Petition for Writ of Certiorari — Naquan Reyes, Petitioner v. United States

Supreme Court briefOct 6, 2020

Ask Donna

What actually matters in this document.

Text

UNITED STATES DISTRICT COURT

:T l:il_: Tti:: I_:1_Y1_t:ii---x

uNrrED STATES OF AMERTCA,

United States Courthouse

Brooklyn, New York

October 24, 20LB

-against-

L4-CR-227 (SJ)

11,:00 a.m.

NAQUAN REYES,

Defendant.

-----;--x

TRANSCR]PT OE CRIMINAL CAUSE FOR RE_SENTENCING

BEFORE THE HONORABLE STERLING JOHNSON, JR.

UNITED STATES SEN]OR DISTRICT JUDGE

APPEARANCES

For the Government:

UNITED STATES ATTORNEY'S OEEICE

EasLern Dlstri-ct of New York

277 Cadman PLaza East

Brooklyn, New York 11207

BY: ELIZABETH GEDDES, ESQ.

Assistant United States Attorney

1_5

FOr the Defendant:

LAW OEFICE OF DONNA R. NEWMAN

20 Vesey Street

New York, New York 10007

BY: DONNA NEWMAN, ESQ.

AIso Present:

VfCTORIA MAfN, Probation Department

Court Reporter:

Rivka Teich, CSR, RPR, RMR, FCRR

Phone z 7tB-61,3-2268

EmaiI: RivkaTeichGgmail.com

Proceedings recorded by mechanical stenography. Transcript

produced by computer-aided t.ranscription.

.'t

Riuka Teich CSR, RP& RMR FCRR

Official Court Reporter

(In open court.)

THE COURTROOM DEPUTY: A11 Rise.

versus Naquan Reyes.

MS. GEDDES: El-izabeth Geddes for the Government.

United States

Good morning, your Honor.

MS. MAIN: Vj-ctoria Main, Probation Department.

MS. NEWMAN: Good morning, your Honor. Donna Newman

on behalf of Mr. Reyes. Wopld you like Mr. Reyes to join

here? Can we t.ake off his handcuffs?

THE COURT: No, the Marshals want it

11_

stay on.

on; it will

Come on up.

MS. NEWMAN: Thank you, your Honor.

THE COURT: We're here for sentencing.

MS. NEWMAN: Yes.

MS. GEDDES: Yes, .Judge.

THE COURT: Mr. Reyes, have you read and discussed'

the presentence report with your lawyer?

THE WITNESS: Yes.

THE COURT: Are you ready for sentencinq?

THE WITNESS: Yes, sir.

THE COURT: You want.to say something? First.

all,

There are some objections to the presentence report., I'm going

to rnake a ruling

before we do, 1et's have some administrative matters.

o.n them.

MS. GEDDES: I don't know that there are any

RiukaTeich CS& RPB RMR FCRR

OJJicial Court Reporter

objections.

MS. NEWMAN: I didn't object to any of the

calculations to the presentence report.

think there was, like we had agreed, the Government and the

defense agrees, that he should get three points for

acceptance.

THE COURT: He's going to

MS. GEDDES: Than[ you, Judge.

THE COURT: That guideline,

Other than the, I

get the three points.

instead of l-ife it is

The question before me is, where in the

now 360 to life.

guidelines or bel-ow the guidelines I'm going to sentence the

1,2

defendant.

MS. NEWMAN: That is correct, your Honor, and if

may talk

to that, but I'11 wait.

THE COURT: I want. to hear from the defendant first

then you can.

MS. NEWMAN: Thank you, your Honor.

THE COURT: Go ahead Mr. neyes.

1,9

THE WITNESS: Thank you, your Honor, first

start off by showing my deeply remorse my apologizing to the

Thompson family,

f want to

her mother, her father, loved ones.

When this

situation happened I was young and you

know I grew from this situation.

I'm 34 years old now, my

mentality, my atti,tude is definitely

penitentiary going over two years now. I've had time to

different.

RiukaTeich CS& RPB RMR F.CRR

Official Court Reporter

I've been in

reflect on a lot of things I did wrong in my life,

Nicole's murder that I participated in.

including

What I do is pretty much have taken programs where I

was al-so doing victim impacting and became a mentor t.o other

inmates so they wonrt. make the same mist.ake that I did.

Thank you for l-isteni-ng.

THE COURT: Okay.

MS. NEWMAN: Than( you, your Honor, for giving us

Ms. Newman.

this opportunity.

Your Honor, I would like first

to address the

Government's sentencing memo and an issue they raised.

agree t.hat this Court has to declde whether Mr. Reyes can get

a term of years as opposed to life.

bottom of the guideline range. And I t.hink that what the

Government has sugiqest.ed is.that

get three points, they also say, you know what, he hasn't

1,7

Iearned his Iesson, he's not rehabititating.

We're asking for the

while they agree he should

Centerj-ng on the one thing tfrat they center on,

1_9

which is a phone call tn 2OL1 I just would like to briefly

explain it,

very lonq call.

because I listened it to four times, it's

THE COURT: Is this

not a

the telephone call from the

defendant to this person?

MS. NEWMAN: The cousin.

MS. GEDDES: The confidential- source.

it,

RiukaTeich CSB RPB RMR FCRR

Official Courl Reporter

MS. NEWMAN: We all know who it is, it's

Hers really a co-conspirator in the underlying bank fraud.

In any event, your Honor, it's

the cousin

important to

understand several things to get the context of the

conversation.

to suggest that. this is evidence he's not rehabilitated.

when we listen

on the calI, first

learned this

is that actpally he recej-ved the number

because his cousin wrote him a fetter

I only bring it. up because the Government seems

thing to know -- I just

saying, I want to make

amends. He doesn't have the l-etter here. Obviously I

1t_

couldn't have gotten it because I listened last night to the

calIs, I just got this.

what do you hear, you hear Naquan begs, cryj_ng out, and

saying, why did you do this.

But if you really li-st.en, as I did,

And frankly, you know what, it reminded, it really

reminded me, of the scene in Julius Caesar, where Caesar is "'

1,7

stabbed by Brutus.

mean to compare them, but because to Caese, he had nurtured

Brutus, it was like his son. Wel-l, Naquan looked to his

cousins as his mentors.

He saysrrr Et tu, Brut.e.rr I don't really

He didn't

have a father.

acted as his surrogate father.

approval, for guidance. And it is it is unquestionable that

it is the cousins,. wdy back when, that got him j-nvolved in

bank fraud.

Itis not an excuse.

It was hi-s cousins who

l-ooked to them for

Werre not bl-aming the

Riuka Teich CS& RP& RMR FCRR

Official Court Reporter

cousins. He readily got involved, but it helps us explain the

call and the context of it.

He's saying, how can you do this?

He's cryinq,

al-most he's begging, what coul-d you do? Why did you do this?

Why did you do this?

stabbed you in the heart.

like your father

involved with his cousi-ns w.hen all thls happened -THE COURT: Werre talking

the same, it's

You have Lo understand that Naquan, when he got

ft's

about the tel-ephone from

the institution.

MS. NEWMAN: Right, yes.

But I'm trying to give you

the context of it and why he feels so -- begging and crying,

why did you do this.

It is not a threat.

He's crying out to him. It's

no question he

because Naquan when young was vul-nerable. It's

was slbw.

this.

repeat the fourth grade. He was learnj-ng disabled, led

poisoning.

problems. He lived through 9/1,L and was traumatized from

this.

from the science, that effects the individual.

it directly

to his cousin

He was slow 1n school; his records demonstrate

He has the gift

of qab, but academically he had to

He had Attention Deficit

Disorder, emotional

His father was killed when he was younger. We know

In this

effected hj-m and made him partlcularly

What he's saying, Why did you do this?

RiukaTeich CSR, RPB RMR FCRR

Official Court Reporter

case

vulnerable

Why did you

do this?

do this to me. It has nothing to do wj-th his remorse for his

actions.

That's what he's saying. It gioes to, how could you

This is not a threat.

The fact that he call-s him a rat, we1l, t.hat's the

Irm sorry, in jail

vernacular.

cooperate, the euphonism used by the Government as anything

but rats, that's their language. It is just interesting,

you look at the whofe thing..

1,2

they don't call- people who

when

And they tal-k about papers, and that's one thing the

Government points out he asked him.

THE COURT: Is this

a telephone cal-l- the defendant

made to the cousin?

MS. NEWMAN: Yes. Hers saying to him, and the

cousin is t.alking about papers, well let. me give you the back

drop of that, that's not a threat.

', When you go t.o jail after you've been convicLed,

1,7

every single one of my clients asks me for one thing -- they

ask for several things, but I must have my sentencing minutes,

I must have it.

any sentencing submissions. Why? Because the qangs conLrof

the prison, and if you don't have that you're labeled as a

cooperator. Thatrs what he's saying. That.'s Lhe papers.

I must have any docket sheet. f must. have

I can remember about, 15 years dgo, maybe more werre

going to say 15 fo.r our sake, when Judge Chen was a

prosecutor, I had a cooperator with her.

Riuka Teich CSB RPB RMR FCRR

Official Court Reporter

He called me from

prison terrified

Judge Chen and I wanted to avoid that.

punishment.. So we called the warden together to explain

that's not right, he's not the one that should be in soJ-itary

and extra punishment. And the warden then said to us, there

is nothing I can do because the ganqs control, and if I don't

put him in solitary he will be harmed because he can't prove

he didn't cooperate. That '.s the situation.

times worse than it was when Judge Chen and f made that call.

and he was going to be put i-n solitary.

What is interesting

We felt

that was extra

Now it's

100

is what Naquan said during this,

a brief conversation, he says when the word qot out

it's

someone wanted to hurt, you meanlng the cousins, I

What is the cousin's response about papers? He says, well,

don't worry about me in jall,

if he got fraudulent paperwork. But, I circulated your

paperwOrk, he says. What does that mean? He says he's

circulated.

the other telephone call-, that Naquan *iO" to Ms. Tyson when

he was in jail

obstruction, which we donrt object to.

telephone call.

I got paperwork. I don't know

That conversation, now that's the telephone call,

i nitiall-y,

which forms the two points for

He says, I put that out.

said no.

But that's that

What is he talking about?

In that call- it suggests that Naquan is tel-l-inq Ms. Tyson to

cooperate with the Government but to lie to say something

different

and by putting that call out there he's suggesting

RiukaTeich CSB RPR, RMR FCRR

Official Courl Reporter

t.hat Naquan is a cooperator

saying.

That's what t.he cousins i-s

So while Naquan is saying what paperwork, you don'L

have paperwork. He's saying, the cousin -- I don't know j-f

it's

your paperwork, so you look like a cooperator. This whole

conversation has nothing at. all to do with whether or not

Naquan is trying hard to ma[e amends. It is him cryinq out

because he's so hurt that this mentor, his family member, has

true, I'm just saying -- I put out paperwork about you,

been involved, was involved and yet cooperated.

Hers not saying in any way that he was right in

doing what he's doing, what he did.

There is no threat here.

cousin saying I put out the paperwork so you look like

cooperator.

That's not what is here.

The only threat is realIy from the

,salrs that the real -L7

from this is that the cousin is saying hj-s motivation for

cooperating, whether it's

l_9

sayj-ng what the conversation says, and getting Naguan in so

much trouble,

thing to do, but because Naquan was going to cooperate against

him and his brother.

true or not I don't know, I'm just

was not because he thought it was the right

So the call is insightful

but it doesn't have any

relevance to what .the Court has to decide here; and that is,

the individual,

Naquan Reyes, standing here before you.

RiukaTeich CSR, RPB RMR FCRR

Official Court Reporter

this a man who has made efforts at rehabilitation?

man who now has the remorse that he needs that should get a

term and have hope as opposed to just plain l-ife.

Is this

I want to point out some other things briefly,

that.

he has. It cannot be ignored, the efforts that he made. 53

certificates,

tutoring that he's doing.

to get his GED, and sometimgs from my own experience when I

was a teacher those make the best teachers, the people who

the bibfe study, the comments that he had, the

I know it took Naquan a long time

join a ganq in prison.

work the hardest.

took courses and courses and courses to better himself.

So Naquan didn't

And, your Honor, a message that. I think needs to be

said to the prison, to the inmates, you can have hope if

do the right t.hing.

and take the courses, study the bib1e, cooperate with the jail

1,6

facilit,y,

1,1

that's a message of deterrent, positive reinforcement is

important. here.

That is, don't go with the gang but go

work in the jail.

That is what we need to send,

I canrt stress that enougfr.

I end with slmilarly

1,9

I gave the statj-stics about

simil-arly-situated

are not in any way mitigating the crime.

minimize the crime at all.

Naquan Reyesr. who stands here today, is

filt.er

you

defendants who have not received l-ife.

We are not trying

What we are asking for in light

to gj-ve him and to

down to the. others, hope with a term of years.

I do want to go back to, now f remember what we may

RiukaTeich CSB RPR, RMR FCRR

Official Court Reporter

have been talking about the guidel-ine.

t.hat. doesn't rea1ly effect the guidel-ines on a variance with

respect to double counting on the obstructj-on. But it was a

variance argument, it's

not a guideline.

guideline calculation.

I just want to say that, so it's

cl-ear.

r made an argumenL

we agree with the

Thank you, your Honor, for giving me that time.

THE COURT: Counqel.

MS. GEDDES: Your Honor, the Government here seeks a

t_0

sentence of rife and we don't do this 1ight1y.

sentencing proceeding Ms. Thompson's family was present and

they had the opportunlty to speak about the magnitude of the

loss that t.hey suffered.

wanted to be here, but one of the Thompsons' has health

At the initiar

They are not here today.

They

issues, t.hat's what prevented them.

'; f can speak on thelr behalf and tell_ you about,

obvj-ously, the great pain that they have because of the

actions of Mr. Reyes, and certainrv trrai is the cause in any

l_9

murder. But r think the circumstances of this murder are

particularly --

1_5

THE COURT: This murder she was strangled;

21,

is that

right ?

MS. GEDDES: That is what Mr. Reyes said on the

ZL}

recording to his the cousin, who is the confident.ial source.

He said she was strangled.

RiukaTeich CSR, RPR, RMR FCRR

Official C ourt Rep orter

Her body was found in a Dumpster in Landover,

Maryland. And there was evidence of stranqulaLion, so that

seems to be an accurate portrayal

by Mr. Reyes.

The conduct is just senseless. And Mr. Reyes'

comments about t.he murder, which were made four years after

the murder or afmost four years after the murder, in

February 24, he said somewhat prophetically,

again if my life

"I would do it

were on thg line. "

What I think is so crucial about that stat.ement is

She was cooperating in a

Mr. Reyes' tife was not on the line.

bank fraud case, a counterfeit check that. had been deposi-ted.

Maybe he faced a very short time in

long time in jail,

on the line.

murder, that the right thing to do was to kill

he would do it aqain

jaiI.

Even if he faced a

which I submit he dj-d not, his life

wasnrL

And he thought, even al-most four years aft.er the

her and he said

f don't want to put too much emphasis on the cal-I

that was mad.e in September 20L7, but r ion't think it

be discounted either.

reason, he reached out -- f'm not making any representation as

to why he reached out to the source -- but he called him and

he said,

Brooklyn. "

This is the same man t.hat Naquan told, "I would do

it aqain if

my l1fe were on the fine. "

interpretation of that, "you're never going to be able to come

shoul-d

fn that call- Mr. Reyes, for whatever

I'You I re never going to

be able to come back to

The only

Riuka Teich CSB RP& RMR FCRR

Olficial Court Reporter

back to Brookfyn, " is that harm is going to come to you if you

come back to Brooklyn.

This isn't

about paperwork. First of all,

there was

no paperwork in this case with respect to the source.

source didn't -- there was no cooperation agreement wit.h the

Government. There is no issue about havinq a clean plea

agreement or a clean judgment in this case. The paperwork I

be1ieve that Ms. Newman is Eeferencing that was discussed, was

paperwork that happened years earlier.

The

What is critical

and

1_0

what was discussed in that phone call- was that Reyes said,

"they have the video."

not video of a judgment. The video is the video of the source

talking with Naquan Reyes in February 201-4 in a hotel room,

the Marriott,

Reyes confessed to the murder. That is a reference to his

current cooperation or his -- his current cooperation. And''

when he says, You're not going to

t_B

he doesn't use that word. He says, you can't go to a

penitentiary,

in a penj-tentiary.

And more personally, you can't come back

to Brooklyn.

a threat.

And video is not paperwork. Video is

just down the street from here, where Naquan

survive in a penitentiary,

the translation is, you're not going to survive

It's

It I s not indicative of an individual who has

rehabilltated

t.hing is to obstruct justice.

defendant is a perpetual obstructer, if nothing else.

himsel-f and no longer agrees that the right

It is evidence that the

RiukaTeich CSB RPR, RMR FCRR

Official Court Repor-ter

He has

killed because somebody cooperated.

He came into this courtroom, not this courtroom but

Judge Towns' courtroom. He t.ook the stand. And he told

version of events that was completely beJ-ied by the evidence

in the case. ft was not candid at all.

He cafl-ed his ex-girlfrj_end and tried to get the

ex-girlfriend

support an effort of lenj_er1cy for Mr. Reyes. And then just

year aqo he calls his cousins and says you can't qo back to

to feed a story to the Government to try to

Brooklyn. He obstructs justice.

extraordinary crime and he did it with a really very

supportive family.

He has commi_tted an

I donrt want to undermine the circumstances of his

youth.

learning problems and he certainly encountered tragedies along

1,6

the wai, but what he did have was a very loving and supportive

fami-Iy, many of whom are present today. He did have the gift

of gab. He had charisma. People liked him. They wanted to

spend time with him. And yet, his choice was to engage in a

bank fraud which obviously is a serious crime but is not the

reason why we're asking for the sentence that we're asklng.

r don't take issue with the fact that he may wel-1 have

He engaged in obstruction and he kill_ed a

24-year-oId girl because she threat.ened his criminal

l-iverihood.

time.

She threatened his freedom for a short period of

Then he sai-d, f 'd do it

again if my life were on the

RiukaTeich CSR, RPB RMR F'CRR

Official Couri Reporler

Iine.

fn the light of the seriousness of his conduct and

his statements during the February 2074 recording and all of

the other evidence in t.his case we ask your Honor to impose

the Same sentence that Judge Townes imposed after hearing from

Naquan Reyes during the sentencing proceeding when he took an

oath testified.

the great and extraordinarY. Ioss

After hearing from the Thompson family about

THE COURT: Do we have the J&C from Judge Townes?

shoul-d be on ECF '

COURTROOM DEPUTY: It

MS. NEWMAN: I ask you, your Honor, I just want to

1,2

while we're looking for t.he J &c, going back to Brooklyn, that

had nothing to do with a threat.

doesn't belong to a gang, he has no ability.

Government would agree, he

The truth of the

matter is, the people knew in Brooklyn and he wouldn't. go

back. I have plenty of cooperators who are not going back t'o

where they are from.

But indeed the cousin was invol-ved in

Mr. Reyes's bringing the body where it was. He was part of

the, I guess you might say -- f don't know if -- the cousin --

MS. GEDDES: No, none of the cousins were invofved

i-n transporting the body from Brooklyn to Landover, Maryland'

They were all in jail

MS. NEWMAN:

It's

understanding based on the

evidence that I have reviewed, that his brother, Jamal, was

out of jail.

He made

the caII

I'm telling

RiukaTeich CSR, RPR, RMR FCRR

Official Court RePorter

you what I

underst.and from the evidence that frve reviewed from telephone

calls, your Honor. f'm at a disadvantaqe, as your Honor

knows, because I onJ-y came j-n for resentencinq. But my

understanding, regardless, is they had an input, that's why he

went to where he went to dispose of the body. That doesn'L

excuse, I'm giving you, just aqain, the context.

This threat about paperwork is a non-threat if

of jails.

know the reality

it is, f know they can't be that naive.

you

.And for the Government to say that

This is what it's

called, paperwork. I hear it every single e-mai-I after

sentencinq. And I don't know what in reality what they know,

but I know if you don't come in with those documents, the

paperwork, you'11 have problems. So that's what he was

talking about.

But the cousin says, not a problem, I got paperwork.

So this' wasn't a threat to the cousin.

1.1

call.

God. He's very cal-m, and certainly *.r,a" to make amends with

Mr. Reyesr so there is no t.hreat.

what he is today, and that's what we're looking at.

The cousin invit.es fhe

The cousin doesn't get off the phone and say, oh, my

THE COURT: If

This is not rel-evant to

this was an innocent call, why did he

use another inmate's PIN number to make the call?

MS. GEDDES: That was a different

Randy Tyson while .he was incarcerated at MDC prior to

sentencing, where he told Ms. Tyson to craft this story and

Riuka Teich CSB i?PR, RMR PCRR

Official C ourt Rep orter

cal-l.

That was to

say what she knew when she didn't actually know those things.

This was a telephone call made from his own account

when he was incarcerated while hls appeal was pending.

THE COURT: ft's

agreed this is a particularly

It wasn't a gun. It

It wasn't a knife.

horrendous crime.

was personal-, the deceased was strangled.

Ms. Newman tal-ks about the defendant is

But I have here before me an incident report

rehabilitated.

from the institution,

he's flghting with another person, phone

abuse, assaulting someone without. body injury,

l-1

obey an order.

That. rea1ly is a little

rehabilitation

that I'm concerned wlth.

different

MS. NEWMAN: Does it refl-ect that the second to last

1_3

was thrown out? He claims it was thrown out.

reports, and I can't get hem.

THE COURT: I

don't know. The addendum is from --'

And they just don't qive up these reports;

with my client.

but his claim -- I can't get it,

THE COURT: This is

I don't get the

MS. NEWMAN: I got that addendum. I did discuss it

and refusing to

I tried in the past.

an addendum that I assume that

you got.

MS. NEWMAN: I did get it.

I'm saying his

contention is that it was thrown out.

sometime untif

I'm disputing the amount of time.

So he did serve

they getting around, until- they dismissed it.

You spend that time until

Riuka Teich CSR, RPB RMR FCRR

Officiat Coutt Reporter

they throw it out.

MS. GEDDES: Your Honor, t.he Probation Officer has a

I'm not disputing what was here.

copy of a record documenting the incident report.

MS. MAIN: It's

the Sentry, the interna1 database

from the MDC. There is the incident, the charge, and the

sanction; but there 1s not.hing noted under this case t.hat the

charge was ever di-smj-ssed or modified.

It doesn't say anything about pending good conduct, like I've

seen in the past.

THE COURT: WeII t.hat's one of

l_1

The sanction stood.

several incidents

attributed to this defendant.

3553 (a) says that

I must impose a sentence that is

sufficient

purposes of the statute.

nature of the circumstances of the offense.

said before, was personal and horrendous. I take into

consideration the history and the characteristics of this

defendant. I must also take into

but not greater than necessary Lo compry with the

f must take into considerat.i_on t.he

"o."ii"ration

seriousness to promote a respect for the law.

The offense, as r

the

I listened to the argument of counsel. I read the

submissions and f think a sentence that is sufficient

greater than necessary is the following.

but not

I'm gioing to sentence the defendant to 1ife in

prison.

counts is it?

I'm going. to sentence the defendant to, how many

RiukaTeich CSR, RP& RMR .F.CRR

Official Court Reporter

MS. GEDDES: Two counts, Count One and Count Seven.

THE COURT: $100 special assessment on each count.

And there will

supervised rel-ease.

be no supervised release -- make it five years

MS. GEDDES: Yes, Judge. I assume you're imposing

life

statutory

on the obstruction count, and 30 years which is the

maximum?

MS. NEWMAN: Same.as Judge Townes.

THE COURT: Same thing

that Judge Townes said.

Anything else? No open counts?

MS. GEDDES: I assume you're not -- there are

1,2

open -- I don't. think there are open counts. We dismissed

them to the extent they exist.

Again, I'm assuming your Honor is not inflicting

fine, as there j-s no abiJ-ity to pay.

THE COURT: I

said the special assessment.

You have the right to appeal this sentence and afso

appeal this convj-ction.

MS. GEDDES: Your Honor, in the original

1,9

there was a forfeiture

order --

order.

THE COURT: That forfeiture

MS. NEWMAN: What was the forfeiture

sentence

I assume that that forfeiture

stands.

sorry; I want. t.o b.e sure.

MS. GEDDES: $184, 000.

RiukaTeich CSR, RPR, RMRFCRR

Official Court Reporter

order? I'm

MS. NEWMAN: From the bank fraud?

MS. GEDDES: Correcl.

MS. NEWMAN: That's what he personal-ly received?

Your Honor, what we're trying to decide -- I'm sorry, is the

forfeiture.

personally received as opposed to the conspiracy in qeneral.

I don't know that information.

woul-d it be okay if they hapded that in this week so that they

could just check that this is what he personally received so

As you know after Honeycut it has to be what he

So I just ask the Government,

we donrt have a Honeycut problem.

MS. GEDDES: We'll do that, your Honor. And ask

t.hat your Honor at.tach that forfeiture

I'11 work with defense counsel because there is likely

1,4

Honeycut issue

THE COURT: Okay.

1,6

order to the judgment.

All- right

(Whereupon, the matter was concluded. )

*****

I certify that the foreqoing 1s a correct transcript

record of proceedings in the above-entitled matter.

Rivka Teich, CSR RPR RMR FCRR

Official Court Reporter

Eastern District of New York

Riuka Teich CSR, RP& RMR FCRR

Official Couri Reporter

from the

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.