Debra Parris Edwards, John Tufts' Mom's Federal Plea Deal Nov 17th 2021 22 Pages

Case: 1:20-cr-00424-JG Doc #: 100 Filed: 11/24/21 1 of 22.
PageID #: 1445
1
1 UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF OHIO
2 EASTERN DIVISION
3 ------------------------------X
UNITED STATES OF AMERICA, : Case No. 1:20-cr-00424
4 : Cleveland, Ohio
Plaintiff, :
5 :
v. : Wednesday, November 17, 2021
6 : 1:15 p.m.
DEBRA PARRIS, :
7 :
Defendant. :
8 ------------------------------X
9
[Proceedings held via Zoom videoconference)
10
11
12 TRANSCRIPT OF CHANGE OF PLEA PROCEEDINGS
13 BEFORE THE HONORABLE JAMES S. GWIN
14 SENIOR UNITED STATES DISTRICT JUDGE
15
16 Court Reporter: Donnalee Cotone, RMR, CRR, CRC

Realtime Systems Administrator
17 United States District Court
801 West Superior Avenue
18 Court Reporters 7-189
Cleveland, Ohio 44113
19 216-357-7078
donnalee_cotone@ohnd.uscourts.gov
20
21
22
23
24 Proceedings recorded by mechanical stenography, transcript
25 produced by computer-aided transcription.

Case: 1:20-cr-00424-JG Doc #: 100 Filed: 11/24/21 2 of 22. PageID #: 1446
2
1 APPEARANCES:
3 For the Government: CHELSEA S. RICE,

Assistant United States Attorney
4 801 West Superior Avenue
Suite 400
5 Cleveland, Ohio 44113
216-622-3600
6 chelsea.rice@usdoj.gov
7
For the Government: JASON M. MANNING
8 U.S. Department of Justice, Criminal
Division
9 1400 New York Avenue, N.W., Suite 600
Washington, DC 20005
10 202-514-6256
jason.manning@usdoj.gov
11
12 For the Defendant: BRET E. MARTIN, ESQ.

Law Offices of Bret E. Martin
13 P.O. Box 93565, Suite 100
Southlake, Texas 76092
14 214-505-2168
bretmartinatty@gmail.com
15
16
17
18
19
20
21
22
23
24
25
3
1 AFTERNOON SESSION. WEDNESDAY, NOVEMBER 17, 2021
2 (Proceedings commenced at 1:15 p.m.)
3 - - -
4 THE COURT: And, Ms. Parris, can you hear us?
5 THE DEFENDANT: Yes, sir.
6 THE COURT: And do you consent to have this
7 hearing go forward using videoconference?
8 THE DEFENDANT: Yes. Yes, sir.
9 THE COURT: I'll ask you -- I'll find the
10 defendant's consented to the videoconference, and I'll find
11 the ends of justice support using it.
12 I'd ask the defendant to raise her right hand.
13 (Defendant sworn.)
14 THE COURT: Tell us your name, and tell us how
15 you spell your last name.
16 THE DEFENDANT: Debra Parris. P-A-R-R-I-S.
17 THE COURT: How old are you?
18 THE DEFENDANT: 69.
19 THE COURT: How far did you go in school?
20 THE DEFENDANT: Third year of college.
21 THE COURT: Can you read and understand
22 English?
23 THE DEFENDANT: Yes.
24 THE COURT: Are you a United States citizen?

4
1 THE COURT: Are you right now under the
2 influence of alcohol or drugs?
3 THE DEFENDANT: No.
4 THE COURT: Have you had any alcohol or drug
5 treatment in the last five years?
6 THE DEFENDANT: No.
7 THE COURT: Are you under the treatment of any
8 mental health provider?
9 THE WITNESS: No.
10 THE COURT: Have you had mental health
11 treatment in the last five years?
12 THE DEFENDANT: No, sir.
13 THE COURT: Mr. Martin, do you believe your
14 client's competent?
15 MR. MARTIN: She is competent, Your Honor.
16 THE COURT: And, Ms. Rice, do you believe that
17 Ms. Parris is competent?
18 MS. RICE: Yes, Your Honor.
19 THE COURT: I'm going to ask you some
20 questions. Your answers are given under oath. You'd be
21 subject to penalty if you fail to give an accurate and a
22 complete response.
23 If I ask you a question you're unsure of, do not
24 answer it. Instead, ask me to restate or rephrase the
25 question.
5
1 Do you understand all that?
3 THE COURT: In Count 1 of the indictment
4 you're charged with conspiracy in violation of 18 United
5 States Code Section 371.
6 In Count 11 you're also charged with a conspiracy in
7 violation of 18 United States Code Section 371.
8 As to conviction as to either of those or as to -- you
9 could be incarcerated up to five years, you could be fined
10 up to $250,000, or you could alternatively be fined twice
11 the gross pecuniary gain to you or twice the gross pecuniary
12 loss to others.
13 After any period of incarceration, you can then be
14 subjected to a term of supervised release. Supervised
15 release is a post-incarceration supervision period.
16 If during that period you violated its conditions, you
17 could be sent back to prison.
18 You can also be required to pay the cost of this
19 prosecution, pay the cost of your own incarceration, pay the
20 cost of your own supervised release.
21 You can also be required to make restitution in the
22 case.
23 You can also be required to forfeit property gained
24 through this offense or property used to commit these
25 offenses.
6
1 Do you understand -- in addition, you'd have to pay
2 $100 special assessment as to each of these counts.
3 Do you understand the nature of the crimes that you
4 have been charged with?
5 THE DEFENDANT: Yes, sir, I do.
6 THE COURT: Do you understand the penalty you
7 will face if you're convicted?
9 THE COURT: You have the right to a jury
10 trial.
11 Do you understand that right, and do you give that
12 right up?
13 THE DEFENDANT: Yes, sir, I do understand,
14 and, yes, I do give it up.
15 THE COURT: You can waive a jury trial, and
16 you can ask to try this to a judge without a jury.
17 Do you understand that right?
19 THE COURT: And do you give that right up?
21 THE COURT: You have a right to confront
22 witnesses.
24 right up?

7
1 THE COURT: You have a right to compulsory
2 process.
4 right up?
6 THE COURT: You have an overall right to
7 require the United States to prove your guilt by proof
8 beyond a reasonable doubt.
10 right up?
12 THE COURT: You also have a right to present a
13 defense on your own behalf, and you have a right to give
14 testimony or to take the witness stand to support a defense.
16 right up?
17 THE DEFENDANT: Yes, sir, I do, and, yes, I
18 do.
19 THE COURT: You also have a right not to be
20 compelled or required to give testimony.
22 right up?
24 THE COURT: You also have the right to the
25 help and the assistance of an attorney, and if you are

8
1 unable to pay for representation, you have a right to have
2 counsel appointed to represent you and to have that counsel
3 paid for by the Government.
4 Do you understand that right?
6 THE COURT: Now, you've been represented in
7 the case by Mr. Martin.
8 Has he consulted with you about alternative ways you
9 might defend this case?
11 THE COURT: Has he been available to talk
12 about your case with you?
14 THE COURT: Do you have any complaints about
15 the representation that he has given you?
16 THE DEFENDANT: No, not at all.
17 THE COURT: I have been handed a plea
18 agreement, which on the 17th page has the signature of
19 Debra Parris, which is dated November 11th, 2021.
21 THE COURT: Is that your signature?
22 THE DEFENDANT: Yes, sir, it is.
23 THE COURT: Did you execute this plea
24 agreement on November 11th, 2021?
25 THE DEFENDANT: Yes, sir, I did.

9
1 THE COURT: Okay. Have you read through each
2 paragraph of the plea agreement?
4 THE COURT: And have you consulted with
5 Attorney Martin about the nature and impact of each
6 paragraph?
8 THE COURT: At the bottom of each page there
9 are initials, "DP."
10 Did you initial each page after reviewing each page
11 with Mr. Martin?
12 THE DEFENDANT: Yes, sir, I did.
13 THE COURT: Does this plea agreement
14 accurately describe the understandings and agreements you
15 have with the United States about your case?
16 THE DEFENDANT: Yes, it does.
17 THE COURT: Has anybody made any outside
18 threats or promises that you've relied upon in entering a
19 plea?
20 THE DEFENDANT: No, sir.
21 THE COURT: Under the plea agreement you
22 generally agree to plead guilty to -- excuse me -- Count 1
23 and Count 11 of the indictment?
25 THE COURT: Do you understand how -- have you

10
1 ever had any federal criminal cases before?
2 THE DEFENDANT: Never.
3 THE COURT: What's the Government's agreement
4 if the defendant -- if the defendant enters pleas to
5 Counts 1 and 11, what's the Government's consideration at
6 the time of sentencing?
7 MS. RICE: Your Honor, at the time of
8 sentencing, in addition to what we previously discussed, the
9 parties have an agreed combined offense level before
10 acceptance of 26 and --
11 THE COURT: No. What I'm referring to is
12 paragraph 9.
13 MS. RICE: Oh, thank you, Your Honor.
14 So at the time of sentencing, the United States will
15 move to dismiss Counts 2 through 10 of the indictment as
16 related to Ms. Parris.
17 THE COURT: Okay. Is that your understanding,
18 Ms. Parris?
20 THE COURT: Have you ever had a federal
21 criminal case before?
22 THE DEFENDANT: Never.
23 THE COURT: Under federal sentencing law, upon
24 a plea of guilty or a jury finding of guilty, federal judges
25 are charged with picking a sentence that's sufficient, but

11
1 not longer than needed.
2 And in making a decision as to what the sentence
3 should be, federal judges first consider the federal
4 sentencing guidelines and the sentence recommended under
5 those guidelines. They then consider whether to depart or
6 to vary from those guidelines. They then consider certainly
7 generalized factors under Section 3553, including the nature
8 and circumstances of the offense, the defendant's history
9 and characteristics, the need to deter others, the need to
10 avoid disparities, the need to reflect the seriousness of
11 the offense, certain other factors.
12 But then after considering all of those factors, the
13 judge would need to pick a sentence that's sufficient, but
14 not longer than needed.
15 Is it true that in this presentence report there's no
16 agreement with you or with the United States Attorney's
17 Office as to whether your sentence should be below the
18 guidelines, at the guideline -- within the guideline range,
19 or above the guidelines?
20 THE DEFENDANT: No, there's not.
21 THE COURT: And do you understand that
22 sentencing is left to the judge, and that ultimately the
23 prosecutor would have the ability to make a recommendation,
24 but it's ultimately the judge -- myself's decision as to
25 what the sentence should be?

12
2 THE COURT: Do you, however, reach certain
3 calculations as to the guideline calculation?
4 And specifically, in paragraph 16, with regard to
5 bribing a foreign official, do you stipulate that the base
6 offense level should be set at 12?
7 Do you stipulate there should be a two-level increase
8 because more than one bribe was involved?
9 Do you further stipulate that there should be a
10 four-level further increase because the bribe succeeded
11 [sic] $15,000?
12 Do you further stipulate that the offenses involved
13 high-level or sensitive public officials, and that there
14 should be a further four-level increase?
15 And do you further stipulate that there were a large
16 number of vulnerable victims, and that there should be a
17 four-level increase because of that, for a total offense
18 level of 26?
20 THE COURT: Do you also stipulate that as to
21 the visa fraud there should be a base offense level and a
22 total offense level of 11?
24 THE COURT: Do you also stipulate that as to
25 the conspiracy to defraud the United States that the base

13
1 offense level would be 7, that there was a substantial
2 effort outside the United States to carry out the
3 conspiracy, and a two-level increase should attach?
4 And do you further stipulate that there should be a --
5 it should -- there should be a further three-level increase
6 to enhance the offense to 12?
8 THE COURT: And then under the grouping
9 analysis, do you stipulate that the combined offense level
10 before acceptance of responsibility should be set at 26?
12 THE COURT: And does the Government believe
13 that to this time the defendant's accepted responsibility
14 and should qualify for a three-level reduction?
15 MS. RICE: We do, Your Honor.
16 THE COURT: And, Ms. Parris, under the federal
17 sentencing law, the other major sentencing guidelines input
18 is past criminal record, if any.
19 Is it true that there is no guarantee or
20 representation as to how that would be scored?
22 THE COURT: As part of the plea, do you also
23 waive and give up any appeal of your conviction?
24 THE DEFENDANT: Yes, I do.
25 THE COURT: Do you also give up any appeal of

14
1 your sentence if it's within the range we've been speaking
2 about?
4 THE COURT: Have you read the factual -- do
5 you also agree as part of the plea agreement to make
6 restitution as I determine restitution to be owing?
8 THE COURT: Have you read the factual
9 description given in paragraphs 21, A through Q, together
10 with paragraph 22?
12 THE COURT: And is the factual description
13 given in those paragraphs true?
14 THE DEFENDANT: It's accurate, yes, sir.
15 THE COURT: And I'll ask Ms. Rice or
16 Mr. Manning to -- if they might summarize what they believe
17 the defendant's criminal conduct to have been.
18 MS. RICE: Thank you, Your Honor.
19 First, with respect to the Uganda scheme, from in or
20 about 2012 to in or about 2017, Ms. Parris worked for an
21 international adoption agency based in Strongsville, Ohio,
22 which was located in the Northern District of Ohio, Eastern
23 Division.
24 Her responsibilities included managing aspects of
25 adoption agency's adoption program in Uganda in coordination

15
1 with Robin Longoria and others.
2 In or about 2013, the adoption agency entered into an
3 agreement with Dorah Mirembe, an attorney based in Kampala,
4 Uganda, to provide adoption-related services to the adoption
5 agency.
6 From in or about 2013 to in or about 2016, the
7 adoption agency directed clients to hire Mirembe as their
8 attorney for adoption-related proceedings in Uganda.
9 From in or about 2013 through in or about 2016, the
10 adoption agency, in collaboration with Mirembe, facilitated
11 the adoption of more than 30 Ugandan children.
12 Mirembe caused bribes to be paid to Ugandan government
13 officials for the purpose of influencing them to misuse
14 their official positions by taking actions that assisted
15 Mirembe and the adoption agency in facilitating the
16 adoptions. These bribes included bribes to probation
17 officers to influence them to issue favorable probation
18 reports recommending that a particular child be placed into
19 a orphanage; bribes to court registrars to influence them to
20 assign particular cases to adoption-friendly judges; and
21 bribes to high court judges to influence them to issue
22 favorable guardianship orders to adoption agency's clients.
23 Mirembe and her staff regularly sent emails to
24 Ms. Parris and Longoria requesting payment. These emails
25 included charts listing specific costs for services

16
1 performed and incurred -- and costs incurred by Mirembe.
2 The charts identified the services and costs with reference
3 to particular adoption agency clients. The charts included
4 descriptions of the services and costs. Bribe payments were
5 not explicitly described as bribes, but rather as fees or
6 other types of costs. For example, bribes to court
7 registrars were often described as court filing fees, and
8 bribes to judges were often described as judges' fees.
9 Individual bribes were often in the amount of hundreds of
10 U.S. dollars or more.
11 Beginning in at least 2015, Ms. Parris participated in
12 the scheme knowing that Mirembe would use these fees, at
13 least in part, to cause bribes to be paid to Ugandan
14 government officials to influence these officials
15 official -- those officials' acts in their official capacity
16 to assist adoption agency in obtaining business.
17 Ms. Parris, together with Longoria and others, understood
18 that adoption agency wired funds to Mirembe knowing that the
19 funds would be used, at least in part, to pay bribes.
20 Ms. Parris, beginning in at least 2015, also
21 understood that Longoria and Mirembe caused adoption
22 agency's clients to provide false information to the State
23 Department for the purpose of misleading the State
24 Department in its adjudication of visa applications from
25 Uganda. Ms. Parris, nevertheless continued to direct

17
1 adoption agency clients to retain Mirembe as their attorney
2 for adoption-related proceedings in Uganda.
3 In connection with the Poland part of the scheme in
4 this case, the facts are -- agreed to are as set forth.
5 Poland client was a client of adoption agency who
6 traveled to Poland in approximately May 2015 to adopt two
7 siblings, Child 1 and Child 2. While Poland client was
8 still in Poland, adoption agency executive director
9 Margaret Cole contacted Ms. Parris and told her that Poland
10 client had told Cole, in sum and substance, that the Poland
11 client could not raise Child 2.
12 Ms. Parris then spoke with Poland client while still
13 in Poland, and Poland client also told Ms. Parris that
14 Poland client and Poland client's spouse had decided they
15 could bring Child 1 into their home, but not Child 2.
16 While Poland client was still in Poland, Cole
17 recommended to Ms. Parris that Parris relatives 1 and 2 take
18 custody of Child 2 from Poland client once Poland client and
19 Child 2 arrived in the U.S. Parris Relatives 1 and 2 agreed
20 to do so, and Ms. Parris informed Cole of that.
21 On July 4th, 2015, Poland client traveled from Poland
22 to Dallas/Fort Worth International Airport with Child 1 and
23 2. There, Poland client met Ms. Parris, who had arranged
24 for an attorney in Texas to create transfer of custody
25 documents to transfer Child 2 from Poland client to Parris

18
1 Relatives 1 and 2. Ms. Parris also had arranged for
2 Longoria to meet them at the airport to notarize the
3 signatures on the transfer of custody paperwork.
4 Poland client signed the transfer of custody documents
5 on the Dallas airport. Ms. Parris escorted Child 2 from
6 Poland client to Parris Relative 2. Child 2 then lived with
7 Parris Relatives 1 and 2.
8 By the time that Parris Relatives 1 and 2 took custody
9 of Child 2 on July 4th, 2015, Ms. Parris had told Cole that
10 Parris Relatives 1 and 2 were her relatives, Parris
11 Relatives 1 and 2 intended to raise Child 2 in their home,
12 and Parris Relatives 1 and 2 had not completed a home study
13 which was required for intercountry adoption. Cole advised
14 Ms. Parris that she should proceed with transferring Child 2
15 to Parris Relatives 1 and 2.
16 In the period between July 2015 and August 2016,
17 Ms. Parris informed Cole occasionally that Parris Relatives
18 1 and 2 continued to raise Child 2 in their home.
19 In August of 2016, Child 2 was injured and
20 hospitalized. Ms. Parris spoke with Cole after Child 2 was
21 hospitalized. Cole, in sum and substance, expressed concern
22 for the repercussions for adoption agency, but did not
23 express concern for Child 2's well-being.
24 Ms. Parris understood that adoption agency's conduct
25 in relation to Child 2 could place in jeopardy the adoption

19
1 agency's ability to facilitate intercountry adoptions.
2 Ms. Parris understood, among other things, that the
3 adoption agency could have its accreditation revoked by the
4 Council on Accreditation or the State Department, and its
5 ability to operate in Poland could be revoked by Polish
6 authorities.
7 Ms. Parris agreed to assist Cole to conceal the roles
8 of Ms. Parris and Cole and the adoption agency in causing
9 the transfer of Child 2 from Poland client to Parris
10 Relatives 1 and 2.
11 Specifically, on or about December 9th, 2016, Parris
12 Relative 1 wrote an email to Ms. Parris that falsely stated,
13 "We were just temporary guardians of their four-year-old
14 child from Poland until they decided what they wanted to do
15 with the child until February of 2016." Ms. Parris
16 forwarded this false email to Cole and did so knowing that
17 Cole would use this false email to concealed from
18 authorities, including the State Department and Polish
19 central authority for intercountry adoption, that Cole and
20 adoption agency caused the permanent transfer of Child 2 to
21 Parris Relatives 1 and 2 in contravention of applicable
22 rules and regulations governing intercountry adoption.
23 Thank you, Your Honor.
24 THE COURT: Is that all true, Ms. Parris?

20
1 THE COURT: And where -- did certain of these
2 activities take place in the Northern District of Ohio?
3 THE DEFENDANT: No. Well, yes. Yes. I'm
4 sorry. I'm sorry. That's where the company is.
5 THE COURT: Okay. Does the United States
6 believe anything else needs to be asked about?
7 MS. RICE: One moment, Your Honor.
8 (Pause in proceedings.)
9 MS. RICE: Thank you, Your Honor.
10 The only other provision would be paragraph 24
11 regarding the financial statement.
12 THE COURT: As part of the plea agreement, do
13 you agree to provide a financial statement over -- setting
14 out the assets, liabilities, income, and expenses of
15 yourself and family members?
17 THE COURT: And including any transfers within
18 the last three years?
20 THE COURT: Okay. Do you think we should ask
21 anything else, Mr. Martin?
22 MR. MARTIN: I don't, at this time, Judge. I
23 think we've covered everything.
24 THE COURT: Okay. Ms. Parris, in Count 1
25 you're charged with conspiracy in violation of 18 United

21
1 States Code Section 371.
2 How do you plead to that?
3 THE DEFENDANT: Guilty.
4 THE COURT: In Count 11 you're charged with a
5 conspiracy in violation of 18 United States Code
6 Section 371.
7 How do you plead to that?
8 THE DEFENDANT: Guilty.
9 THE COURT: I find that the defendant has
10 knowingly and voluntarily waived her rights.
11 I'll accept her guilty pleas as to both Counts 1 and
12 11.
13 Do we have a proposed sentencing date, Lexie?
14 COURTROOM DEPUTY: Yes, Judge.
15 I have March 9th, 2022, at 1:00 p.m.
16 THE COURT: Okay. We'll set the sentencing
17 for that time.
18 Now, before that time, the probation department will
19 prepare a draft presentence report. They'll circulate that
20 to Mr. Martin and through him to you.
21 When that comes in you need to go through it
22 carefully, and if you believe there are any mistakes in the
23 report, you need to raise objection or suggest corrections
24 within 14 days.
25 Does the United States have any objection to the

22
1 continuation of bond that was earlier set?
2 MS. RICE: No objection, Your Honor.
3 THE COURT: Okay. I'll continue the bond that
4 was earlier set. You'll be under the same bond conditions
5 that you've been operating under for some period of time.
6 Is there anything else that anybody believes we should
7 talk about?
8 MS. RICE: Not from the United States,
9 Your Honor.
10 Thank you.
11 MR. MARTIN: Not from the defense either,
12 Your Honor.
13 Thank you.
14 THE COURT: Okay. Thank you.
15 And we will adjourn.
16 - - -
17 (Proceedings adjourned at 1:46 p.m.)
18
19 C E R T I F I C A T E
20 I certify that the foregoing is a correct transcript

from the record of proceedings in the above-entitled matter.
21
/s/ Donnalee Cotone 24th of November, 2021
22 DONNALEE COTONE, RMR, CRR, CRC DATE
Realtime Systems Administrator
23
24
25

Debra Parris Edwards, John Tufts' Mom's Federal Plea Deal Nov 17th 2021 22 Pages

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Debra Parris Edwards, John Tufts' Mom's Federal Plea Deal Nov 17th 2021 22 Pages

Uploaded by

Copyright:

Available Formats

Case: 1:20-cr-00424-JG Doc #: 100 Filed: 11/24/21 1 of 22.

1 UNITED STATES DISTRICT COURT

12 TRANSCRIPT OF CHANGE OF PLEA PROCEEDINGS

13 BEFORE THE HONORABLE JAMES S. GWIN

14 SENIOR UNITED STATES DISTRICT JUDGE

16 Court Reporter: Donnalee Cotone, RMR, CRR, CRC

24 Proceedings recorded by mechanical stenography, transcript

25 produced by computer-aided transcription.

3 For the Government: CHELSEA S. RICE,

12 For the Defendant: BRET E. MARTIN, ESQ.

1 AFTERNOON SESSION. WEDNESDAY, NOVEMBER 17, 2021

2 (Proceedings commenced at 1:15 p.m.)

4 THE COURT: And, Ms. Parris, can you hear us?

5 THE DEFENDANT: Yes, sir.

6 THE COURT: And do you consent to have this

7 hearing go forward using videoconference?

8 THE DEFENDANT: Yes. Yes, sir.

9 THE COURT: I'll ask you -- I'll find the

10 defendant's consented to the videoconference, and I'll find

11 the ends of justice support using it.

12 I'd ask the defendant to raise her right hand.

14 THE COURT: Tell us your name, and tell us how

15 you spell your last name.

16 THE DEFENDANT: Debra Parris. P-A-R-R-I-S.

17 THE COURT: How old are you?

18 THE DEFENDANT: 69.

19 THE COURT: How far did you go in school?

20 THE DEFENDANT: Third year of college.

21 THE COURT: Can you read and understand

23 THE DEFENDANT: Yes.

24 THE COURT: Are you a United States citizen?

25 THE DEFENDANT: Yes.

1 THE COURT: Are you right now under the

2 influence of alcohol or drugs?

3 THE DEFENDANT: No.

4 THE COURT: Have you had any alcohol or drug

5 treatment in the last five years?

6 THE DEFENDANT: No.

7 THE COURT: Are you under the treatment of any

8 mental health provider?

9 THE WITNESS: No.

10 THE COURT: Have you had mental health

11 treatment in the last five years?

12 THE DEFENDANT: No, sir.

13 THE COURT: Mr. Martin, do you believe your

15 MR. MARTIN: She is competent, Your Honor.

16 THE COURT: And, Ms. Rice, do you believe that

17 Ms. Parris is competent?

18 MS. RICE: Yes, Your Honor.

19 THE COURT: I'm going to ask you some

20 questions. Your answers are given under oath. You'd be

21 subject to penalty if you fail to give an accurate and a

23 If I ask you a question you're unsure of, do not

24 answer it. Instead, ask me to restate or rephrase the

1 Do you understand all that?

2 THE DEFENDANT: Yes, sir.

3 THE COURT: In Count 1 of the indictment

4 you're charged with conspiracy in violation of 18 United

5 States Code Section 371.

6 In Count 11 you're also charged with a conspiracy in

7 violation of 18 United States Code Section 371.

8 As to conviction as to either of those or as to -- you

9 could be incarcerated up to five years, you could be fined