTER: Thank you, Judge. Good afternoon.

We're here today because James Snyder violated the public's

trust. He took an oath to serve the people of the City of

Portage, Indiana, and he violated that oath by putting his own

interests ahead of those of the people of Portage.

We have proven James Snyder guilty beyond a reasonable

doubt. At the beginning of this trial, my co-counsel, Ankur

Srivastava, told you that the Government embraces its burden of

proof. That is our responsibility to bring you proof beyond a

reasonable doubt and we have done that.

As Judge Kennelly just instructed you, the Indictment

charges Defendant with bribery. In order for you to find the

Defendant guilty of this charge, the Government must prove each

of the following five elements beyond a reasonable doubt:

First, that the Defendant was an agent of the City of

Portage. I suggest to you, ladies and gentlemen, that's

obvious. He was the mayor. He was an agent of the City of

Portage. He was also the president of the Board of Works, and

you heard testimony about that.

Second, that the Defendant solicited, demanded, accepted

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

or agreed to accept a thing of value from another person. You

heard testimony and evidence that $13,000 was provided to the

Defendant in the form of a check, that he accepted it, and went

into his bank account and the money then was transferred to his

personal account. So there is ample evidence that the

Defendant accepted a thing of value from another person.

The Defendant acted corruptly, with the intent to be

influenced or rewarded in connection with the contracts with

the City of Portage -- and I'll come back to that element in

just a minute.

The contracts involved a thing of value of $5,000 or more.

That too, ladies and gentlemen, you have heard plenty of

testimony about the contracts in this case totaled

$1.125 million.

And, finally, that the City of Portage, in one year,

received benefits of more than $10,000 under any federal

program involving a grant, contract, subsidy, loan, guarantee,

insurance or other assistance.

On that element you heard testimony directly from Lynn

Reed at the clerk treasurer's office in Portage, Indiana, as

well as from John Shepherd. Both of them told you that there's

never been a year that the City of Portage has not received at

least $10,000 in federal benefits, whether it be Medicare,

Medicaid, or grants or public safety, Department of

Transportation benefits for the building of roads, highways,

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

maintenance, that sort of thing.

So that brings us back to the one element that I haven't

yet addressed, and that is, the Defendant acted corruptly with

the intent to be influenced or rewarded in connection with

contracts with the City of Portage.

That is the element that I'm going to address for the

remainder of my argument.

First, I want to talk to you about circumstantial versus

direct evidence.

In opening statement, Mr. Bennett told you that all of the

evidence you're going to hear is circumstantial evidence; you

will hear no direct evidence that this actually happened. Now,

ladies and gentlemen, the way that that was worded in opening,

I suggest to you, is not in accordance with the law.

The law states people sometimes look at a fact and

conclude from it that another fact exists. This is called an

inference. You are allowed to make reasonable inferences, so

long as they are based on the evidence.

For example, earlier this week, it snowed overnight. You

wake up in the morning, you see snow on the ground. You didn't

see the snow fall on the ground, but it's there. You can infer

from the snow on the ground that it snowed. That's an

inference.

You may have heard the terms "direct evidence" and

"circumstantial evidence." Direct evidence is evidence that

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

directly proves a fact, such as seeing the snow fall to the

ground. Circumstantial evidence is evidence that indirectly

proves a fact, such as waking up and seeing snow on the ground.

You are to consider both direct and circumstantial

evidence. The law does not say that one is better than

another. It is up to you to decide how much weight to give any

evidence, whether it is direct or circumstantial.

I want to talk for a moment about motive to accept or

demand a bribe or gratuity. And, ladies and gentlemen, the

evidence we've presented in this case really fits into six

different categories.

The first category is this one: Motive to accept or

demand a bribe or gratuity. The other categories are:

Evidence of bid rigging, timing of the payment and the sale, no

documentation of work allegedly performed, efforts to conceal,

and consciousness of guilt.

I will address each of those categories of evidence in

turn and walk you through the evidence that was presented in

the case.

Let's start with motive evidence.

You heard ample testimony from the beginning of the trial

from Special Agent Jerry Hatagan of the IRS that the Defendant,

James Snyder, needed money.

In March of 2013, the Defendant received notices from the

IRS that he owed over $11,000 on his 2006 and 2007 taxes.

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

In April of 2013, the Defendant filled out a form for the

IRS under oath and declared he had $11,000 in credit card debt.

He was upside down on two home mortgages, for a total of over

$66,000, and he was upside down on his Honda Odyssey over

$7,000, meaning he owed more on those assets than they were

worth. So if he had sold them, he would actually still owe

money to the bank for the assets.

You also heard testimony from Special Agent Hatagan that

James Snyder received notice in September of 2013 that the IRS

was assessing against him what are called trust fund penalties,

and those trust fund penalties are for unpaid payroll taxes.

He was informed that September that $39,523 in trust fund

penalties would be assessed against him personally, meaning he

was personally liable for that additional nearly $40,000.

You also heard evidence that, in January of 2014, as was

the case in many of the prior months, the Defendant was past

due on his car payment. And by January, he was past due over

$1600.

He also had received several notices of foreclosure from

the bank; in this case, Chase Bank. And this notice, in

particular, is relevant because he received it soon -- on or

about December 11th, 2013; almost a month to the day before

the Defendant accepted the $13,000 check from Great Lakes

Peterbilt.

And in this notice, he was informed that his rental

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

property was in default, that there was an intent to foreclose

on that property, and he owed $2300.

(Audio played, Government's Exhibit 190; and 190-A

transcript displayed to the jury.)

You heard it directly from the Defendant's mouth in that

interview. He needed money.

Now let's talk about the evidence of bid rigging.

The Defendant inserted himself in the bid process for

these two contracts in a number of ways. The first way was

that he took out of the process the man who would normally have

been responsible for overseeing it, and that is Steve

Charnetzky, the superintendent of Streets and Sanitation.

You heard Steve Charnetzky's testimony that he had handled

at least 25 different bid processes in his prior years as

superintendent of Streets and Sanitation, which he had served

in that position by the time he was reappointed by James Snyder

for 16 years.

Steve Charnetzky had a ton of knowledge and experience

about the bid process, but James Snyder didn't want him

involved. Why not? Why wouldn't you want the most-experienced

person involved in a process that is quite complicated? Ask

yourselves.

Instead, he put his good friend, Randy Reeder, in charge

of that process. And you've heard testimony directly from

Mr. Reeder. He wasn't qualified to be a small engine mechanic.

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

He was working as a maintenance man, part-time, before he was

hired by the Defendant. He volunteered for the Defendant's

campaign; helped put up some signs. The Defendant promised him

a job. Next thing he knows, he's assistant superintendent of

Streets and Sanitation and responsible for the acquisition of

over $1.125 million of equipment on behalf of the City of

Portage.

And I hope it was clear, ladies and gentlemen, from the

testimony of Mr. Reeder that he is a follower. He is a

follower of James Snyder. James Snyder tells him to do

something, and he does it. That's why Randy Reeder was put in

charge of this process. 

John Beck took the stand. He was a mechanic. And I

should mention, ladies and gentlemen, these photographs are not

in evidence. They're just to remind you of the witnesses that

the Government called, because it's been -- it's been a while

since you've seen some of them.

John Beck took the witness stand and testified he was a

mechanic for the City of Portage for a very, very long time. I

think somewhere north of 20 years, 24 years. Before that, he

was a semi truck driver and drove Mack trucks.

And he told you that he had been asked to provide specs

for the trucks that would be best for the Department of

Sanitation. And he contacted Waste Management and Republic,

and he arrived at an opinion as to what type of truck the City

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

should buy, what type of truck is best for the application of

refuse collection.

And he expressed those opinions to Randy Reeder. He told

him exactly the type of truck that he preferred and why. And

significantly, perhaps not the brand didn't matter, but things

like full-eject mattered. 

And he gave you the reasons why, because sometimes the

trash can freeze overnight in the winter, and it makes it

difficult and dangerous for the employees who are trying to

empty the trash trucks at the dump or at the -- I think they

call it a station -- what is it called -- transfer station.

Thank you.

At the transfer station, the trash can get stuck in the

back of the body of the truck, and it doesn't come out. And

then they have to shove, I think he said, wooden crates into

the back to try to shove the trash, get the trash to shove out.

And that's dangerous.

He expressed his opinions to Randy Reeder. And Randy

Reeder, one of those opinions was, he does prefer a Cummins

engine. And Randy Reeder did put that into the spec.

You heard testimony, though, that, in order to make it

fair for all bidders, you would normally put something like a

Cummins engine and put the horsepower and the torque that you

prefer or equivalent. We don't see that language in this spec.

And what was interesting about the testimony that we heard

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

from the witnesses is that Randy Reeder picked and chose which

advice from the mechanics he followed; right? You heard

cross-examination of the salesmen who came in and testified by

Defendant: Well, those Mack trucks didn't have a Cummins

engine, so they couldn't have been chosen, because that's what

the mechanics wanted, Cummins engine.

Yeah, but what the mechanics also wanted was full-eject,

and that wasn't followed. So Randy Reeder wants you to believe

that Cummins engine is in there because the mechanics preferred

it, but it also just happens to be the type of engine that's in

Great Lakes Peterbilt's chasses.

And they chose not to follow the advice of the mechanics

as to other aspects.

This is Truck 406. You heard a lot of testimony about

this truck. Probably learned more about this truck than you

care to know. This is the truck that sat on Great Lakes

Peterbilt's lot for two years prior to its sale to the City of

Portage.

You heard testimony, ladies and gentlemen, that, after the

first round, after three truck contracts had been awarded to

Great Lakes Peterbilt, the Defendant and Randy Reeder tried to

purchase that truck directly from Great Lakes Peterbilt; and

they -- Randy Reeder wrote an email to Greg Sobkowski, the City

Attorney saying, "Mayor wanted me to ask you if the City was

able to order a fourth Peterbilt truck with the same body

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

style. Do we have to rebid, or can we just order another one

like the three we just purchased?" 

They were looking to do it directly. They wanted to do it

directly. But Mr. Sobkowski said, "If it costs more than

$150,000 you have to have a bid process; that's the law."

So what does the Defendant do? He says, "Well, how much

is it?" Randy Reeder says, "It's 180 to 200." Randy Reeder

says, "He probably called Steve Charnetzky." His recollection

is Charnetzky said, "Yeah, we can't sell it for less than

$150,000," so they had to do a bid process.

But that didn't stop James Snyder from asking, ask him if

they can get it below 150; we can buy it directly without doing

a formal bid process. They were motivated and interested in

buying that truck. And ask yourselves why; why the interest in

this two-year-old truck that had been sitting on Great Lakes

Peterbilt's lot?

Do you think it was the only used truck in this area

available for sale that could carry refuse? Of course it

wasn't. It was the only used truck -- I said the word "used."

I didn't mean "used" in the sense that it had been titled and

driven; I just meant older. Used in the sense it was aged.

Was it the only aged truck sitting around that could have been

sold to the City of Portage? Of course not, no. But it was

the only aged truck that Great Lakes Peterbilt was desperate to

sell.

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

How else was this bid process rigged? You heard testimony

from Lynn Reed. She's been in the clerk treasurer's office, I

think she said, over 30 -- 35 years. And she told you that

addressing the bids to the mayor's office was highly unusual.

It hadn't been done in the past. They were supposed to go

to the clerk treasurer's office. Why are they supposed to go

to the clerk treasurer's office? Because that is the

individual and the office that is responsible for securing them

and making sure and knowing what's happening with those bids

between when they're received and when they're opened at a

public meeting.

And you've heard some testimony -- We've asked some

witnesses about these envelopes that we had. They're in

evidence. They're Government's Exhibit 53. And the bottom

line, ladies and gentlemen, with regard to these envelopes and

with regard to whatever happened after the bids were delivered

but before they were opened at a public meeting is this: We

don't know. We don't know what happened. And I suggest to you

that that was by design.

Randy Reeder and James Snyder directed that the bids be

delivered to the mayor's office, and that wasn't an accident.

It was an unusual thing that hadn't happened before and hasn't

happened since. They've told you that just in the last few

days. You've heard testimony that has been changed. That was

not an accident. The envelopes were delivered there, and it

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

was highly irregular, and you'll have a chance to look at them

yourselves.

But one thing we do know: The handwriting on this

envelope does not belong to Scott McIntyre. He testified under

oath that's not his handwriting. Does not belong to Robert or

Steven Buha. And if you look through the exhibits in this

case, you'll see there are some handwriting exhibits with

Robert and Steven Buha's handwriting. Both of them have

beautiful penmanship. Beautiful. Remarkably beautiful

penmanship. This is not their handwriting. He wasn't kidding

when he said, "I write much neater than that." He has

beautiful penmanship. Not this.

You heard testimony from three men who have worked in the

trucking industry for a long time as salesmen. Their job is to

sell trucks. Their goal is to get companies and municipalities

and cities to buy their trucks. And they each noticed

irregularities in this process.

Now keep in mind, ladies and gentlemen, these are people

who don't know about the $13,000 payment, who don't know about

a lot of the other facts that you know about. All they knew

about were the invitations to bid, the specs, and the voting on

the bids. That was the extent of their knowledge. And based

on just those facts, they observed things that were not normal,

that were irregular, that seemed to them to be improper.

And some of them were so frustrated and dismayed by what

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

they saw, they didn't even bid in the second round. These are

salesmen who make their livelihood selling trucks, and they

didn't even try to sell trucks in the second round. What does

that tell you?

Another irregularity and other evidence of bid rigging is

the communication between only one of the salesmen involved in

the process, or one of the companies involved in the process,

and James Snyder.

And we put into evidence these telephone summaries that

show you -- this is the first round of bidding. We checked

every phone number provided by all of these salesmen on the

paperwork to the City, and these are the only numbers that were

called.

In the first round, Steven Buha. He was the only salesman

the Defendant had direct contact with. Why is the mayor of

Portage talking and texting with a man who is in the process of

and then submits a bid to the City to sell equipment? Why

would that be happening? Why has the mayor injected himself

into this process?

And this is the second round. Way more communication

during the second round between the Defendant and both Robert

and Steven Buha. Again, why? You heard testimony that there

was allegedly a consulting arrangement. Well, that

arrangement, even if you believe it existed, didn't occur until

January 10th, 2014. That's after this process ended. This

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

is not consulting that's happening here. What are they talking

about? Why are they talking? Why are they meeting?

We know they met because there's emails; there's Outlook

invitations to meetings that were found by the Government's

search warrant. Why are they having lunch the day before the

bids are due?

Defendant called Bob Buha to testify, and you heard from

him yesterday and today, but you didn't hear testimony or

questions about that. Ask yourselves why not.

Taking you back to Truck 406, you heard testimony and

evidence that the general terms of the specifications issued by

the City state, "All equipment furnished shall be new, unused,

and the same as the manufacturer's current production model."

Defense counsel tried to get up when cross-examining some

witness and say, "Well, that's not really where the specs are.

The specs are really on the following pages."

These are the general terms. And it says "shall" --

"shall be new, unused and the same as the manufacturer's

current production model." 

And you heard witness after witness say that this truck

was not the same as the manufacturer's current production

model. It was a model 2012, and it was sold to the City at the

same time as a new truck right off the assembly line, which was

a model 2015. They are not the same. 

You heard testimony and evidence about the EPA changing

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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

the emissions standards in between there.

You heard testimony and evidence that every year these

trucks become more expensive. Why? Better and faster computer

chips and other things are put into the trucks. They developed

these trucks. They make improvements.

You know, in your mind, if you went to a dealership and

said, "I want to buy a new car," and they said, "Here's this

perfectly good 2018," would you say, "Oh, yeah, that's probably

the same as the 2021"? Sure. Of course, it's not. You

wouldn't want it. Why would the City want it?

Government's Exhibit 167 shows that that truck was built

in November of 2011. It was delivered to Great Lakes Peterbilt

at that time, and it sat on their lot for two years. The

Cummins engine passed 2010 emissions standards, not 2013

emissions standards.

Government's Exhibit 87 is a document where Randy Reeder

sends out two weeks before the Board of Works votes in the

second round, he sends out this chart. And the chart has and

compares every other bid in the first round to Great Lakes

Peterbilt's bid.

So two weeks before the Board has even voted, has even

decided they're going to go with Great Lakes Peterbilt,

Randy Reeder has created a chart showing and comparing that

particular bid to every other bid.

It's obvious from the testimony and evidence, and you can

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 17 of 77
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Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

use your common sense, that they chose to prioritize the

delivery date over every other spec that was written in the

specifications for a reason. They did it because Great Lakes

Peterbilt was one of the only companies that could meet that.

Probably, they thought, the only company. Unbeknownst to them,

Best had a Peterbilt 320 that happened to have already been

manufactured and could meet that same deadline.

You heard testimony from Randy Reeder about the delivery,

because both Charnetzky and Mr. Beck, when asked, said there

was no rush. Yeah, it was time to buy some new trucks, and

everybody was in favor of the automation. Government is not

arguing automation was bad or trucks shouldn't have been

purchased. Any one of these trucks would have been automated.

The point, ladies and gentlemen, is that they favored

Great Lakes Peterbilt's trucks, and Randy Reeder told you why.

He said the mayor has pressed that this should happen as soon

as possible. The urgency came from the mayor.

That was one of the things-- and the mayor's knowledge

about that 150 days --that Mr. Reeder got on the stand in a

previous hearing and tried to retract from his grand jury

testimony. And why would he do that? Why would he retract

something he already said under oath? He did it because the

Defendant asked him to, just like everything else Randy Reeder

does. Defendant asks him, and he does it.

And if you look at the two charts and comparing now

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 18 of 77
 Page 19

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Government's Exhibit 34 with Government's Exhibit 38, you can

see that a lot of people who bid in the first round, including

some of the salesmen that you heard from during the trial,

decided not to even bid in the second round.

And what's so interesting if you compare the two rounds is

that, in the first round, it was all about the delivery date.

It was all about speed, how fast can we get it; right? 

They prioritized delivery over price. They paid $59,000

for a truck because it could be delivered -- $59,000 more for

three trucks, excuse me, that could be delivered within

150 days, which worked out to about $560 a day for those trucks

than they could have paid if price was the most important

thing, for other trucks that just would have taken longer to

manufacture.

And both Charnetzky and Beck told you there was no

urgency. There was never a day that the City of Portage was

not able to pick up all of the trash. They had enough working

vehicles. They had even retrofitted tippers on the back of

their rear-loaded refuse vehicles.

There was no urgency. The only urgency came from

James Snyder. And Randy Reeder admitted that in the grand

jury. He had said he never did find out from James Snyder what

was the rush.

Yet, in the second round, they didn't prioritize delivery

date over price, like they had in the first. In the second

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 19 of 77
 Page 20

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

round, they prioritized price over delivery date; just the

opposite.

There was one truck that was available 21 days after being

ordered, but they didn't order it. What happened to the

urgency? All of a sudden, the urgency was gone and now what we

care about now is the price. After paying $60,000 extra in the

first round, now we care about price.

And you heard that Randy Reeder created this chart and he

wrote at the bottom, "All companies meet bid specs and lowest,

responsive-bidder goes to lowest cost," but that wasn't true.

Not all of the companies met the bid specs.

Both Link and Peterbilt were trying to sell a chassis to

the City of Portage that was a model 2012. That didn't meet

the specs. Under Indiana law, it should have been rejected.

And it wasn't. Why wasn't it?

The only people who knew about the model 2012,

Randy Reeder and the mayor. The only people at the Board of

Works meeting who knew about the model 2012 stayed silent and

didn't mention it.

Mayor Snyder voted in favor of awarding the contracts in

both rounds to Great Lakes Peterbilt, and I suspect you might

hear, ladies and gentlemen -- It was under law, he has to be on

the Board of Works so that, you know, it was his duty to vote.

There's nothing wrong with that. He could have recused

himself. He could have said, "You know, I had all this contact

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 20 of 77
 Page 21

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

with this company. It's probably not appropriate for me to

vote on this particular contract." But he didn't do that. He

voted, and he voted in favor of Great Lakes Peterbilt.

So let's talk now about the timing of the payment and the

timing of the City's purchase of that truck.

Steve Buha and Bob Buha, the owners of Great Lakes

Peterbilt, were in dire straits during this time. You heard a

lot of testimony about, yes, in November of 2014 they sold

their business and they got -- we got different numbers, but

probably Mr. Buha knows best. He said around $5 million net.

So, yeah, they were sitting pretty in November of 2014.

But that was not the case in 2013.

You heard testimony, the very first witness who testified

at trial, Mr. Peyton Harrell from Peterbilt Motor Company. And

he told you Great Lakes Peterbilt was one of the most

underperforming dealer groups in the Peterbilt dealer network,

ranking 55 of 61 in 2013 and 53 of 61 in 2014. The dealership

has shown a negative net profit three of the last six years.

He told you their credit rating had been lowered from a D

to an E, that they had been put in SOT status. "SOT" means

"sales out of trust," meaning they sold trucks; they sold

trucks and didn't pay back their financier, PACCAR, despite

getting the cash in their account, didn't turn that cash back

over to PACCAR. They were sales out of trust.

He also told you that Steve and Bob Buha infused $450,000

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 21 of 77
 Page 22

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

into the dealership. And I walked the agent through the bank

records to show money comes out of Edward Jones, goes into the

operating account, and goes into the payroll account and into

the FET account and into the operating account -- Sorry. I

misspoke. Went out of Edward Jones into Steve Buha's checking

account, then went into the payroll account, the FET account

and the Great Lakes Peterbilt operating account.

I suggest to you, ladies and gentlemen, you don't take

money out of your personal retirement account unless your

business depends on it, unless you're literally going to lose

your business and the only way to make payroll is to get that

money out of your personal retirement account and use it to

make payroll; and that's what happened. 

And Brett Searle testified that the second time it

happened, which was $150,000 taken out of Steven Buha's

retirement account, he didn't get paid back before selling the

dealership. He did get money, though; obviously, they were

doing fine after they sold the dealership, shew. But during

this time, they were in trouble.

They were past due $76,000 the same month they wrote a

check to James Snyder for $13,000. What sense does that make?

What sense? It makes no sense. Your business is failing, and

you write a $13,000 check for IT and health insurance

consulting? So they claim. That makes absolutely no sense. 

They wanted to sell this truck, Truck 406. They needed to

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 22 of 77
 Page 23

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

sell this truck. They had $45,000 invested in this truck.

They had $60,000 due on this truck. It came due on

November 24th, 2013, just a month before the Board of Works

voted to buy the truck. So they were overdue by a month on

this curtailment, these curtailment payments, by the time they

finally sold it.

If they didn't make those curtailment payments, PACCAR

could have taken back the truck, and they would have lost their

$45,000 they had invested in that truck.

By selling the truck, they get back their 45,000, plus the

additional 30,000 they made a payment on January 3rd, 2014.

So they get back their $75,000. They can use that money in

their operating account. They were cash-poor. They were

non-liquid. They had cash-flow problems. They needed that

money back.

We saw a text exchange between Steve Buha and James Snyder

where James Snyder says, "I have a purchase order for you. You

there today?" And we know that purchase order was delivered,

because Randy Reeder testified he wrote it up. He gave it to

James Snyder. We see James Snyder's signature on it. The

purchase order is dated January 3rd, 2014. And we know that

on that date the Buhas made a $30,000 payment toward the truck.

Probably, they were saying, if we weren't going to be able

to sell that truck, we might just have said goodbye to that

$45,000. But once they had a purchase order in hand, okay, we

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 23 of 77
 Page 24

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

can make this $30,000 payment, we'll use the purchase order to

get an extension from PACCAR on the remaining $30,000. That's

exactly what happened.

You can see here in this memo from January of 2014, "Great

Lakes Peterbilt has requested approval to postpone the final

payment on one new 2012 Peterbilt vehicle identification number

ending in 412, given the pending sale to the City of Portage,

PO attached." Purchase order attached. 

And you heard from Bob Buha himself today said: Yeah, it

would be helpful to have that, right, because then they know

you're good for the money; you're going to get the money from

the City of Portage.

And what's interesting about this evidence, ladies and

gentlemen, is that they did get a curtailment modification, and

they were permitted until April 30th to pay for this truck.

But as of May 1st, 2014, they still hadn't paid. They still

had, and if you look at the very bottom of the current balance,

call them, you'll see they still had a balance as of May 1st

of $30,237.

Do you remember Bob Buha, what he said today on the stand:

Took a while to get paid. Like, it took longer than we would

have liked. That was a frustration. I made a lot of phone

calls.

They needed that money, ladies and gentlemen. They

needed it.

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 24 of 77
 Page 25

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

And you heard some testimony about political donations

that were made to the Defendant by the Buhas. This is a

timeline to put those donations into context, okay? We have

when Snyder takes office, and then we have the two different

rounds of bidding for the truck contracts.

You can see that, in the beginning, in 2012, they gave

$2,000 to Snyder for his roundtable. They joined the

roundtable. 2013, they gave $2,000 for his trip to Austria.

They donated that money to his PAC. But even more, they then

wrote a check for $5,000 to James Snyder for the golf outing.

Now, Brett Searle told you that James Snyder was the only

political candidate that the Buhas were giving donations to

directly that he can recall.

Bob Buha on the stand made it sound like, "Oh, yeah, you

know, I make these donations. I don't know. I don't keep

track of who we give the money to." They were giving it all to

James Snyder, and they were doing that at a time that they were

in deep trouble. Why would they do that? 

Mr. Searle told you he likes to have backup when he writes

a check. This is a good example. This is part of Government's

Exhibit 20. This is when they made the check for the Austria

trip. He kept in his file a copy of the Austria letter. And

then you have the printout, which is a copy of the check. He

likes to have backup. 

And there was something interesting about that $5,000

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 25 of 77
 Page 26

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

payment. Government is not alleging there was anything illegal

about that payment. However, it is very interesting, they

agreed to be gold sponsors of a golf outing, which should get

them recognition throughout the day, and a foursome, but then

they decide we're not even going to show up. You can give away

our tee spot, but we're going to be gold sponsors. 

Who sponsors an event and then doesn't show up for the

recognition? If you're sponsoring an event to get recognition

in the community to prompt sales, you would think you would

want to be there so the other members of the community that are

participating in the event could see you there and you would

get that recognition. There's something in it for them, too,

when they give a political donation along these lines. But yet

they didn't show up. They didn't come.

Instead, Steve Buha wrote a personal check to James

Snyder, which was deposited into his account, and then reported

on his campaign account as a $5,000 donation from Steve Buha

personally. But you heard testimony from Mr. Searle that he

was reimbursed. Steve Buha was reimbursed for this donation.

And I asked him: Well, why couldn't Great Lakes Peterbilt have

just made the check out directly? He didn't know.

And then finally we saw this $13,000 payment in January of

2014. So to put that in context, and regarding the timing, it

is important to note that just two weeks after receiving the

second of two contracts worth $1.125 million, the Buhas cut

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 26 of 77
 Page 27

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

that $13,000 check to James Snyder.

Now I want to talk to you about the lack of documentation

of work allegedly performed.

(Government's Exhibit 188 audio played.)

So let's review. In July of 2014, Steve Buha tells the

FBI six different times: We have a contract. We have a

written contract. In fact, I think we even ran it past a

lawyer. You can't do that without a written contract; right?

He's confident they have a written contract. That's what he

tells the FBI. And guess what? There was no contract. He

lied.

I submit to you, ladies and gentlemen, that it is not

believable for Bob Buha to take that witness stand and tell you

he did think we had a contract, but he wasn't sure and, you

know, he couldn't remember. This is the mayor of Portage. If

you entered into a contract with a public official who was the

mayor, you would remember it. It's not something you forget.

You either have the document or you don't, especially after the

fact when the FBI comes knocking.

You heard testimony that there were two subpoenas issued

by Government to try to obtain copies of this contract, and any

other documentation, any other written documentation showing

actual work performed -- letters, summaries, emails even,

business cards, anything at all showing actual work performed.

And when I say "business cards," I'm talking about with "SRC

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 27 of 77
 Page 28

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Consulting" on it. Because, as you heard, ladies and

gentlemen, multiple witnesses were asked, "Did you ever have

any letterhead with SRC Consulting? Anything else?" No. Why?

It didn't exist.

There's no evidence in the record of the existence of SRC

Consulting, except for the check for $13,000. That is the only

evidence of its existence. That is in the record.

Now I want to talk to you about efforts to conceal.

(Audio of Government's Exhibit 150 played; and 150-A

transcript displayed.)

That was the full discussion, the full discussion before

the second round contract was awarded. Nobody mentioned. We

know Randy Reeder was present. We know James Snyder was

present. We can hear their voices. They didn't mention the

age of the model 2012 truck to the other voting members.

And on the subject of concealment, I already mentioned

about SRC Consulting, that the only place that that company

appears on any piece of paper in the record is on this check.

We know that SRC Properties was registered with the

Indiana Secretary of State. It was registered as a mortgage

company. And James Snyder was the only signatory on its bank

account. That is the account into which the $13,000 check was

deposited. This is Government's Exhibit 18.

And we know from Government's Exhibit 157 that the

Secretary of State documentation shows James Snyder registered

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 28 of 77
 Page 29

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

SRC Properties effective September of 2009, but that it was

administratively dissolved on February 14th, 2013; almost a

year before he got a check made out to SRC Consulting and

deposited that check into SRC Properties' bank account.

(Government's Exhibit 190 audio played; and Government's

Exhibit 190-A transcript displayed to the jury.)

And I'm going to stop it there. It gives you a long

explanation that basically tells you nothing about SRC -- what

is it, why is it receiving this check made out to SRC

Consulting?

That was an effort at concealment, ladies and gentlemen.

To the extent that it was not smart to accept a bribe in the

form of a check, I would submit to you that it was at least

smarter that it wasn't made out to him. And you notice when

you look at the back of the check, he didn't even endorse the

check; he didn't sign his name on the check.

It was also an effort at concealment in the sense that I

will talk about this in a second, that he didn't disclose it to

the City of Portage as he was required under the ordinance that

was shown to you by Nina Revas, the current clerk treasurer.

And the ordinance states that statements of economic

interest must be filed for the preceding year no later than

February 1st of each year, complete through February 1st of

the preceding year, and that it must disclose the name of any

person from which the official received any compensation to

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 29 of 77
 Page 30

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

which, to the best of the filer's knowledge, does business with

an agency during his or her term of office or employment with

an agency, or is in the process of bidding for a contract with

an agency during his or her term of office or employment with

the agency. 

James Snyder should have disclosed that payment to the

City of Portage. And what's really interesting about it, is

that he knew he was supposed to, because he says it to the FBI

in the interview clips that you heard: Oh, yeah I'm supposed

to do that, but not until next year, February. 

February comes. And even though the FBI asked him about

the payment, he doesn't disclose it to the City.

It's not because he didn't know how to fill out the form,

because, here, we have a copy of his 2014 form. This is

Government's Exhibit 163. He knows about the form. He knows

he's required to fill it out. He did fill it out for the

preceding year, but he didn't fill one out in 2015 for the 2014

year.

And there's no question that Great Lakes Peterbilt was

doing business with the City of Portage at the time. This is

Government's Exhibit 2, was put into evidence by Lynn Reed, and

it shows all of the different payments to Great Lakes Peterbilt

during 2013 and 2014. They were doing business with the City

of Portage.

And that brings me to the final category: Consciousness

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 30 of 77
 Page 31

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

of guilt. "Consciousness of guilt" is a fancy way of saying

"behavior that looks and smacks of guilt." If it looks like a

duck and it talks like a duck and walks like a duck, it must be

a duck. "Consciousness of guilt," ladies and gentlemen.

You heard that James Snyder told John Shepherd he was

doing lobbying work for Great Lakes Peterbilt, lobbying

regarding truck matters in Indianapolis.

And he told Randy Reeder he was doing phone and payroll

consulting -- phone and payroll. Yet, he told the FBI a

different story.

(Government's Exhibit 190 audio played; and Government's

Exhibit 190-A transcript displayed to the jury.)

How do we know that James Snyder was not doing health

insurance consulting? We know because he wasn't licensed to be

a health insurance consultant. And Mr Evans testified and

walked you through the definition of a "consultant," a person

who, in exchange for money, holds themselves out to the public

as being engaged in the business of offering, or for a fee,

offers any advice, counsel, opinion, or service with respect to

the benefits, advantages, or disadvantages promised under any

policy of insurance that could be issued in Indiana.

James Snyder had never applied for a license, nor had he

ever taken classes that one would need to take in order to

become licensed in health insurance consulting.

There's also evidence in the record-- this is Government's

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 31 of 77
 Page 32

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Exhibit 51 --that shows that, when questions were asked

relating to health insurance-- and this is as of November of

2014, 10 months after he supposedly was hired by the Buhas to

be a health insurance consultant --James Snyder is still

referring questions about health insurance to actual health

insurance consultants like Mark Miller.

And Lynn Reed put into evidence the financial statements

from the City showing payments to Mark Miller. He was hired as

a consultant.

You also heard testimony from two witnesses who addressed

the Defendant's lack of IT knowledge; Josh Pagel and Grant

Andres; and they both testified based on their conversations

with the Defendant. And you know, if you're an expert and you

know something about a specific area, you can tell by talking

to another person who has that same interest exactly how much

do they know. Do they know more than you? Do they know less? 

And experts can tell pretty quickly where they're talking

to somebody who speaks their language; and both of these men

said James Snyder did not have advanced-level knowledge or even

greater-than-the-average person's knowledge when it came to IT

matters.

And, again, we have an exhibit, Government's Exhibit 70

that shows that James Snyder himself, his own business, was

hiring an IT consultant. This is in October of 2013, just a

few months before, supposedly, he's going to work as an IT

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 32 of 77
 Page 33

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

consultant for Great Lakes Peterbilt. He's hiring, meaning

paying out of his own pocket, IT consultants.

(Government's Exhibit 190 audio played; and Government's

Exhibit 190-A transcript displayed.)

So why is that answer in a section of argument about

consciousness of guilt? Because it's an obvious lie. It's an

easily proven lie, and we have proven it to be a lie through

the testimony and the evidence in this case.

Why would James Snyder tell the FBI: I have nothing to do

with the bid process. Nothing at all. Nope, completely

separate from me. I stay out of it on purpose?

Why would he do that? Because he knew how it looked. He

got a payment from a company that had just gotten

$1.125 million in contracts from those bid processes. He

wanted the FBI to believe he had nothing to do with it.

Well, they didn't take him at his word, ladies and

gentlemen. That's their job. People give them information.

They verify it. Not all the information turns out to be true.

And that's true of witnesses. It's true of everybody; right?

But that's their job. They have to investigate. And that's

what they did. They investigated, and the investigation showed

it wasn't true.

Other evidence of consciousness of guilt: James Snyder

directed Steve Charnetzky to fire John Beck because he was seen

talking to the FBI at the Streets and Sanitation Department.

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 33 of 77
 Page 34

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Why wouldn't he want city employees to talk to the FBI? If

there was nothing wrong with his relationship with the Buhas in

accepting that $13,000, so what, let him talk. Why would you

tell somebody to fire another person just because they're

talking to the FBI, unless you have something to hide?

And who else did he tell what to say or do in this case?

He told Randy Reeder to retract his testimony in the grand

jury. Retract. And you may remember Randy Reeder was on the

stand, and we were talking about how in the grand jury he

volunteered -- he had like an epiphany: I was a pawn; he used

me like a pawn. 

And then later Snyder told him retract that, and so

he did.

Well, the Judge's instructions indicate to you that: When

you hear evidence that before trial a witness made a statement

that is inconsistent with their testimony here in court, you

may consider the inconsistent statement made before the trial

to help you decide how truthful and accurate the witness'

testimony was here in court. If the earlier statement was made

under oath, you can also consider the earlier statement as

evidence of the truth of whatever the witness said in the

earlier statement.

Randy Reeder is the definition of a "pawn." What can get

more pawn-like that when you say you're a pawn and the person

who is incriminated by that says "Take that back," you take it

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 34 of 77
 Page 35

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

back? And that's what he did. He tried to take it back. But

it's sworn testimony under oath, ladies and gentlemen.

THE COURT: I'm just giving you a head's up; you're

at about 55 right now.

MS. KOSTER: Thank you, Judge.

And then we saw the defense's star witness, Bob Buha, take

the stand.

Bob Buha told you his account is that the consulting

arrangement wasn't even conceived of until about a week to two

weeks before they wrote the check, the $13,000 check, to James

Snyder.

And, ladies and gentlemen, I wish I had put the slide back

in here, but remember what happened a week before that check

was written? The text message: I have a purchase order for

you. James Snyder to Steve Buha.

Then the handwritten purchase order by Randy Reeder, it

gets delivered to Great Lakes Peterbilt just in time for them

to seek a curtailment modification. They needed that purchase

order. They needed it. He delivered it. They submitted it to

PACCAR to get an extension on that $30,000 payment.

James Snyder went to Great Lakes Peterbilt that day with

that purchase order. Bob Buha's account proves he's guilty.

He hands them a purchase order for the truck they're desperate

to sell and says: I need money. I need money. I have tax

problems. I've got these family things, the holidays.

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 35 of 77
 Page 36

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Whatever explanation he gives. 

And Bob Buha says: Well, we're not going to pay you

15,000, but we'll pay you $13,000 up front. Because somehow

that math makes it seem reasonable to pay a public official

$13,000.

Keep in mind, the government proves its case if the

defendant acted with intent to be influenced or rewarded -- or

rewarded.

And you heard my colleague, Ankur Srivastava, ask Mr. Buha

questions about: Well, why do you think he came to you

that day? 

He went to the company that just won $1.125 million in

bids and told them he needed money. He was asking for a

reward.

And let's talk about Bob Buha.

We know he lied to law enforcement. He said it was his

idea to hire James Snyder. Well, that's not true. It wasn't

his idea at all. According to him, James Snyder showed up at

his business and said: I need money.

And when he was confronted with that in the grand jury, he

said: Well, that was a defense mechanism. 

Why, Mr. Buha, did you make it seem -- When you were

interviewed by law enforcement in July of 2014, why did you

make it seem like that was a legitimate transaction, like you

had actually received $13,000 worth of work performed? Why?

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 36 of 77
 Page 37

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

He said: "Defense mechanism." His words, "Defense

mechanism."

"Because you thought you might be in trouble; right?" 

"Yes."

So James Snyder wasn't the only one with consciousness of

guilt.

But Bob Buha lied to law enforcement to make it look like

the transaction had been legitimate, just like Steve Buha did.

We have a contract, six different times. 

He also then failed to disclose that he had just met with

the mayor when the FBI came in to interview him.

If you're a victim of a crime, if the mayor has shown up

and asked you for money and you only paid him because he's the

mayor, wouldn't you want to tell the FBI about that when they

came to your business? Wouldn't you say, "I'm glad you guys

are here, because you're never going to believe what's been

happening. James Snyder came to us and asked us for money

right after we won these contracts. We paid him, you know,

because he's the mayor." But they didn't do that. He didn't

do that.

What else was unbelievable about Bob Buha's testimony? He

said he was angry. Do you remember at the beginning of the

direct: I'm angry about the press coverage and the way -- the

things people have been saying about what happened. I'm angry

about it.

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 37 of 77
 Page 38

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

Well, if you're angry about the press coverage and you're

concerned about the press coverage, you would remember the

facts related to the press coverage; right? You would remember

the days you had meetings, what you talked about. You would

remember the services rendered. You would be able to recite.

It's your reputation. 

These men are still businessmen in the community. They've

lived in this community their entire lives. Their reputation

is at stake. And he comes in and says: I can't really

remember. I don't know. I can't remember if I said that, and

if the record says I said it, then I said it.

Really? You're angry and you can't remember anything?

Doesn't that strike you as odd, as unbelievable?

He says: Well, no, no. Not a loan. But we'll just hand

him the money.

Explain that to me. At least with a loan you might get

some payment back; right? Why not a loan? Why not a loan? No

way. But, yeah, we'll hand him a check for $13,000 in advance

without a contract and with no, you know, really understanding

of what work is going to be performed. That's fine. But loan,

no. What sense does that make? 

He admitted Snyder was a man of influence, he called him.

A man of influence. And that is consistent with what Brett

Searle told you. That Bob Buha told him when he was writing

the $13,000 check and he asked for backup and none was

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 38 of 77
 Page 39

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

provided, Brett Searle said that Bob Buha said: He's the

mayor. He's got a lot of contacts. He's got a lot of

contacts, that mayor. I want the inside track.

Man of influence.

And, yet, today Bob Buha denied ever saying that.

We have met our burden. We have proven that James Snyder

is guilty of accepting a bribe, accepting the $13,000 with

intent to be influenced or rewarded in connection with

contracts of the City of Portage. He violated the public's

trust. He took an oath to serve the people of Portage. And,

instead, he put his own financial interests ahead of those

people.

We have proven James Snyder guilty beyond a reasonable

doubt; and for that reason, we ask that you find him guilty.

Thank you.

(WHEREUPON, further proceedings were had and reported, but

not made a part of this record.)

* * * 

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 39 of 77
 Page 40

Angela Phipps, RMR, CRR, CSR

(219) 852-3616 - Angela_Phipps@innd.uscourts.gov

CERTIFICATE OF REPORTER

 I, Angela Phipps, RMR, CRR, CSR, certify that the 

foregoing is a true, complete, and accurate excerpt of 

transcript of the record of proceedings in the above-entitled 

matter before the Honorable Matthew F. Kennelly, on March 18, 

2021. 

Date: March 24, 2021 S/Angela Phipps, RMR, CRR, CSR 

 Official Court Reporter

 for the U.S. District Court

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 40 of 77
 MS. KOSTER: [2]

 3/6 35/5

 THE COURT: [1] 

 35/3

$

$1.125 [5] 4/14

 9/6 26/25 33/14

 36/12

$1.125 million

 [5] 4/14 9/6

 26/25 33/14

 36/12

$10,000 [2] 

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$11,000 [2] 

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$13,000 [17] 

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$150,000 [3] 

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$2300 [1] 8/2

$30,000 [4] 

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$30,237 [1] 

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$39,523 [1] 

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$40,000 [1] 

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$450,000 [1] 

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$59,000 [2] 

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$60,000 [2] 

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$66,000 [1] 7/4

$7,000 [1] 7/5

$75,000 [1] 

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$76,000 [1] 

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-

--that [1] 

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1

10 [1] 32/3

10th [1] 15/25

11th [1] 7/22

14th [1] 29/2

15,000 [1] 36/3

150 [3] 12/12

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150 days [1] 

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150-A [1] 28/9

1500 [1] 1/13

157 [1] 28/24

16 [1] 8/17

163 [1] 30/15

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18 [3] 1/8

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188 [1] 27/4

190 [4] 8/3

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190-A [4] 8/3

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1st [4] 24/16

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2

20 [2] 9/20

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2006 [1] 6/25

2007 [1] 6/25

2009 [1] 29/1

2010 [1] 17/14

2011 [1] 17/12

2012 [7] 16/22

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 41 of 77
2

2013... [3] 

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2014 [16] 7/15

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2015 [2] 16/24

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2018 [1] 17/8

2021 [4] 1/8

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2023 [1] 1/21

2029 [1] 1/17

21 [1] 20/3

219 [2] 1/17

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219-852-2770 [1]

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219-937-5500 [1]

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24 [2] 9/20

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24th [1] 23/3

25 [1] 8/14

2770 [1] 1/14

2:16-cr-00160-MF

K-2 [1] 1/4

3

30 [1] 13/3

30,000 [1] 

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30th [1] 24/15

312-353-3148 [1]

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3148 [1] 1/18

317-713-3500 [2]

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317-713-3699 [2]

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320 [1] 18/6

34 [1] 19/1

35 [1] 13/3

3500 [4] 1/21

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3616 [1] 2/11

3699 [2] 1/22

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406 [3] 11/14

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46204-2023 [1] 

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51 --that [1] 

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6

60604-2029 [1] 

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61 [2] 21/17

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70 [1] 32/22

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852-3616 [1] 

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able [4] 11/25

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about [58] 

above [1] 40/4

above-entitled

 [1] 40/4

absolutely [1] 

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accept [4] 4/1

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USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 42 of 77
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accepted [4] 

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accepting [3] 

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accident [2] 

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accordance [1] 

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According [1] 

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account [22] 

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accurate [2] 

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acquisition [1] 

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acted [3] 4/7

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actual [3] 

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actually [3] 

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additional [2] 

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address [2] 5/6

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addressing [1] 

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administratively

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admitted [2] 

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advance [1] 

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advanced [1] 

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advanced-level

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advantages [1] 

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advice [3] 11/2

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after [12] 

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afternoon [1] 

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age [1] 28/15

aged [3] 12/21

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agency [4] 30/2

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agent [5] 3/20

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aided [1] 2/25

all [18] 5/10

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allegedly [3] 

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alleging [1] 

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allowed [1] 

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almost [2] 7/22

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along [1] 26/13

already [3] 

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AMERICA [1] 1/3

ample [2] 4/5

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 43 of 77
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ample... [1] 

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Andres [1] 

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angela [4] 2/10

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angry [5] 37/22

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ANKUR [3] 1/16

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Ankur.Srivastava

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another [8] 4/1

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answer [1] 33/5

any [11] 4/16

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anything [4] 

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APPEARANCES [2] 

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appears [1] 

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application [1] 

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applied [1] 

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appropriate [1] 

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approval [1] 

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April [2] 7/1

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are [26] 5/17

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area [2] 12/17

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arguing [1] 

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argument [4] 

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around [2] 

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arrangement [3] 

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arrived [1] 

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as [32] 3/16

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ask [7] 8/21

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asked [11] 9/22

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asking [2] 

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asks [1] 18/24

aspects [1] 

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assembly [1] 

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assessed [1] 

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assessing [1] 

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assets [2] 7/5

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assistance [1] 

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assistant [1] 

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attached [2] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 44 of 77
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attached... [2] 

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Attorney [1] 

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Attorney's [2] 

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audio [6] 8/3

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AUSA [2] 1/12

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Austria [3] 

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automated [1] 

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automation [2] 

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available [2] 

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average [1] 

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awarded [2] 

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awarding [1] 

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away [1] 26/5

B

back [19] 4/9

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backup [3] 

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bad [1] 18/12

balance [2] 

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bank [7] 4/4

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based [3] 5/18

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basically [1] 

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be [32] 4/7

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beautiful [4] 

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because [28] 

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Beck [5] 9/13

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become [2] 17/3

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been [22] 4/22

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before [19] 1/9

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before the [1] 

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beginning [4] 

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behalf [1] 9/6

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 45 of 77
B

behavior [1] 

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being [2] 20/3

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believable [1] 

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believe [4] 

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belong [2] 14/4

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below [1] 12/12

benefits [4] 

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BENNETT [2] 

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best [5] 9/23

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better [2] 6/5

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between [5] 

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beyond [4] 3/11

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bid [23] 6/14

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bidder [1] 

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bidders [1] 

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bidding [3] 

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bids [7] 13/4

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Board [6] 3/23

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Bob [17] 16/7

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body [2] 10/14

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both [10] 4/21

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bottom [3] 

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 24/17

brand [1] 10/5

Brett [4] 22/14

 25/11 38/23

 39/1

bribe [4] 6/9

 6/13 29/12 39/7

bribery [1] 

 3/17

bring [1] 3/14

brings [2] 5/2

 30/25

Buha [29] 14/6

 15/14 15/22

 16/7 21/6 21/6

 21/10 21/25

 23/16 24/9

 24/20 25/14

 26/15 26/17

 26/19 27/5

 27/13 35/6 35/8

 35/15 36/2 36/9

 36/15 36/22

 37/7 37/8 38/24

 39/1 39/5

Buha's [5] 14/8

 22/5 22/15

 35/22 37/21

Buhas [6] 23/22

 25/2 25/12

 26/25 32/3 34/2

building [1] 

 4/25

built [1] 17/11

burden [2] 3/13

 39/6

business [13] 

 21/9 22/10

 22/11 22/22

 27/24 27/25

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 46 of 77
B

business... [7] 

 30/1 30/20

 30/23 31/18

 32/23 36/19

 37/15

businessmen [1] 

 38/7

buy [6] 10/1

 12/12 14/16

 17/7 18/10 23/4

buying [1] 

 12/14

C

call [2] 10/11

 24/18

called [8] 5/16

 7/10 9/16 10/11

 12/8 15/13 16/7

 38/22

calls [1] 24/23

came [9] 11/3

 18/17 19/20

 23/2 32/20

 36/10 37/11

 37/15 37/17

campaign [2] 

 9/3 26/17

can [20] 5/21

 10/8 10/13 12/1

 12/12 12/12

 17/25 19/1 19/7

 23/12 24/1 24/4

 25/6 25/13 26/5

 28/14 32/14

 32/17 34/20

 34/23

can't [5] 12/9

 27/8 38/9 38/10

 38/12

candidate [1] 

 25/12

car [2] 7/17

 17/7

card [1] 7/2

cards [2] 27/24

 27/25

care [3] 11/16

 20/6 20/7

carry [1] 12/18

case [11] 1/4

 4/13 6/10 6/19

 7/16 7/20 14/7

 21/12 33/8 34/6

 36/6

cash [4] 21/23

 21/23 23/13

 23/14

cash-flow [1] 

 23/14

cash-poor [1] 

 23/13

categories [3] 

 6/11 6/13 6/17

category [2] 

 6/12 30/25

CERTIFICATE [1] 

 39/19

certify [1] 

 40/2

chance [1] 14/1

changed [1] 

 13/24

changing [1] 

 16/25

charge [3] 3/18

 8/23 9/12

charges [1] 

 3/17

Charnetzky [7] 

 8/12 8/18 12/8

 12/9 18/9 19/15

 33/24

Charnetzky's [1]

 8/13

chart [4] 17/18

 17/18 17/23

 20/8

charts [1] 

 18/25

Chase [1] 7/20

Chase Bank [1] 

 7/20

chasses [1] 

 11/11

chassis [1] 

 20/12

check [26] 4/3

 7/23 22/21

 22/23 25/10

 25/20 25/21

 25/23 26/15

 26/21 27/1 28/6

 28/18 28/22

 29/3 29/4 29/9

 29/13 29/15

 29/16 29/16

 35/10 35/10

 35/13 38/18

 38/25

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 47 of 77
C

checked [1] 

 15/10

checking [1] 

 22/5

Chicago [1] 

 1/17

chips [1] 17/4

chose [3] 11/1

 11/12 18/1

chosen [1] 11/5

circumstantial

 [6] 5/8 5/11

 5/25 6/2 6/4

 6/7

cities [1] 

 14/16

city [31] 3/8

 3/20 3/22 4/9

 4/15 4/22 5/5

 9/6 9/19 9/25

 11/17 11/23

 11/24 12/23

 15/12 15/17

 16/12 16/22

 17/10 19/16

 20/13 24/7

 24/12 29/19

 30/7 30/12

 30/20 30/23

 32/8 34/1 39/9

City's [1] 21/5

claim [1] 22/24

classes [1] 

 31/23

clear [1] 9/8

clerk [5] 4/20

 13/2 13/6 13/7

 29/20

clips [1] 30/9

CLOSING [2] 1/8

 3/5

co [1] 3/12

co-counsel [1] 

 3/12

colleague [1] 

 36/9

collection [1] 

 10/2

come [3] 4/9

 10/14 26/14

comes [4] 22/2

 27/19 30/11

 38/9

common [1] 18/1

communication

 [2] 15/6 15/20

community [4] 

 26/9 26/10 38/7

 38/8

companies [5] 

 14/15 15/7 18/4

 20/9 20/11

company [7] 

 18/5 21/1 21/14

 28/17 28/21

 33/13 36/12

compare [1] 

 19/5

compares [1] 

 17/19

comparing [2] 

 17/23 18/25

compensation [1]

 29/25

complete [2] 

 29/23 40/3

completely [1] 

 33/10

complicated [1] 

 8/21

computer [2] 

 2/25 17/3

computer-aided

 [1] 2/25

conceal [2] 

 6/15 28/8

concealment [3] 

 28/16 29/11

 29/17

conceived [1] 

 35/9

concerned [1] 

 38/2

conclude [1] 

 5/16

confident [1] 

 27/9

confronted [1] 

 36/20

connection [3] 

 4/8 5/4 39/8

consciousness

 [7] 6/16 30/25

 31/1 31/4 33/6

 33/23 37/5

consider [3] 

 6/4 34/17 34/20

consistent [1] 

 38/23

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 48 of 77
C

consultant [6] 

 31/15 31/16

 32/4 32/9 32/24

 33/1

consultant

 --James [1] 

 32/4

consultants [2] 

 32/6 33/2

consulting [13] 

 15/23 16/1

 22/24 28/1 28/3

 28/6 28/17 29/3

 29/10 31/9

 31/14 31/24

 35/8

contact [2] 

 15/15 20/25

contacted [1] 

 9/24

contacts [2] 

 39/2 39/3

context [2] 

 25/3 26/23

Continued [1] 

 2/1

contract [14] 

 4/17 21/2 27/6

 27/7 27/8 27/9

 27/10 27/14

 27/16 27/21

 28/12 30/3 37/9

 38/19

contracts [12] 

 4/8 4/11 4/13

 5/5 8/9 11/20

 20/20 25/5

 26/25 33/14

 37/18 39/9

conversations

 [1] 32/12

copies [1] 

 27/21

copy [3] 25/22

 25/23 30/14

corruptly [2] 

 4/7 5/3

cost [1] 20/10

costs [1] 12/4

could [12] 

 12/18 12/22

 18/4 18/7 19/9

 19/10 19/12

 20/24 20/25

 23/8 26/11

 31/21

couldn't [3] 

 11/5 26/20

 27/15

counsel [3] 

 3/12 16/14

 31/19

course [3] 

 12/18 12/23

 17/9

court [6] 1/1

 1/9 34/16 34/19

 40/8 40/9

coverage [4] 

 37/23 38/1 38/2

 38/3

cr [1] 1/4

crates [1] 

 10/15

created [2] 

 17/23 20/8

credit [2] 7/2

 21/19

crime [1] 37/12

cross [2] 11/3

 16/14

cross-examinatio

n [1] 11/3

cross-examining

 [1] 16/14

CRR [3] 2/10

 40/2 40/8

CSR [3] 2/10

 40/2 40/8

Cummins [6] 

 10/19 10/23

 11/4 11/6 11/9

 17/14

current [5] 

 16/13 16/19

 16/21 24/17

 29/20

curtailment [5] 

 23/5 23/5 23/7

 24/14 35/18

cut [1] 26/25

D

dangerous [2] 

 10/9 10/17

date [6] 18/2

 19/6 19/25 20/1

 23/22 40/8

dated [1] 23/21

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 49 of 77
D

day [7] 7/22

 16/5 19/11

 19/16 26/4

 35/21 36/11

days [5] 13/24

 18/19 19/11

 20/3 38/4

deadline [1] 

 18/7

dealer [2] 

 21/16 21/16

dealership [5] 

 17/6 21/17 22/1

 22/17 22/18

Dearborn [1] 

 1/17

debt [1] 7/2

December [1] 

 7/22

decide [3] 6/6

 26/5 34/18

decided [2] 

 17/22 19/4

declared [1] 

 7/2

deep [1] 25/18

default [1] 8/1

defendant [31] 

 1/6 1/20 2/3

 2/8 3/17 3/18

 3/20 3/25 4/3

 4/6 4/7 5/3

 6/22 6/24 7/1

 7/16 7/23 8/8

 9/2 9/3 11/4

 11/21 12/6

 15/15 15/21

 16/7 18/23

 18/24 25/2

 32/13 36/7

Defendant's [3] 

 8/5 9/2 32/11

defense [4] 

 16/14 36/21

 37/1 37/1

defense's [1] 

 35/6

definition [2] 

 31/16 34/23

delivered [9] 

 13/16 13/21

 13/25 17/12

 19/9 19/10

 23/18 35/17

 35/19

delivery [6] 

 18/2 18/8 19/6

 19/8 19/24 20/1

demand [2] 6/9

 6/13

demanded [1] 

 3/25

denied [1] 39/5

Department [3] 

 4/24 9/23 33/25

depends [1] 

 22/10

deposited [3] 

 26/16 28/23

 29/4

design [1] 

 13/19

desperate [2] 

 12/24 35/23

despite [1] 

 21/22

developed [1] 

 17/4

did [17] 10/20

 18/3 18/22

 19/22 22/17

 24/14 27/14

 28/2 30/16

 32/19 33/21

 34/6 34/13 35/1

 36/22 36/23

 37/8

didn't [32] 

 5/20 8/19 10/5

 11/4 12/11

 12/20 15/1 15/3

 15/24 16/8

 19/24 20/4

 20/13 20/19

 21/2 21/22

 21/23 22/16

 23/7 26/14

 26/14 26/21

 28/4 28/14

 29/15 29/16

 29/18 30/13

 30/17 33/16

 37/19 37/19

different [8] 

 6/11 8/14 21/9

 25/4 27/6 30/22

 31/10 37/9

difficult [1] 

 10/9

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 50 of 77
D

dire [1] 21/7

direct [8] 5/9

 5/12 5/24 5/25

 6/4 6/7 15/15

 37/23

directed [2] 

 13/20 33/24

directly [10] 

 4/19 6/1 8/5

 8/24 11/22 12/3

 12/4 12/12

 25/13 26/21

disadvantages

 [1] 31/20

disclose [4] 

 29/18 29/24

 30/12 37/10

disclosed [1] 

 30/6

discussion [2] 

 28/11 28/11

dismayed [1] 

 14/25

displayed [5] 

 8/4 28/10 29/6

 31/12 33/4

dissolved [1] 

 29/2

DISTRICT [4] 

 1/1 1/1 1/9

 40/9

DIVISION [1] 

 1/2

do [26] 9/10

 12/1 12/3 12/3

 12/6 12/10

 12/17 14/3

 18/21 21/2

 24/20 25/18

 27/8 30/10

 31/13 32/16

 32/16 32/16

 33/9 33/12

 33/15 34/6

 36/10 37/19

 37/20 37/22

document [2] 

 17/16 27/18

documentation

 [5] 6/15 27/2

 27/22 27/22

 28/25

does [12] 6/5

 9/11 10/19 12/6

 14/4 14/5 15/3

 18/24 18/24

 22/21 30/1

 38/21

doesn't [4] 

 10/14 26/7

 30/12 38/13

doing [8] 12/12

 22/18 25/17

 30/20 30/23

 31/6 31/8 31/13

don't [10] 

 10/24 13/18

 13/18 14/19

 14/19 22/8

 25/15 25/15

 27/18 38/10

donated [1] 

 25/9

donation [3] 

 26/13 26/17

 26/19

donations [4] 

 25/1 25/3 25/12

 25/15

done [2] 3/15

 13/5

doubt [4] 3/12

 3/15 3/19 39/14

down [2] 7/3

 7/4

driven [1] 

 12/21

driver [1] 9/21

drove [1] 9/21

duck [4] 31/3

 31/3 31/3 31/4

due [6] 7/17

 7/17 16/6 22/20

 23/2 23/2

dump [1] 10/10

during [7] 

 15/21 19/3 21/7

 22/18 30/2 30/4

 30/23

duty [1] 20/23

E

each [4] 3/18

 6/17 14/16

 29/23

earlier [4] 

 5/19 34/19

 34/20 34/22

easily [1] 33/7

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 51 of 77
E

economic [1] 

 29/21

Edward [2] 22/2

 22/5

effective [1] 

 29/1

effort [2] 

 29/11 29/17

efforts [2] 

 6/15 28/8

either [1] 

 27/18

eject [2] 10/6

 11/7

element [4] 4/9

 4/19 5/2 5/6

elements [1] 

 3/19

else [5] 13/1

 18/23 28/3 34/6

 37/21

email [5] 1/15

 1/18 1/23 2/6

 11/23

emails [2] 16/3

 27/23

embraces [1] 

 3/13

emissions [3] 

 17/1 17/14

 17/15

employees [2] 

 10/9 34/1

employment [2] 

 30/2 30/4

empty [1] 10/10

ended [1] 15/25

ending [1] 24/7

endorse [1] 

 29/15

enforcement [3] 

 36/16 36/23

 37/7

engaged [1] 

 31/18

engine [8] 8/25

 10/20 10/23

 11/5 11/6 11/9

 11/10 17/14

enough [1] 

 19/17

entered [1] 

 27/16

entire [1] 38/8

entitled [1] 

 40/4

envelope [1] 

 14/4

envelopes [3] 

 13/13 13/15

 13/25

EPA [1] 16/25

epiphany [1] 

 34/10

equipment [3] 

 9/6 15/17 16/12

equivalent [1] 

 10/24

especially [1] 

 27/18

Evans [1] 31/15

even [15] 15/1

 15/3 15/24

 17/21 17/21

 19/4 19/18 25/9

 26/5 27/7 27/23

 29/15 30/11

 32/19 35/9

event [3] 26/7

 26/8 26/11

ever [3] 28/2

 31/23 39/5

every [5] 15/11

 17/2 17/19

 17/24 18/2

everybody [2] 

 18/11 33/19

everything [1] 

 18/23

evidence [40] 

 4/2 4/5 5/9

 5/11 5/11 5/12

 5/18 5/24 5/25

 5/25 5/25 6/2

 6/2 6/5 6/7

 6/10 6/14 6/17

 6/18 6/20 7/15

 8/7 9/15 13/14

 15/5 15/9 16/11

 16/25 17/2

 17/25 24/13

 28/5 28/7 30/21

 31/25 32/7 33/8

 33/23 34/15

 34/21

exactly [3] 

 10/4 24/3 32/15

examination [1] 

 11/3

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 52 of 77
E

examining [1] 

 16/14

example [2] 

 5/19 25/20

except [1] 28/6

excerpt [2] 1/7

 40/3

exchange [2] 

 23/16 31/17

excuse [1] 

 19/10

exhibit [22] 

 8/3 13/14 17/11

 17/16 19/1 19/1

 25/21 27/4 28/9

 28/23 28/24

 29/5 29/6 30/15

 30/21 31/11

 31/12 32/1

 32/22 32/22

 33/3 33/4

exhibits [2] 

 14/6 14/7

exist [1] 28/4

existed [1] 

 15/24

existence [2] 

 28/5 28/7

exists [1] 5/16

expensive [1] 

 17/3

experience [1] 

 8/18

experienced [1] 

 8/20

expert [1] 

 32/13

experts [1] 

 32/17

Explain [1] 

 38/16

explanation [2] 

 29/8 36/1

expressed [2] 

 10/3 10/18

extension [2] 

 24/2 35/20

extent [2] 

 14/22 29/12

extra [1] 20/6

F

fact [6] 5/15

 5/16 6/1 6/3

 27/7 27/19

facts [3] 14/20

 14/23 38/3

failed [1] 

 37/10

failing [1] 

 22/22

fair [1] 10/22

fall [2] 5/21

 6/1

family [1] 

 35/25

fancy [1] 31/1

fast [1] 19/7

faster [1] 17/3

favor [3] 18/11

 20/20 21/3

favored [1] 

 18/14

Fax [3] 1/14

 1/22 2/5

FBI [13] 27/6

 27/10 27/19

 30/8 30/11 31/9

 33/9 33/15

 33/25 34/1 34/5

 37/11 37/14

February [5] 

 29/2 29/23

 29/23 30/10

 30/11

federal [4] 

 1/13 2/10 4/16

 4/23

fee [1] 31/18

FET [2] 22/4

 22/6

few [2] 13/23

 32/25

file [1] 25/22

filed [1] 29/22

filer's [1] 

 30/1

fill [4] 30/13

 30/16 30/16

 30/17

filled [1] 7/1

final [2] 24/5

 30/25

finally [3] 

 4/15 23/6 26/22

financial [2] 

 32/7 39/11

financier [1] 

 21/22

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 53 of 77
F

find [3] 3/17

 19/22 39/14

fine [2] 22/18

 38/20

fire [2] 33/24

 34/4

first [13] 3/20

 5/8 6/12 8/9

 11/20 15/10

 15/14 17/19

 19/2 19/6 19/25

 20/7 21/13

fits [1] 6/10

five [1] 3/19

Floor [1] 1/17

flow [1] 23/14

follow [1] 

 11/12

followed [2] 

 11/2 11/8

follower [2] 

 9/9 9/10

following [2] 

 3/19 16/16

foreclose [1] 

 8/1

foreclosure [1] 

 7/19

foregoing [1] 

 40/3

forget [1] 

 27/17

form [6] 4/3

 7/1 29/13 30/13

 30/14 30/15

formal [1] 

 12/13

found [1] 16/4

foursome [1] 

 26/4

fourth [1] 

 11/25

freeze [1] 10/8

friend [1] 8/23

front [1] 36/3

frustrated [1] 

 14/25

frustration [1] 

 24/22

full [4] 10/6

 11/7 28/11

 28/11

full-eject [2] 

 10/6 11/7

fund [3] 7/10

 7/11 7/12

furnished [1] 

 16/12

further [1] 

 39/16

G

gave [4] 10/7

 23/19 25/6 25/8

general [2] 

 16/11 16/17

gentlemen [21] 

 3/21 4/12 5/13

 6/9 9/8 9/14

 11/19 13/15

 14/18 18/14

 20/22 22/8

 24/14 24/24

 27/12 28/2

 29/11 31/4

 33/17 35/2

 35/12

get [21] 10/13

 10/16 12/12

 14/15 16/14

 19/7 22/11

 22/16 22/17

 23/10 23/12

 24/2 24/11

 24/14 24/21

 26/3 26/8 26/12

 34/23 35/20

 38/16

gets [1] 35/17

getting [1] 

 21/23

give [5] 6/6

 25/16 26/5

 26/13 33/17

given [1] 24/7

gives [2] 29/7

 36/1

giving [3] 

 25/12 25/16

 35/3

glad [1] 37/15

go [3] 13/5

 13/6 17/22

goal [1] 14/15

goes [3] 20/10

 22/2 22/3

going [13] 5/6

 5/11 17/22

 22/10 23/23

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 54 of 77
G

going... [8] 

 24/11 26/5 26/6

 29/7 32/25 36/2

 37/16 38/20

gold [2] 26/3

 26/6

golf [2] 25/10

 26/3

gone [1] 20/5

good [5] 3/6

 8/23 17/8 24/11

 25/20

goodbye [1] 

 23/24

got [8] 18/19

 21/9 21/9 29/3

 33/13 35/25

 39/2 39/2

gotten [1] 

 33/13

government [10] 

 1/8 1/12 3/5

 3/13 3/18 9/16

 18/11 26/1

 27/21 36/6

Government's

 [22] 8/3 13/14

 16/4 17/11

 17/16 19/1 19/1

 25/20 27/4 28/9

 28/23 28/24

 29/5 29/5 30/15

 30/21 31/11

 31/11 31/25

 32/22 33/3 33/3

grand [5] 18/20

 19/21 34/7 34/9

 36/20

grant [2] 4/17

 32/11

grants [1] 4/24

gratuity [2] 

 6/9 6/13

Great [25] 7/23

 11/11 11/16

 11/21 11/22

 12/15 12/24

 17/12 17/19

 17/22 18/3

 18/15 20/21

 21/3 21/6 21/15

 22/7 24/4 26/20

 30/19 30/22

 31/6 33/1 35/17

 35/21

greater [1] 

 32/20

Greg [1] 11/23

ground [5] 5/20

 5/21 5/22 6/2

 6/3

groups [1] 

 21/16

guarantee [1] 

 4/17

guess [1] 27/10

guilt [8] 6/16

 31/1 31/1 31/2

 31/4 33/6 33/23

 37/6

guilty [6] 3/11

 3/18 35/22 39/7

 39/13 39/14

guys [1] 37/15

H

had [41] 

HADLEY [1] 2/3

hadn't [3] 13/5

 13/22 24/16

HAMMOND [3] 1/2

 1/13 2/11

hand [3] 23/25

 38/14 38/18

handled [1] 

 8/13

hands [1] 35/23

handwriting [5] 

 14/3 14/5 14/7

 14/8 14/10

handwritten [1] 

 35/16

happen [1] 

 18/16

happened [12] 

 5/12 13/16

 13/18 13/22

 13/23 18/6 20/4

 22/13 22/15

 24/3 35/13

 37/24

happening [4] 

 13/9 15/18 16/1

 37/17

happens [1] 

 11/10

Harrell [1] 

 21/14

has [14] 4/22

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 55 of 77
H

has... [13] 

 13/24 14/11

 15/18 17/18

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 17/23 18/16

 20/22 21/18

 24/5 32/15

 37/12

hasn't [1] 

 13/22

Hatagan [2] 

 6/22 7/8

have [55] 

haven't [1] 5/2

having [1] 16/5

he [156] 

he did [1] 

 34/13

he's [11] 9/4

 27/9 30/16

 32/25 33/1

 35/22 37/13

 37/19 39/1 39/2

 39/2

head's [1] 35/3

health [8] 

 22/23 31/13

 31/15 31/24

 32/2 32/4 32/5

 32/5

hear [6] 5/11

 5/12 16/8 20/22

 28/14 34/15

heard [40] 3/24

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hearing [1] 

 18/20

help [1] 34/18

helped [1] 9/3

helpful [1] 

 24/10

her [2] 30/2

 30/4

here [8] 3/7

 16/1 24/4 30/14

 34/16 34/19

 35/13 37/16

Here's [1] 17/7

hide [1] 34/5

highly [2] 13/4

 14/1

highways [1] 

 4/25

him [25] 7/10

 7/13 8/19 9/3

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 16/8 18/23

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 29/14 30/11

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himself [5] 8/8

 15/18 20/25

 24/9 32/23

hire [1] 36/17

hired [3] 9/2

 32/3 32/8

hiring [2] 

 32/24 33/1

his [35] 3/9

 4/4 4/4 6/25

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 37/1 39/11

holds [1] 31/17

holidays [1] 

 35/25

Hollister [2] 

 1/20 2/3

home [1] 7/3

Honda [1] 7/4

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 56 of 77
H

HONORABLE [2] 

 1/9 40/5

hope [1] 9/8

horsepower [1] 

 10/23

how [10] 6/6

 12/6 13/1 19/7

 30/13 31/13

 32/15 33/12

 34/9 34/18

However [1] 

 26/2

I

I'll [1] 4/9

I'm [8] 5/6

 27/25 29/7 30/9

 35/3 37/15

 37/23 37/24

I've [1] 35/25

idea [2] 36/17

 36/18

identification

 [1] 24/6

illegal [1] 

 26/1

Illinois [1] 

 1/17

important [2] 

 19/12 26/24

improper [1] 

 14/24

improvements [1]

 17/5

including [1] 

 19/2

inconsistent [2]

 34/16 34/17

incriminated [1]

 34/25

INDIANA [12] 

 1/1 1/13 1/21

 1/21 2/4 2/4

 2/11 3/9 4/20

 20/14 28/20

 31/21

Indianapolis [3]

 1/21 2/4 31/7

indicate [1] 

 34/14

Indictment [1] 

 3/16

indirectly [1] 

 6/2

individual [1] 

 13/8

industry [1] 

 14/14

infer [1] 5/21

inference [2] 

 5/17 5/23

inferences [1] 

 5/17

influence [3] 

 38/22 38/23

 39/4

influenced [4] 

 4/8 5/4 36/7

 39/8

information [2] 

 33/17 33/18

informed [2] 

 7/12 7/25

infused [1] 

 21/25

injected [1] 

 15/18

innd.uscourts.go

v [1] 2/12

inserted [1] 

 8/8

inside [1] 39/3

instead [3] 

 8/23 26/15

 39/11

instructed [1] 

 3/16

instructions [1]

 34/14

insurance [10] 

 4/18 22/23

 31/14 31/15

 31/21 31/24

 32/2 32/4 32/5

 32/6

intent [5] 4/7

 5/4 8/1 36/7

 39/8

interest [3] 

 12/14 29/22

 32/15

interested [1] 

 12/13

interesting [6] 

 10/25 19/5

 24/13 25/25

 26/2 30/7

interests [2] 

 3/10 39/11

interview [3] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 57 of 77
I

interview... [3]

 8/6 30/9 37/11

interviewed [1] 

 36/23

invested [2] 

 23/1 23/9

investigate [1] 

 33/20

investigated [1]

 33/21

investigation

 [1] 33/21

invitations [2] 

 14/21 16/4

involved [5] 

 4/11 8/20 8/21

 15/6 15/7

involving [1] 

 4/17

irregular [2] 

 14/1 14/24

irregularities

 [1] 14/17

irregularity [1]

 15/5

IRS [4] 6/22

 6/25 7/2 7/9

is [83] 

issued [3] 

 16/11 27/20

 31/21

it [131] 

it's [14] 5/21

 9/16 9/16 12/7

 17/9 17/25 21/1

 27/17 30/13

 33/6 33/6 33/19

 35/2 38/6

its [5] 3/13

 11/17 28/7

 28/21 36/6

J

JACKIE [1] 1/20

JAMES [46] 

James Snyder [1]

 19/21

January [7] 

 7/15 7/17 15/25

 23/11 23/21

 24/4 26/22

jbennett [1] 

 1/23

Jerry [1] 6/22

JILL [1] 1/12

Jill.Koster [1] 

 1/15

job [4] 9/4

 14/14 33/17

 33/20

John [5] 4/21

 9/13 9/18 31/5

 33/24

joined [1] 25/7

Jones [2] 22/2

 22/5

Josh [1] 32/11

Judge [3] 3/6

 3/16 35/5

Judge's [1] 

 34/14

July [2] 27/5

 36/23

JUNIOR [1] 1/20

jury [10] 1/7

 3/4 8/4 18/20

 19/22 29/6

 31/12 34/8 34/9

 36/20

just [25] 3/16

 4/10 9/15 11/10

 12/1 12/2 12/21

 13/23 14/23

 18/23 19/13

 20/1 23/3 23/24

 26/21 26/24

 32/24 33/13

 34/4 35/3 35/17

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K

keep [3] 14/18

 25/15 36/6

KENNELLY [3] 

 1/9 3/16 40/5

kept [1] 25/22

kidding [1] 

 14/10

knew [5] 14/20

 20/16 20/18

 30/8 33/12

knocking [1] 

 27/19

know [34] 11/16

 13/18 13/18

 14/3 14/19

 14/19 14/20

 16/3 17/6 20/23

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 58 of 77
K

know... [24] 

 20/25 23/18

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knowing [1] 

 13/9

knowledge [7] 

 8/18 14/22

 18/18 30/1

 32/11 32/19

 32/20

knows [4] 9/4

 21/10 30/15

 30/15

KOSTER [1] 1/12

L

lack [2] 27/2

 32/11

ladies [21] 

 3/21 4/12 5/13

 6/9 9/8 9/14

 11/19 13/15

 14/18 18/14

 20/22 22/8

 24/13 24/24

 27/12 28/1

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 33/16 35/2

 35/12

Lakes [25] 7/23

 11/11 11/16

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 12/15 12/24

 17/12 17/19

 17/22 18/3

 18/15 20/21

 21/3 21/6 21/15

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 31/6 33/1 35/17

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language [2] 

 10/24 32/18

last [2] 13/23

 21/18

later [2] 29/22

 34/12

law [9] 5/14

 5/15 6/5 12/5

 20/14 20/22

 36/16 36/23

 37/7

lawyer [1] 27/8

learned [1] 

 11/15

least [4] 4/23

 8/14 29/13

 38/16

legitimate [2] 

 36/24 37/8

less [2] 12/9

 32/16

let [1] 34/3

let's [5] 6/20

 8/7 21/4 27/5

 36/15

letter [1] 

 25/22

letterhead [1] 

 28/3

letters [1] 

 27/23

level [1] 32/19

liable [1] 7/14

license [1] 

 31/22

licensed [2] 

 31/14 31/24

lie [3] 33/6

 33/7 33/7

lied [3] 27/11

 36/16 37/7

like [18] 10/6

 10/22 12/2

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 32/6 34/10

 34/11 34/24

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liked [1] 24/22

likes [2] 25/19

 25/24

line [2] 13/15

 16/23

lines [1] 26/13

Link [1] 20/12

liquid [1] 

 23/14

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 59 of 77
L

literally [1] 

 22/10

lived [1] 38/8

livelihood [1] 

 15/2

lives [1] 38/8

LLP [2] 1/20

 2/3

loaded [1] 

 19/19

loan [6] 4/17

 38/14 38/16

 38/17 38/17

 38/20

lobbying [2] 

 31/6 31/6

long [4] 5/18

 9/19 14/14 29/7

longer [2] 

 19/13 24/21

look [7] 5/15

 14/1 14/6 18/25

 24/17 29/15

 37/7

looked [1] 

 33/12

looking [1] 

 12/3

looks [2] 31/2

 31/2

lose [1] 22/10

lost [1] 23/8

lot [10] 11/14

 11/17 12/16

 14/20 17/13

 19/2 21/8 24/22

 39/2 39/2

lowered [1] 

 21/19

lowest [2] 20/9

 20/10

lunch [1] 16/5

Lynn [4] 4/19

 13/2 30/21 32/7

M

Mack [2] 9/21

 11/4

made [15] 3/2

 23/11 23/22

 24/22 25/2

 25/14 25/21

 26/21 29/3 29/9

 29/14 34/15

 34/17 34/19

 39/17

maintenance [2] 

 5/1 9/1

make [14] 5/17

 10/21 15/2 17/5

 22/11 22/13

 22/21 23/7 24/1

 25/15 36/22

 36/24 37/7

 38/21

makes [4] 10/8

 22/22 22/24

 36/4

making [1] 13/9

man [6] 8/10

 9/1 15/16 38/22

 38/23 39/4

Management [1] 

 9/24

manufacture [1] 

 19/14

manufactured [1]

 18/7

manufacturer's

 [3] 16/13

 16/18 16/21

many [1] 7/16

MARCH [4] 1/8

 6/24 40/5 40/8

Mark [2] 32/6

 32/8

math [1] 36/4

matter [2] 10/5

 40/5

mattered [1] 

 10/6

matters [2] 

 31/7 32/21

MATTHEW [2] 1/9

 40/5

may [5] 5/24

 24/16 24/18

 34/8 34/17

mayor [16] 3/22

 11/24 15/15

 15/18 18/16

 18/17 20/17

 20/20 27/15

 27/17 37/11

 37/12 37/14

 37/19 39/2 39/3

mayor's [3] 

 13/4 13/21

 18/18

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 60 of 77
M

McIntyre [1] 

 14/4

me [7] 11/24

 19/10 21/1

 30/25 33/11

 34/11 38/16

mean [1] 12/20

meaning [4] 7/5

 7/13 21/21 33/1

means [1] 21/20

meant [1] 12/21

mechanic [3] 

 8/25 9/13 9/19

mechanics [5] 

 11/2 11/6 11/7

 11/9 11/12

mechanism [3] 

 36/21 37/1 37/2

Medicaid [1] 

 4/24

Medicare [1] 

 4/23

meet [4] 18/4

 18/7 20/9 20/13

meeting [4] 

 13/11 13/17

 16/2 20/18

meetings [2] 

 16/4 38/4

members [2] 

 26/10 28/15

memo [1] 24/4

men [3] 14/13

 32/18 38/7

mention [3] 

 9/14 20/19

 28/14

mentioned [2] 

 28/12 28/16

message [1] 

 35/14

met [4] 16/3

 20/11 37/10

 39/6

MFK [1] 1/4

might [4] 20/21

 23/24 37/3

 38/16

Miller [2] 32/6

 32/8

million [6] 

 4/14 9/6 21/10

 26/25 33/14

 36/12

mind [3] 14/18

 17/6 36/6

minute [1] 4/10

misspoke [1] 

 22/5

model [9] 16/13

 16/19 16/22

 16/22 16/24

 20/13 20/16

 20/18 28/15

modification [2]

 24/14 35/18

moment [1] 6/8

money [23] 4/4

 6/23 7/7 8/6

 22/2 22/9 22/12

 22/17 23/12

 23/15 24/11

 24/11 24/24

 25/9 25/16

 31/17 35/24

 35/24 36/13

 36/19 37/13

 37/17 38/15

month [4] 7/22

 22/20 23/3 23/4

months [3] 7/16

 32/3 32/25

more [11] 4/11

 4/16 7/5 11/15

 12/4 15/20 17/3

 19/9 25/9 32/16

 34/24

morning [1] 

 5/20

mortgage [1] 

 28/20

mortgages [1] 

 7/3

most [3] 8/20

 19/12 21/15

most-experienced

 [1] 8/20

motivated [1] 

 12/13

motive [3] 6/8

 6/12 6/20

Motor [1] 21/14

mouth [1] 8/5

Mr [11] 9/9

 12/4 18/9 18/19

 21/10 21/14

 25/19 26/18

 31/15 36/9

 36/22

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 61 of 77
M

Mr Evans [1] 

 31/15

Mr. [2] 5/10

 8/25

Mr. Bennett [1] 

 5/10

Mr. Reeder [1] 

 8/25

much [4] 6/6

 12/6 14/11

 32/15

multiple [1] 

 28/2

municipalities

 [1] 14/15

must [4] 3/18

 29/22 29/24

 31/3

my [3] 3/12 5/7

 36/9

N

name [2] 29/16

 29/24

nearly [1] 7/14

neater [1] 

 14/11

need [4] 31/23

 35/24 35/24

 36/19

needed [9] 6/23

 8/6 22/25 23/14

 24/24 24/25

 35/18 35/19

 36/13

needed it [1] 

 24/25

negative [1] 

 21/18

net [2] 21/10

 21/18

network [1] 

 21/16

never [5] 4/22

 19/16 19/22

 31/22 37/16

new [6] 16/12

 16/18 16/23

 17/7 18/10 24/6

next [2] 9/4

 30/10

Nina [1] 29/20

no [19] 1/4

 5/12 6/14 12/23

 18/10 19/15

 19/20 22/22

 22/24 27/10

 28/3 28/5 29/22

 30/19 38/14

 38/14 38/17

 38/19 38/21

Nobody [1] 

 28/12

non [1] 23/14

non-liquid [1] 

 23/14

none [1] 38/25

Nope [1] 33/10

normal [1] 

 14/23

normally [2] 

 8/10 10/22

north [1] 9/20

NORTHERN [1] 

 1/1

not [45] 

note [1] 26/24

nothing [6] 

 20/24 29/8 33/9

 33/10 33/15

 34/2

notice [4] 7/9

 7/20 7/25 29/14

noticed [1] 

 14/16

notices [2] 

 6/24 7/19

November [5] 

 17/12 21/8

 21/11 23/3 32/2

November 24th

 [1] 23/3

now [12] 5/12

 8/7 14/18 18/25

 20/5 20/6 20/7

 21/4 25/11 27/2

 28/8 35/4

number [3] 8/9

 15/11 24/6

numbers [2] 

 15/12 21/9

O

oath [8] 3/8

 3/9 7/2 14/5

 18/22 34/20

 35/2 39/10

observed [1] 

 14/23

obtain [1] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 62 of 77
O

obtain... [1] 

 27/21

obvious [3] 

 3/22 17/25 33/6

obviously [1] 

 22/17

occur [1] 15/24

October [1] 

 32/24

odd [1] 38/13

Odyssey [1] 7/4

off [1] 16/23

offering [1] 

 31/18

offers [1] 

 31/19

office [12] 

 1/12 1/16 4/20

 13/2 13/4 13/6

 13/7 13/8 13/21

 25/4 30/2 30/4

official [5] 

 2/10 27/16

 29/25 36/4 40/8

Oh [3] 17/8

 25/14 30/9

okay [2] 23/25

 25/3

old [1] 12/15

older [1] 12/21

once [1] 23/25

one [20] 1/21

 2/4 4/15 5/2

 6/5 6/12 10/19

 12/1 14/3 15/6

 15/7 18/4 18/13

 18/18 20/3

 21/15 24/6

 30/17 31/23

 37/5

only [19] 12/17

 12/19 12/22

 12/24 15/6

 15/12 15/14

 18/4 18/5 19/20

 20/16 20/17

 22/11 25/11

 28/6 28/17

 28/21 37/5

 37/13

opened [2] 

 13/10 13/17

opening [2] 

 5/10 5/13

operating [4] 

 22/3 22/4 22/7

 23/13

opinion [2] 

 9/25 31/19

opinions [3] 

 10/3 10/18

 10/19

opposite [1] 

 20/2

order [17] 3/17

 10/21 11/25

 12/1 20/4 23/17

 23/18 23/21

 23/25 24/1 24/8

 31/23 35/14

 35/16 35/19

 35/22 35/23

ordered [1] 

 20/4

ordinance [2] 

 29/19 29/21

other [15] 4/18

 6/13 11/13

 14/20 15/5 17/4

 17/19 17/24

 18/2 19/13

 26/10 27/22

 27/22 28/15

 33/23

our [3] 3/14

 26/6 39/6

out [27] 7/1

 8/10 10/14

 10/16 17/17

 17/18 19/11

 19/22 21/21

 21/24 22/2 22/5

 22/9 22/12

 22/15 26/21

 29/3 29/9 29/14

 30/13 30/16

 30/16 30/17

 31/17 33/2

 33/11 33/18

outing [2] 

 25/10 26/3

Outlook [1] 

 16/3

over [11] 6/25

 7/3 7/4 7/17

 9/6 13/3 18/2

 19/8 19/25 20/1

 21/24

overdue [1] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 63 of 77
O

overdue... [1] 

 23/4

overnight [2] 

 5/19 10/8

overseeing [1] 

 8/11

owe [1] 7/6

owed [3] 6/25

 7/5 8/2

own [4] 3/9

 32/23 33/2

 39/11

owners [1] 21/6

P

PAC [1] 25/9

PACCAR [5] 

 21/22 21/24

 23/7 24/2 35/20

Pagel [1] 32/11

pages [1] 16/16

paid [7] 19/8

 19/12 22/16

 24/16 24/21

 37/13 37/18

paper [1] 28/18

paperwork [1] 

 15/12

part [4] 3/2

 9/1 25/20 39/17

part-time [1] 

 9/1

participating

 [1] 26/11

particular [3] 

 7/21 17/24 21/2

passed [1] 

 17/14

past [5] 7/16

 7/17 13/5 22/20

 27/7

pawn [5] 34/10

 34/11 34/23

 34/24 34/24

pawn-like [1] 

 34/24

pay [5] 21/22

 24/15 36/2 36/3

 36/4

paying [2] 20/6

 33/2

payment [16] 

 6/14 7/17 14/19

 21/4 23/11

 23/22 24/1 24/6

 26/1 26/2 26/22

 30/6 30/12

 33/13 35/20

 38/17

payments [4] 

 23/5 23/7 30/22

 32/8

payroll [7] 

 7/11 22/3 22/6

 22/11 22/13

 31/8 31/9

penalties [3] 

 7/10 7/11 7/13

pending [1] 

 24/7

penmanship [3] 

 14/9 14/10

 14/12

people [11] 3/8

 3/10 5/15 14/18

 19/2 20/16

 20/17 33/17

 37/24 39/10

 39/12

perfectly [1] 

 17/8

performed [6] 

 6/15 27/3 27/23

 27/24 36/25

 38/20

perhaps [1] 

 10/5

permitted [1] 

 24/15

person [8] 4/1

 4/6 8/21 29/25

 31/16 32/15

 34/4 34/24

person's [1] 

 32/20

personal [4] 

 4/5 22/9 22/12

 26/15

personally [3] 

 7/13 7/14 26/18

Peterbilt [26] 

 7/24 11/21

 11/22 11/25

 12/24 17/12

 17/22 18/4 18/6

 20/12 20/21

 21/3 21/7 21/14

 21/15 21/16

 22/7 24/5 24/6

 26/20 30/19

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 64 of 77
P

Peterbilt... [5]

 30/22 31/6

 33/1 35/17

 35/21

Peterbilt's [5] 

 11/11 11/17

 12/16 17/20

 18/15

Peyton [1] 

 21/14

phipps [4] 2/10

 2/12 40/2 40/8

phone [4] 15/11

 24/22 31/8 31/9

photographs [1] 

 9/14

pick [1] 19/17

picked [1] 11/1

piece [1] 28/18

place [1] 28/17

played [6] 8/3

 27/4 28/9 29/5

 31/11 33/3

Plaza [2] 1/13

 2/10

plenty [1] 4/12

plus [1] 23/10

PO [1] 24/8

pocket [1] 33/2

point [1] 18/14

policy [1] 

 31/21

political [3] 

 25/1 25/12

 26/13

poor [1] 23/13

Portage [25] 

 3/9 3/10 3/21

 3/23 4/9 4/15

 4/20 4/22 5/5

 9/7 9/19 11/18

 12/23 15/16

 19/16 20/13

 24/7 24/12

 27/15 29/19

 30/7 30/20

 30/24 39/9

 39/10

position [1] 

 8/16

possible [1] 

 18/17

postpone [1] 

 24/5

preceding [3] 

 29/22 29/24

 30/17

prefer [2] 

 10/19 10/24

preferred [2] 

 10/4 11/9

present [4] 2/8

 3/4 28/13 28/14

presented [2] 

 6/10 6/18

president [1] 

 3/23

press [4] 37/23

 38/1 38/2 38/3

pressed [1] 

 18/16

pretty [2] 

 21/11 32/17

previous [1] 

 18/20

price [6] 19/8

 19/12 19/25

 20/1 20/6 20/7

printout [1] 

 25/23

prior [3] 7/16

 8/14 11/17

prioritize [2] 

 18/1 19/24

prioritized [2] 

 19/8 20/1

probably [7] 

 11/15 12/8 17/8

 18/5 21/1 21/10

 23/23

problems [2] 

 23/14 35/25

proceedings [4] 

 2/24 3/1 39/16

 40/4

process [18] 

 8/8 8/10 8/19

 8/21 8/24 9/12

 12/5 12/10

 12/13 13/1

 14/17 15/7 15/7

 15/16 15/19

 15/25 30/3

 33/10

processes [2] 

 8/14 33/14

produced [1] 

 2/24

production [3] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 65 of 77
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production...

 [3] 16/13

 16/19 16/21

profit [1] 

 21/18

program [1] 

 4/17

promised [2] 

 9/3 31/20

prompt [1] 26/9

proof [2] 3/14

 3/14

Properties [2] 

 28/19 29/1

Properties' [1] 

 29/4

property [2] 

 8/1 8/2

prove [1] 3/18

proven [5] 3/11

 33/7 33/7 39/6

 39/13

proves [4] 6/1

 6/3 35/22 36/6

provide [1] 

 9/22

provided [3] 

 4/2 15/11 39/1

public [6] 4/24

 13/11 13/17

 27/16 31/17

 36/4

public's [2] 

 3/7 39/9

purchase [13] 

 11/22 21/5

 23/17 23/18

 23/21 23/25

 24/1 24/8 35/14

 35/16 35/18

 35/22 35/23

purchased [2] 

 12/2 18/13

purpose [1] 

 33/11

put [15] 8/23

 9/3 9/11 10/20

 10/22 10/23

 15/9 17/4 21/20

 25/3 26/23

 30/21 32/7

 35/12 39/11

putting [1] 3/9

Q

qualified [1] 

 8/25

question [1] 

 30/19

questions [4] 

 16/9 32/1 32/5

 36/10

quickly [1] 

 32/17

quite [1] 8/21

R

ran [1] 27/7

Randy [28] 8/23

 9/11 10/3 10/18

 10/18 10/20

 11/1 11/8 11/21

 11/23 12/7 12/7

 13/20 17/16

 17/23 18/8

 18/15 18/23

 19/21 20/8

 20/17 23/19

 28/13 31/8 34/7

 34/8 34/23

 35/16

Randy Reeder [2]

 17/23 20/17

ranking [1] 

 21/17

rating [1] 

 21/19

really [7] 6/10

 16/15 16/16

 30/7 38/9 38/12

 38/19

reappointed [1] 

 8/16

rear [1] 19/19

rear-loaded [1] 

 19/19

reason [2] 18/3

 39/14

reasonable [6] 

 3/11 3/15 3/19

 5/17 36/4 39/13

reasons [1] 

 10/7

rebid [1] 12/1

recall [1] 

 25/13

received [9] 

 4/16 4/22 6/24

 7/9 7/19 7/21

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 66 of 77
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received... [3] 

 13/10 29/25

 36/25

receiving [2] 

 26/24 29/9

recite [1] 38/5

recognition [4] 

 26/4 26/8 26/8

 26/12

recollection [1]

 12/8

record [8] 3/2

 28/5 28/7 28/18

 31/25 38/11

 39/17 40/4

records [1] 

 22/2

recused [1] 

 20/24

Reed [4] 4/20

 13/2 30/21 32/7

Reeder [31] 

 8/23 8/25 9/9

 9/11 10/3 10/18

 10/19 10/20

 11/1 11/8 11/21

 11/23 12/7 12/7

 13/20 17/16

 17/23 18/8

 18/15 18/19

 18/23 19/21

 20/8 20/17

 23/19 28/13

 31/8 34/7 34/8

 34/23 35/16

referring [1] 

 32/5

refuse [3] 10/2

 12/18 19/19

regard [2] 

 13/15 13/16

regarding [2] 

 26/23 31/7

registered [3] 

 28/19 28/20

 28/25

reimbursed [2] 

 26/19 26/19

rejected [1] 

 20/14

related [1] 

 38/3

relating [1] 

 32/2

relationship [1]

 34/2

relevant [1] 

 7/21

remainder [1] 

 5/7

remaining [1] 

 24/2

Remarkably [1] 

 14/9

remember [12] 

 24/20 27/15

 27/17 34/8

 35/13 37/22

 38/2 38/3 38/5

 38/10 38/10

 38/12

remind [1] 9/15

rendered [1] 

 38/5

rental [1] 7/25

reported [4] 

 2/24 3/1 26/16

 39/16

REPORTER [3] 

 2/10 40/1 40/8

Republic [1] 

 9/24

reputation [2] 

 38/6 38/8

requested [1] 

 24/5

required [2] 

 29/19 30/16

respect [1] 

 31/19

responsibility

 [1] 3/14

responsible [3] 

 8/11 9/5 13/8

responsive [1] 

 20/10

responsive-bidde

r [1] 20/10

retirement [3] 

 22/9 22/12

 22/16

retract [5] 

 18/20 18/21

 34/7 34/8 34/12

retrofitted [1] 

 19/18

Revas [1] 29/20

review [1] 27/5

reward [1] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 67 of 77
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reward... [1] 

 36/14

rewarded [5] 

 4/8 5/4 36/7

 36/8 39/8

rigged [1] 13/1

rigging [3] 

 6/14 8/7 15/5

right [11] 11/2

 16/23 19/7

 24/10 27/8

 33/19 35/4 37/3

 37/18 38/3

 38/17

RMR [3] 2/10

 40/2 40/8

roads [1] 4/25

Robert [3] 14/5

 14/8 15/21

ROCHELLE [1] 

 1/12

round [16] 

 11/20 15/1 15/3

 15/10 15/14

 15/20 15/21

 17/18 17/19

 19/2 19/4 19/6

 19/24 20/1 20/7

 28/12

rounds [3] 19/5

 20/21 25/5

roundtable [2] 

 25/7 25/8

rush [2] 18/10

 19/23

S

S/Angela [1] 

 40/8

safety [1] 4/24

said [29] 10/15

 12/4 12/9 12/19

 13/3 14/11 17/7

 17/7 18/9 18/16

 18/22 19/22

 20/25 21/10

 23/24 24/9

 24/20 32/19

 34/21 36/16

 36/19 36/21

 37/1 37/22

 38/10 38/11

 38/11 39/1 39/1

sale [4] 6/14

 11/17 12/18

 24/7

sales [3] 21/21

 21/24 26/9

salesman [1] 

 15/14

salesmen [6] 

 11/3 14/14 15/2

 15/6 15/11 19/3

same [10] 11/25

 16/13 16/18

 16/21 16/23

 16/24 17/9 18/7

 22/20 32/15

Sanitation [5] 

 8/12 8/15 9/5

 9/24 33/25

sat [2] 11/16

 17/13

saw [4] 15/1

 23/16 26/22

 35/6

say [8] 6/5

 16/15 16/20

 17/8 27/25 34/6

 34/24 37/15

saying [5] 

 11/24 23/23

 31/1 37/24 39/5

says [12] 12/6

 12/7 12/8 16/17

 23/17 30/8

 34/25 35/24

 36/2 38/9 38/11

 38/14

Scott [1] 14/4

search [1] 16/5

Searle [6] 

 22/14 25/11

 25/19 26/18

 38/24 39/1

second [13] 

 3/25 15/1 15/3

 15/20 15/21

 17/18 19/4

 19/24 19/25

 22/14 26/25

 28/12 29/18

Secretary [2] 

 28/20 28/25

section [1] 

 33/5

securing [1] 

 13/8

see [10] 5/20

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 68 of 77
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see... [9] 5/21

 10/24 14/7 19/2

 23/20 24/4

 24/18 25/6

 26/11

seeing [2] 6/1

 6/3

seek [1] 35/18

seem [3] 36/4

 36/22 36/24

seemed [1] 

 14/24

seen [2] 9/17

 33/24

sell [10] 12/9

 12/25 14/15

 15/3 15/17

 20/12 22/25

 23/1 23/24

 35/24

selling [3] 

 15/2 22/16

 23/10

semi [1] 9/21

sends [2] 17/17

 17/18

sense [9] 12/20

 12/21 18/1

 22/21 22/22

 22/22 22/24

 29/17 38/21

separate [1] 

 33/11

September [3] 

 7/9 7/12 29/1

serve [2] 3/8

 39/10

served [1] 8/15

service [1] 

 31/19

services [1] 

 38/5

several [1] 

 7/19

shall [3] 16/12

 16/17 16/18

she [2] 13/3

 13/3

She's [1] 13/2

Shepherd [2] 

 4/21 31/5

shew [1] 22/18

should [6] 9/14

 10/1 18/16

 20/14 26/3 30/6

shouldn't [1] 

 18/12

shove [3] 10/15

 10/16 10/16

show [5] 15/10

 22/2 26/5 26/7

 26/14

showed [2] 

 33/21 36/18

showing [4] 

 17/23 27/22

 27/24 32/8

shown [3] 21/18

 29/20 37/12

shows [5] 17/11

 28/25 30/22

 32/1 32/23

sign [1] 29/16

signatory [1] 

 28/21

signature [1] 

 23/20

significantly

 [1] 10/5

signs [1] 9/3

silent [1] 

 20/18

since [2] 9/17

 13/23

sitting [3] 

 12/15 12/22

 21/11

six [4] 6/10

 21/18 27/6 37/9

slide [1] 35/12

smacks [1] 31/2

small [1] 8/25

smart [1] 29/12

smarter [1] 

 29/14

snow [5] 5/20

 5/21 5/22 6/1

 6/3

snowed [2] 5/19

 5/22

SNYDER [50] 

Snyder's [1] 

 23/20

so [24] 4/5 5/2

 5/17 7/6 11/5

 11/8 12/6 12/10

 14/25 17/21

 19/5 20/23 21/4

 21/11 22/24

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 69 of 77
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so... [9] 23/4

 23/12 26/10

 26/23 27/5 33/5

 34/3 34/12 37/5

Sobkowski [2] 

 11/23 12/4

sold [8] 7/6

 12/23 16/22

 21/8 21/21

 21/21 22/18

 23/6

solicited [1] 

 3/25

some [11] 9/3

 9/17 13/12

 13/12 14/7

 14/25 16/14

 18/10 19/3 25/1

 38/17

somebody [2] 

 32/18 34/4

somehow [1] 

 36/3

something [8] 

 9/11 10/22

 18/22 25/25

 26/12 27/17

 32/14 34/5

sometimes [2] 

 5/15 10/7

somewhere [1] 

 9/20

soon [2] 7/21

 18/16

Sorry [1] 22/4

sort [1] 5/1

SOT [2] 21/20

 21/20

sound [1] 25/14

South [1] 1/17

speaks [1] 

 32/18

spec [3] 10/20

 10/24 18/2

Special [2] 

 6/22 7/8

specific [1] 

 32/14

specifications

 [2] 16/11 18/3

specs [7] 9/22

 14/21 16/15

 16/16 20/9

 20/11 20/14

speed [1] 19/7

sponsoring [1] 

 26/8

sponsors [3] 

 26/3 26/6 26/7

spot [1] 26/6

Square [2] 1/21

 2/4

SRC [10] 27/25

 28/3 28/5 28/17

 28/19 29/1 29/3

 29/4 29/8 29/9

SRIVASTAVA [3] 

 1/16 3/13 36/9

stake [1] 38/9

stand [8] 9/13

 9/18 18/19

 24/20 25/14

 27/13 34/9 35/7

standards [3] 

 17/1 17/14

 17/15

star [1] 35/6

start [1] 6/20

state [3] 16/12

 28/20 28/25

statement [6] 

 5/10 34/15

 34/17 34/19

 34/20 34/22

statements [2] 

 29/21 32/7

states [7] 1/1

 1/3 1/9 1/12

 1/16 5/15 29/21

station [3] 

 10/11 10/11

 10/13

status [1] 

 21/20

stay [1] 33/11

stayed [1] 

 20/18

stenotype [1] 

 2/24

Stettinius [2] 

 1/20 2/3

Steve [15] 8/11

 8/13 8/18 12/8

 21/6 21/25 22/5

 23/16 26/15

 26/17 26/19

 27/5 33/24

 35/15 37/8

Steven [5] 14/6

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 70 of 77
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Steven... [4] 

 14/8 15/14

 15/22 22/15

still [6] 7/6

 24/16 24/16

 24/18 32/4 38/7

stop [2] 12/11

 29/7

story [1] 31/10

straits [1] 

 21/7

Streets [4] 

 8/12 8/15 9/5

 33/25

strike [1] 

 38/13

stuck [1] 10/13

style [1] 12/1

subject [1] 

 28/16

submit [2] 

 27/12 29/13

submits [1] 

 15/17

submitted [1] 

 35/19

subpoenas [1] 

 27/20

subsidy [1] 

 4/17

such [2] 6/1

 6/3

sudden [1] 20/5

suggest [4] 

 3/21 5/14 13/18

 22/8

Suite [3] 1/13

 1/21 2/4

summaries [2] 

 15/9 27/23

superintendent

 [3] 8/12 8/15

 9/4

supposed [4] 

 13/5 13/6 30/8

 30/9

supposedly [2] 

 32/3 32/25

sure [3] 13/9

 17/9 27/14

suspect [1] 

 20/21

sworn [1] 35/2

T

Taft [2] 1/20

 2/3

taftlaw.com [2] 

 1/23 2/6

take [8] 22/8

 27/13 31/23

 33/16 34/25

 34/25 35/1 35/6

taken [4] 19/13

 22/15 23/8

 31/23

takes [1] 25/4

Taking [1] 

 16/10

talk [10] 5/8

 6/8 8/7 21/4

 27/2 28/8 29/18

 34/1 34/3 36/15

talked [1] 38/4

talking [9] 

 15/16 16/1 16/2

 27/25 32/14

 32/17 33/25

 34/5 34/9

talks [1] 31/3

tax [1] 35/24

taxes [2] 6/25

 7/11

tee [1] 26/6

telephone [1] 

 15/9

tell [8] 15/4

 27/13 32/14

 32/17 33/9 34/4

 34/6 37/14

tells [4] 9/10

 27/5 27/10 29/8

term [2] 30/2

 30/4

terms [3] 5/24

 16/11 16/17

testified [8] 

 9/18 11/3 14/4

 21/13 22/14

 23/19 31/15

 32/12

testify [1] 

 16/7

testimony [37] 

 3/24 4/2 4/13

 4/19 6/21 7/8

 8/13 8/24 9/9

 10/21 10/25

 11/14 11/19

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 71 of 77
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testimony...

 [24] 13/1

 13/12 13/24

 14/13 15/22

 16/8 16/10

 16/25 17/2

 17/25 18/8

 18/21 21/8

 21/13 25/1

 26/18 27/20

 32/10 33/8 34/7

 34/16 34/19

 35/2 37/21

text [2] 23/16

 35/14

texting [1] 

 15/16

than [12] 4/16

 6/5 7/5 11/15

 12/4 12/9 14/11

 19/12 24/21

 29/22 32/16

 32/20

Thank [4] 3/6

 10/12 35/5

 39/15

that [253] 

that day [1] 

 36/11

that's [22] 

 3/21 5/22 9/11

 10/17 11/5

 11/10 12/5 14/5

 15/25 16/1

 16/15 17/8

 22/13 24/2 27/9

 33/17 33/19

 33/20 33/20

 35/1 36/17

 38/20

their [24] 

 14/10 14/14

 14/15 14/16

 14/22 15/2

 17/13 19/19

 21/9 21/19

 21/22 21/23

 23/8 23/10

 23/12 23/13

 28/14 32/12

 32/18 33/17

 33/20 34/16

 38/8 38/8

them [16] 4/21

 7/6 9/17 13/8

 14/1 14/8 14/24

 14/25 18/5

 24/18 26/4

 26/12 33/17

 35/17 35/23

 36/13

themselves [1] 

 31/17

then [17] 4/4

 10/15 15/17

 22/6 24/10 25/4

 25/9 25/23 26/4

 26/7 26/16

 26/22 34/12

 35/6 35/16

 37/10 38/11

there [22] 4/5

 5/21 8/1 11/9

 13/25 14/7

 15/22 17/1 18/9

 19/15 19/16

 19/20 20/3

 23/18 25/25

 26/1 26/10

 26/11 27/10

 27/20 29/7 34/2

there's [8] 

 4/21 16/3 16/3

 20/24 26/12

 28/5 30/19

 31/25

these [20] 8/9

 9/14 13/13

 13/15 14/18

 15/1 15/9 15/11

 15/12 16/17

 17/2 17/5 18/13

 23/5 25/15

 26/13 32/18

 35/25 37/18

 38/7

they [116] 

they're [9] 

 9/15 13/10

 13/10 13/13

 13/14 17/22

 32/17 34/4

 35/23

They've [2] 

 13/23 38/7

thing [8] 4/1

 4/6 4/11 5/1

 9/4 13/22 14/3

 19/13

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 72 of 77
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things [6] 10/5

 14/23 17/4

 18/18 35/25

 37/24

think [9] 9/20

 10/10 10/15

 12/17 13/3 26/9

 27/7 27/14

 36/10

this [72] 

those [14] 3/10

 6/17 7/5 7/11

 10/3 10/19 11/4

 13/9 14/23

 19/11 23/7 25/3

 33/14 39/11

though [3] 

 10/21 22/17

 30/11

thought [2] 

 18/5 37/3

three [5] 11/20

 12/2 14/13

 19/10 21/18

through [6] 

 6/18 14/6 22/1

 29/23 31/16

 33/7

throughout [1] 

 26/4

time [14] 8/16

 9/1 9/19 14/14

 16/23 17/13

 18/10 21/7

 22/14 22/19

 23/5 25/17

 30/20 35/17

timeline [1] 

 25/3

times [2] 27/6

 37/9

timing [4] 6/14

 21/4 21/5 26/23

tippers [1] 

 19/18

titled [1] 

 12/20

today [6] 3/7

 16/8 23/18 24/9

 24/20 39/5

told [23] 3/13

 4/21 5/10 9/22

 10/3 13/3 13/23

 18/15 19/15

 21/15 21/19

 21/25 25/11

 25/19 31/5 31/8

 31/9 34/7 34/12

 35/8 36/13

 38/24 38/24

ton [1] 8/18

too [2] 4/12

 26/12

took [7] 3/8

 8/10 9/13 9/18

 24/21 24/21

 39/10

torque [1] 

 10/23

total [1] 7/3

totaled [1] 

 4/13

toward [1] 

 23/22

track [2] 25/16

 39/3

transaction [2] 

 36/24 37/8

transcript [7] 

 2/24 8/4 28/10

 29/6 31/12 33/4

 40/4

transcription

 [1] 2/25

transfer [2] 

 10/11 10/13

transferred [1] 

 4/4

Transportation

 [1] 4/25

trash [6] 10/8

 10/10 10/13

 10/16 10/16

 19/17

treasurer [1] 

 29/20

treasurer's [4] 

 4/20 13/2 13/6

 13/7

trial [7] 1/7

 3/12 6/21 19/3

 21/14 34/15

 34/17

tried [4] 11/21

 16/14 18/20

 35/1

trip [2] 25/8

 25/22

trouble [3] 

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 73 of 77
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trouble... [3] 

 22/19 25/18

 37/3

truck [41] 

trucking [1] 

 14/14

trucks [20] 

 9/21 9/23 10/10

 11/4 14/15

 14/16 15/2 15/3

 17/3 17/4 17/5

 18/10 18/12

 18/13 18/15

 19/10 19/11

 19/13 21/21

 21/22

true [7] 20/10

 33/18 33/19

 33/19 33/22

 36/17 40/3

trust [7] 3/8

 7/10 7/11 7/12

 21/21 21/24

 39/10

truth [1] 34/21

truthful [1] 

 34/18

try [3] 10/16

 15/3 27/21

trying [2] 10/9

 20/12

turn [2] 6/18

 21/23

turns [1] 33/18

two [15] 7/3

 8/9 11/17 12/15

 17/13 17/17

 17/21 18/25

 19/5 25/4 26/24

 26/25 27/20

 32/10 35/9

two-year-old [1]

 12/15

type [4] 9/25

 10/1 10/4 11/10

U

U.S [1] 40/9

Unbeknownst [1] 

 18/5

unbelievable [2]

 37/21 38/13

under [10] 4/16

 7/2 14/4 18/22

 20/14 20/22

 29/19 31/20

 34/20 35/2

underperforming

 [1] 21/16

understanding

 [1] 38/19

UNITED [5] 1/1

 1/3 1/9 1/12

 1/16

unless [3] 22/9

 22/10 34/5

unpaid [1] 7/11

until [4] 15/24

 24/15 30/10

 35/9

unused [2] 

 16/12 16/18

unusual [2] 

 13/4 13/22

up [14] 5/20

 6/3 6/6 9/3

 16/14 19/17

 23/19 26/5 26/7

 26/14 35/3 36/3

 36/18 37/12

upside [2] 7/3

 7/4

urgency [6] 

 18/17 19/16

 19/20 19/20

 20/5 20/5

us [3] 5/2

 37/17 37/17

usdoj.gov [2] 

 1/15 1/18

use [4] 18/1

 22/12 23/12

 24/1

used [6] 12/17

 12/19 12/19

 12/20 12/21

 34/10

V

value [3] 4/1

 4/6 4/11

vehicle [1] 

 24/6

vehicles [2] 

 19/18 19/19

verify [1] 

 33/18

versus [1] 5/8

very [5] 9/19

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 74 of 77
V

very... [4] 

 9/19 21/13

 24/17 26/2

vhadley [1] 2/6

victim [1] 

 37/12

violated [3] 

 3/7 3/9 39/9

VIVEK [1] 2/3

voices [1] 

 28/14

volunteered [2] 

 9/2 34/10

vote [2] 20/23

 21/2

voted [5] 17/21

 20/20 21/3 21/3

 23/4

votes [1] 17/17

voting [2] 

 14/21 28/15

vs [1] 1/4

W

wake [1] 5/20

waking [1] 6/3

walk [1] 6/18

walked [2] 22/1

 31/16

walks [1] 31/3

want [13] 5/8

 6/8 8/19 8/20

 17/7 17/10

 17/10 26/10

 27/2 28/8 34/1

 37/14 39/3

wanted [6] 11/6

 11/7 11/24 12/3

 22/25 33/15

wants [1] 11/8

warrant [1] 

 16/5

was [128] 

wasn't [15] 

 8/25 11/8 12/19

 13/21 14/10

 20/10 20/15

 20/15 27/14

 29/14 31/14

 33/22 35/9

 36/17 37/5

Waste [1] 9/24

way [7] 5/13

 8/9 15/20 22/11

 31/1 37/23

 38/18

ways [1] 8/9

we [56] 

we'll [4] 24/1

 36/3 38/14

 38/18

we're [4] 3/7

 26/5 26/6 36/2

we've [2] 6/10

 13/12

week [3] 5/19

 35/9 35/13

weeks [4] 17/17

 17/21 26/24

 35/10

weight [1] 6/6

well [14] 4/21

 11/4 12/6 15/23

 16/15 26/20

 33/16 34/14

 36/2 36/10

 36/17 36/21

 38/1 38/14

went [6] 4/3

 17/6 22/5 22/6

 35/21 36/12

were [38] 3/1

 7/5 12/3 12/13

 13/5 13/16

 13/17 13/25

 14/21 14/23

 14/24 14/25

 15/12 16/4

 20/12 21/7

 21/11 21/24

 22/17 22/19

 22/20 23/4

 23/13 23/13

 23/23 24/15

 25/2 25/12

 25/16 25/17

 25/17 27/20

 28/2 30/23 32/1

 34/9 36/22

 39/16

weren't [1] 

 23/23

what [35] 7/10

 9/25 10/1 10/11

 10/25 11/5 11/7

 12/6 13/18

 14/25 15/3 16/1

 19/22 20/4 20/5

 22/13 22/21

 22/22 24/3

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 75 of 77
W

what... [16] 

 24/20 27/9

 27/10 29/8

 33/21 34/3 34/6

 34/23 35/1

 35/13 37/21

 37/24 38/4

 38/20 38/21

 38/23

what's [5] 13/9

 19/5 24/13 30/7

 37/16

whatever [3] 

 13/16 34/21

 36/1

when [21] 13/10

 13/10 14/11

 16/14 18/9 25/4

 25/19 25/21

 26/13 27/19

 27/25 29/14

 32/1 32/20

 34/14 34/24

 36/20 36/22

 37/11 37/14

 38/24

where [4] 16/15

 17/16 23/17

 32/17

Whereupon [2] 

 3/1 39/16

whether [2] 

 4/23 6/7

which [11] 8/15

 11/1 16/23

 19/11 22/15

 25/23 26/3

 26/16 28/22

 29/25 30/1

while [2] 9/16

 24/21

who [21] 8/10

 10/9 11/3 14/13

 14/19 14/19

 15/2 15/16 19/2

 20/16 20/18

 21/13 25/16

 26/7 27/16

 31/17 32/10

 32/15 32/18

 34/6 34/25

why [37] 8/20

 8/20 9/11 10/4

 10/7 12/14

 12/14 13/6

 15/15 15/17

 15/18 15/22

 16/2 16/2 16/5

 16/9 17/3 17/10

 18/15 18/21

 18/21 20/15

 25/18 26/20

 28/3 29/9 33/5

 33/9 33/12 34/1

 34/3 36/10

 36/22 36/23

 36/25 38/17

 38/17

will [3] 5/12

 6/17 29/18

winter [1] 10/8

wish [1] 35/12

within [1] 

 19/10

without [3] 

 12/12 27/8

 38/19

witness [9] 

 9/18 16/15

 16/20 16/20

 21/13 27/13

 34/15 34/21

 35/6

witness' [1] 

 34/18

witnesses [6] 

 9/15 11/1 13/13

 28/2 32/10

 33/19

won [2] 36/12

 37/18

wooden [1] 

 10/15

word [2] 12/19

 33/16

worded [1] 5/13

words [1] 37/1

work [8] 6/15

 27/3 27/23

 27/24 31/6

 32/25 36/25

 38/20

worked [2] 

 14/13 19/11

working [2] 9/1

 19/17

Works [5] 3/23

 17/17 20/18

 20/23 23/3

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 76 of 77
W

worth [3] 7/6

 26/25 36/25

would [29] 7/6

 7/13 8/10 9/23

 10/22 15/18

 17/8 17/10

 18/13 18/21

 18/21 19/13

 23/8 24/10

 24/21 25/18

 26/9 26/9 26/11

 27/17 29/13

 31/23 33/9

 33/12 34/3 38/2

 38/3 38/4 38/5

wouldn't [5] 

 8/20 17/10 34/1

 37/14 37/15

write [2] 14/11

 22/23

writes [1] 

 25/19

writing [1] 

 38/24

written [6] 

 18/2 27/7 27/8

 27/9 27/22

 35/14

wrong [2] 20/24

 34/2

wrote [7] 11/23

 20/9 22/20

 23/19 25/10

 26/15 35/10

Y

yeah [9] 11/7

 12/9 17/8 18/10

 21/11 24/9

 25/14 30/9

 38/18

year [11] 4/15

 4/22 12/15 17/2

 29/3 29/22

 29/23 29/24

 30/10 30/17

 30/18

years [8] 8/14

 8/17 9/20 9/20

 11/17 13/3

 17/13 21/18

yes [2] 21/8

 37/4

yesterday [1] 

 16/8

yet [5] 5/3

 19/24 26/13

 31/9 39/5

you [178] 

you'll [3] 14/1

 14/7 24/18

you're [13] 

 5/11 22/10

 24/11 24/11

 26/8 32/13

 34/24 35/3

 37/12 37/16

 38/1 38/1 38/12

you've [4] 8/24

 9/17 13/12

 13/24

your [9] 17/6

 18/1 22/9 22/9

 22/11 22/12

 22/22 37/15

 38/6

yourselves [4] 

 8/22 12/14 14/2

 16/9

USDC IN/ND case 2:16-cr-00160-MFK document 512 filed 03/26/21 page 77 of 77