DAY 2 Trial of Carrie Neighbors
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Transcript of DAY 2 Trial of Carrie Neighbors
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
UNITED STATES DISTRICT COURTDISTRICT OF KANSAS
UNITED STATES OF AMERICA, Docket No. 07-20124
Plaintiff, Kansas City, Kansas
Date: 9/14/10v.
CARRIE NEIGHBORS,
Defendant....................
TRANSCRIPT OFJURY TRIAL - DAY TWO
BEFORE THE HONORABLE CARLOS MURGUIA,UNITED STATES DISTRICT JUDGE.
APPEARANCES:
For the Plaintiff: Marietta ParkerAsst. US Attorney360 US Courthouse500 State AvenueKansas City, KS 66101
For the Defendant: John Duma
Attorney at Law303 E Poplar StreetOlathe, KS 66061
Court Reporter: Nancy Moroney Wiss, CSR, RMR, FCRROfficial Court Reporter558 US Courthouse500 State AvenueKansas City, KS 66101
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
I N D E X
GOVERNMENT'S WITNESSES:David Nitz
Direct Exam by Ms. Parker 5Cross Exam by Mr. Duma 57
Re-Direct Exam by Ms. Parker 65Jason Steffen
Direct Exam by Ms. Parker 72Nicolle Beach
Direct Exam by Ms. Parker 90Cross Exam by Mr. Duma 115Re-Direct Exam by Ms. Parker 122
Peter Anthony GarciaDirect Exam by Ms. Parker 125Cross Exam by Mr. Duma 131
Timothy J CoulterDirect Exam by Mr. Oakley 139Cross Exam by Mr. Duma 158Re-Direct Exam by Mr. Oakley 160
Vicki CoulterDirect Exam by Mr. Oakley 164Cross Exam by Mr. Duma 168
Travis KaiserDirect Exam by Ms. Parker 171Cross Exam by Mr. Duma 195Re-Direct Exam by Ms. Parker 201
Micky RantzDirect Exam by Ms. Parker 204
EXHIBITS: OFFERED RECEIVEDGovt's 1.1, 1.1 TR 253 253Govt's 1.2, 1.3 251 251Govt's 1.4 254 254Govt's 1.5, 1.6 259 260Govt's 2.1, 2.1 TR 268 268Govt's 2.2, 2.3 52,266 52,266Govt's 2.4, 2.5 268 269Govt's 3.1, 3.1 TR 274 275Govt's 3.2 52,272 52,272Govt's 3.3, 3.5, 3.6 272 272
Govt's 3.7, 3.8, 3.9, 3.10 276 276Govt's 4.2, 4.3, 4.4, 4.5 52 52Govt's 5.2, 5.3 52 52Govt's 6.1, 6.2 52 52Govt's 7.2, 7.3 52 52Govt's 9.2 52 52Govt's 10.1 183 183Govt's 10.2, 10.3 52 52Govt's 10.5, 10.6, 10.7 52 52
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
EXHIBITS: OFFERED RECEIVEDGovt's 10.5A, 10.6B, 10.7C 147 147Govt's 11.1 103 103Govt's 11.2 44 45Govt's 11.5, 11.6 127 127Govt's 12.1 106 106
Govt's 12.2 52 52Govt's 12.3 76 76Govt's 13.1 108 109Govt's 13.2 52 52Govt's 14.2, 14.3 52 52Govt's 15.3 52 52Govt's 16.3 52 52Govt's 17.2 184 184Govt's 17.3 52 52Govt's 18.3 52 52Govt's 100 6 6Govt's 101 6 6Govt's 109, 109.1 25 25Govt's 110 37 37Govt's 111 38 38Govt's 112 39 39Govt's 113 40 40Govt's 114-124 16 16Govt's 125 209 209Govt's 126 225 225Govt's 128 214 214Govt's 129, 129 TR 247 248Govt's 130 226 227
Govt's 131 226 226Govt's 223.1 114 115Govt's 223.2 52 52Govt's 224 83 83Govt's 229 79 79Govt's 232, 233 54 54Govt's 241 16 16Govt's 242 16 16Govt's 243 56 56
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
(9:03 AM, court and jury returned.)
THE COURT: Get everybody situated in your
chair over there. We had to add a chair in the end for
our box; only has 14 seats and we have 16 people, so
we've added those -- those chairs. Hopefully, Mr.
Heintzelman and Miss Reed, you can see and hear
everything as well. If you don't or if you have some
difficulty, please let me know. Good morning.
THE JURY: Good morning.
THE COURT: Thank you. Hopefully everybody
had a good night's rest. We're ready to go. We had a
full day yesterday as you're aware. We're in a
different courtroom than the big courtroom upstairs. A
lot more people. And we went through the process as
you're now aware of selecting this jury. And it took
most of our day. But we did start with the trial late
yesterday afternoon at which time if you recall, court
read to you some preliminary jury instructions. Also
the parties, the government and the defendant gave you
their opening statements. At this time the court is
ready to have the government present their evidence in
their case-in-chief and we're ready to start at this
time. Miss Parker?
MS. PARKER: Thank you, Your Honor. As its
first witness, the United States will call United States
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
Postal Inspector David Nitz.
THE COURT: Before you take your seat, what
I need for you to do is raise your right hand.
(Witness sworn.)
THE WITNESS: I do.
THE COURT: Please take your seat. Careful
as you get in there. You might want to move that
microphone around. If you would, as you give your
answers to the questions you're asked, please speak up
loud and clear and speak into the microphone. Have you
start with you stating your name.
THE WITNESS: My name is David Nitz, last
name is spelled N I T Z.
THE COURT: Thank you. Miss Parker.
MS. PARKER: Thank you, Your Honor.
DAVID NITZ,
Called as a witness on behalf of the government, having
been first duly sworn, testified as follows:
DIRECT EXAMINATION
BY MS. PARKER:
Q. Sir, where are you employed?
A. I'm employed by the United States Postal
Inspection Service as a United States postal inspector.
MS. PARKER: And Your Honor, before we get
into the testimony of Office-- of Agent Nitz, I would
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
like to offer Government's Exhibit 100, which is a
stipulation to the business records foundation of
certain of the documents that Agent Nitz is going to be
testifying about, and I would offer Government's
Exhibit 101, which is a stipulation to certain facts
that -- some of which will be covered by Inspector Nitz
during his testimony.
THE COURT: In regards -- in regards to
Exhibit Numbers 100, 101, any objection, Mr. Duma?
MR. DUMA: No, Your Honor.
THE COURT: What the court would tell you is
that these exhibits are now admitted, and usually the
exhibit is admitted just by the fact that the court
makes a ruling and it gets admitted. There may or may
not be objections to it being admitted. In this
particular instance, I believe I heard the government's
attorney say this was a stipulation which also you'll
get an instruction on regarding stipulations, but in
essence, it means that this is an exhibit the parties
agreed on in regards to this evidence that's going to be
presented to you at this time. Miss Parker. Continue.
MS. PARKER: Thank you, Your Honor.
BY MS. PARKER:
Q. Inspector Nitz, have you been involved in an
investigation that has been referred to as the Yellow
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
House investigation?
A. Yes, I have.
Q. And when did your involvement begin?
A. My involvement began shortly before the execution
of the first two search warrants in December of 2005,
probably about the latter week or two of November of
2005.
Q. And what interest does the United States Postal
Inspection have in this case? What allows you to have
jurisdiction to investigate?
A. What allows the inspection service to have
jurisdiction in a case is the use of the United States
mail involved in some sort of alleged or criminal
activity.
Q. And how long have you been with the postal
inspection service?
A. I started in January of 1999.
Q. All right. And before that, what did you do?
A. Before that, I was a postal -- or excuse me, an
auditor, tax auditor with the Missouri Department of
Revenue.
Q. And as a postal inspector, would you tell the
jury what types of investigations you most frequently
conduct?
A. Most frequent investigation, I've conducted
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
probably include mail fraud and mail theft. I've also
conducted investigations in most of the areas including
the prohibited mails, child exploitation, narcotics,
bottom investigations, as well.
Q. All right. And what training or experience do
you have in the field of financial analysis or document
analysis?
A. Well, beginning with my degree, I have a degree
in accounting from Northeast Missouri State University
in Kirksville, graduated from there in 1992, with the
state. I conducted investigations of business records
for compliance with tax laws. Most of that time with
the state was spent assigned to our criminal
investigation bureau to conduct those investigations in
support of criminal cases, and then just training and
experience in working mail fraud investigations, and
tracing money through those types of investigations with
the postal inspection service.
Q. And you've testified that you became involved in
this investigation shortly before the first search
warrant -- warrants were executed in December of 2005?
A. That's correct.
Q. And what were the circumstances that got you
involved in this?
A. Lawrence Police Department contacted the
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
inspection service in our Kansas City field offices,
requesting assistance from us for a potential case that
we may be interested in participating in, and I was
assigned that investigation probably partly because of
my background and also experience in working financial
investigations, because that was going to be primarily
the focus if I was involved in the case as far as my
aspect or part of the case would be the financial
investigative part.
Q. And in the course of this investigation, were
records obtained?
A. Yes, they were.
Q. And how were they obtained?
A. The financial records were obtained both through
state search warrants executed at the time of the search
warrants on the physical business and the house, as well
as follow-up federal grand jury subpoenas for records.
Q. All right. And there are several boxes here in
the courtroom on the floor and on the table in front of
you. Are you familiar with the contents of those boxes?
A. I am.
Q. And are they the financial records that were
obtained in this investigation that you have done some
analysis on?
A. Yes.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
Q. I'm going -- may I approach the witness, Your
Honor?
THE COURT: Yes.
BY MS. PARKER:
Q. And with the court's permission, I'm just going
to put the box over here for simplicity sake. Can you
tell the court and the jury what Exhibit 102 is?
A. Exhibit 102 is a bank account from Intrust Bank.
Q. And who was the signatory on that bank account?
A. The signers on the account are Guy Neighbors,
Carrie Neighbors and AJ Neighbors.
Q. What are is last four digits of that bank account
number?
A. Last four digits are 3603.
Q. All right. And what period of time do these
checks in Exhibit 102 cover?
A. January of 2004 through December 2005.
Q. Show you Government's Exhibit 103. What is that?
A. Government's Exhibit 103 is for an Intrust Bank
account ending in the account number 4014.
Q. And who are the account holders?
A. Guy and Carrie Neighbors, the account is listed
as Professional Delivery Services, DBA Yellow House
Store Topeka.
Q. And what period of time do these checks cover?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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A. March of 2004 through December of 2005.
Q. Show you Government's Exhibit 104. Can you tell
the court and jury what that is?
A. Yes, Exhibit 104 is for another Intrust Bank
account ending in 4197, and it is for Yellow House
Quality Appliances, Incorporated or Inc, attention
Carrie M. Neighbors.
Q. All right. What period of time do these records
in 104 cover?
A. February through April of 2004.
Q. Show you Government's Exhibit 105. Can you
identify that please?
A. Yes. Government's Exhibit 105 is Intrust Bank
records for account ending in 4286, and it is Carrie
Neighbors DBA Yellow House Store, Topeka, with signers
Carrie Neighbors and Guy Neighbors.
Q. And what period of time does 105 cover?
A. Covers January of 2004 through March of 2005.
Q. Show you Government's Exhibit 106. Can you
identify that please?
A. It's another Intrust Bank account ending in 7108,
and it is for Carrie M. Neighbors DBA Yellow House Store
covering the periods of January through March of 2004.
Q. All right. And finally, in this box I show you
Government's Exhibit 107. What's that?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
A. Government's Exhibit 107 is Intrust Bank records
for account ending in 1169. It's for Guy Neighbors DBA
Guy's Store.
Q. What period of time does Exhibit 107 cover?
A. December of 2005 through January of 2006.
MS. PARKER: Your Honor, these documents are
being identified and the foundation being laid for the
purpose of supporting summaries, but we will not offer
them into the record as an exhibit unless and until it
becomes necessary to do so.
BY MS. PARKER:
Q. Finally, for purposes of identification, I'm
going to show you what's been marked Exhibit 108. What
is that?
A. Exhibit 108 is for the Commerce Bank records
ending in account 90223. It is for Carrie M. Neighbors,
Guy Neighbors, DBA Yellow House Quality Appliance at the
1904 Massachusetts address.
Q. All right. And who are the signers on there?
A. Carrie M. Neighbors and Guy Neighbors.
Q. All right. What period of time do the documents
in Exhibit 108 cover?
A. January 2004 through December 2005.
Q. And these were identified for the same purpose,
Your Honor. Now, all of these documents, Exhibits 102
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
through 108, did you conduct some financial analysis on
those documents?
A. Yes, I did.
Q. Would you tell the grand jury what kind -- I'm
sorry, the court and the jury what kind of an analysis
you performed on this big stack of documents?
A. The primary analysis conducted on -- on these
records was to determine who checks were being written
to, for the purpose of identifying not only who the
Neighbors were writing checks to, but in what volume or
quantity they were writing them.
Q. So, is it fair to say that you took those checks
and you isolated checks out by who the -- who the check
was written to?
A. Yes, that's correct.
Q. All right. And then did you make some exhibits
and some summaries of those exhibits?
A. Yes.
Q. Let me start with Exhibit 114. Would you tell
the grand jury what that is please -- I'm sorry, the
jury what that is please?
A. Exhibit 114 is a notebook containing copies of
checks payable to Nicolle Beach as well as a summary
chart of those -- those checks.
Q. And all of these books I'm about to ask you to
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
identify, the contents of those books are duplicates of
the checks that you have just identified in Exhibits 102
through 108?
A. Yes, they are.
Q. And then at the front of each of those books is a
summary that basically on one or two pages summarizes
the information in each book, correct?
A. Yes, it does.
Q. All right. What is Exhibit 115?
A. 115 is the same type of notebook containing
copies of checks and a summary for checks payable to
Travis Kaiser.
Q. All right. Exhibit 116. What's that?
A. Exhibit 116 is a notebook for checks and summary
charts for Joey Cadenhead.
Q. Exhibit Number 117. Can you identify that
please?
A. Yes. Exhibit Number 117 is for checks and
summary charts for checks payable to Laura Helm.
Q. Exhibit Number 118, I'm handing you that. What
is that?
A. Exhibit Number 118 is for checks written from
Yellow House to Lewis Parsons and a summary chart.
Q. Exhibit 119?
A. 119 is the checks and summary chart for checks
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
payable to Norma Payne.
Q. Exhibit 120, what is that?
A. Notebook containing checks and summary chart for
checks payable to Michael Aldridge.
Q. Can you identify the contents of Exhibit 121?
A. Yes, Exhibit 121 is for checks and summary charts
for checks payable to Bradley Byrne.
Q. Show you Exhibit 122. What is that?
A. 122 is the checks and summary chart for checks
payable to Pat Nieder or -- Pat Nieder or Patrick
Nieder.
Q. All right. Exhibit 123. What's that?
A. 123 is for checks and summary charts for checks
payable to Stacy Barnes or Stacy Barnes-Catlett.
Q. All right. Exhibit 124. What is that?
A. Exhibit 124 is for checks and summary charts for
checks payable to Jim or James Ludwig.
Q. And finally in the notebook area, what's Exhibit
Number 1-- I'm sorry, 242?
A. Exhibit 242 is a summary and copies of checks for
checks payable between the various Yellow House Store
checking accounts or bank accounts.
Q. And Exhibit Number 241. Tell the jury what that
is.
A. 241 is a summary chart for checks payable to
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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Marcus Crawford.
MS. PARKER: Your Honor, at this time the
United States would offer Government's Exhibits 241 and
242, and Exhibits 114, 115, 116, 117, 118, 119, 120,
121, 122, 123, and 124.
THE COURT: Any objections?
MR. DUMA: No objections, Your Honor.
THE COURT: At this time the court is going
to admit Exhibits 241 and 242 as well as admit Exhibits
114 through 124.
MS. PARKER: All right.
BY MS. PARKER:
Q. All right. Now, if you would open Government's
Exhibit -- well, the one that's there on the witness
stand. I believe it's Exhibit 124, is that right?
A. That's correct.
Q. All right. And I'm going to put up on the
overhead the document. Do you see that?
A. Yes, I do.
Q. All right. And is this document --
THE COURT: Are your monitors on in the jury
box?
UNIDENTIFIED JUROR: Can you make it a
little bigger?
UNIDENTIFIED JUROR: Yeah, can it go larger?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
BY MS. PARKER:
Q. Now, we'll zoom in and get a little closer on
some of these columns, but for the purpose of explaining
the entire summary chart, can you tell the jury what
each column stands for?
A. Yes. The original order column is just ordering
of how we entered them in to begin with.
Q. All right. That's your number, that's first
check, second check?
A. Yes.
Q. All right. And then the next column, it says
bank. What's that?
A. That is the actual bank that the account is drawn
on. Particularly, this one, the first one listed is
Intrust.
Q. So, that relates to the Intrust Bank records
you've just testified about?
A. Correct.
Q. All right. What does account number mean? I
think it's obvious, but --
A. Yeah, account number is the last few digits of
the account number.
Q. Then there is a column that is entitled count.
What does that stand for?
A. That count is to reference any of the checks that
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
are associated to a particular count in the indictment.
Q. All right. So, this check here that's numbered
15 on the list that has the 16 next to it, that check
relates to the charges in Count 16, is that correct?
A. Correct.
Q. All right. Then the next column is a column
entitled overt act. What's that?
A. That's a column that references back to the
indictment as well basically a paragraph number of an
overt act.
Q. And then the column entitled source, bank or SW,
what does that mean?
A. That means that is the source of where we
obtained the records, either from -- directly from the
bank or via search warrant.
Q. And the next column bate stamped number
beginning?
A. Yeah, bate stamp number is a reference to the
number that is printed on the bottom right of the check
in the process of preparing them for court.
Q. All right. So, that is a number that enables you
if you need to go to that big box of checks to go
immediately by the bate stamp number to find it if you
need to?
A. Correct.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
1
Q. The next column is for what?
A. Umm, that is a sub-section if it was needed, if
there was more than one page referencing a particular
check, or like if I was referencing a bank statement
somewhere.
Q. The next one, bate stamp?
A. It would be the ending number of that.
Q. That's pretty blank?
A. Yes, most of the checks are contained on one
page. Some of them are on two pages.
Q. BS number?
A. That's the bate stamp sub-section, the ending
part of it. So, if there's one that's listed as 325 A,
then the A would be the sub-section part of that.
Q. So, the four columns we've just talked about are
really columns that would have provided you with the
information you need to quickly go to a check that's on
this list. Is that fair?
A. Correct. Yeah.
Q. The next check, check date?
A. That is the date that is reflected on the check
itself as far as when the check was made payable for.
Q. All right. Date paid?
A. That would reference when -- when the check
cleared the bank or appeared to be presented for
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
payment.
Q. Check number, I assume that means that's the
number on the check?
A. Correct.
Q. That's the printed number that the bank sends
when it sends a checkbook -- a book of checks?
A. Yes.
Q. All right. Amount?
A. That is the amount that is written on the check
payable for the amount for.
Q. And the next column is witness?
A. Yeah, witness, that is just the last name of the
person that the check was written to.
Q. All right. And how about payee, what is that?
A. The payee is the actual person that the check was
written payable to.
Q. Now, in most of the entries here on this first
page of the summary, it shows the witness and the payee
as James Ludwig, correct?
A. Correct.
Q. All right. But on this very top one, the payee
is Arlette Ludwig. Do you know who that is?
A. Yes, that is the wife of James Ludwig.
Q. And so, that means the check was made out to
Arlette, but James Ludwig has information about it?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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A. Yes.
Q. And then finally, the memo column here. What
does that represent?
A. That represents the description that was written
on the check itself in the memo column by the person
writing and signing the check.
Q. All right. And these are checks I believe you've
all ready testified to that were written on bank
accounts belonging to either Guy or Carrie Neighbors?
A. Yes.
Q. Or both?
A. Yes.
Q. And so, the memo section of the check would have
been filled in by Guy or Carrie Neighbors, or at least
would have been there when either one of them signed the
check?
A. That would be the presumption. It was on the
check all ready when we obtained them.
Q. Okay. And let's just go down this column here,
and the -- I -- I've zoomed in a little bit so that what
we've got I think a little bit more readable now are the
check dates, and I'm really interested in the check
dates and in the memo section. On January the 8th of
2004, a check was written which indicates that it was
for -- or at least the memo section says Samsung DVD
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
VCR. Do you see that?
A. Yes.
Q. All right. And from your investigation, have you
been able to determine that the memo section is
basically a recording of what the person came in and
sold at the Yellow House?
A. Yes, that's correct.
Q. All right. So, this would indicate that on
January 6th, a DVD VCR was sold?
A. Yes.
Q. All right. What -- on January the 14th, what was
sold?
A. Tools.
Q. All right. And on January the 28th, what was
sold?
A. DVD and Craftsman.
Q. All right. On January 29th, what was sold?
A. Tools.
Q. On -- again, on January 29th, what was sold?
A. Tools.
Q. Again on January 29th, what was sold?
A. Tools.
Q. All right. And this goes down like that for one,
two, three, four, five, six pages. Do you agree?
A. Yes.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
Q. Or five and a half pages, five pages and a little
bit of six?
A. Yes.
Q. All right. And what is the last date that you
had a check for where Jim Ludwig was the payee?
A. On November 28th, 2005.
Q. And what was sold that day?
A. Tools.
Q. And there is a column here under amount that has
the total there. What is that?
A. That's the total of the checks on the summary
chart.
Q. Total of the value of the checks?
A. The value, yes.
Q. So, the Yellow House bank accounts were used to
transfer $104,616.30 to James Ludwig or a member of his
family --
A. Yes.
Q. -- during this period of time. Now, did you get
checks after December 31st of 2004?
A. Umm, after December 2004?
Q. I'm sorry, 2005.
A. We obtained a few checks for -- just based on the
investigation.
Q. But the search warrants and subpoenas were not
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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issued for any checks of 2006, except for the few that
you've referred to, mainly checks for Joey Cadenhead?
A. That's correct.
Q. All right. So, the summary charts that you
prepared here really only go up until December of '05?
A. That's correct. They generally just cover
January 2004 through December of 2005.
Q. And then the summary charts and the checks in all
of those books are set up just like the one we just
reviewed in James Ludwig's case, correct?
A. That's correct.
Q. Now, you also got some eBay and some PayPal
records, did you not?
A. Yes, I did.
Q. And what eBay records did you subpoena or -- or
what eBay records were obtained by search warrant?
A. EBay records that were obtained -- well, they
were eBay and PayPal records combined for Yellowhair
Bargains and Bargain Guy 44.
Q. All right. Let me show you -- Your Honor, would
you like me to ask each time I approach the witness for
permission or is --
THE COURT: That's not necessary, but thank
you for bringing that up.
BY MS. PARKER:
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
Q. Show you Exhibit 109. What is that?
A. 109 is a CD or DVD, CD of the records that were
provided by eBay slash PayPal in referencing the
Yellowhair Bargains and Bargain Guy 44 accounts.
Q. And let me show you Government's Exhibit 109.1.
Would you tell the jury what that is?
A. 109.1 is printed hard copy information from the
records that were provided electronically from eBay and
PayPal, and includes information pertaining to the
owners of those accounts.
MS. PARKER: Your Honor, at this time,
government would offer Exhibits 109 and 109.1.
THE COURT: Any objection?
MR. DUMA: No objection, Your Honor.
THE COURT: At this time court admits
Exhibit 109 and 109.1.
BY MS. PARKER:
Q. Before we get into the information that you are
able to obtain from those eBay and PayPal records, I
want to go back for just a moment to our discussion of
the bank documents. In the course of your employment
and in your training and experience, are you aware of
how the banking industry affects inter-- interstate
commerce, if it does?
A. Yes. Yes, I am aware of that. Transactions
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
that -- that get processed through banks, for instance,
checks will be processed through the bank that is the
owner of that check in a sense. So, whether it's
Intrust or Commerce Bank, those checks travel between
state lines in order to get processed and run through
the Federal Reserve Bank, for instance, locally here in
Kansas City, Missouri. Also, transactions that are
electronic as far as transfers between bank accounts or
in the -- in the specifics like of this case when we
have transfers that go from a PayPal account on eBay
that get transferred into the bank account in Kansas,
those would be traveling via interstate commerce or
affecting interstate commerce, traveling electronically
from, you know, say California to Kansas.
Q. And do the banks themselves engage in interstate
financial activity?
A. Yes, they do. There are inter-bank transfers
that are made electronically to more quickly transfer
funds than --
Q. Banks make loans for houses or businesses or to
buy commercial buildings in states other than where they
actually are situated themselves, correct?
A. That's correct.
Q. All right. So, in your professional opinion, do
the checks here represent activity that affects
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
2
interstate commerce?
A. Yes, it does.
Q. All right. Now, we'll go back to the eBay and
the PayPal records. Exhibit 109, can you start with
Page 1?
A. This is on 109.1?
Q. 109.1. Before we go into talking about that,
these records were obtained by search warrant?
A. Yes, that's correct.
Q. How does that happen?
A. This was through a state search warrant.
Typically, on a state level, a search warrant will be
issued. For records on a federal level, it will be a
grand jury subpoena. In this case, search warrants were
obtained for business records by the Lawrence Police
Department at the same time the search warrants were
being applied for and obtained for the physical
locations of the business and the residence.
Q. So, the law enforcement agencies in this case did
not go out to eBay in California and search through
their records to find these. They served them with a
copy of the search warrant, and eBay then mailed back to
them these documents?
A. Yes, in the form of an electronic version.
Q. All right. And what was the type of information
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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that was requested from eBay under that search warrant?
A. Basically, ownership and transaction activity.
Q. All right. And Exhibit 109.1 is a document that
relates to some of the information from the eBay
account, correct?
A. Correct, 109.1 references account ownership
information.
Q. All right. And let's start at the top here.
There is a column, eBay user ID, eBay e-mail address.
Do you see that?
A. Yes.
Q. All right. What's number one, what's that?
A. That is listing the eBay user Yellowhair Bargains
and the eBay e-mail address of
Q. Do you know what that negative $353.84 is?
A. I do not know.
Q. That's something that eBay provided to you?
A. Yes, that's in the original form. That wasn't
something I added.
Q. And then this is the form that they sent you this
information in, correct?
A. Correct.
Q. All right. The name of this account is what?
A. Yellow House.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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Q. With an address where?
A. 1904 Massachusetts Street, Lawrence, Kansas,
66046.
Q. And then it shows a creation date. What's that?
A. It shows a creation date of January 17th of 2003,
which is the date that eBay reflects as that account
being created -- or created.
Q. And then the account status, it shows suspended?
A. At the time that they printed this, it was
suspended.
Q. And what time -- what time-frame was this sent to
you and printed? Would this have been in 2006?
A. It would have been about the beginning of 2006.
I don't remember exactly when we received it.
Q. And then the number two here under the eBay
account, what is that?
A. Number two references Bargain Guy 44 with the
e-mail address of [email protected].
Q. All right. And the eBay user ID is the name that
would appear on the eBay site if Bargain Guy 44 was
selling something?
A. Correct.
Q. And then if someone wanted to communicate with
the owner of the Bargain Guy 44 account, they would send
an e-mail message to [email protected], is that
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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right?
A. Yes, they could send an e-mail.
Q. And the name associated with that account is?
A. Guy Neighbors.
Q. And the address?
A. 1835 Northwest Topeka Boulevard, Number 131,
Topeka, Kansas.
Q. And then there are several telephone numbers
there, correct?
A. Yes.
Q. All right. And it shows that was created or that
account was opened when?
A. November 17th, 2003.
Q. All right. Now, we've talked about eBay.
There's PayPal e-mail addresses on here. How are PayPal
and eBay related, if you know?
A. EBay is the actual on line auction site where an
individual or business would -- would post something to
be sold, and that is where the auction takes place.
PayPal is a -- for lack of better description, similar
to bank account, basically making a transfer between
accounts. So, an individual can have a PayPal account
that they will pre-fund and have money available in that
or provide some sort of funding for that account, and
then if they purchase something from another eBay seller
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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and that eBay seller has an account set up, then the
transfer of funds can go from one PayPal account to
another PayPal account rather than having to send a
check or money order or cash to the person who's selling
it.
Q. And the PayPal money in the PayPal account can be
transferred directly from PayPal to the account owner's
own bank account if they choose, correct?
A. Yes, it can.
Q. Now, the first PayPal e-mail address here is the
A. Yes, that's correct.
Q. Same as the e-mail address that goes back to the
Yellow House, correct?
A. Yes.
Q. And the account number on this one ends in 8604,
correct?
A. Yes.
Q. All right. And the name that is associated with
that account as the owner?
A. Carrie Neighbors.
Q. And it has the 1904 Massachusetts address. If
you have another one, what's that?
A. 1104 Andover, Lawrence, Kansas. Address is the
physical residence of Guy and Carrie Neighbors.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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Q. All right. And the creation date of this account
was when?
A. March 7th, 2003.
Q. All right. And then there is a column there
indicating that the account should be restricted by the
time the law enforcement agents received the disk,
correct?
A. Yes.
Q. All right. PayPal account number two,
[email protected], same address as is on the Bargain
Guy 44 eBay user ID?
A. Well, it includes the address 1104 Andover.
Q. But I'm talking about just right now the -- the
e-mail address?
A. Oh, yes, the e-mail address.
Q. Same as in number two under eBay user ID?
A. Yes.
Q. All right. And this is associated with Guy
Neighbors?
A. Yes.
Q. And he also was using the 1104 Andover there,
correct?
A. Yes.
Q. All right. And this is the account that ends in
4029?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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A. Yes.
Q. And when was that created?
A. That was created November 18th, 2003.
Q. And again, that account should have been
restricted by the time this information was received by
law enforcement?
A. Yes.
Q. And then next page is just an address of the
contact to send the information to. That would be
Officer Micky Rantz of the Lawrence Police Department?
A. Yes.
Q. Now, Page 3 of Exhibit 109.1. Can you tell the
court and the jury what this document is?
A. This is the actual printed account information
page for the [email protected] or the Yellowhair
Bargains account in the name of Carrie Neighbors.
Q. All right. And down here, there is a column for
financials. Do you know what that's for?
A. Umm, that is going to reflect a balance that's
listed in the account as well as some dollar amounts
that the eBay or PayPal is reflecting as the amount
sent.
Q. And in this --
A. In the account.
Q. And in this case, for the Carrie Neighbors
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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account, it shows $579,178.96?
A. Yes.
Q. And what is Page 2?
A. Page 2 is a continuation of the account
information page, and it lists -- down at the bottom, it
begins listing some of the addresses associated with the
account.
Q. And those are the addresses for the most part
that you have all ready testified about?
A. Yes.
Q. The next page?
A. It is Page 3 of the account information page. It
begins with the addresses, and then continues into the
bank accounts.
Q. So, it reflects some of the bank accounts that
you have all ready testified about?
A. Yes.
Q. Okay. And then the next page, this is product
information for Carrie Neighbors. Again, it's more
information relating to her account at eBay. I'm sorry,
this is a PayPal.
A. This is a PayPal information page.
Q. All right. Now I'm going to skip through some of
these, but in any event, going to the page that at the
top is listed as Page 5 of 8, do you have that?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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A. Yes.
Q. All right. And I'm going to the redemption codes
available, coupons available. That's more information
about the account?
A. Umm, yes, you're zoomed in right now on it,
but --
Q. So, there is extensive information that eBay and
PayPal are able to provide about its customers, correct?
A. Correct.
Q. You -- referring to the Document 109.1, one of
the accounts was bank account -- Intrust Bank account
ending in 42861 of the accounts associated with these
records?
A. It was listed in there.
Q. All right. Intrust Bank account ending in 4014.
Is that also associated with the PayPal and eBay
records?
A. Yes. Yes.
Q. Account ending in 7108 at Intrust Bank was also
linked to the eBay/PayPal records for Carrie and Guy
Neighbors?
A. Yes.
Q. And Intrust Bank account ending in 4197, that as
well?
A. Yes.
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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Q. Intrust Bank account 8095, was that also
associated with the eBay/PayPal records?
A. Yes.
Q. Intrust Bank 0995, account ending in 0995, was
that also associated?
A. Yes.
Q. And finally, Commerce Bank account ending in
0223, was that associated with those records?
A. Yes.
Q. And the association of the bank and the account
numbers with those records, did that mean that PayPal
could transfer money in either Bargain Guy 44 or
Yellowhair Bargains accounts directly into the bank
accounts?
A. It could. If they chose to do that, they could
transfer money directly into those accounts.
Q. Okay. I want to show you what has been marked as
Government's Exhibit Number 110. Do you recognize that?
A. I do.
Q. What is that?
A. That is a print-out of all the information going
from left to right on, including all of the columns that
would be provided by eBay.
Q. All right.
MS. PARKER: Your Honor, at this time
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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government offers Exhibit 110.
MR. DUMA: No objection.
THE COURT: At this time court admits
Exhibit Number 110.
BY MS. PARKER:
Q. All right. Is this the size it print out or has
this been enlarged just for demonstration purposes?
A. No, if you wanted to print all of the columns
that they provide, at least in somewhat readable form,
you would have to print it that large.
Q. All right. And so, you, in -- during the period
of your analysis, took the -- is this the eBay
print-out?
A. That is the eBay print-out, yes.
Q. So, in order to have it in a usable format, using
all of the columns, you would have to have a stack of
documents this big?
A. Correct, if you wanted to print all the columns,
yes.
Q. So, did you then take the information on
Exhibit 109 and reduce it to a smaller size?
A. Yes.
Q. All right. Show you Government's Exhibit 111.
Can you identify that please?
A. Yeah, Exhibit 111 is the -- the print-out of the
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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selected information, the columns that I left in for
analysis purposes.
Q. All right.
MS. PARKER: Your Honor, at this time the
government offers Government's Exhibit 111.
THE COURT: Any objection?
MR. DUMA: No objection, Your Honor.
THE COURT: At this time the court admits
Exhibit Number 111.
BY MS. PARKER:
Q. And I'm going to put Exhibit 111 on the overhead
and just -- what was your purpose in doing this
analysis?
A. This -- the purpose of doing this analysis was
to -- well, this is actually the -- the complete printed
information from eBay including all the information that
was reflected in postings on the eBay sites.
Q. And this last column here has the high bidder
name that actually identifies who purchased the product?
A. Yes, that identifies who won the bid or the
bidding process for each item.
Q. All right. And all of these entries here in
Government's Exhibit 111, they relate only to the
Bargain Guy 44 and Yellowhair Bargains or Yellow House
accounts, correct?
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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A. That's correct.
Q. Now, also on that disk was information for
PayPal, correct?
A. Correct.
Q. I'm going to show you Government's Exhibit 112.
What's that?
A. That is a print-out on large format of all of the
columns that are included for PayPal. PayPal has quite
a few additional columns than what eBay print-outs
actually have.
MS. PARKER: Your Honor, at this time the
government would offer Government's Exhibit 112.
THE COURT: Any objection?
MR. DUMA: No objection.
THE COURT: At this time the court admits
Exhibit Number 112.
BY MS. PARKER:
Q. Okay. And now I'm going to turn it right side up
and display this for the jury. Now, did you have to
enlarge this, or is this the size that it takes to print
out all the information directly from that disk about
PayPal?
A. That's the size if its basically shrunk down to
get onto that -- onto that paper right there.
Q. So, it's impractical to print out directly from
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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the disk, the 109, the information from PayPal?
A. Yes, it would go on several pages just to include
all the columns of going from left to right.
Q. So, in order to have information in a usable
form, did you again take the disk and put it into a form
that was more easily dealt with?
A. Yes.
Q. All right. Can you tell the jury what Exhibit
113 is, please?
A. Exhibit 113 is the print-out of the PayPal
records associated with the Yellowhair Bargains and the
Guy -- or Bargain Guy 44 accounts.
Q. All right.
MS. PARKER: And Your Honor, at this time
the government would offer Government's Exhibit 113.
THE COURT: Any objection?
MR. DUMA: No objection.
THE COURT: At this time the court admits
Exhibit Number 113.
BY MS. PARKER:
Q. Now, Exhibit 112 -- I'm sorry, 111 which is the
print-out of the eBay information, what did you do with
this? Did you make any summaries or reduce this to some
kind of a summary at all?
A. Umm, not so much the eBay, but did with the
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USA V CARRIE NEIGHBORS
NANCY MORONEY WISS, CSR, RMR, FCRR
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PayPal records.
Q. All right. The PayPal records in Exhibit 113,
what did you do with those in the course of your
investigation?
A. Took the -- I took -- took the information that
was contained in there listing their sales, and this is
the sales that would come through PayPal. This does not
include sales if somebody would mail a check or cash
payment or pay by credit card. This would be just the
sales that were completed through eBay and paid through
a PayPal account. Took that information and began
removing certain items that were sold by them that we do
not believe -- may not be related to the case,
particularly removing items such as conducted searches
and removed items such as appliances that were typically
being stored or sold in the store, such as a used oven
or refrigerator, some item like that. Conducted
searches, and this is electronic searches through the
spreadsheet for any item that lists used or used search
terms like -- for like -- like new, trying to remove
each item that was not an item that was listed as new or
new in the box type item, and then did a line by line
search of the remaining items to remove any additional
ones that we didn't think applies to the specifics of
this case.
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NANCY MORONEY WISS, CSR, RMR, FCRR
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Q. All right. So, the final product that you have
reflected only the PayPal information relating to new
items sold by Yellow House. Is that a correct
statement?
A. Well, that exhibit actually is a printing of all
of the items. But in order for -- to determine maybe
like a dollar amount, approximate of the items that were
new or new in boxes items, I conducted that search and
removal of items. But the actual exhibit is a print-out
of -- of all the information.
Q. But after you winnowed out all of the extraneous
items and were left with what you believe was just an
accounting for new items, were you able to determine how
much the Yellow House stores received from PayPal for
new items?
A. Yes, it was a little over $600,000.
Q. And the $600,000, that is only PayPal. Are there
other methods for merchants who sell on eBay to get
payment besides going through PayPal?
A. Yes, they can receive payment via money order,
cash, check that would be mailed to them, they could
accept orders over the phone, or actually, I mean, not
orders, but payment over the phone using a credit card.
So, there could be other ways. It's just PayPal is one
way in which they can transfer money and pay for the
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item.
Q. All right. So, assuming that there was some
activity outside of the PayPal account, this $600,000
total figure would likely go up?
A. Yes.
Q. All right. Now, did you also isolate certain
pages from the eBay and the PayPal records?
A. Yeah. I isolated certain pages that related
specifically to the counts in the indictment.
Q. All right. I'm going to show you Exhibit 11.2.
What's that?
A. 11.2 is a print-out of eBay records relating to
Count 11, and on each of these pages in these, there
will be a line or more than one line depending on how
many items per page are related, that is highlighted,
and that highlights the items specifically related to
that count.
Q. All right. The highlights that are on these
exhibits in yellow are highlights you put there,
correct?
A. Correct.
Q. To indicate which of the lines relate to certain
counts, correct?
A. Yes.
Q. But other than that, have there been any changes
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made to those documents?
A. No.
Q. All right. Is there a number down in the corner?
A. Yes, the number down in the corner next to, for
instance, Exhibit -- you know, this is Government's
Exhibit 11.2. There's a number E B 136. That is
basically a bate stamp number that we had printed on
here so that once again I could refer back to a specific
page for that account that would have been in that full
complete print-out that we've all ready done.
MS. PARKER: I'm sorry, are you finished?
At this time the government offers Exhibit 1-- I'm
sorry, 11.2.
THE COURT: Any objection?
MR. DUMA: Judge, could I please ask one
question of this witness before I --
THE COURT: Yes.
MR. DUMA: Agent Nitz, that is as to a
specific count in the indictment, is that correct?
THE WITNESS: Yes, that relates to a
specific count in the indictment. 11.2 would be
referencing Count 11.
MR. DUMA: Thank you. No objections.
THE COURT: At this time the court does
admit Exhibit 11.2.
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BY MS. PARKER:
Q. And maybe that is good time to do a little bit of
explaining of how these exhibits are numbered. Exhibits
that start -- in this case we've referred to
Exhibit 11.2. What does that first number mean?
A. The first number 11 is a reference to Count 11 in
the indictment.
Q. And this would be the second document that
relates to Count 11?
A. Yes, the .2 would reference a second document.
Q. And so, any exhibit that starts in a Number 11
will be an exhibit that relates to Count 11, correct?
A. Correct.
Q. All right. There are 18 counts in the
indictment, correct?
A. Correct.
Q. All right. So, numbers starting with 2, 3, 4
would all relate to Count 2 or Count 3 or Count 4?
A. Correct.
Q. Then there are exhibits that have been marked Buy
One and Buy Two. What do those relate to?
A. Those are relating to specific buys, are relating
to undercover activity by our undercover officers. That
would be -- Buy One would reference the first sale of --
by the undercover officer to Carrie Neighbors or the
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first buy that she made from the undercover officer.
Q. And then there are documents that are -- and then
anything related to Buy One will be Buy 1.1, 1.2, Buy
1.2, Buy 1.3. So that you -- anybody reading those
numbers would know that all of these documents that have
Buy 1. something relate to that first buy on
October 27th?
A. Yes, that's correct.
Q. Now, we have documents that are marked CI 1.1, CI
1.2. What do those refer to?
A. Those refer to our confidential informant,
cooperating individual, specifically Joey Cadenhead.
And the one would reference the first sale to Yellow
House, CI 2 would reference a second sale, and any of
the .1 .2 .3 would reference individual documents or
items within that were associated with that first or the
second or the third buy.
Q. And at the request of the law enforcement agent,
Joey Cadenhead went into the Yellow House on three
occasions and had contact with Carrie Neighbors, is that
right?
A. Yes.
Q. And so, CI 1, 2, 3 are the references to those
three visits that were recorded?
A. Yes.
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Q. All right. Now, in front of you I have set a
stack of folders. Can you identify by exhibit number
what are contained in those folders?
A. Yes. Item 12.2 is an eBay print-out. It has two
highlighted items on there, but this references -- at
least one of those items references Count 12.
Q. All right. Do you also have Exhibit -- and
that -- these pages that you are referring to in this
stack you're about to identify all look like 11.2 as far
as their form goes?
A. Yes.
Q. All right. What's Exhibit 13.2? What does that
relate to?
A. 13.2 is another print-out from the eBay records,
and it references to Count 13.
Q. All right. Exhibit 20 -- I'm sorry, 223.2,
what's that?
A. That is another eBay print-out.
Q. All right. Exhibit 10.5?
A. Exhibit 10.5 is a -- another eBay print-out
referencing Count 10.
Q. All right. Exhibit 10.6?
A. 10.6 is a -- an eBay print-out, and it also
references Count 10.
Q. Exhibit 10.7?
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A. Another eBay print-out referencing 10. -- or
referencing Count 10.
Q. All right. Do you have Exhibit 10.2 there?
A. Yes.
Q. Is that another eBay page that references Count
10?
A. Yes.
Q. All right. Exhibit 10.3, is that an eBay page
that references Count 10?
A. 10.3 is a PayPal page in reference to Count 10.
Q. All right. Exhibit 17.3. What's that?
A. 17.3 is a pay -- a print-out from the PayPal
documents in reference to Count 17.
Q. All right. Exhibits 5.2 and 5.3, are those
documents that relate to Count 5?
A. Yes, they are. They are both eBay documents.
Q. Exhibits 7.2 and 7.3, are those documents
relating to Count 7?
A. Yes, they would be, and both of them are eBay
print-outs.
Q. Exhibit 18.3, what's that?
A. 18.3 is a PayPal print-out referencing Count --
or Count 18 for the transfer of funds to the bank
account.
Q. All right. That's for the transfer of funds from
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PayPal to one of the Yellow House bank accounts?
A. Yes.
Q. All right. And when those funds are transferred,
does PayPal transfer those electronically?
A. Yes, that is done electronically.
Q. And does that electronic transfer of funds from
PayPal into the Yellow House bank account affect
interstate commerce?
A. Yes, it does.
Q. Exhibits 2.2 and 2.3, what are they?
A. 2.2 is an eBay print-out in reference to Count 2
and Exhibit 2.3 is a PayPal print-out in reference to
Count 2.
Q. Now, when you say that 2.2 is an eBay account
record and 2.3 is a PayPal account record, are each one
of those clearly marked someplace where it shows this is
PayPal, this is eBay?
A. Yes, the eBay in particular 2.2 is in reference
to eBay Page Nine, E B Nine.
Q. All right. And how is that?
A. And then Pay --
Q. Where do you find that?
A. That is on the bottom right corner.
Q. All right. And I'm goin