ATTORNEY WORK PRODUCT — PRIVILEGED & CONFIDENTIAL — PREPARED FOR BENJAMIN B. COOPER, ESQ. — NOT FOR FILING

OverviewSection 01

CASE OVERVIEW

USA v. Redmond, 5:24-cr-00376-JLS (E.D. Pa., Schmehl)

V2 · Compiled 2026-08-27
“The IRS wrote on its own signed form that it applied this man’s payments to the wrong liability — and refunded him for it. Then charged him criminally for not paying.” The one sentence
7 Counts Tax counts 21–27, § 7202
$1.23M Charged total vs $2.46M+ identified credits
3 Identical ledgers Same certified ledger, 3x over 26 months
43 Re-designations IRS-executed, in its own records
0 Signature records Forms 8655/2848 in 8,835 produced pp.

Redmond appears on 0 of the 12 customer-call wire counts

The two counts he touches are internal emails.

2 counts — internal emails
DEFENSE

Element-by-element kills, honest concessions (Cts 23/24 exact)

OFFENSE

Particulars · Brady/IVR · Severance · Rule 29 · derivation demands.

Verification tiers
NATIVE IMAGE-VERIFIED OCR SEEN UNVERIFIED
Attorney Work Product · Privileged & Confidential

How We Got Here

United States v. Redmond, No. 5:24-cr-00376-JLS (E.D. Pa., Schmehl) — from the first FD-302 to the trial date the pack cannot yet confirm.

Government move Defense / court move Docket entry

10/11/2019

FD-302 — first agent interview report

First of the three agent interview reports in the case. Jencks/Rule 26.2 target D-14; agent notes demonstrably exist for the later 302.

11/19/2021

FD-302 — second agent interview report

Second agent interview report. Jencks target D-14.

3/9/2022

FD-302 — third agent interview report

States on its face that agent notes were attached — the strongest Jencks lever in the pack.

10/17/2024

ORIGINAL INDICTMENT — 6 counts

All tax, Redmond alone, $1,068,680.47 across six Bene Market quarters. US Attorney Jacqueline C. Romero; AUSAs Crawley + Dalke. 26 U.S.C. § 7202 only. No forfeiture, no overt acts, no wire counts.

1/27/2025 → 2/2025

Smith letter walked to the USAO

CPA Malcolm Smith's letter (dated 1/27/2025) states credits were not applied; directs $240,016.75 to Counts 23 and 24. Walked to the USAO in February 2025 — trigger point in the T9 vindictive-superseder theory. Native letter and schedule still missing.

3/12/2025

David Metcalf sworn in as US Attorney

Replaces Romero. Career AUSAs were floating dismissal before Metcalf; case becomes a flagship for the White-Collar Justice Program.

5/8/2025

SUPERSEDING INDICTMENT — 27 counts

+204 days from the original; 63 days after Metcalf sworn in. 1 conspiracy + 19 wire fraud + 7 tax. Six defendants. SCAMS Act added. $30M forfeiture + 4 named properties. 72 overt acts. Tax total $1,230,048.42.

Docket entry — date not specified in source

Groff plea (Doc 96-1) & Walsh plea (Docs 127/128/130)

No cooperation obligation, no § 5K1.1 clause, no promise to testify appears in either public plea; each recites only a sealed supplemental agreement.

8/3/2026

Cooper enters — ECF 162–164

Benjamin Brait Cooper, Esq. enters as counsel of record for Alan Redmond, Bene Market LLC, and Seguro Medico LLC.

8/6/2026 → 8/7/2026

Continuance — ECF 167 / ECF 168

ECF 167: defense motion to continue (docket row; PDF not pulled). ECF 168: order granting the motion — trial continued (docket row; PDF not pulled).

11/16/2026

Pretrial conference — ECF 169

10:00, Reading. NEF-verified in the master docket.

12/7/2026

Motions in limine — ECF 169

Voir dire / instructions / trial memos / verdict slips due. Also the operative deadline for the government's 404(b) supplementation wave.

1/11/2027

Jury selection — ECF 171

9:30, Reading. NEF-verified.

1/12/2027

TRIAL — ECF 171

9:30, Reading, 5th floor. NEF-verified.

Six Counts Became Twenty-Seven

Original Indictment (10/17/2024) vs. Superseding Indictment (5/8/2025) — EX-C § C-4

Original · 10/17/24

6
$1,068,680.47
All tax · § 7202 only
Redmond alone · no forfeiture

Superseding · 5/8/25

27
$1,230,048.42
1 conspiracy + 19 wire fraud + 7 tax
+ SCAMS Act · $30M forfeiture
+204 days filing delta New US Attorney Romero → Metcalf +2 AUSAs Murray + Hines added
First Ask

Confirm before calendaring The project file contains two mutually exclusive trial schedules and both are still cited by live systems.

Confirm the criminal calendar in writing from the native ECF 167 / 168 / 169 / 171 PDFs. Everything downstream sequences off that confirmation.

  • ECF 167 (8/6/2026) — defense motion to continue. Docket row; PDF not pulled.
  • ECF 168 (8/7/2026) — order granting the motion, trial continued. Docket row; PDF not pulled.
  • ECF 169 (8/11/2026) — pretrial 11/16/2026; MIL/voir dire/instructions/trial memos/verdict slips due 12/7/2026. NEF-verified.
  • ECF 171 (8/11/2026) — pretrial 11/16; jury selection 1/11/2027 9:30; trial 1/12/2027 9:30, Reading, 5th floor. NEF-verified.

Decision rule: do not say “trial 9/14” or “trial 9/15” — that is the superseded ECF 103 / ECF 135 schedule. Say nothing until the four PDFs are in hand. Filing to the wrong schedule is a default-adjacent event in either direction.

Attorney work product — privileged · Section 04

The 27 Counts

Every count in the superseding indictment (Doc 16, filed 5/8/2025), with its kill status reproduced verbatim from EXHIBIT A · COUNT_MATRIX. Nineteen § 1343 wire counts (twelve customer calls, seven internal emails), one § 1349 conspiracy count, seven § 7202 trust-fund counts. Zero counts are overcome or killed. Counts 1 and 2 are NOT OVERCOME and are shown in red; that is not softened anywhere on this board. Click any card to open its element grid — Element · Government proof · Defense answer · Exhibit ref — transcribed verbatim from the chapter files.

Status legend

Tally strip — counted off EXHIBIT A · COUNT_MATRIX

Derivation, so the arithmetic is auditable. NOT OVERCOME = 23 — Counts 1–20, 23, 24, 26 carry the phrase in the matrix kill-status cell. Element not killed = 4 — Counts 21 (“Element NOT killed”), 22 (“NOT a legal acquittal”), 25 (“Figure existence NOT killed”), 27 (“RP NOT a merits kill”) state the same conclusion without the phrase. Weakened = 5 — Counts 3, 4, 19, 20, 21. Contested = 2 — Counts 12 and 8, where Barrera's plea counts read UNVERIFIED. Attack-live = 3 — Counts 21, 22, 27. Chips overlap by design (Count 21 is red, amber and green); each card carries exactly one border class, and the 27 borders total 20 red · 5 amber · 2 green.

Filter

Showing 27 of 27 counts

118 USC 1349

Conspiracy to commit wire fraud

All six

NOT OVERCOME — Groff+Walsh admitted Count 1

Scope/duration of Alan's membership; script vs closer (¶28); no Alan consumer-call voice

Element grid — Count 1

Element A — agreement between two or more persons to commit wire fraud

ElementGovernment proofDefense answerExhibit ref
Two or more persons agreedSix charged defendants plus “others known and unknown”; ¶¶ 14–15 misrepresentation roster; ¶¶ 23–36 manner and means; Groff's signed agreement pleading guilty to Count 1; Walsh's guilty plea to Count 1No available answer denies that a sales operation existed or that two men pled guilty to conspiring. The answer is scope: what agreement, on what misrepresentations, and over what period. Two entity co-defendants make a “no agreement at all” theory unusable[EX-A] ¶ 17; [EX-G] Doc 96-1 ¶ 1; [EX-H] ECF 126
Redmond was a party to that agreement¶ 6 control; nominee structure ¶ 15(p); Overt Acts naming Redmond as actor or recipientNot one public plea admits an agreement with Redmond. Groff's ¶ 1 locates his own role as “a salesman and manager” of the Bene Market Group and names no co-conspirator; no public factual proffer describes any Redmond directive[EX-E] § 7; [EX-G]
Unlawful objective was wire fraud¶¶ 17–22 object; charged wires Counts 2–20 as the fruitObjective as pleaded includes conduct the government itself concedes was lawful: “During the charged period, neither the ACA nor state insurance laws made it illegal to offer for sale any of these Limited Benefit Plans” — ECF 96 at 6; ECF 127 at 6, verbatim in both[EX-E] § 5; [EX-G]; [EX-H]

Element A status: NOT OVERCOME. Two co-defendants have pled guilty to Count 1. The existence of a conspiracy is locked as to them. Nothing in the record eliminates this element, and no filing should suggest otherwise.

Element B — knowing and willful joinder with intent to further the objective

ElementGovernment proofDefense answerExhibit ref
Knowledge of the scheme's fraudulent characterOvert Act 4 (2/16/2019, Redmond received a list of 25 pending licensing issues and complaints); Overt Act 8 (9/13/2019, Redmond emailed about seven outstanding regulatory actions against Groff); Overt Act 25 (1/10/2021, list showing 7 of 19 closers licensed); Overt Act 61 (1/7/2022, list showing 4 of 16 licensed)Notice of regulatory complaints is notice of a compliance problem, not agreement to a lie told to a purchaser. Willful blindness (5.06) is the government's fallback and must be resisted on the instruction, not conceded[EX-A]; [EX-F] 72 OVERT ACTS MAP
Intent to further, by directionOvert Act 1 (payroll transition); Overt Act 16 (6/23/2020 “combat 'this is not insurance'” email = Count 2 wire); Overt Act 30 (4/21/2021 pull Groff calls for training = Count 6); Count 7 KISS brochure; Overt Act 65 (4/1/2022 Bene-to-Seguro transition); Overt Act 69 (6/7/2022 “seek approval from me first … ZERO” = Counts 19–20)¶ 28 of the government's own instrument states that closers made false statements “beyond those contained in the standard scripts.” If the fraud the jury is asked to punish is the closer ad-lib, then intent to join that fraud is a Pinkerton and variance question[EX-A] ¶¶ 25, 28; [EX-C] WIRE_TABLE footer
Intent proved through the defendant's own voiceCounts 2 and 7: Redmond is the sender. Counts 4, 8, 19, 20: Redmond is recipient or the source of the quoted instructionRedmond is the sender on 2 of 7 email wires and the speaker on 0 of 12 customer calls. From the government's own ECF 148 Attachment A (38 [REDACTED]: 7 internal + 31 Five9 victim calls) he is the primary subject of exactly three, and not one is a charged wire[EX-C] WIRING_ZERO; [EX-E] § 6; [EX-M]
Refund and complaint conduct as intent evidenceOvert Acts 42, 44, 54, 66: instructions to withhold refunds until the purchaser retracted a fraud or Department of Insurance complaint, and to send refund emails while directing “DO NOT REFUND”These are the hardest overt acts in the instrument to explain and they name Redmond directly. They are not charged as wires, so they arrive as § 1349 and § 2326 context. Their reach must be fought on relevance and on limiting instructions, not on the facts[EX-F] 72 OVERT ACTS MAP

Element B status: NOT OVERCOME. It is weakened at the margin — Redmond is not the voice on any charged consumer call, and the instrument itself splits scripts from closer ad-libs. It is not eliminated. Counsel should not be told this element is dead.

Element C — the incorporated § 1343 components

ElementGovernment proofDefense answerExhibit ref
Scheme to defraud / obtain money by material falsehood¶¶ 14–15 roster; the twelve charged calls; the quoted “national enrollment center” text (Count 8)Materiality is the live lane: Neder v. United States, 527 U.S. 1 (1999) [VERIFY PINCITE]. Government's noticed expert JoAnn Volk will opine that “prior to being asked to purchase a plan, a consumer should be provided a written summary” — an opinion about a duty the government has already conceded did not exist. That is a Rule 702 motion, not a cross[EX-A]; [EX-E] § 5
Property objectPremiums and commissionsBecause the alleged object is money, the right-to-control line is unavailable and irrelevant. The Ciminelli attack is foreclosed by Kousisis v. United States, 145 S. Ct. 1382 — RETIRED. Do not file it.[EX-E] § 4
Interstate wire in furtheranceCharged wires Counts 2–20; interstate call and email routingFurtherance is real but not automatic. For the seven internal emails the government must show the transmission advanced the scheme, not merely that it crossed a line. Whether the government can prove interstate routing for each internal email is [UNVERIFIED] in the present record[EX-A]; [EX-D] § 2

Kill status — Count 1: NOT OVERCOME. Two co-defendants have pled guilty to this count; two of the six defendants are entities Redmond owned or controlled; Redmond authored two of the charged wires (2 and 7); the notice overt acts are documentary; the refund-conditioning overt acts name him directly; ¶ 72 puts his own sworn words in the case.

Cites — Doc 16 ¶17; Doc 96-1 ¶1; ECF 126 · Grid: CH_01 §3, kill status CH_01 §10 · Matrix: EXHIBIT A §A-1 row 1 · Unverified hole — Barrera counts; sealed 97/130 · Window 2018-01-01 to 2022-12-02 · Cooperator pled: Groff + Walsh YES; Barrera UNVERIFIED · Alan on the communication: N/A (agreement, not a single wire)

218 USC 1343

Wire — training email · 2020-06-23

All six

NOT OVERCOME — Alan is the author. Worst email count.

Authenticity/Rule 106; product-category explanation vs instruction to lie; not a consumer statement

Element grid — Count 2

The alleged wire. An email from Redmond to Barrera and Walsh containing instructions to train closers with “fraudulent and misleading sales tactics.” Overt Act 16 supplies the content the government will read to the jury: how to combat the verification screen statement that “this is not insurance,” by describing the product as a “health sharing plan” that “mimics health insurance.”

ElementGovernment proofDefense answerExhibit ref
Scheme to defraud / material falsehoodThe email is offered as the training instruction that produced the closer misrepresentations charged in Counts 3–18; ¶¶ 14–15 roster; ¶ 27The email is not a statement to any purchaser on 6/23/2020. “Health sharing” is a recognized product category, and the government has conceded the products were lawful to sell. The materiality question is whether this instruction caused a material falsehood to a buyer, which requires the calls[EX-A]; [EX-E] § 5
Specific intent to defraudRedmond is the author. He is telling managers how to handle a disclosure that says the product is not insurance. The government will argue consciousness of guilt in the plainest terms available to itReframe on the honest ground available: the same email proves the verification disclosure existed and was being delivered, and that Redmond knew its text. An operator instructing agents to explain a product category accurately is not the same as an operator instructing agents to lie — but this is a jury argument, not a legal answer[EX-F] CRITICAL FINDINGS ¶ 5
Interstate wire in furtheranceInternal email transmitted in interstate commerce; furtherance through training of the closer forceFurtherance is arguable if the training produced the scripts and the charged lies were off-script ad-libs (¶ 28). Routing proof [UNVERIFIED][EX-A] ¶ 28
Authenticity / completenessBusiness-records and email custodian proofNative email not in the present ingest. Rule 106 completion of the full thread, including any reply and any attached script, is the first demand. Authorship of forwarded text within the thread must be separated from Redmond's own text[EX-E] § 4; [EX-D] § 2

Kill status: NOT OVERCOME. This count is a problem, and it is the government's best Redmond-voice wire. Redmond is the author, not a recipient. The email shows he knew the verification screen said “this is not insurance.” The word “combat” is the government's opening line. The native message is not in hand, so the completeness attack cannot yet be specified. On the elements, nothing in the record eliminates any element of Count 2.

Cites — Doc 16 Count 2; OA16 · Grid: CH_02 §3 · Matrix: EXHIBIT A §A-1 row 2, §A-2 row 2 · Unverified hole — Native email · Alan on the communication: YES sender · Cooperator pled this count: No · Quoted lie in count table: Partial — OA16 quotes the combat language

318 USC 1343

Wire — cancel call L.F. CA · 2020-12-30

All six

NOT OVERCOME — weakened (unnamed, no quote)

Alan not on call; no quoted lie; retention vs origination

Element grid — Count 3

Count 3 — 12/30/2020 — unnamed Bene Market representative ↔ L.F. (CA) — cancellation call.

ElementGovernment proofDefense answerExhibit ref
Material falsehoodRepresentative “misled L.F.” on an attempted cancellation; workbook maps a claim to be a “compliance officer for California” and ties the count to Overt Act 23No quoted statement in the count table. Retention-desk conduct (¶ 32) is pleaded, but a cancellation-call misstatement is a different animal from origination bait — the purchase decision was already made[EX-A] Count 3, ¶ 32; [EX-F]
IntentSave-desk practice as scheme conductSpeaker unnamed; no intent proof exists until he is identified and the recording heard[EX-C]
CompletenessOne recording on ECF 148 Attachment AAudio completeness on this charged wire is 6.452% — 31 CDR records, 2 produced [REDACTED], 1 on Attachment A; missing types include ivr_verification, sales, welcome, esign_live, service, refund, chargeback, renewal. Redmond on call: false. Rule 106 completion set: true[EX-I]

NOT OVERCOME. Weakened — unnamed speaker, no quoted lie, 6.452% completeness. The natural lead exhibit for Rule 106 and Rule 1006 practice.

Cites — Doc 16 Count 3; HANDOFF_V3 Pillar 2 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 3, §A-2 row 3, §A-3 (0 of 12) · Unverified hole — WAV + specific false statement · Alan on the call: NO — 0 of 12 · Quoted lie in count table: NO QUOTE · Note: the interstate-wire-in-furtherance element is not separately contested on the calls and is omitted from the grid (CH_03 §2)

418 USC 1343

Wire — agents list email · 2021-01-10

All six

NOT OVERCOME as furtherance; weakened as consumer fraud

Alan is recipient not author; license ≠ 1343 without purchaser materiality

Element grid — Count 4

The alleged wire. An email to Redmond with an attachment that “assigned all non-selling licenses to non-licensed agents,” so that unlicensed employees sold under licensed agents' licenses. Overt Act 25 describes the same date: Redmond received a list showing 7 of 19 closers licensed.

ElementGovernment proofDefense answerExhibit ref
Scheme / material falsehoodLicense parking as a means of staffing phones with unlicensed closers; ¶ 14(s), ¶ 15(e)Unlicensed sale is an insurance-code violation. Converting it into § 1343 requires a purchaser-facing material falsehood plus knowledge that the licenses were used to deceive buyers, not merely to staff phones. No purchaser statement is alleged in this count[EX-A]; [EX-D] § 2
IntentRedmond's receipt of the list is offered as knowledge; the pattern worsens by Overt Act 61 (4 of 16 licensed, 1/7/2022)Redmond is the recipient, not the author. Receiving a compliance roster is not transmitting a falsehood. The government's own theory needs a further inferential step to convert receipt into direction[EX-C] WIRE_TABLE
Wire in furtheranceEmail advancing the staffing of the sales floorFurtherance is the government's better argument on this count than materiality. The honest assessment is that this email hurts Count 1 knowledge more than it proves that anyone was defrauded on 1/10/2021[EX-D] § 2
Authenticity / completenessAttachment and custodianThe spreadsheet native is not in the present ingest. Rule 106: the transmittal text and any reply[EX-C] GAPS

Kill status: NOT OVERCOME as a furtherance wire; WEAKENED as standalone consumer fraud. The count survives because furtherance is a low bar and the licensing allegations are documentary. It is weak as a fraud count because no purchaser is on the wire and Redmond did not write it.

Cites — Doc 16 Count 4; ¶14(s) ¶15(e) · Grid: CH_02 §4 · Matrix: EXHIBIT A §A-1 row 4, §A-2 row 4 · Unverified hole — Spreadsheet native · Alan on the communication: RECIPIENT · Cooperator pled this count: No

518 USC 1343

Wire — unlicensed closer P.G. FL · 2021-01-20

All six

NOT OVERCOME

Unlicensed ≠ false; Alan not on call; need tape vs script vs verification

Element grid — Count 5

Count 5 — 1/20/2021 — unlicensed closer ↔ P.G. (FL).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodUnlicensed closer “fraudulently solicited P.G. … through numerous misrepresentations and half-truths”; workbook maps “not supplemental” and “full major medical”Selling without a license is not a false statement to a purchaser. The license overlay (¶ 14(s), ¶ 15(e)) is an add-on, not a substitute for materiality[EX-A] Count 5; [EX-F]
IntentUnlicensed status as consciousness of the schemeSpeaker unnamed; intent cannot be measured against script or verification without the recording[EX-C]
VerificationGovernment: closers steered buyers past the verificationIf the verification exists and P.G. completed it, informed consent is in the case despite the closer. IVR status: NEED TO VERIFY[EX-F] IVR DEFENSE MAP

NOT OVERCOME. Recording not reviewed; license theory is atmosphere, not an element.

Cites — Doc 16 Count 5; ¶15(e); HANDOFF_V3 Pillar 2 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 5, §A-2 row 5, §A-3 (0 of 12) · Unverified hole — WAV; license proof · Alan on the call: NO — 0 of 12 · Quoted lie in count table: NO QUOTE

618 USC 1343

Wire — pull Groff calls · 2021-04-21

All six

NOT OVERCOME — Walsh pled Count 6

Not a consumer lie; furtherance = training on alleged deceptive calls

Element grid — Count 6

The alleged wire. Walsh's email to Redmond confirming that Barrera would “pull the Albert [Groff] calls … for training” new sales agents. Overt Act 30, same date.

ElementGovernment proofDefense answerExhibit ref
Scheme / material falsehoodUsing an allegedly deceptive closer's calls as the training exemplar is offered as proof the deception was the method, not a deviationNo purchaser statement. The theory is circular unless the government proves the specific Groff calls used for training were themselves deceptive — which requires the tapes it selected, not the tapes it charged[EX-A] ¶ 15(d); [EX-D] § 2
IntentWalsh pled guilty to this count (ECF 126). The government will present a participant who admits this email furthered a fraudRedmond is the recipient. Walsh's admission binds Walsh. It reaches Redmond only through Pinkerton, § 2, or a co-conspirator-statement predicate[EX-H]; [EX-E] § 7
Wire in furtheranceTraining the closer forceAvailable to the government. The fight is which calls, and whether they were compliant[EX-D] § 2

Kill status: NOT OVERCOME. Walsh's plea to this count is a brick. Demand the identity and audio of the specific Groff calls that were pulled; if the training set was compliant, the government's furtherance theory becomes an argument about labels.

Cites — Doc 16 Count 6; ECF 126 · Grid: CH_02 §5 · Matrix: EXHIBIT A §A-1 row 6, §A-2 row 6 · Unverified hole — The Groff training calls themselves · Alan on the communication: RECIPIENT · Cooperator pled: WALSH YES

718 USC 1343

Wire — KISS Principles · 2021-04-27

All six

NOT OVERCOME — Walsh pled Count 7

Read the brochure: incomplete vs false; Alan is sender

Element grid — Count 7

The alleged wire. Redmond forwarding a Walsh email together with a “misleading internal sales brochure summary titled 'KISS Principles'” for employees selling Limited Benefit Plans.

ElementGovernment proofDefense answerExhibit ref
Scheme / material falsehoodThe brochure title is alleged to be misleading; the government will read the brochure as the distilled sales pitchThe brochure has to be read before this count can be assessed. The pleaded defect is that a summary was misleading — incomplete is not false. If the plan documents were available and the summary was a sales aid, materiality is the lane. The government has conceded that no pre-sale written-summary duty existed, which is precisely what a “misleading summary” theory needs[EX-E] § 5; [EX-A] ¶ 14(m)
IntentRedmond is the sender. Walsh pled guilty to this countForwarding a colleague's brochure is thinner than authoring a training instruction, but Redmond's fingerprints are on the transmission. Separate authored text from forwarded text; identify who wrote KISS[EX-C] WIRE_TABLE; [EX-H]
Wire in furtheranceDistribution of sales materials to the manager who ran the floorAvailable to the government[EX-A]
Authenticity / completenessBrochure and threadKISS PDF not in the present ingest. Rule 106 completion: the full brochure, the Walsh email being forwarded, and any accompanying compliance material[EX-C] GAPS

Kill status: NOT OVERCOME. Redmond is the sender and a pleading co-defendant has admitted the count. The count cannot be assessed further until the brochure is read; that document is a top-tier discovery priority.

Cites — Doc 16 Count 7; ECF 126 · Grid: CH_02 §6 · Matrix: EXHIBIT A §A-1 row 7, §A-2 row 7 · Unverified hole — KISS PDF · Alan on the communication: YES sender · Cooperator pled: WALSH YES

818 USC 1343

Wire — 2000 SMS copy · 2021-05-25

All six

NOT OVERCOME — quoted falsehood is clean

Did texts send; who approved; trade name vs government-sounding bait

Element grid — Count 8

The alleged wire. Barrera's email containing the copy for texts to approximately 2,000 unsold consumers; the texts “falsely stated, 'I am reaching out from the national enrollment center for health insurance.'” Matches ¶ 14(h) and ¶ 27.

ElementGovernment proofDefense answerExhibit ref
Material falsehoodThis is the cleanest quoted falsehood in the non-call counts. A specific sentence, in quotation marks, alleged to have gone to 2,000 consumersAttack the premises the quote does not supply: whether the texts were actually sent, to whom, by whom, and with whose approval. “National enrollment center” as a trade or marketing identity versus a government-sounding identity is a jury question, and the government's own concession that the products were lawful to sell reaches the framing[EX-A] ¶ 14(h); [EX-E] § 5
IntentRedmond on the recipient line; approval chainBarrera is the author. Presence on a distribution line is not authorship or approval. The government needs an approval document or a plea admission it does not, on this record, have — Barrera's plea counts are [UNVERIFIED][EX-C]; [EX-E] § 7
Wire in furtheranceOutbound marketing to unsold leadsAvailable to the government[EX-A] ¶ 27
Proof of transmissionSMS vendor recordsSMS vendor logs are not in the present ingest. If the campaign was never sent, the count is a proposal, not a wire to a consumer — though the charged wire is the internal email itself, which does not depend on the texts going out[EX-C] GAPS

Kill status: NOT OVERCOME. The quoted sentence is the government's best non-call falsehood. The available work is on authorship, approval, and whether the campaign was executed.

Cites — Doc 16 Count 8; ¶14(h) ¶27 · Grid: CH_02 §7 · Matrix: EXHIBIT A §A-1 row 8, §A-2 row 8 · Unverified hole — SMS vendor logs · Alan on the communication: RECIPIENT · Cooperator pled this count: No (Barrera counts [UNVERIFIED]) · Quoted lie in count table: YES quoted

918 USC 1343

Wire — closer B.B. DE · 2021-07-27

All six

NOT OVERCOME

Alan not on call; unnamed closer; Pinkerton

Element grid — Count 9

Count 9 — 7/27/2021 — unnamed closer ↔ B.B. (DE).

ElementGovernment proofDefense answerExhibit ref
Material falsehood“Numerous misrepresentations and half-truths”; workbook maps “government stamp of approval” and “ACA policy”If that content is on a produced recording it is a serious falsehood; if not, the count is unspecified. Bill of particulars[EX-A] Count 9; [EX-F]
IntentCloser conduct as scheme executionUnnamed speaker; ¶ 28 off-script exposure[EX-A] ¶ 28

NOT OVERCOME.

Cites — Doc 16 Count 9; HANDOFF_V3 Pillar 2 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 9, §A-2 row 9, §A-3 (0 of 12) · Unverified hole — WAV + quote · Alan on the call: NO — 0 of 12 · Quoted lie in count table: NO QUOTE · IVR answer on this count is generic per CH_03 §4

1018 USC 1343

Wire — Groff P.L. MD · 2021-08-18

All six

NOT OVERCOME as to Groff; not killed as to Alan

Alan not on call; ¶28 off-script vs Groff; Pinkerton is the Alan theory

Element grid — Count 10

Count 10 — 8/18/2021 — Albert Groff ↔ P.L. (MD).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodGroff “fraudulently solicited P.L.”; workbook maps “covered day one dollar one” and an instruction to skip verificationNo quote in the count table; Redmond not on the call[EX-A] Count 10; [EX-F]
IntentGroff pled guilty to this count (Doc 96-1 ¶ 1)A party admission against Groff. It reaches Redmond only through Pinkerton, § 2, or a co-conspirator predicate[EX-G]; [EX-E] § 7
VerificationGovernment: Groff told P.L. to skip itIf P.L. completed it anyway, the disclosures were delivered notwithstanding the closer. NEED TO VERIFY — highest-value pull[EX-F]

NOT OVERCOME as to Groff; not killed as to Redmond.

Cites — Doc 16 Count 10; Doc 96-1 ¶1 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 10, §A-2 row 10, §A-3 (0 of 12, Groff band 5) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: GROFF YES Doc 96-1 · Pull order priority 1 for the verification (CH_03 §4)

1118 USC 1343

Wire — closer T.M. ME · 2021-09-02

All six

NOT OVERCOME

Alan not on call; unnamed

Element grid — Count 11

Count 11 — 9/2/2021 — unnamed closer ↔ T.M. (ME).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodWorkbook maps maternity coverage, “$50/visit,” “birth is nothing”No quote in the count table. Maternity promises, if made, are specific and damaging — take no position before hearing the recording[EX-A] Count 11; [EX-F]
IntentCloser conductUnnamed speaker; ¶ 28[EX-C]

NOT OVERCOME.

Cites — Doc 16 Count 11; HANDOFF_V3 Pillar 2 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 11, §A-2 row 11, §A-3 (0 of 12) · Unverified hole — WAV + quote · Alan on the call: NO — 0 of 12 · Quoted lie in count table: NO QUOTE · Identity of the unnamed closer unknown (CH_03 §9)

1218 USC 1343

Wire — Barrera R.S. RI · 2021-10-23

All six

NOT OVERCOME

Alan not on call; manager-on-phone optics worse; Barrera plea counts unread

Element grid — Count 12

Count 12 — 10/23/2021 — Jesus Barrera ↔ R.S. (RI).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodBarrera “fraudulently solicited R.S.”; workbook maps a fabricated ACA history, “$20 copay no bill,” and use of the sales name “Jerry”No quote in the count table; Redmond not on the call[EX-A] Count 12; [EX-F]
IntentBarrera is an SVP reporting to Redmond (¶ 8); a manager personally closing is the government's “this was the company” exhibitOptics are bad; concede that internally. His plea was entered 6/26/2026 (ECF 138–140) but his counts are [UNVERIFIED], no memorandum located, ECF 142 unread[EX-A] ¶ 8; [EX-E] § 7

NOT OVERCOME.

Cites — Doc 16 Count 12; ECF 138 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 12, §A-2 row 12, §A-3 (0 of 12, Barrera band 1) · Unverified hole — Barrera plea PDF; WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: Barrera UNVERIFIED

1318 USC 1343

Wire — Groff E.T. TX (for G.T.) · 2021-11-17

All six

NOT OVERCOME as to Groff

Alan not on call; third-party insured issues on tape

Element grid — Count 13

Count 13 — 11/17/2021 — Groff ↔ E.T. (TX), plan purchased for husband G.T.

ElementGovernment proofDefense answerExhibit ref
Material falsehoodGroff solicited E.T. to buy for G.T.; workbook maps a recitation of five major-medical carriers and “$350 then 100%”Open question with real upside: whether the product actually sold on this call was a genuine major-medical policy. If it was, the count's premise changes materially. Status: unverified[EX-A] Count 13; [EX-F] GROFF PLEA ANALYSIS
IntentGroff pled guilty to this countAdmission against Groff only[EX-G]
Third-party purchaseSale to a spouse for another insuredAdds identity, authority and materiality questions on the recording: who purchased, who was insured, what was promised to whom[EX-C]

NOT OVERCOME as to Groff. Verify the product issued before adopting a position.

Cites — Doc 16 Count 13; Doc 96-1 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 13, §A-2 row 13, §A-3 (0 of 12, Groff band 5) · Unverified hole — WAV; product type (CH_03 §9 item 5) · Alan on the call: NO — 0 of 12 · Cooperator pled: GROFF YES

1418 USC 1343

Wire — Groff L.R. NY · 2021-12-11

All six

NOT OVERCOME as to Groff

Alan not on call

Element grid — Count 14

Count 14 — 12/11/2021 — Groff ↔ L.R. (NY).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodWorkbook maps “comprehensive Major Medical,” an “$80K cornea transplant for $350,” and “no cap”No quote in the count table. If the mapped content is on the recording it is a fabrication no company script contained — the rogue-agent predicate, not a defense to the count[EX-A] Count 14; [EX-F]
IntentGroff pled guilty to this countAgainst Groff only[EX-G]

NOT OVERCOME as to Groff.

Cites — Doc 16 Count 14; Doc 96-1 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 14, §A-2 row 14, §A-3 (0 of 12, Groff band 5) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: GROFF YES · Cornea figure escalates $50K → $80K → $90K → $120K (CH_03 §7)

1518 USC 1343

Wire — Walsh R.C. MA · 2022-01-03

All six

NOT OVERCOME — Walsh pled

Alan not on call; COO voice = company

Element grid — Count 15

Count 15 — 1/3/2022 — Arthur Walsh ↔ R.C. (MA).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodWorkbook maps “largest enrollment center” and “99.9% accept this plan”No quote in the count table; Redmond not on the call[EX-A] Count 15; [EX-F]
IntentWalsh pled guilty to this count (ECF 126); the COO personally closing is the government's institutional-conduct exhibitWalsh was a licensed executive, so the unlicensed-closer theory does not touch this count. His admission binds him[EX-H]; [EX-C]

NOT OVERCOME.

Cites — Doc 16 Count 15; ECF 126 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 15, §A-2 row 15, §A-3 (0 of 12, Walsh band 2) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: WALSH YES

1618 USC 1343

Wire — Walsh J.S. CA · 2022-01-03

All six

NOT OVERCOME — Walsh pled

Alan not on call

Element grid — Count 16

Count 16 — 1/3/2022 — Walsh ↔ J.S. (CA) — same day as Count 15.

ElementGovernment proofDefense answerExhibit ref
Material falsehoodWorkbook maps an instruction to “keep pressing 1” through the verificationNo quote in the count table; Redmond not on the call[EX-A] Count 16; [EX-F]
IntentCoaching a purchaser through the verification is offered to show the disclosures were treated as an obstacle; Overt Acts 58 and 63 describe the same practiceThe two-edged reading is that a purchaser who pressed 1 at each prompt heard and acknowledged each disclosure. Genuinely double-edged — do not lead with it. See CH_03 § 4[EX-F]; [EX-J] 2.4
VerificationGovernment: the verification was defeated by coachingWhether J.S. completed it, and what it said, is NEED TO VERIFY[EX-F]

NOT OVERCOME. Walsh pled this count.

Cites — Doc 16 Count 16; ECF 126 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 16, §A-2 row 16, §A-3 (0 of 12, Walsh band 2) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: WALSH YES · Pull order priority 4 for the verification (CH_03 §4)

1718 USC 1343

Wire — Groff A.C. ME + spouse · 2022-01-24

All six

NOT OVERCOME as to Groff

Alan not on call

Element grid — Count 17

Count 17 — 1/24/2022 — Groff ↔ A.C. and spouse (ME).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodWorkbook maps “full-fledged Major Medical,” a “$120K cornea transplant for $350,” and an instruction to “ignore” the verificationNo quote in the count table; Redmond not on the call. The escalating cornea figure is the rogue-agent exhibit[EX-A] Count 17; [EX-F]
IntentGroff pled guilty to this countAgainst Groff only[EX-G]
VerificationGovernment: Groff told A.C. to ignore itIf A.C. completed it anyway, disclosures were delivered. NEED TO VERIFY — high value[EX-F]

NOT OVERCOME as to Groff.

Cites — Doc 16 Count 17; Doc 96-1 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 17, §A-2 row 17, §A-3 (0 of 12, Groff band 5) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: GROFF YES · Pull order priority 2 for the verification (CH_03 §4)

1818 USC 1343

Wire — Groff D.P. NY post-sale · 2022-02-22

All six

NOT OVERCOME as to Groff

Post-sale furtherance still Schmuck-viable; Alan not on call

Element grid — Count 18

Count 18 — 2/22/2022 — Groff ↔ D.P. (NY) — post-sale (spouse's plan sold 1/28/2022).

ElementGovernment proofDefense answerExhibit ref
Material falsehoodMisrepresentations “in connection with” a plan already sold to D.P.'s spouse; workbook maps that D.P.'s physician called the plan limited and Groff overrode himNot an origination call — service conduct after the purchase decision, and the purchase was induced by a different call to a different person[EX-A] Count 18; [EX-F]
IntentGroff pled guilty to this countAgainst Groff only; Redmond not on the call[EX-G]
Furtherance and materialityPost-sale furtherance and lulling; continued premium paymentsThis is Schmuck territory and it is available to the government. Do not brief post-sale calls as categorically outside § 1343. Materiality of a post-purchase statement is a jury question[EX-D] § 2

NOT OVERCOME as to Groff. A different species — service and retention rather than origination.

Cites — Doc 16 Count 18; Doc 96-1 · Grid: CH_03 §3 · Matrix: EXHIBIT A §A-1 row 18, §A-2 row 18, §A-3 (0 of 12, Groff band 5) · Unverified hole — WAV · Alan on the call: NO — 0 of 12 · Cooperator pled: GROFF YES · Pull the original 1/28/2022 sale recording (CH_03 §4)

1918 USC 1343

Wire — Walsh control email · 2022-06-07

All six

NOT OVERCOME as furtherance; WEAKENED as victim-falsehood

Control/concealment not a consumer lie; proves Alan still ran Seguro (gov nominee theory)

Element grid — Counts 19 & 20

The alleged wires. Two emails on the same date to Seguro Medico senior management, one from Walsh (Count 19) and one from Barrera (Count 20), each conveying the same Redmond instruction: outside requests must “seek approval from me first … before doing anything. EVER. Nothing external is done unless run through me. ZERO. No interviews. No look ups. No nothing.

A source conflict to resolve before any Rule 12 filing. The charge book quotes the instruction itself as the content of both counts. The analysis workbook describes Counts 19 and 20 as charging the same email thread in which Walsh and Barrera “each replied 'confirm'” to Redmond. Those are materially different charged wires — a transmitted directive versus a one-word acknowledgment — and the multiplicity argument is stronger under the second reading. The count tables in Doc 16 must be read against the native thread before the multiplicity motion is filed.

ElementGovernment proofDefense answerExhibit ref
Scheme / material falsehood to a purchaserThe government does not allege a purchaser falsehood in the charged content. It offers the directive as concealment in furtherance of the scheme, and as proof Redmond still controlled Seguro Medico (¶ 6, ¶ 15(p))This is the one genuine sufficiency gap identified across all twenty-seven counts: Counts 19 and 20 contain no false pretense to a purchaser in the charged content. Everything else in the instrument is a weight argument; this is the Rule 29 argument[EX-E] § 10
Intent to defraudTiming — the directive issues while regulators and investigators are active; ¶ 30 and OA 59 supply the concealment contextExecutive oversight of external communications is lawful and ordinary. Intent to defraud a purchaser through an internal do-not-speak order requires an inference the charged text does not carry[EX-C]; [EX-F]
Wire in furtheranceConcealment and lulling furtherance under the Schmuck lineThe government's real answer, and it must be met head-on rather than ignored. Furtherance-by-concealment requires the scheme to be proved first; if Count 1 narrows, these two fall with it[EX-D] § 2
Multiplicity (Count 20)Two senders, two transmissionsSame date, same thread, same instruction, same recipients. Count 20 is charged as a second felony for a duplicate transmission of Count 19's content. Barrera did not, on this record, plead Count 20[EX-F] CRITICAL FINDINGS ¶ 4; [EX-C]

Count 19: NOT OVERCOME as a furtherance-and-concealment wire; WEAKENED to the point of a genuine Rule 29 argument on the false-pretense element. Walsh pled guilty to this count, which is the reason it is not simply dismissible: a participant has admitted that this email was part of the fraud. Do not oversell it. Brief it as a Rule 29 argument preserved from the start and renewed, not as a pretrial dismissal certainty.

Cites — Doc 16 Count 19; ECF 126 · Grid: CH_02 §8 (shared with Count 20) · Matrix: EXHIBIT A §A-1 row 19, §A-2 row 19 · Unverified hole — Full email chain · Alan on the communication: SUBJECT of instruction; Walsh sender · Cooperator pled: WALSH YES · Quoted lie in count table: YES quoted

2018 USC 1343

Wire — Barrera same control email · 2022-06-07

All six

NOT OVERCOME if 19 survives; weakened standing alone

Multiplicity with 19 [THEORY]; Barrera sender

Element grid — Counts 19 & 20

The alleged wires. Two emails on the same date to Seguro Medico senior management, one from Walsh (Count 19) and one from Barrera (Count 20), each conveying the same Redmond instruction: outside requests must “seek approval from me first … before doing anything. EVER. Nothing external is done unless run through me. ZERO. No interviews. No look ups. No nothing.

A source conflict to resolve before any Rule 12 filing. The charge book quotes the instruction itself as the content of both counts. The analysis workbook describes Counts 19 and 20 as charging the same email thread in which Walsh and Barrera “each replied 'confirm'” to Redmond. Those are materially different charged wires — a transmitted directive versus a one-word acknowledgment — and the multiplicity argument is stronger under the second reading. The count tables in Doc 16 must be read against the native thread before the multiplicity motion is filed.

ElementGovernment proofDefense answerExhibit ref
Scheme / material falsehood to a purchaserThe government does not allege a purchaser falsehood in the charged content. It offers the directive as concealment in furtherance of the scheme, and as proof Redmond still controlled Seguro Medico (¶ 6, ¶ 15(p))This is the one genuine sufficiency gap identified across all twenty-seven counts: Counts 19 and 20 contain no false pretense to a purchaser in the charged content. Everything else in the instrument is a weight argument; this is the Rule 29 argument[EX-E] § 10
Intent to defraudTiming — the directive issues while regulators and investigators are active; ¶ 30 and OA 59 supply the concealment contextExecutive oversight of external communications is lawful and ordinary. Intent to defraud a purchaser through an internal do-not-speak order requires an inference the charged text does not carry[EX-C]; [EX-F]
Wire in furtheranceConcealment and lulling furtherance under the Schmuck lineThe government's real answer, and it must be met head-on rather than ignored. Furtherance-by-concealment requires the scheme to be proved first; if Count 1 narrows, these two fall with it[EX-D] § 2
Multiplicity (Count 20)Two senders, two transmissionsSame date, same thread, same instruction, same recipients. Count 20 is charged as a second felony for a duplicate transmission of Count 19's content. Barrera did not, on this record, plead Count 20[EX-F] CRITICAL FINDINGS ¶ 4; [EX-C]

Count 20: WEAKENED standing alone, and the multiplicity candidate. It rises or falls with Count 19 on furtherance, and it is the count to move against under Rule 12. The controlling ledger says 19 and 20 are the only clean element gap across the whole instrument, and it also says everything else is weight.

Cites — Doc 16 Count 20 · Grid: CH_02 §8 (shared with Count 19) · Matrix: EXHIBIT A §A-1 row 20, §A-2 row 20 · Unverified hole — Whether Barrera pled this · Alan on the communication: SUBJECT of instruction; Barrera sender · Cooperator pled: No · Quoted lie in count table: YES quoted (duplicate)

2126 USC 7202

Fail to pay over TF — Bene Q2-2019 · $142,665.72

Redmond only

AMOUNT unexplained = BOP gold. Balance-zero WEAKENS loss. Element NOT killed.

Charged figure matches NEITHER 4183 nor TC240 (untraceable). Module later $0. Thayer: due-date failure still lives.

Element grid — Count 21

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 21 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2019 Q2Bene Market142,665.727/29/2019YesDeparts from [EX-B1] by 83,076.08Certified CVPN balance $0.00; TC670 −242,772.61 (8/8/2023) exceeds the TC240. 941 module balance was $398,798.03 on the 8/2023 pull — different module, do not collapseOutside the CARES wage window

The charging-source proof. MFT 55 module 201906 carries TC240 assessed 06/13/2022 of 225,741.80 against a charged figure of 142,665.72 — a delta of −83,076.08. Two bridges were tested and both fail: gross TFRP is not the charged number, and TFRP net of in-period deposits gives 225,741.80 − 11,400.00 (TC650) = 214,341.80, still 71,676.08 above the charged figure. That is the Rule 7(f) bill of particulars, and [EX-B1] is Exhibit A to it. Frame the relief narrowly: identify the document and the computation, not dismiss the counts. Particulars on Counts 21 and 22 is a 35-55% partial-grant proposition; dismissal on this record is not.

Kill status: AMOUNT unexplained = BOP gold. Balance-zero WEAKENS loss. Element NOT killed. Thayer means a failure complete at the due date is not undone by later collection — that is the honest ceiling. Say “the parallel § 6672 module was collected to zero.” Never say “the count is paid.” He signed Count 21's 941 (RedmondTax006791, title “Member”); “he never signed a 941” is RETIRED.

Cites — Doc 16 tax table; public.tax_counts Ct21 GOLD-SEEN · Grid: CH_05 §5.1 (all seven counts) + §5.4 module row + §5.2 charging-source table · Matrix: EXHIBIT A §A-1 row 21 · Unverified hole — EFTPS full set; BOP derivation · Cooperator / Alan on communication: N/A (tax) · Statute read per United States v. Thayer, 201 F.3d 214, 220-21 (3d Cir. 1999) — adverse and controlling · Instruction trap: 5.07 good faith NOT available on the tax counts; willfulness rides inside Cheek v. United States, 498 U.S. 192, 201 (1991)

2226 USC 7202

Fail to pay over TF — Bene Q3-2019 · $143,591.46

Redmond only

STRONGEST payment count. NOT a legal acquittal of 10/30/19 failure.

Civil module PAID IN FULL $0. Two in-period deposits. $94k civil/criminal figure gap.

Element grid — Count 22

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 22 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2019 Q3Bene Market143,591.4610/30/2019YesDeparts by 94,696.23Strongest payment count. TC640 −258,939.50 (11/15/2023) drove the TFRP module to $0.00 as of 3/11/2024Outside the window

The charging-source proof. MFT 55 module 201909 carries TC240 assessed 06/13/2022 of 238,287.69 against a charged figure of 143,591.46 — a delta of −94,696.23. TFRP net of in-period federal tax deposits gives 238,287.69 − 107,950.10 (TC650 65,078.00 + 42,872.10) = 130,337.59, now 13,253.87 below the charged 143,591.46. The deposit hypothesis over-corrects on Count 21 and under-corrects here. Whatever arithmetic produced $142,665.72 and $143,591.46, it is not on any produced page.

Kill status: STRONGEST payment count. NOT a legal acquittal of 10/30/19 failure. Counts 21 and 22 close at $0.00 on the certified civil-penalty modules more than a year before Doc 1 — the government's own collection function treated that money as recovered, and every filing describing it as unpaid meets a transcript line rather than an argument. Do not drift into inability to pay. Never assert “the tax counts net to zero.”

Cites — Handoff; tax_counts Ct22; CVPN p.2 · Grid: CH_05 §5.1 + §5.4 module row + §5.2 · Matrix: EXHIBIT A §A-1 row 22 · Unverified hole — None material on payment; Thayer still applies · Cooperator / Alan on communication: N/A · Vehicle: Rule 7(f) particulars, MFT 55 table as Ex. A, ripe pretrial (CH_05 §5.9)

2326 USC 7202

Fail to pay over TF — Bene Q4-2019 · $228,125.75

Redmond only

NOT OVERCOME

Payments ~$126k; remaining certified $102,693.09. Honest weak point on the number.

Element grid — Count 23

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 23 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2019 Q4Bene Market228,125.751/30/2020YesExact match — concede the figureTC670 −21,611.53 (8/8/2023) + TC640 −102,952.20 and −2,078.30 (11/15/2023); balance reduced, not zero ($102,693.09)Outside the window; but see Smith's direction of ERC to this quarter (§5.6)

Why the concession is load-bearing. MFT 55 module 201912 carries TC240 assessed 06/13/2022 of 228,125.75 — exact to the penny against the charged figure, on the same certified page, in the government's own type. Counts 23 and 24 are conceded on the figure for exactly that reason, and the concession buys the credibility that makes the Counts 21/22 departure attack land. Smith's letter directs $240,016.75 of unapplied ERC to Q4-2019 and Q1-2020 — i.e. Counts 23 and 24; usable as a Cheek and loss argument [EX-B8].

Kill status: NOT OVERCOME. The honest weak point is the number: payments of roughly $126k leave a remaining certified balance of $102,693.09. Under Thayer, a failure complete at the due date is not undone by later collection.

Cites — Doc 16; tax_counts Ct23; Handoff · Grid: CH_05 §5.1 + §5.4 module row + §5.2 MFT 55 table · Matrix: EXHIBIT A §A-1 row 23 · Unverified hole — ERC N/A (2019) · Cooperator / Alan on communication: N/A · Government's noticed expert on Counts 21-27: IRS Revenue Agent Hang L. Tran (CH_05 §5.3)

2426 USC 7202

Fail to pay over TF — Bene Q1-2020 · $188,953.17

Redmond only

NOT OVERCOME. Gross-vs-net is loss/willfulness, not missing element.

'6672≠7202' RETIRED. No payments on module. ERC eligibility UNVERIFIED computation.

Element grid — Count 24

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 24 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2020 Q1Bene Market188,953.174/29/2020YesExact match — concede the figureTC240 188,953.17 + TC196 1,001.70 interest = 189,954.87; no payments on that module [EX-B6 p.6]Inside COVID; Smith directs credits here

Charging source. MFT 55 module 202003 carries TC240 assessed 06/13/2022 of 188,953.17 — the second of the two exact matches that prove the MFT 55 TFRP ledger is the charging source for the 2019–2020 Bene counts. The charged figure equals the TC240 misc penalty of 6/13/22 on the personal transcript.

Kwong scoping. Kwong v. United States, 179 Fed. Cl. 382 (2025) (No. 23-267, Ct. Fed. Cl., 11/25/2025, on appeal) invalidated the regulatory one-year cap on the mandatory postponement period, 1/20/2020–7/10/2023. This count's offense date falls inside that window. But 26 C.F.R. § 301.7508A-1(c)(1) and Rev. Proc. 2018-58 exclude employment-tax deposits unless specifically listed, and Kwong is a duration case, not a scope case. It is corroboration for a state of mind and the engine of the civil refund track — never a merits defeat of the pay-over element.

Kill status: NOT OVERCOME. Gross-vs-net is loss/willfulness, not missing element. “It is a 6672 penalty, not a 7202 tax, so the count fails” is RETIRED — researched and closed; the statutes travel together. ERC eligibility computation remains UNVERIFIED.

Cites — TARGETS smoking gun; tax_counts Ct24 · Grid: CH_05 §5.1 + §5.4 module row + §5.2 + §5.6 ERC ledger · Matrix: EXHIBIT A §A-1 row 24 · Unverified hole — Smith ERC worksheet · Cooperator / Alan on communication: N/A · Two uncharged modules on the same certified page — 201809 ($18,535.56) and 201903 ($146,727.22), $165,262.78 never charged; selection evidence for the particulars motion, never pleaded as a legal defect (CH_05 §5.3)

2526 USC 7202

Fail to pay over TF — Bene Q4-2020 · $149,298.17

Redmond only

Figure existence NOT killed. ERC already inside the charged number.

0-HIT THESIS RETIRED. Figure = TF minus refundable ERC $31,542.61 on filed 941 (GJ Ex 5). Reporting Agent PIN not Alan wet-sign.

Element grid — Count 25

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 25 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2020 Q4Bene Market149,298.171/30/2021YesDerives from the filed 941: line 3 WH 114,142.00 + ½ SS 52,637.37 + ½ Medicare 14,061.41 = TF 180,840.78 − line 13d refundable ERC 31,542.61 = 149,298.17 exact [EX-B3]941 module balance $140,548.59 (8/2023)ERC already netted into the charged number. TC766 −31,542.61 is the only IRS-labeled ERC in the corpus

DO NOT FILE. “Count 25 has 0 hits in any certified transcript” is RETIRED. The figure derives exactly from the filed 941: TF 180,840.78 minus refundable ERC 31,542.61 [EX-B3]. The government already applied ERC on that count. Also retired: Count 25 three-year limitations “lapsed 2/22/2024, unrevivable” — not filed without a limitations memo (original indictment 10/17/2024; superseder 5/8/2025).

Kill status: Figure existence NOT killed. ERC already inside the charged number. The blank-signature wedge is Count 27, with supporting pattern at Count 25 and one uncharged quarter — the Reporting Agent PIN, not an Alan wet-sign.

Cites — tax_counts Ct25; GJ Ex 5 Bates RedmondTax005570-77 · Grid: CH_05 §5.1 + §5.4 module row + §5.6 ERC ledger + DO NOT FILE box items 1, 8, 12 · Matrix: EXHIBIT A §A-1 row 25 · Unverified hole — Do not file 0-hit language. SOL memo if anyone still wants it. · Cooperator / Alan on communication: N/A · Only $31,542.61 of ERC is IRS-labeled; no TC810 refund freeze appears anywhere in the corpus

2626 USC 7202

Fail to pay over TF — Bene Q4-2021 · $216,046.20

Redmond only

NOT OVERCOME. 'Never assessed' is false.

'Assessed 2/21/2025 post-indictment' RETIRED (TC150 02-21-2022). Fidalgo-scope + IIJA ERC repeal arguments survive.

Element grid — Count 26

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 26 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2021 Q4Bene Market216,046.201/31/2022YesMatches Form 4183 TF [EX-B2]Certified entity balance $349,940.38; TC150 300,334.52 posted 02-21-2022IIJA repealed Q4-2021 ERC retroactively 11/15/2021 — shortfall predicted to IRS in writing 1/10/2022 [UNVERIFIED until Bates]

DO NOT FILE. “Count 26 was assessed 2/21/2025, after the original indictment” is RETIRED. TC150 $300,334.52 posted 02-21-2022, cycle 202205 [EX-B6 p.4]. The date argument is dead; Fidalgo-scope and IIJA willfulness survive. The zero-balance letter's “never assessed” line as to Counts 25 and 26 is retired and does not enter a filing merely because a CPA wrote it.

Kill status: NOT OVERCOME. 'Never assessed' is false.

Cites — tax_counts Ct26; CVPN p.4 · Grid: CH_05 §5.1 + §5.4 module row + §5.8 + DO NOT FILE box item 2 · Matrix: EXHIBIT A §A-1 row 26 · Unverified hole — 1/10/2022 prediction letter Bates · Cooperator / Alan on communication: N/A · Motion hook: pre-2019 taxpaying record as 404(b) — in limine, keyed to the 12/7/2026 wave

2726 USC 7202

Fail to pay over TF — Seguro Q2-2022 · $161,367.95

Redmond only

Amount untraceable = BOP. RP NOT a merits kill.

Charged matches NEITHER TC150 $270,986.20 nor balance $236,140.44. RP merits theory RETIRED (Alan 8/11/26). Signature/INOLES for impeachment only.

Element grid — Count 27

Element grid — all seven § 7202 counts (CH_05 § 5.1)

ElementGovernment proofDefense answerExhibit ref
E1 · Duty — person required to collect, account for, pay overDoc 16 ¶¶6-7 (payroll, accounts, “signing forms”); Smith MOI-071423 item 29 (“sole signatory… in full control”); bank signature authorityCounts 21-26: largely conceded. Do not over-fight. Preserve two precision points only — the charging language “general partner” vs. LLC member, and that more than one responsible person existed. Count 27: genuinely contested, and contested through the government's own four sources (§5.7)[EX-B9], [EX-B11]
E2 · Failure to collect / truthfully account for or pay overCertified transcripts showing unpaid modules at each due dateConceded as to the act at the due date. The fight is which figure the government says was not paid over, and whether later collection zeroes the parallel module (§5.3)[EX-B1], [EX-B6]
E3 · Willfulness — voluntary, intentional violation of a known legal dutyPersonal-benefit spending while taxes unpaid; escrow movement; RO warningsCheek good faith, which need not be objectively reasonable: ERC belief documented pre-indictment; § 7508A(d) postponement belief; contemporaneous payment machinery; 26 months of agency non-processing[EX-B7], [EX-B8], [EX-B10]
E3-a · CPA reliance (separate, weak)Smith profferDo not lead with reliance on the Bene counts. Smith's own proffer (items 28, 29, 34) says he repeatedly told Redmond to pay and never advised delay. Reliance is contradicted by the witness it depends on[EX-B9]
Loss / amount (Rule 29 + sentencing)Charged $1,230,048.42Gross figure computed without applying filed ERC; United States v. Banks, 55 F.4th 246 (3d Cir. 2022) (actual loss) — verify current force after the 2024 guideline amendment[EX-B3], [EX-B8]

Per-count module detail — Count 27 (CH_05 § 5.4)

QuarterEntityCharged941 due (offense date)In Doc 1?Charging-source statusPayment postureERC posture
2022 Q2Seguro Medico161,367.957/31/2022No — added in the supersederTC150 tax 270,986.20 (filed 8/22/2022); certified balance 236,140.44. See §5.7 and the DO NOT FILE boxTC650 −36,724.08 in-period (4/12/2022)Post-ERC window; zero TC766 for Seguro anywhere

The duty-element attack — four government-authored sources, three different names, none of them Redmond (CH_05 § 5.7)

SourceWhat it saysTier
SW affidavit 22-MJ-1897 ¶7 (SA Simmons, 11/30/2022)“Though Redmond is not a registered owner of Seguro, or on the payroll…”[NATIVE]
Certified IRS entity transcriptNameline “STEPHANIE MILLER MBR”[SEEN]
Sardella GJ MOI ¶¶29, 31 (4/25/2024)Kroemmelbein 96% / Walsh 4%; the Seguro 941s “always went to Kroemmelbein for review and signature and never to Walsh”[SEEN]
Seguro operating agreement (Feb 2020)Members Kroemmelbein and Walsh only[SEEN] — executed copy outstanding

Add ¶7(a): “Until the second quarter of 2022, all Seguro employees were paid by checks drawn on bank accounts held by Bene Markets LLC and not Seguro.” The charged quarter is the transition quarter, on their oath. Add ¶77: Kroemmelbein is not on the Seguro payroll either. Add the signature rail: the charged 941 carries “PIN Entered By: REPORTING AGENT / Jurat: REPORTING AGENT PIN”, third-party designee C. Malcolm Smith III CPA, EFIN 231990, filing IP 173.163.117.129, and the “Print your name here” field is empty [EX-B4], while the government's own witness proffers that Redmond “signed the 941s” [EX-B9]. Zero Forms 8655, 2848, or signature records appear in 8,835 produced pages.

How to run it. This is a Rule 29 sufficiency argument about the government's proof, presented through the government's own documents — not an affirmative “wrong man” defense and not a suggestion that Kroemmelbein or Miller is the responsible person. That distinction is the whole ballgame. Prior probability work put P(Rule 29 acquittal on Count 27) at 45% [90% CI 30-62%]. Treat that as a planning number, not a promise. The government's bridge is bank signature authority plus cooperator-sourced control testimony (W11 ¶44) — signature authority is a factor, not the duty, and the control testimony comes from two co-defendants who have pled (Giglio; sentencings 10/14, 11/5, 11/6/2026 all precede trial).

Kill status: Amount untraceable = BOP. RP NOT a merits kill. Two retirements govern: “He was not the responsible person” as a MERITS theory is RETIRED per client instruction 8/11/2026 — signature provenance and INOLES stay in for impeachment and scope only. And “Count 27's figure matches no ledger” is RETIRED per the controlling corrections ledger; the derivation matrix reconciles Count 27 exactly, to the penny. Any Count 27 particulars request must ask the government to state ITS derivation, and must not assert untraceability. See CONTRADICTION C-1 in Chapter 8.

Cites — Doc 16; tax_counts Ct27; INOLES Bates RedmondTax007738 · Grid: CH_05 §5.1 + §5.4 module row + §5.7 four-source table + DO NOT FILE box items 4, 6 · Matrix: EXHIBIT A §A-1 row 27 · Unverified hole — Form 8655; OA; bank cards · Cooperator / Alan on communication: N/A · Vehicle: Rule 29 at the close of the government's case (CH_05 §5.9) · P0 open item: Seguro Form 8655 and the Q2-2022 e-file signature record, or the government's written admission that none exists — dispositive on Count 27

Honesty rail. Every kill status on this board is the EXHIBIT A · COUNT_MATRIX cell, transcribed without softening. Counts 1 and 2 are NOT OVERCOME and read that way on the card, in the modal, and in the tally. Nothing in the record eliminates any element of any count. The one genuine sufficiency gap across all twenty-seven is Counts 19 and 20 on the false-pretense element — and Walsh pled guilty to Count 19. Redmond is the speaker on 0 of 12 customer calls and the sender on 2 of 7 email wires (Counts 2 and 7); that is a speaker fact, not an element fact, and it does not kill Pinkerton, aiding, or Count 1. Do not tell Cooper the 12 counts are dismissed. Element grids are quoted verbatim from CH_01 §3 (Count 1), CH_02 §§3–8 (Counts 2, 4, 6, 7, 8, 19, 20), CH_03 §3 (Counts 3, 5, 9–18), and CH_05 §5.1 with the §5.4 module rows (Counts 21–27). Where a call grid omits the interstate-wire-in-furtherance element, that is CH_03 §2's own scoping, not an omission here.

United States v. Redmond · No. 5:24-cr-00376-JLS · Attorney Work Product

Defense Board — the wire-fraud defense visualized

Twelve customer-call wire counts, the IVR kill-shot map, acquittal-probability estimates, the Groff plea wedge, and the unnamed-agent counts — laid out from the superseding indictment analysis. Every figure below is reproduced verbatim from source.

01

Wiring Zero — Redmond is on none of the twelve

Of the twelve call-based wire-fraud counts, Alan Redmond is not on a single one. Redmond voice on a customer call: 0 of 12. Sender on an email wire: 2 of 7 (Counts 2, 7).

COUNT 3
L.F.
CA · Unnamed Bene Market rep
Redmond: not on call
COUNT 5
P.G.
FL · Unlicensed closer
Redmond: not on call
COUNT 9
B.B.
DE · Unnamed closer
Redmond: not on call
COUNT 10
P.L.
MD · Albert Groff
Redmond: not on call
COUNT 11
T.M.
ME · Unnamed closer
Redmond: not on call
COUNT 12
R.S.
RI · Jesus Barrera
Redmond: not on call
COUNT 13
E.T.
TX · Albert Groff
Redmond: not on call
COUNT 14
L.R.
NY · Albert Groff
Redmond: not on call
COUNT 15
R.C.
MA · Arthur Walsh
Redmond: not on call
COUNT 16
J.S.
CA · Arthur Walsh
Redmond: not on call
COUNT 17
A.C.
ME · Albert Groff
Redmond: not on call
COUNT 18
D.P.
NY · Albert Groff
Redmond: not on call
Internal emails Redmond touches →
COUNT 2 · sender

Redmond email to Barrera/Walsh re: training closers with fraudulent tactics — the "this is not insurance" combat email.

Redmond: on wire
COUNT 7 · forwarder

Redmond forwarding Walsh's "KISS Principles" sales brochure to Barrera.

Redmond: on wire

Nineteen §1343 counts: twelve calls, seven emails. Redmond on a customer call: 0 of 12. Redmond as sender on an email wire: 2 of 7 (Counts 2, 7).

02

IVR kill-shot map

Every charged sale ran through a recorded verification (IVR). Every status reads NEED TO VERIFY — no charged-call verification has been confirmed produced and reviewed.

COUNT 5 · 01/20/21
P.G. · FL
Unlicensed closer
Possible
Agent claimIVR would disclose
"Not supplemental" / "full major medical""Not ACA compliant" / "Limited benefit plan" / plan limitations
COUNT 9 · 07/27/21
B.B. · DE
Unknown closer
Possible
Agent claimIVR would disclose
"Government stamp of approval" / "ACA policy""Not ACA compliant" / plan limitations
COUNT 10 · 08/18/21
P.L. · MD
GROFF
High if completed
Agent claimIVR would disclose
"Covered day one dollar one" / told to skip verificationFull disclosure of limitations
COUNT 11 · 09/02/21
T.M. · ME
Unknown closer
Possible
Agent claimIVR would disclose
Maternity covered / "$50/visit" / "birth is nothing"Plan limitations / exclusions
COUNT 12 · 10/23/21
R.S. · RI
BARRERA
Possible
Agent claimIVR would disclose
Fake ACA history / "$20 copay no bill""Not ACA compliant" / actual copay structure
COUNT 13 · 11/17/21
E.T. · TX
GROFF
High if UHC
Agent claimIVR would disclose
Listed 5 Major Medical carriers / "$350 then 100%"Plan limitations / actual coverage
COUNT 14 · 12/11/21
L.R. · NY
GROFF
High
Agent claimIVR would disclose
"Comprehensive Major Medical" / "$80K cornea for $350" / "no cap""Not major medical" / caps and limitations
COUNT 15 · 01/03/22
R.C. · MA
WALSH
Possible
Agent claimIVR would disclose
"Largest enrollment center" / "99.9% accept this plan"Plan limitations / network restrictions
COUNT 16 · 01/03/22
J.S. · CA
WALSH
High — ironic
Agent claimIVR would disclose
Told to "keep pressing 1" on verificationFull disclosures
COUNT 17 · 01/24/22
A.C. · ME
GROFF
High if completed
Agent claimIVR would disclose
"Full-fledged Major Medical" / "$120K cornea for $350" / "ignore verification"Full disclosure of limitations
COUNT 18 · 02/22/22
D.P. · NY
GROFF
Moderate
Agent claimIVR would disclose
Doctor said limited. Groff said doctor "wrong."Original IVR from 01/28/22 sale

Source: IVR DEFENSE MAP, Exhibit C-3. IVR status on every row: NEED TO VERIFY.

03

Acquittal probability, by count

Wire Fraud Classification, all nineteen §1343 counts (2–20). Percentages verbatim from source; not element conclusions.

Ct 3
45%
Ct 5
35%
Ct 9
40%
Ct 10
50%
Ct 11
40%
Ct 12
45%
Ct 13
50%
Ct 14
50%
Ct 15
45%
Ct 16
50%
Ct 17
50%
Ct 18
50%
Customer call count

Source: WIRE FRAUD CLASSIFICATION, Exhibit C-5.

04

Groff — plea and the rogue-agent wedge

Pled counts

  • Count 1 — 18 U.S.C. §1349 (Conspiracy)
  • Count 10 — P.L. (MD)
  • Count 13 — E.T. (TX)
  • Count 14 — L.R. (NY)
  • Count 17 — A.C. (ME)
  • Count 18 — D.P. (NY)

Groff pled guilty to Counts 1, 10, 13, 14, 17 and 18 — the conspiracy plus five charged calls, all his own.

● Giglio / Brady demand — sealed supplement (Para 17), 85–90%

Rogue-agent wedge

Paragraph 28 concedes the closers spoke beyond the scripts, and the workbook maps Groff's cornea-transplant claim escalating call after call:

$50K → $80K → $90K → $120K

(Overt Acts 52, 53, 56, 60, 63). No company script instructed an agent to invent a personal cornea-transplant figure and inflate it call after call. That escalation is the best available proof that the charged lies on the Groff counts were his inventions.

Groff Testimony Credibility: 40–50% (discounted) — cornea transplant escalation ($50K→$120K) proves Groff is a serial fabricator; jury may discount.

Source: GROFF PLEA ANALYSIS, Exhibit C-2; Chapter 3 §7.

05

Unnamed-agent strip

Wire Fraud Classification, "Agent Identified" = NO.

COUNT 3
Unknown Bene rep · L.F. (CA)
No speaker named
COUNT 4
Unknown sender to Redmond
No speaker named
COUNT 9
Unknown closer · B.B. (DE)
No speaker named
COUNT 11
Unknown closer · T.M. (ME)
No speaker named

Source: WIRE FRAUD CLASSIFICATION, Exhibit C-5.

Section 06Tax Attack · Counts 21–27 26 U.S.C. § 7202 Redmond alone · no entity, no co-defendant, no cooperator

The charging source is the government’s own certified ledger.

Charged total $1,230,048.42 (Doc 16 ¶11). The original indictment (Doc 1, 10/17/2024) charged six Bene Market quarters totalling $1,068,680.47; Count 27 (Seguro Medico) exists only in the superseder. The single most valuable tax document in the file is [EX-B1] — the certified MFT 55 trust-fund-recovery-penalty transcript, six modules, all assessed 06/13/2022, transcript run 07/28/2022.


Charging-source proof — charged $ vs MFT 55 TC240

Two exact matches prove the source. Two departures prove the motion.

Charged figure (Doc 16) MFT 55 TC240 assessed 06/13/2022
Bars scaled to $238,287.69 = 100% · grain: one MFT 55 civil-penalty module per charged quarter · source [EX-B1] certified MFT 55 transcript, six modules, run 07/28/2022, Bates RedmondTax007831-36
COUNT 212019 Q2 · Bene Market · 941 due 7/29/2019 · module 201906
Charged$142,665.72
MFT 55 TC240$225,741.80
$83,076.08 unexplained DEPARTS from [EX-B1] by −83,076.08 Gross TFRP bridge fails 225,741.80 − 11,400.00 (TC650) = 214,341.80 — still 71,676.08 above charged
COUNT 222019 Q3 · Bene Market · 941 due 10/30/2019 · module 201909
Charged$143,591.46
MFT 55 TC240$238,287.69
$94,696.23 unexplained DEPARTS from [EX-B1] by −94,696.23 Gross TFRP bridge fails 238,287.69 − 107,950.10 (TC650 65,078.00 + 42,872.10) = 130,337.59 — now 13,253.87 below charged
COUNT 232019 Q4 · Bene Market · 941 due 1/30/2020 · module 201912
Charged$228,125.75
MFT 55 TC240$228,125.75
To the penny Exact match — concede the figure TC240 13 Jun 2022 — “MATCHES COUNT 23 EXACTLY”
COUNT 242020 Q1 · Bene Market · 941 due 4/29/2020 · module 202003
Charged$188,953.17
MFT 55 TC240$188,953.17
To the penny Exact match — concede the figure TC240 13 Jun 2022 — “MATCHES COUNT 24 EXACTLY”

Two exact matches, to the penny, on the same certified page, in the government’s own type. That is not coincidence and it is not an alternative computation — the MFT 55 TFRP ledger is the charging source for the 2019–2020 Bene counts. Counts 23 and 24 are conceded on the figure for exactly that reason, and the concession buys the credibility that makes the next sentence land. Counts 21 and 22 depart from that same source and no produced document explains how. The deposit hypothesis over-corrects on one count and under-corrects on the other. Whatever arithmetic produced $142,665.72 and $143,591.46, it is not on any produced page. That is the Rule 7(f) bill of particulars, and [EX-B1] is Exhibit A to it. Frame the relief narrowly: the ask is identify the document and the computation, not dismiss the counts. Particulars on Counts 21 and 22 is a 35-55% partial-grant proposition; dismissal on this record is not.

Selection and snapshot — what the certified page shows and what no page shows

Two modules on the same page, assessed the same day, never charged.

Uncharged quarters · 201809 + 201903 · selection evidence

MFT 55 moduleQuarter endingTC240 assessed 06/13/2022Charged count
20180930 Sep 201818,535.56none — never charged
20190331 Mar 2019146,727.22none — never charged
Assessed trust-fund liability the grand jury never saw as a count165,262.78

Assessed on the same day, by the same officer, on the same theory, and never charged. Both amounts are shown as sourced from the MFT 55 native transcript read (RedmondTax007831-36) — and only from that read: no assessed dollar figure for either period appears in any of the five source workbooks, so Exhibit B carries 201809 and 201903 as an evidentiary gap, not as a figure. Attribute the numbers to the transcript, never to the workbook.

This is not a legal defect and it should never be pleaded as one. It is worth three things: selection evidence for the particulars motion, because the government made count-level choices inside a six-module page and can therefore state the criteria it applied; cross of the revenue agent — the government’s noticed expert on Counts 21-27 is IRS Revenue Agent Hang L. Tran, and the six-module page frames every question about how the charged figures were derived and why two modules dropped out; and loss, because a charged set chosen for reasons the government will not articulate carries that problem into the guidelines figure.

“A limitations answer concedes the charging decision was calendar-driven.”

Open item: the 2018 and 3/31/2019 transcripts are marked [NOT OBTAINED] — “not available through Alan’s personal account - I would have to call IRS” · “NEVER OBTAINED — Smith offered to call IRS”. A known gap Smith himself flagged.

Every produced certified transcript predates the payment.

The $500K / $324,708.84 transcript gap · CH_05 §5.5 · CH_06 §6.8 · C-2

Every certified IRS transcript in the production is an August 2023 pull — that is, it predates the $500,000 payment of 8/8/2023 and predates all ERC processing. The consequence is that the government’s charged figures, its loss computation, and its “unpaid” rhetoric all rest on a ledger snapshot taken before the largest payment in the case posted.

The post-8/8/2023 activity presently known to the defense is recited inside Form 843 Line 8 statements prepared by a tax professional, not read off a certified transcript in the production. That is a recitation, not evidence, and it cannot be put in front of a jury in that form.

Identifiable 8/8/2023 postings in the working ledgerAmount $
TC670 — Count 21 parallel module−242,772.61
TC670 — 6672 TFRP module ending 31 Dec 2019−21,611.53
TC670 — Joint 1040 TY2021−58,055.38
TC706 — credit transferred in−232.66
TC706 — credit transferred in−2,036.66
Sum — roughly, and not $500,000324,708.84

Demand current-date certified transcripts:

  • MFT 01, EIN 81-2680613 (Bene Market) — all charged quarters
  • MFT 30, SSN …5092 (individual)
  • MFT 55, SSN …5092 (trust-fund recovery penalty)

[CONTRADICTION C-2] The demand is unaffected — the point is that no certified transcript in the production shows any 8/8/2023 activity — but the $500,000 figure must be reconciled before it appears in a filing or a proffer.

The willfulness wall — four independent supports, inside Cheek

A good-faith belief negates willfulness and need not be objectively reasonable. Model Instruction 5.07 is not available on the tax counts — the showing rides inside the Cheek definition, not as a free-standing charge.

PILLAR I

Kwong / § 7508A(d) window

Kwong v. United States, 179 Fed. Cl. 382 (2025) (No. 23-267, Ct. Fed. Cl., 11/25/2025, on appeal) invalidated the regulatory one-year cap on the mandatory postponement period, 1/20/2020–7/10/2023. Five of seven counts (23, 24, 25, 26, 27) have an offense date inside that window.

But 26 C.F.R. § 301.7508A-1(c)(1) and Rev. Proc. 2018-58 exclude employment-tax deposits unless specifically listed, and Kwong is a duration case, not a scope case. REG-115057-20 gives the government its answer in advance.

FENCE: corroboration for a state of mind and the engine of the civil refund track only. Never plead Kwong as a merits defeat of the pay-over element.

PILLAR II

ERC filed credits

The honest statement: the government charged the gross trust-fund figure while filed credits sat unprocessed. That is a genuine loss-methodology and materiality point and a genuine willfulness point.

IRS-labeled ERC actually posted — TC766, Bene Q4-202031,542.61
ERC abatement, Bene Q2-2020 — TC291, credit taken away−66,313.66
Smith letter “credits not applied,” directed to Cts 23 & 24240,016.75

The only IRS-labeled ERC in the corpus is $31,542.61, and it is already netted into Count 25. The TC291 abatement is adverse; own it.

FENCE: retire $1,576,093.06. Never assert “the tax counts net to zero.” Never represent a documented TC810 freeze — no TC810 appears anywhere in the corpus.

PILLAR III

Contemporaneous compliance

Eleven Form 843 protective claims filed 7/10/2026, FedEx 874245637020 [EX-B7] — contemporaneous compliance acts, and the engine of the civil refund track.

Also contemporaneous: the 2/9/2024 e-mail forwarded to William McSwain — “they have never applied ERC tax credits during Covid times… we have made every effort to get caught up” — documented good-faith belief eight months before the original indictment, with two attachments evidencing attempts to pay. Pull the attachments.

[CONFLICT C-10] “Kwong Form 843 protective claims: 11 claims filed 7/10/2026 with a FedEx tracking number versus ‘the July 10 deadline was missed for all five taxpayers’” → Direct conflict, and it is load-bearing — contemporaneous compliance is one of four supports for the Cheek good-faith showing. Resolve before that support is argued.

PILLAR IV

Payments actually made, including a $0.00 module

Count 22 is the strongest payment count. TC640 −258,939.50 (11/15/2023) drove the TFRP module to $0.00 as of 3/11/2024. On Count 21, TC670 −242,772.61 (8/8/2023) exceeds the TC240 and the certified CVPN balance is $0.00. Both close more than a year before Doc 1.

Payment machinery existing across the charged period — escrow balances of $359,768.47 (12/13/2021), a completed wire of $213,493.47 (1/4/2022), a $431,603.52 balance with $125,132.60 earmarked (5/25/2022) — is Cheek evidence, not payment evidence.

MODULE DISCIPLINE [C-5]: say “the parallel § 6672 module was collected to zero.” Never say “the count is paid.” The 8/2023 MFT 01 balances ($398,798.03, $302,122.74, $366,602.12, $320,394.26, $140,548.59, $349,940.38) are real. Never plead inability to pay — Easterday drift converts good faith into an admission.

Count 27 — duty-element sufficiency, Rule 29 only

Four government-authored sources address who ran Seguro Medico. They name three different people. None is Redmond.

Ct 27 · 2022 Q2 · Seguro Medico · charged $161,367.95 · 941 due 7/31/2022 · added in the superseder

[NATIVE] SW affidavit 22-MJ-1897 ¶7
SA Simmons, 11/30/2022
“Though Redmond is not a registered owner of Seguro, or on the payroll…” Not Redmond
[SEEN] Certified IRS entity transcript
nameline
Nameline reads “STEPHANIE MILLER MBR” Stephanie Miller
[SEEN] Sardella GJ MOI ¶¶29, 31
4/25/2024
Kroemmelbein 96% / Walsh 4%; the Seguro 941s “always went to Kroemmelbein for review and signature and never to Walsh” Kroemmelbein
[SEEN] — executed copy outstanding Seguro operating agreement
Feb 2020
Members Kroemmelbein and Walsh only Kroemmelbein + Walsh
DISAGREE THREE NAMES · NONE IS REDMOND

Add ¶7(a): “Until the second quarter of 2022, all Seguro employees were paid by checks drawn on bank accounts held by Bene Markets LLC and not Seguro.” The charged quarter is the transition quarter, on their oath. Add ¶77: Kroemmelbein is not on the Seguro payroll either — the payroll-control theory has nobody on the payroll.

The signature rail. The charged 941 carries “PIN Entered By: REPORTING AGENT / Jurat: REPORTING AGENT PIN,” third-party designee C. Malcolm Smith III CPA, EFIN 231990, filing IP 173.163.117.129, and the “Print your name here” field is empty [EX-B4] (RedmondTax007239-007250, sig block 007241), while the government’s own witness proffers that Redmond “signed the 941s” [EX-B9]. Zero Forms 8655, 2848, or signature records appear in 8,835 produced pages. The entity’s own Form 1065 (TY2022) was signed by Kroemmelbein, the 96% owner.

How to run it. This is a Rule 29 sufficiency argument about the government’s proof, presented through the government’s own documents — not an affirmative “wrong man” defense. That distinction is the whole ballgame. Prior probability work put P(Rule 29 acquittal on Count 27) at 45% [90% CI 30-62%] on a reference class of § 7202 / § 6672 prosecutions where no government source names the defendant as owner, officer, or payroll-listed and the charged return was filed under a third-party reporting-agent PIN. Treat that as a planning number, not a promise.

The government’s bridge is bank signature authority on the Seguro accounts plus cooperator-sourced control testimony (W11 ¶44: “Redmond controls the business through Barrera and Walsh”). Signature authority is a factor, not the duty; it must be paired with control over which creditors were paid in the charged quarter, which ¶7(a) itself unsettles. The control testimony comes from two co-defendants who have pled — Giglio, and their sentencings (10/14, 11/5, 11/6/2026) all precede trial.

FENCE: No substitute-responsible-person theory (RETIRED 8/11/26). Rule 29 sufficiency built from the government’s own four sources only — never as an affirmative wrong-man defense, and never as “Kroemmelbein or Miller was responsible.” Signature provenance and INOLES stay in for impeachment and scope only. Do not plead untraceability on Count 27 [C-1] — any particulars request must ask the government to state ITS derivation.

Do not file — retired theories

These were tested and lost. Each one, if signed, hands the government a free correction.

  1. “Count 25 has 0 hits in any certified transcript.” RETIRED. The figure derives exactly from the filed 941: TF 180,840.78 minus refundable ERC 31,542.61 [EX-B3]. The government already applied ERC on that count.
  2. “Count 26 was assessed 2/21/2025, after the original indictment.” RETIRED. TC150 $300,334.52 posted 02-21-2022, cycle 202205 [EX-B6 p.4]. The date argument is dead; Fidalgo-scope and IIJA willfulness survive.
  3. “It is a 6672 penalty, not a 7202 tax, so the count fails.” RETIRED — researched and closed. The statutes travel together.
  4. “He was not the responsible person” as a MERITS theory on Counts 21-26. RETIRED per client instruction 8/11/2026. Signature provenance and INOLES stay in, for impeachment and scope only. On Count 27 the argument runs as Rule 29 sufficiency built from the government’s own four sources — not as an affirmative wrong-man defense, and never as “Kroemmelbein or Miller was responsible.”
  5. Citing THAYER for “no amount element.” RETIRED. Not locatable in the opinion. Thayer is adverse and controlling; use CTM 9.03 / Citron for that proposition.
  6. “Count 27’s figure matches no ledger.” RETIRED per the controlling corrections ledger — the derivation matrix reconciles Count 27 exactly, to the penny. Any Count 27 particulars request must ask the government to state ITS derivation, and must not assert untraceability. See CONTRADICTION C-1 in Chapter 8.
  7. “The tax counts net to zero” / “ERC exceeds the indictment” / a documented TC810 refund freeze / “$1,576,093.06 in ERC was filed.” RETIRED or unsourced. ~$150,892.71 identifiable against $1,068,680.47. Only $31,542.61 is IRS-labeled. No TC810 appears anywhere in the corpus.
  8. “He never signed a 941.” RETIRED. He signed several, including Count 21’s (RedmondTax006791, title “Member”). The blank-signature wedge is Count 27, with supporting pattern at Count 25 and one uncharged quarter.
  9. Kwong / 7508A(d) as a MERITS defeat of the pay-over element. RETIRED — employment-tax deposits are outside the default postponement. Willfulness and the civil refund track only.
  10. Vindictive-prosecution PRESUMPTION on the superseder. FORECLOSED for pretrial charge increases by United States v. Goodwin, 457 U.S. 368. P(dismissal) 3-5%. The Smith-letter-to-superseder timeline stays as narrative and pressure only.
  11. Inability to pay. NEVER PLEAD IT. Easterday drift converts good faith into an admission.
  12. Count 25 three-year limitations “lapsed 2/22/2024, unrevivable.” NOT FILED without a limitations memo. Original indictment 10/17/2024; superseder 5/8/2025.

ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL Sources: CH_05_TAX_2127 §§5.2-5.9 · EXHIBIT_B_TAX_MODULES B-1, B-2, B-7, B-9, B-10 · CH_06 §6.8 · CH_08 C-1, C-2, C-5, C-10 Figures verbatim. Derived or unsourced figures do not enter a filing, a pitch, or a conversation with the government as fact.

Chapter 6 · The Discovery Attack

The Five9 Hole, Visualized

Every number below is a live census of the produced corpus, captured 2026-08-27, not an estimate.

Channel 01 — the single best discovery fact in the case

95.510% Channel 01 — absent

Channel 01 is the talk channel, and it is the one that is gone.

Produced timeline talk sitting on a missing channel-01 stamp: 95.510% — 42.736 h of 44.746 h, across 379 of 412 rows. Produced talk on rows whose channel 01 is present: 1.979 h.

This is a dropped channel, not 213,000 missing calls — but on the sales calls the government intends to play, it is absent 100% of the time.

586 stamps / 134.641 MBproduced code-01 files missing overall
135 / 135 — 100%2022 produced code-01 missing
213,401 of 243,541 — 87.624%estate-wide code-01 hole (32.601 GB)

A million-file pile, and what actually opens

1,041,582
Native Five9 WAVs, unhashed / unstamped
0 / 1,041,582 sha256 filled · 0 / 1,041,582 bates_number filled
945
Bates = the literal string “NOT PRODUCED”
69.6% of the 1,357-row victim_timelines table
0 of 1,073
Channels 02–05 fetchable, corpus-wide
Produced files with a fetchable copy on channels 02 through 05
0 of 64
Channels 02–05 fetchable, Count 3’s day
The charged 2020-12-30 date — channels 02 through 05: none fetchable
100%
Sold-call talk on a missing channel 01
17.640 h of 17.640 h · 59 of 59 produced Sold rows

The three absences — tax side

Forms 4183
The trust-fund recommendation documents behind the charged figures.
FTD notices
The government’s own notice evidence on willfulness.
Forms 8655
Dispositive on who authorized the reporting agent to file the Count 27 return.

Bates-log census of the tax production: 559 documents, 8,835 pages. Zero of the above in all of them.

Retention, configuration, and the un-mounted production

The Five9 retention configuration, 2018–2022

Which channels were recorded, which were retained, retention periods by disposition, and every configuration change during the charged window. Nothing in the produced set answers this — it is the only document that will explain whether channel 01 was never collected, was collected and dropped in processing, or aged out. UNVERIFIED whether previously demanded — treat as a new demand

Of 800,600 Five9 objects, 800,068 carry user metadata whose only keys are mtime and, on 38 objects, md5chksum — and those 38 are not even WAV files. There is no call-audio transcript table anywhere in the corpus.

PROD7 — the 8.2 TB handoff, unopened

The seventh production, delivered 7/24/2026 via Box/USAfx, has not been downloaded, indexed, or reconciled against AUSA Dalke’s cover letter. The 8.2 TB transfer and physical disc handover to counsel is likewise open.

Until PROD7 is indexed against the cover letter, no completeness representation to the Court is safe — the absence may be sitting in an un-mounted production. This is the first discovery task, ahead of every motion in this chapter.

The demands, D-1 through D-20

P010 demands
D-1
Index and reconcile PROD7 (7/24/2026, Box/USAfx) against Dalke’s cover letter; complete the 8.2 TB transfer.
DemandCounsel task — precedes everything
D-2
Five9 recording and retention configuration, 2018–2022, with all change history.
DemandRule 16(a)(1)(E)
D-3
The process by which Five9 records were obtained, plus the warrant return for 22-MJ-1897.
DemandRule 16 / Franks track
D-4
All native files for channel 01 on the 631 produced stamps, or a written statement that they do not exist.
DemandRule 16 + Brady
D-5
Working copies of the 27 catalog ghosts and the 1,073 channel-02-through-05 files with no fetchable copy.
DemandRule 16
D-6
A production index / Bates manifest for the 1,041,582-file native batch, with hashes.
DemandRule 16
D-7
All IVR verification and e-sign records for the twelve charged victim calls, including the ¶59 edited recording and its unedited source.
DemandBrady + Rule 16
D-8
The 945 “NOT PRODUCED” recordings, or a category-by-category statement of the basis for withholding.
DemandRule 16 + Brady
D-9
Current-date certified transcripts: MFT 01 EIN 81-2680613; MFT 30 and MFT 55 SSN …5092.
DemandRule 16 / Brady
D-10
Forms 4183, all FTD notices, and all Forms 8655/2848 for the charged entities and quarters.
DemandRule 16
P18 demands
D-11
The government’s loss computation for Counts 21–27 and whether it applied filed ERC claims.
DemandRule 16 / Brady
D-12
The six native Bene 941-X filings in the government’s possession.
DemandRule 16
D-13
Complete methodology for the ¶71 “more than 90%” review: sample frame, protocol, reviewer identities, materiality definition.
DemandFranks / Brady
D-14
Agent notes and all prior versions of the FD-302s of 10/11/2019, 11/19/2021, and 3/9/2022.
DemandRule 26.2 / Jencks
D-15
Giglio on Groff, Walsh, Barrera: plea agreements, sealed supplements ECF 97 / 130 / 142, Rule 35(b) understandings.
DemandBrady / Giglio
D-16
The ten outstanding 902(11) certifications, with a date certain; ripeness objection preserved.
DemandResponse to ECF 147
D-17
Native e-mail threads behind the phone production — 118 native versus ~63 government-captioned fragments — and a strike of prosecutor-authored filenames.
DemandRule 106 / Rule 16
D-18
Written cutoff on supplementation of the ECF 148 Attachment A recording list.
DemandIn limine, 12/7/2026 wave
P22 demands
D-19
Position statement locking Cruz as expert or summary witness before the Rule 1006 charts are built.
DemandRule 16(a)(1)(G) / 702
D-20
Carrier records for the client’s lines, charged period, after the account structure is confirmed.
DemandRule 17(c)
ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL

Chapter 7 — The Cross-Forum War Map

United States v. Redmond and all parallel matters · Board state as of 2026-08-27 · Prepared for Benjamin Brait Cooper, Esq. · Ten forums, one client.
The gate. Discharge cannot enter while AP 25-00254 is pending. FRBP 4004(c)(1)(B). The criminal case is the liberty case. Everything else is collateral fire that can be aimed back at those two.
Forum board — 10 matters
01
Federal criminal
E.D. Pa. 5:24-cr-00376-JLS · Schmehl
Cooper in (ECF 162–164, 8/3/2026); continuance granted (ECF 167/168)
PRETRIAL 11/16/26MIL 12/7/26 · JS 1/11/27 · TRIAL 1/12/27 — confirm from ECF 171 PDF
Liberty
02 · THE GATE
Jordan § 727 — AP 25-00254-PMM
Bankr. E.D. Pa. · Mayer
THE GATE — trial 9/16/26 9:30 PENN4, witness/exhibits 9/2.
At issue, untried, trial set; discovery closed 5/5/2026 (ECF 5 ¶6(a)) — "may be continued only in exceptional circumstances" (¶9). Discharge blocked until resolved.
TRIAL 9/16/26 9:30 PENN4Witness lists + pre-marked exhibits 9/2/26
Gate
03
SBA § 523(a)(2)
4:25-ap-00119-PMM · Mayer
MSJ filed 8/7/26 (ECF 54). Fifth Amendment screen vs criminal.
OPPOSITION 9/3/26pretrial 10/27/26
Collateral
04
Scalia / DOL FLSA
5:20-cv-04265-JLS · Schmehl
Liability decided (ECF 114); damages only. Same judge as criminal.
9/2 vs 9/3 hearingCONFIRM off the notice
Collateral
05
Main bankruptcy — Ch. 7
4:24-bk-13093-PMM · Mayer
Trustee no-distribution report; Ready objects (ECF 554); last continue 8/25/26 (ECF 578). Two exemption amendments UNFILED (Doc 540 ¶2 vehicle, ¶4 watch).
9/22/26 11:00 PENN4ECF 554 hearing
Collateral
06
Jordan § 523 adversary
4:24-ap-00145-PMM · Mayer
SJ won all counts 7/31/25 (Doc 42/43); stayed behind the Gate (ECF 67). Shield — dormant unless AP-254 is lost.
DormantWakes only if AP-254 lost
Collateral
07
Foreclosure — 8 Morgan
Berks CCP 25-13446 · Fudeman
Setley (ours) defending; dismissal rung 8/1/26 per one source, tax sale live per another. Redemption cutoff 9/4.
9/11/26 10:00Upset tax sale
Property
08
Foreclosure — 2 High Rd
Berks (no. unk.) · Fudeman
Athene / US Bank Trust; stay relief BK ECF 454 (9/30/25).
Docket number unresolved
Property
09
Support
Berks 25DR00324 / PACSES 574115910 · Gavin
Stay relief granted 8/19/2025 (BK ECF 427); recusal pending UNVERIFIED.
None verifiedContempt hearing 8/28 1:30, Ctrm 4A
Collateral
10
Jordan state action (remanded)
Berks CCP 22-11757 · UNVERIFIED
Removed as AP 24-00144; remanded 2/11/2025; AP closed 3/6/2025.
Posture UNVERIFIED
Collateral
Deadline horizon — Aug 2026 → Jan 2027
Sep 2026
9/2AP-254 witness lists + exhibits (file)Scalia hrg same day, per matter_master
9/3SBA opposition dueScalia hrg 9/3, per compiled wiki — conflict
9/11Upset tax sale — 8 Morgan / 1198 Reading
9/16AP-254 TRIAL 9:30 PENN4The gate
9/22BK ECF 554 hearing 11:00 PENN4
Oct 2026
10/14Barrera sentencing
10/27SBA pretrial
Nov 2026
11/16Criminal pretrial 10:00, Reading
Dec 2026
12/7MIL / voir dire / instructions / trial memos / verdict slips due
Jan 2027
1/11Jury selection 9:30, Reading
1/12TRIAL 9:30, Reading, 5th floor
hard court date ours to file the gate
Domino order
1Confirm criminal calendar — ECF 167/168/169/171 PDFs, not the live docket or memory patches
2AP-254 gate — 9/2 lists, 9/16 trial
3SBA opposition — 9/3
4BK exemption amendments — vehicle + watch, unfiled
5Everything else
Flags to resolve

BK Doc 540 UNVERIFIED

Working session record states all five provisions ENTERED, none struck — homestead $27,900 and household goods WITH prejudice; vehicle and watch UNVERIFIED WITHOUT prejudice with leave to amend to statutory limits, both amendments unfiled.

The corrections ledger in this input set does not address Doc 540; the "struck three of four" v. "all entered" conflict must be resolved from the native order before anything is filed on it. Pull the native PDF before relying on any provision.

Scalia — 9/2 vs 9/3

Only damages remain before Judge Schmehl, the criminal trial judge, in the same building.

9/2 · 13:30matter_master
9/3 · 14:00compiled wiki

The date conflict is unresolved. Confirm off the notice, not off either table.

Attorney work product · privileged & confidential · not for filing

Offense Lane & Probabilities

Our motions, our theories, our odds — in the order they have to be executed. Everything below is quoted from the pack's own chapters: the Chapter 8 ask list, the T8 theory table, the T14 probability table with reference classes, and the Exhibit B attack-vector ripeness column. Nothing in this chapter promises an outcome. It is a sequence of decisions, in the order they have to be made, and a register of every place this file contradicts itself.

01Filing lane — execution order

Six vehicles, sequenced. Ripeness governs: the chip on each card is the Exhibit B attack-vector ripeness value, and the date chip is the Chapter 8 filing window.

Two disciplines across all ten. Nothing marked as a trial or Rule 29 argument gets pleaded as a pretrial dismissal ground. And every retired theory listed in the Chapter 5 box stays out of every signed paper — the government gets a free correction each time one appears.
Ripeness column governs sequencing. Nothing marked TRIAL should be pleaded as a pretrial dismissal ground — this judge has denied every defence dismissal in the analysed sample.

  1. Rule 7(f) bill of particulars M-1 · Counts 21 and 22  /  M-2 · Count 27, narrowed

    Vehicle Rule 7(f) bill of particulars, Counts 21 and 22; Rule 7(f) particulars, Count 27 — narrowed. Proper name: Insufficiency / bill of particulars (Fed. R. Crim. P. 7(f); Hamling, 418 U.S. 87; Russell, 369 U.S. 749).

    Target State the document and the computation producing $142,665.72 and $143,591.46, which depart from the certified MFT 55 modules on the same page by $83,076.08 and $94,696.23 while Counts 23 and 24 match those modules to the penny. On Count 27 — Identify the derivation of $161,367.95. Ask for the government's computation; do not assert the figure traces to nothing. See C-1.

    Attach: [EX-B1], six-module table (M-1); [EX-B4] (M-2). Strength on the notice vector: 35-55% partial. The reconciling matrix is not in this pack — obtain it before the motion is signed.

    Pretrial 10/15 gate PRETRIAL — filed 17 Jul 2026
  2. Rule 16 / Brady demand M-3 · IVR and e-sign  /  M-4 · the three absences

    Vehicle Brady / Rule 16 demand — IVR and e-sign; Rule 16 / Brady — the three absences. Proper name: Due process / Brady if the freeze and its effect were known to the government (Brady v. Maryland, 373 U.S. 83 (1963); Kyles v. Whitley, 514 U.S. 419 (1995)).

    Target The verification and e-sign records for the twelve charged victim calls, including the ¶59 edited verification recording and its unedited source. The indictment alleges tampering with a verification; the government cannot also treat verification records as immaterial. And — Zero Forms 4183, zero FTD notices, zero Forms 8655 in 559 documents / 8,835 pages.

    Attach: Count 3 completeness row (6.452%), missing types include ivr_verification and esign_live; Bates log as Ex. A. Reverse-risk: LOW if framed as a discovery demand; HIGH if pleaded as misconduct without proof.

    Pretrial Immediate 10/15 gate (M-4) DISCOVERY DEMAND FIRST
  3. Jencks / Rule 26.2 M-7 · agent notes and prior 302 versions

    Vehicle Rule 26.2 / Jencks.

    Target Agent notes and all prior versions of the FD-302s of 10/11/2019, 11/19/2021, 3/9/2022. The 3/9/2022 302 states expressly that the agent's notes were attached — notes demonstrably exist.

    Attach: Disputed-attribution memo. Cross-reference C-9 — RedmondTax004506-07 contains neither charged quote; the quotes are at RedmondTax004504 (p.15:15-17) and RedmondTax004511 (p.22:3-7).

    Pretrial 10/15 gate
  4. Rule 106 — completeness Edited verification recording · channel 01 talk-time

    Vehicle Rule of completeness, run against the government's own audio: no edited exhibit without its unedited source, and no call exhibit without the channel that carries the talk-time.

    Target The ¶59 edited verification recording and its unedited source. Channel 01. Demand the native files, or a written statement that they do not exist. 95.5% of produced call talk-time sits on a channel that was not produced, and on the Sold calls it is 100%. Also the 945 [REDACTED] marked NOT PRODUCED, or a category-level statement of the basis for withholding.

    Attach: The Five9 retention and recording configuration, 2018-2022, with change history — the only document that explains whether channel 01 was never recorded, was dropped in processing, or aged out. Grain discipline per C-7: never mix the denominators in one exhibit; state the grain on the face of every chart.

    Trial Native-file demand now 12/7 wave
  5. Rule 14 severance of Counts 21-27 M-6 · strongest structural move on the tax side

    Vehicle Rule 14 severance / FRE 403 (Fed. R. Crim. P. 14; Fed. R. Evid. 403; Zafiro v. United States, 506 U.S. 534 (1993)).

    Target The tax counts name Redmond alone — no entity, no co-defendant, no cooperator — and the bait-and-switch narrative is not an element of any of them. FRE 403 spillover. Severance keeps greed-and-lifestyle spillover away from willfulness.

    Attach: Zafiro, 506 U.S. 534. STRONGEST STRUCTURAL MOVE ON THE TAX SIDE · reverse-risk LOW.

    Pretrial — file now Pretrial
  6. Giglio — all three co-defendants Ask 3 · item 7 · sealed supplements ECF 97, 130, 142

    Vehicle Giglio demand (Giglio v. United States, 405 U.S. 150 (1972)), carried with the Brady demand at ②.

    Target Giglio on all three co-defendants, including the sealed supplements (ECF 97, 130, 142). All three sentencings now fall before trial, so the reduction-hope cross is gone and Rule 35(b) exposure is the replacement.

    Attach: Sealed supplements ECF 97, 130, 142 — status Unproduced. Whether any cooperation obligation exists at all — no public plea contains a § 5K1.1 or substantial-assistance clause.

    Pretrial All three sentencings now precede trial

02Theories T1-T10

Named, one line each — the T8 table. Hover or focus a card for the line.


03Probability dashboard

T14 — probabilities with reference classes. Solid tick is the point estimate; the bracketed rail is the 90% CI. Two events are stated as ranges rather than a point-plus-CI and are drawn as bands.

Point estimate Stated range (no CI given) 90% CI whisker

  1. All counts dismissed pre-trial 3%

    Reference classBase rate, federal fraud indictments

    90% CI 1–8%
  2. Particulars granted (Cts 21–22 figures) 40%

    Reference classCharged figure traces to no produced record

    90% CI 25–55%
  3. Government drops ≥1 tax count 22%

    Reference classUncharged-quarters + departure pressure

    90% CI 12–35%
  4. Rule 29 on Ct 27 45%

    Reference classNo govt source names him in the duty seat; reporting-agent PIN

    90% CI 30–62%
  5. Brady motion (IVR/eSign) granted 75-85%

    Reference classGroff plea confirms bait-and-switch narrative needs the verification layer

    90% CI —
  6. Franks hearing granted 45-55%

    Reference class¶7/¶71 record; needs affidavit analysis finished

    90% CI —
  7. Tax Court favorable pre-trial signal 30%

    Reference class9/9 status report pressure point

    90% CI 15–45%

04Ask Benjamin — execution order

Chapter 8, in sequence. Until this is confirmed, nothing else in this chapter should be executed — Ask 1 gates the rest.

  1. 1

    Ask 1Confirm the trial calendar, in writing, before anything else

  2. 2

    Ask 2The motions lane

  3. 3

    Ask 3Discovery, in priority order

  4. 4

    Ask 4The two unfiled bankruptcy exemption amendments

  5. 5

    Ask 5The Fifth Amendment screen for the SBA opposition

Filing to the wrong calendar defaults in either direction. Whether ECF 167 ¶8 sets a 10/15/2026 gate for defense motions. Every motion schedule in this pack assumes that paragraph exists. It is [UNVERIFIED] and it is load-bearing. And on discovery: Index PROD7 (delivered 7/24/2026 via Box/USAfx) against Dalke's cover letter, and finish the 8.2 TB transfer. This precedes every motion in §8.2 — it is also the government's first answer to any of them.


05Contradictions register — C-1 to C-20

We audit ourselves first.

Everything below is a conflict inside this file. Each one is a place where a signed filing could be corrected by the government using our own material. Open a row for the resolution. Corrections are kept visible on purpose.

C-1Count 27's figure "matches no ledger" and "traces to no produced record" (element matrix A9) versus the controlling corrections ledger, which retires that claim because a derivation matrix reconciles Count 27 exactly, to the penny

ResolutionCorrections ledger controls. Do not plead untraceability on Count 27. Narrow M-2 to "state your derivation." The reconciling matrix is not in this pack — obtain it before the motion is signed. The surviving particulars target is Counts 21 and 22

C-2The $500,000 payment of 8/8/2023 versus identifiable 8/8/2023 postings totalling roughly $324,708.84 across four modules

ResolutionReconcile the figure before it appears anywhere. The demand for current-date transcripts is unaffected — the point is that no certified transcript in the production shows any 8/8/2023 activity

C-3Thayer cited for "no tax-due-and-owing element" versus the finding that the proposition is not locatable in the opinion and that Thayer is adverse and controlling

ResolutionCite Thayer only for the disjunctive account-or-pay-over holding. Source the no-amount-element point to DOJ CTM § 9.03 and Citron. Verify the pin cite before filing

C-4Client instruction of 8/11/2026 retiring wrong-responsible-person as a merits theory versus the 8/16/2026 Count 27 matrix built on a contested duty element with P(Rule 29) = 45%

ResolutionBoth survive if the argument is run as Rule 29 sufficiency from the government's own four sources, never as an affirmative "someone else was responsible" defense. Cooper's call, and it should be made explicitly

C-5Counts 21 and 22 "certified balance $0.00" versus 8/2023 module balances of $398,798.03 and $302,122.74

ResolutionBoth true — MFT 55 civil-penalty module versus MFT 01 employer module. Say "the parallel § 6672 module was collected to zero." Never say "the count is paid"

C-6One workbook tab holds that the Smith letter's own arithmetic defeats its conclusion; another tab in the same workbook holds that reading was wrong and the full letter reconciles through the $364,169.39 balance

ResolutionThe fuller reading controls, but the native letter and its schedule are still missing. Do not put the netting argument in front of a jury on a transcription

C-7Five9 denominators: 1,100,000 / 853,000 filtered / 247,000 substantive / 23 victim calls (analyst cut) versus 1,041,582 native files / 1,337 proof rows / 408 produced (database census)

ResolutionDifferent objects, different grains. Never mix them in one exhibit. State the grain on the face of every chart

C-8Third Circuit Model Instruction "6.18.1349," cited across prior artifacts

ResolutionIt does not exist. § 1349 runs through the § 371 series. Confirmed numbers: 6.18.1343, 6.18.371H, 7.03 (Pinkerton), 5.06 (willful blindness), 5.07 (good faith — not available on the tax counts), 4.19

C-9Prior artifacts cite RedmondTax004506-07 as the source of the ¶72 charged testimony

ResolutionThat range contains neither charged quote; it is the CPA payroll-advice passage. The quotes are at RedmondTax004504 (p.15:15-17) and RedmondTax004511 (p.22:3-7) — seven pages and roughly two years of subject matter apart, and the second is prefaced "I can't recall" and hedged "I imagine"

C-10Kwong Form 843 protective claims: 11 claims filed 7/10/2026 with a FedEx tracking number versus "the July 10 deadline was missed for all five taxpayers"

ResolutionDirect conflict, and it is load-bearing — contemporaneous compliance is one of four supports for the Cheek good-faith showing. Resolve before that support is argued

C-11Criminal trial date: 9/14-15/2026 versus 1/11-12/2027

ResolutionSee §8.1. Unresolved until the PDFs are read

C-12Doc 540 treated as five provisions entered with an OCR-artifact strikethrough versus the record that the objection was sustained without prejudice as to 2005 Regency Drive and two vehicles

ResolutionThe controlling corrections ledger does not address Doc 540 at all. Read the imaged order before either amendment is filed

C-13The wristwatch identified as a Cartier, and the client's carrier account described as four lines

ResolutionNeither appears in any source document in this pack. Both are [UNVERIFIED] and must be confirmed with the client

C-14"ERC zeroes six of seven counts" / "$1,576,093.06 of ERC was filed" versus the record

ResolutionOverclaim and unsourced. Statutory ERC wages run 3/13/2020-9/30/2021; only $31,542.61 is IRS-labeled anywhere, and it is already netted into Count 25. Retire the $1.576M figure unless the six 941-X filings support it

C-15Kwong / § 7508A(d) as a merits defense versus the covered-acts analysis

ResolutionEmployment-tax deposits are outside the default postponement, and Kwong is a duration case, not a scope case. Willfulness corroboration and the civil refund track only

C-16Vindictive prosecution as a presumption on the superseder

ResolutionForeclosed for pretrial charge increases by Goodwin, 457 U.S. 368. P(dismissal) 3-5%. Keep the timeline as narrative pressure

C-17Ciminelli right-to-control attack

ResolutionForeclosed by Kousisis v. United States, 145 S. Ct. 1382 (2025). Retired

C-18AP-254 count list: docket nature-of-suit codes list § 523(a)(4) and (a)(6) versus a complaint pleading six § 727 counts

ResolutionThe complaint controls

C-19Groff sentencing 4/23/2026 (in an older conversation) versus 11/6/2026

Resolution11/6/2026. All three sentencings now precede trial

C-20Count 26's 1/10/2022 letter predicting the IIJA shortfall to the IRS

Resolution[UNVERIFIED until Bates.] Do not cite it as a contemporaneous good-faith act until the document is located

Sources: CH_08 §§8.1–8.8 · T00 T8 theories · T00 T14 probabilities · EXHIBIT B B-5 attack vectors · 6 motion cards · 10 theory cards · 7 probability bars · 20 contradictions

Attorney Work Product — Privileged

Exhibits Gallery

Five exhibit workbooks, reproduced verbatim, shelved for quick reference. Each card opens to the exhibit's key table only — the full workbook carries additional tabs not reproduced here. Source: USA v. Redmond, No. 5:24-cr-00376-JLS (E.D. Pa.) · Benjamin Cooper Wiki · Exhibit Appendix.

EX-A

Count Matrix, Wire Table & Wiring Zero

Fixes the element-kill status of all 27 superseding counts against the government's own theory, count by count. Proves Redmond is the charged speaker on zero of the 12 customer-call wire counts.

27 rowsSource: CHARGE_BOOK.xlsx
Open EX-A — COUNT_MATRIX (27 rows)
A-1. COUNT_MATRIX — all 27 superseding counts (verbatim; blank cells render as —)
CountStatuteTitleNamed defsWindow / dateAmountGov theory (short)Defense wedgeKill statusCooperator pled?Alan on the communication?CiteUNVERIFIED hole
118 USC 1349Conspiracy to commit wire fraudAll six2018-01-01 to 2022-12-02Agree to bait-and-switch Limited Benefit Plans as Major Medical / equivalent; interstate wiresScope/duration of Alan's membership; script vs closer (¶28); no Alan consumer-call voiceNOT OVERCOME — Groff+Walsh admitted Count 1Groff + Walsh YES; Barrera UNVERIFIEDN/A (agreement, not a single wire)Doc 16 ¶17; Doc 96-1 ¶1; ECF 126Barrera counts; sealed 97/130
218 USC 1343Wire — training emailAll six2020-06-23Alan email: train closers with fraudulent tactics; combat 'not insurance' disclaimer (OA16)Authenticity/Rule 106; product-category explanation vs instruction to lie; not a consumer statementNOT OVERCOME — Alan is the author. Worst email count.NoYES senderDoc 16 Count 2; OA16Native email
318 USC 1343Wire — cancel call L.F. CAAll six2020-12-30Unnamed Bene rep misled L.F. on attempted cancellationAlan not on call; no quoted lie; retention vs originationNOT OVERCOME — weakened (unnamed, no quote)NoNODoc 16 Count 3WAV + specific false statement
418 USC 1343Wire — agents list emailAll six2021-01-10Assigned non-selling licenses to unlicensed agentsAlan is recipient not author; license ≠ 1343 without purchaser materialityNOT OVERCOME as furtherance; weakened as consumer fraudNoRECIPIENTDoc 16 Count 4; ¶14(s) ¶15(e)Spreadsheet native
518 USC 1343Wire — unlicensed closer P.G. FLAll six2021-01-20Unlicensed closer fraudulent solicitation / half-truthsUnlicensed ≠ false; Alan not on call; need tape vs script vs verificationNOT OVERCOMENoNODoc 16 Count 5WAV; license proof
618 USC 1343Wire — pull Groff callsAll six2021-04-21Walsh to Alan: Barrera will pull Groff calls for new-agent trainingNot a consumer lie; furtherance = training on alleged deceptive callsNOT OVERCOME — Walsh pled Count 6WALSH YESRECIPIENTDoc 16 Count 6; ECF 126The Groff training calls themselves
718 USC 1343Wire — KISS PrinciplesAll six2021-04-27Alan forwards Walsh + misleading KISS brochure for selling Limited Benefit PlansRead the brochure: incomplete vs false; Alan is senderNOT OVERCOME — Walsh pled Count 7WALSH YESYES senderDoc 16 Count 7; ECF 126KISS PDF
818 USC 1343Wire — 2000 SMS copyAll six2021-05-25Barrera email with texts falsely claiming 'national enrollment center for health insurance'Did texts send; who approved; trade name vs government-sounding baitNOT OVERCOME — quoted falsehood is cleanNoRECIPIENTDoc 16 Count 8; ¶14(h) ¶27SMS vendor logs
918 USC 1343Wire — closer B.B. DEAll six2021-07-27Closer fraudulent solicitation / half-truths (no quote)Alan not on call; unnamed closer; PinkertonNOT OVERCOMENoNODoc 16 Count 9WAV + quote
1018 USC 1343Wire — Groff P.L. MDAll six2021-08-18Groff fraudulent solicitation / half-truthsAlan not on call; ¶28 off-script vs Groff; Pinkerton is the Alan theoryNOT OVERCOME as to Groff; not killed as to AlanGROFF YES Doc 96-1NODoc 16 Count 10; Doc 96-1 ¶1WAV
1118 USC 1343Wire — closer T.M. MEAll six2021-09-02Closer fraudulent solicitation / half-truths (no quote)Alan not on call; unnamedNOT OVERCOMENoNODoc 16 Count 11WAV + quote
1218 USC 1343Wire — Barrera R.S. RIAll six2021-10-23Barrera (SVP) fraudulent solicitation / half-truthsAlan not on call; manager-on-phone optics worse; Barrera plea counts unreadNOT OVERCOMEBarrera UNVERIFIEDNODoc 16 Count 12; ECF 138Barrera plea PDF; WAV
1318 USC 1343Wire — Groff E.T. TX (for G.T.)All six2021-11-17Groff solicited E.T. for husband G.T.Alan not on call; third-party insured issues on tapeNOT OVERCOME as to GroffGROFF YESNODoc 16 Count 13; Doc 96-1WAV
1418 USC 1343Wire — Groff L.R. NYAll six2021-12-11Groff fraudulent solicitationAlan not on callNOT OVERCOME as to GroffGROFF YESNODoc 16 Count 14; Doc 96-1WAV
1518 USC 1343Wire — Walsh R.C. MAAll six2022-01-03Walsh (COO) fraudulent solicitationAlan not on call; COO voice = companyNOT OVERCOME — Walsh pledWALSH YESNODoc 16 Count 15; ECF 126WAV
1618 USC 1343Wire — Walsh J.S. CAAll six2022-01-03Walsh fraudulent solicitation (same day as 15)Alan not on callNOT OVERCOME — Walsh pledWALSH YESNODoc 16 Count 16; ECF 126WAV
1718 USC 1343Wire — Groff A.C. ME + spouseAll six2022-01-24Groff fraudulent solicitation of A.C. and spouseAlan not on callNOT OVERCOME as to GroffGROFF YESNODoc 16 Count 17; Doc 96-1WAV
1818 USC 1343Wire — Groff D.P. NY post-saleAll six2022-02-22Misrepresentations on a plan sold to spouse 2022-01-28 (not origination)Post-sale furtherance still Schmuck-viable; Alan not on callNOT OVERCOME as to GroffGROFF YESNODoc 16 Count 18; Doc 96-1WAV
1918 USC 1343Wire — Walsh control emailAll six2022-06-07Walsh confirms Alan order: nothing external without Alan approval. ZERO.Control/concealment not a consumer lie; proves Alan still ran Seguro (gov nominee theory)NOT OVERCOME as furtherance; WEAKENED as victim-falsehoodWALSH YESSUBJECT of instruction; Walsh senderDoc 16 Count 19; ECF 126Full email chain
2018 USC 1343Wire — Barrera same control emailAll six2022-06-07Barrera repeats the same Alan instruction to senior managementMultiplicity with 19 [THEORY]; Barrera senderNOT OVERCOME if 19 survives; weakened standing aloneNoSUBJECT of instruction; Barrera senderDoc 16 Count 20Whether Barrera pled this
2126 USC 7202Fail to pay over TF — Bene Q2-2019Redmond onlyQ 2019-06; 941 due 2019-07-29/31142665.72Responsible person willfully failed to pay over trust fundCharged figure matches NEITHER 4183 nor TC240 (untraceable). Module later $0. Thayer: due-date failure still lives.AMOUNT unexplained = BOP gold. Balance-zero WEAKENS loss. Element NOT killed.N/AN/A (tax)Doc 16 tax table; public.tax_counts Ct21 GOLD-SEENEFTPS full set; BOP derivation
2226 USC 7202Fail to pay over TF — Bene Q3-2019Redmond onlyQ 2019-09; due 2019-10-30/31143591.46SameCivil module PAID IN FULL $0. Two in-period deposits. $94k civil/criminal figure gap.STRONGEST payment count. NOT a legal acquittal of 10/30/19 failure.N/AN/AHandoff; tax_counts Ct22; CVPN p.2None material on payment; Thayer still applies
2326 USC 7202Fail to pay over TF — Bene Q4-2019Redmond onlyQ 2019-12; 941 2020-01-30228125.75Same; figure matches 4183 AND TC240Payments ~$126k; remaining certified $102,693.09. Honest weak point on the number.NOT OVERCOMEN/AN/ADoc 16; tax_counts Ct23; HandoffERC N/A (2019)
2426 USC 7202Fail to pay over TF — Bene Q1-2020Redmond onlyQ 2020-03; due 2020-04-29/30188953.17Same; equals TC240 misc penalty 6/13/22 on personal transcript'6672≠7202' RETIRED. No payments on module. ERC eligibility UNVERIFIED computation.NOT OVERCOME. Gross-vs-net is loss/willfulness, not missing element.N/AN/ATARGETS smoking gun; tax_counts Ct24Smith ERC worksheet
2526 USC 7202Fail to pay over TF — Bene Q4-2020Redmond onlyQ 2020-12; 941 2021-01-30149298.17Same0-HIT THESIS RETIRED. Figure = TF minus refundable ERC $31,542.61 on filed 941 (GJ Ex 5). Reporting Agent PIN not Alan wet-sign.Figure existence NOT killed. ERC already inside the charged number.N/AN/Atax_counts Ct25; GJ Ex 5 Bates RedmondTax005570-77Do not file 0-hit language. SOL memo if anyone still wants it.
2626 USC 7202Fail to pay over TF — Bene Q4-2021Redmond onlyQ 2021-12; 941 2022-01-31216046.20Same'Assessed 2/21/2025 post-indictment' RETIRED (TC150 02-21-2022). Fidalgo-scope + IIJA ERC repeal arguments survive.NOT OVERCOME. 'Never assessed' is false.N/AN/Atax_counts Ct26; CVPN p.41/10/2022 prediction letter Bates
2726 USC 7202Fail to pay over TF — Seguro Q2-2022Redmond onlyQ 2022-06; due 2022-07-31161367.95Same; Seguro entityCharged matches NEITHER TC150 $270,986.20 nor balance $236,140.44. RP merits theory RETIRED (Alan 8/11/26). Signature/INOLES for impeachment only.Amount untraceable = BOP. RP NOT a merits kill.N/AN/ADoc 16; tax_counts Ct27; INOLES Bates RedmondTax007738Form 8655; OA; bank cards

Full workbook (not reproduced above): A-2 WIRE_TABLE and A-3 WIRING_ZERO tabs, `CHARGE_BOOK.xlsx`.

EX-B

Tax Modules, Counts 21–27

Reconciles the seven charged tax counts against IRS transcript modules, ERC claims, and signature status. Isolates the two counts where the criminal figure does not match the civil trust-fund assessment.

7 + 2 rowsSource: TAX_ATTACK_V4.xlsx
Open EX-B — COUNTS_MASTER + B-9 gap table
B-1. 01_COUNTS_MASTER — tax counts 21-27 as charged (verbatim; blank cells render as —)
CtQuarterEntityCharged $Form 941 Due (Date of Offense)In original Doc.1 (10/17/24)?Inside Kwong window 1/20/20-7/10/23?Signature status on the charged 941Module balance 8/2023
212019 Q2Bene Market142665.7229 Jul 2019YESNO — pre-windowSIGNED by Redmond, title 'Member'398798.03
222019 Q3Bene Market143591.4630 Oct 2019YESNO — pre-windowNot established in record reviewed302122.74
232019 Q4Bene Market228125.7530 Jan 2020YESYESNot established in record reviewed366602.12
242020 Q1Bene Market188953.1729 Apr 2020YESYESNot established in record reviewed320394.26
252020 Q4Bene Market149298.1730 Jan 2021YESYESREPORTING AGENT PIN — blank signature140548.59
262021 Q4Bene Market216046.231 Jan 2022YESYESNot established in record reviewed349940.38
272022 Q2Seguro Medico161367.9531 Jul 2022NO — ADDED in supersedingYESREPORTING AGENT PIN — BLANK. Bates RedmondTax007241Seguro TC150 $270,986.20 filed 8/22/22

Charged total Cts 21-27 = $1,230,048.42. Source: ECF 16 Counts 21-27 table at p.42; Doc.1; BENEZERO transcript read (8/2023 pull); Bates RedmondTax007239-007250.

B-9. Counts 21 and 22 — civil assessment versus criminal charge (verbatim)
CountEntityQuarterCharged $ criminal (verbatim)TC240 civil assessed $ (verbatim)Gap $ (computed)Charged matches 4183?Gross vs net (verbatim)
21Bene Market LLC2019-Q2 (2019-06)142665.72225741.883,076.08NOCharged is unexplained slice of TF; TC670 -242772.61 later zeroes module
22Bene Market LLC2019-Q3 (2019-09)143591.46238287.6994,696.23NO — $94,696.23 civil vs criminal gapCriminal ≈ TF minus deposits; civil TC240 includes more

Full workbook (not reproduced above): B-2 TRANSCRIPT_LEDGER, B-3 ERC_LEDGER, B-4 ELEMENT_DEFENSE, B-5 ATTACK_VECTORS, B-6 SIGNATURE_MATRIX, B-7 PAYMENTS, B-8 EVIDENCE_GAPS, B-10 uncharged quarters — `TAX_ATTACK_V4.xlsx` tabs 01–09.

EX-C

Superseding Indictment & IVR Defense

Maps the verification-call (IVR/eSign) record against every customer-call wire count. Where the recorded verification would contradict the agent's alleged pitch, informed consent may survive the count regardless of what the agent said.

11 rowsSource: SUPERSEDING.xlsx
Open EX-C — IVR DEFENSE MAP (11 rows)
C-3. IVR DEFENSE MAP — customer-call counts vs verification record (verbatim)
CountCall DateAgentVictimStateAgent Claim (Fraud Alleged)IVR/Verification Would DiscloseDefense TheoryIVR StatusKill Shot?
501/20/21Unlicensed closerP.G.FL"Not supplemental" / "full major medical""Not ACA compliant" / "Limited benefit plan" / plan limitationsIf P.G. acknowledged IVR, informed consent exists despite agent liesNEED TO VERIFYPOSSIBLE
907/27/21Unknown closerB.B.DE"Government stamp of approval" / "ACA policy""Not ACA compliant" / plan limitationsIVR directly contradicts agent. B.B. acknowledged disclosures.NEED TO VERIFYPOSSIBLE
1008/18/21GROFFP.L.MD"Covered day one dollar one" / told to skip verificationFull disclosure of limitationsGroff told P.L. to skip. KEY: did P.L. still complete IVR?NEED TO VERIFYHIGH if completed
1109/02/21Unknown closerT.M.MEMaternity covered / "$50/visit" / "birth is nothing"Plan limitations / exclusionsIf IVR disclosed limitations, T.M. was informed despite agent claimsNEED TO VERIFYPOSSIBLE
1210/23/21BARRERAR.S.RIFake ACA history / "$20 copay no bill""Not ACA compliant" / actual copay structureIVR contradicts Barrera fabricationNEED TO VERIFYPOSSIBLE
1311/17/21GROFFE.T.TXListed 5 Major Medical carriers / "$350 then 100%"Plan limitations / actual coverageCHECK: was this UHC major medical? If yes, count collapses entirely.NEED TO VERIFYHIGH if UHC
1412/11/21GROFFL.R.NY"Comprehensive Major Medical" / "$80K cornea for $350" / "no cap""Not major medical" / caps and limitationsIVR directly contradicts ALL of Groff's claimsNEED TO VERIFYHIGH
1501/03/22WALSHR.C.MA"Largest enrollment center" / "99.9% accept this plan"Plan limitations / network restrictionsIVR would show actual network and coverage limitationsNEED TO VERIFYPOSSIBLE
1601/03/22WALSHJ.S.CATold to "keep pressing 1" on verificationFull disclosuresJ.S. DID press 1 = J.S. acknowledged each disclosure. Walsh instruction actually ENSURED completion.NEED TO VERIFYHIGH — ironic
1701/24/22GROFFA.C.ME"Full-fledged Major Medical" / "$120K cornea for $350" / "ignore verification"Full disclosure of limitationsGroff told A.C. to ignore. KEY: did A.C. still complete IVR?NEED TO VERIFYHIGH if completed
1802/22/22GROFFD.P.NYDoctor said limited. Groff said doctor "wrong."Original IVR from 01/28/22 salePost-sale call. Original IVR from spouse sale would show disclosed limitations.NEED TO VERIFYMODERATE

Full workbook (not reproduced above): C-1 COUNT MAP (27 counts), C-2 GROFF PLEA ANALYSIS, C-4 ORIGINAL vs SUPERSEDING, C-5 WIRE FRAUD CLASSIFICATION, C-6 PROBABILITY DASHBOARD, C-7 CRITICAL FINDINGS, C-8 72 OVERT ACTS MAP — `SUPERSEDING.xlsx`.

EX-D

Legal Artifact Index

Indexes the full legal-slice corpus by relevance to this defense — what exists, where it lives, and its priority for native re-pull. Every path resolves inside the corpus bucket.

20 of 308 matched (1,531 total)Source: _INDEX.xlsx
Open EX-D — category totals + top-20 artifacts
D-2. Filter-matched artifacts by category (verbatim)
CategoryMatched artifacts
Spreadsheets109
Filings & PDFs94
Web/Dashboards32
Memos & Notes28
Word Docs20
Archives13
Code8
Data4
TOTAL308
D-1. Top 20 legal artifacts by relevance (of 100 ranked; verbatim)
RankScoreKeywordsArtifact nameCategorySize (KB)Source conversationConv date
111REDMOND+DISCOVERYUS_v__Redmond__24-cr-376__Seventh_Discovery_Production.pdfFilings & PDFs219.6Legal docket strategy and motion filings2026-07-21
211REDMOND+DISCOVERYRedmond_Pro_Se_Discovery_Letter_7th_production_7_24_26.pdfFilings & PDFs194.3Legal docket strategy and motion filings2026-07-21
311REDMOND+WAR_ROOMREDMOND_WAR_ROOM_MASTER_WORKBOOK.xlsxSpreadsheets65.7Evidence ledger creation and legal categorization ^archived2026-04-14
411REDMOND+WAR_ROOMREDMOND_WAR_ROOM_TRACKER_V4_20260721.xlsxSpreadsheets58Legal docket strategy and motion filings2026-07-21
511REDMOND+WAR_ROOMREDMOND_WAR_ROOM_TRACKER_V3_20260721.xlsxSpreadsheets39.1Legal docket strategy and motion filings2026-07-21
611REDMOND+WAR_ROOMREDMOND_WAR_ROOM_TRACKER_V2_20260721.xlsxSpreadsheets31.7Legal docket strategy and motion filings2026-07-21
711REDMOND+WAR_ROOMREDMOND_WAR_ROOM_TRACKER_V1_20260721.xlsxSpreadsheets25.4Legal docket strategy and motion filings2026-07-21
810REDMOND+DISCOVERYUSA_v_Redmond_Discovery_INDEX_v11.xlsxSpreadsheets25393.13 motions2026-07-17
910REDMOND+TAXREDMOND_TAX_MASTER_V5_MERGED.xlsxSpreadsheets126.6Full docket timeline/and supa org2026-04-08
1010REDMOND+WAR_ROOMREDMOND_WAR_ROOM_MASTER_DOSSIER_2026_03_16.docxWord Docs49.1Complete project documentation and timeline export2026-03-16
1110REDMOND+TAXREDMOND_TAX_COUNTS_ATTACK_MATRIX_V4.xlsxSpreadsheets48.8Full docket timeline/and supa org2026-04-08
1210REDMOND+TAXREDMOND_TAX_COUNTS_ATTACK_MATRIX_V3.xlsxSpreadsheets43.9Full docket timeline/and supa org2026-04-08
1310REDMOND+TAXREDMOND_TAX_COUNTS_ATTACK_MATRIX_V2.xlsxSpreadsheets39.8Full docket timeline/and supa org2026-04-08
1410REDMOND+TAXREDMOND_TAX_COUNTS_ATTACK_MATRIX_V1.xlsxSpreadsheets32Full docket timeline/and supa org2026-04-08
1510REDMOND+DISCOVERYREDMOND_DISCOVERY_INDEX_v1.xlsxSpreadsheets31.6Time to WIN convo2026-05-25
1610REDMOND+DISCOVERYUSA_v_Redmond_Discovery_Workbook_v4_33bd4883.xlsxSpreadsheets18FIND CRIMINAL ATTORNEY2026-07-02
1710REDMOND+DISCOVERYUSA_v_Redmond_Discovery_Workbook_v4_3b9d6825.xlsxSpreadsheets16.73 motions2026-07-17
1810REDMOND+DISCOVERYUSA_v_Redmond_Discovery_MASTER_v3.xlsxSpreadsheets11.7Recreating Dalke's discovery log in Excel2026-06-28
1910REDMOND+DISCOVERYUSA_v_Redmond_Discovery_Index_v1.xlsxSpreadsheets10.9Recreating Dalke's discovery log in Excel2026-06-28
2010REDMOND+DISCOVERYUSA_v_Redmond_Discovery_Index_v2.xlsxSpreadsheets10.9Recreating Dalke's discovery log in Excel2026-06-28

Rows 21–100 of the ranked list, D-3 keyword totals, D-4 full 1,531-artifact category/file-type totals, and D-5 by-conversation breakdown are not reproduced above — see `_INDEX.xlsx` tabs ARTIFACTS and BY CONVERSATION. Path column omitted from this shelf view; all paths root at extracted-artifacts/<type>/.

EX-E [VERIFY] template

Element Shape — Count→Element Matrix

Breaks every count into its legal elements against a pre-marked D-series exhibit list for incoming trial counsel. A shape asset, not an evidentiary one — every amber cell is an unfilled placeholder, not a fact of record.

14 rowsSource: Dossier_ElementMatrix_ExhibitList_v1_7-11-26_1102pm.xlsx
Open EX-E — ELEMENT MATRIX sample (14 of 14 rows)
E-1. ELEMENT MATRIX — Count → Elements → Government Evidence → Defense Answer → Bates (verbatim; amber = [VERIFY])
CountCharge / Statute [VERIFY]Legal elements (gov't must prove each)Government evidence [VERIFY]Defense answer [VERIFY]Bates / exhibit [VERIFY]
COUNT 1 — CONSPIRACY (18 U.S.C. §1349, conspiracy to commit wire fraud) [VERIFY subsection]
1§1349 conspiracy [VERIFY](1) An agreement between two or more persons to commit wire fraud[VERIFY: gov't proof of agreement — emails, testimony, Groff cooperation][VERIFY: no knowing agreement / lawful business relationship / mere association ≠ conspiracy][VERIFY Bates]
1(2) The defendant knowingly and voluntarily joined the agreement[VERIFY: gov't evidence of knowing participation][VERIFY: lack of knowledge / no intent to join / withdrawal][VERIFY Bates]
1(3) One conspirator committed an overt act in furtherance (if required)[VERIFY: alleged overt acts in indictment][VERIFY: challenge each overt act / not in furtherance][VERIFY Bates]
COUNTS 2-20 — WIRE FRAUD (18 U.S.C. §1343) · 19 counts · each count = one wire transmission [VERIFY each]
2-20§1343 wire fraud [VERIFY](1) A scheme to defraud / obtain money by materially false pretenses[VERIFY: the alleged scheme as charged per count][VERIFY: no scheme / good-faith belief / legitimate business / puffery not fraud][VERIFY Bates per count]
2-20(2) Defendant's knowing and willful participation with intent to defraud[VERIFY: intent evidence — Five9 call data, emails per count][VERIFY: no fraudulent intent / good faith / reliance on counsel or others][VERIFY Bates]
2-20(3) Use of interstate wire communication in furtherance of the scheme[VERIFY: the specific wire per count — call, email, transfer][VERIFY: wire not in furtherance / de minimis / not caused by defendant][VERIFY Bates per count]
2-20(4) Materiality — the false statement was capable of influencing[VERIFY: what gov't says was material per count][VERIFY: immaterial / not relied upon / true when made][VERIFY Bates]
FIVE9 ANGLEDefense reasonable-doubt spine (per defense analysis, [VERIFY against produced data]): duration profile of produced call data — a large share of calls under 10s / under 60s — placed against the government's fraud-call theory. Volumes 1-5 reportedly produced empty; only Vol 6 contained data → Brady/Rule 16.
COUNTS 21-27 — TAX (26 U.S.C. — subsection [VERIFY: §7201 evasion / §7206 false return / §7203]) · 7 counts
21-2726 U.S.C. §[VERIFY](1) A tax deficiency / additional tax due and owing [if §7201][VERIFY: gov't computation of deficiency per year/count][VERIFY: no deficiency / correct return / good-faith reliance on CPA (Malcolm Smith)][VERIFY Bates]
21-27(2) An affirmative act of evasion, OR a materially false return [if §7206][VERIFY: the act/false entry alleged per count][VERIFY: no affirmative act / not false / disclosed / amended][VERIFY Bates]
21-27(3) Willfulness — voluntary, intentional violation of a known legal duty[VERIFY: gov't willfulness evidence][VERIFY: no willfulness / reliance on professional / complexity / good faith][VERIFY Bates]

Table shows all 14 rows in the source tab — fewer than 15 exist. Full workbook (not reproduced above): E-2 PRE-MARKED EXHIBIT LIST (D-1 through D-12), E-0 workbook README, E-3 usage notes — `Dossier_ElementMatrix_ExhibitList_v1_7-11-26_1102pm.xlsx` (Supabase Storage, pulled 2026-08-27).

Crop shelf

Named exhibit crops confirmed in the corpus. Bucket references only — not embedded below; pull the file at the listed path before use in any filing.

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EX_75k_ticket.png
legal-slice/knowledge-files/EX_75k_ticket.png

The $75,000 DDA debit memo, RedmondTax005618 — Sardella phone request.

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EX_Ct26_jurat_p32.png
legal-slice/knowledge-files/EX_Ct26_jurat_p32.png

EUP Return Tree 202112: PIN Entered By REPORTING AGENT / jurat REPORTING AGENT PIN, designee C Malcolm Smith III CPA.

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EX_NBOA_2015_p4.png
legal-slice/knowledge-files/EX_NBOA_2015_p4.png

RedmondTax008330: the six-month 2015 reversal/transfer sequence, all pairs legible.

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