Your Honor,
1. Defense: Agent Kelly, the alleged controlled purchase involved two AK47 cases, correct?
Kelly: Correct.
2. Defense: That alleged controlled purchase did not involve narcotics, RPG cases, sniper cases, spike strips, or police scanners, correct?
Kelly: Correct. Those items were recovered separately during the processing.
3. Defense: Those other items were allegedly recovered later during the search, correct?
Kelly: Correct.
4. Defense: You personally logged the items listed in Exhibit C, correct?
Kelly: Correct.
5. Defense: Did any other FBI agent verify the exact quantities listed in Exhibit C before this case was filed?
Kelly: The evidence was processed pursuant to Bureau procedure. The recovered items themselves remained unchanged.
6. Defense: In the original filing, the Bureau presented the charges with multipliers of 7, 8, 3, and 5, correct?
Kelly: Correct.
7. Defense: Those multipliers added up to twenty-three, correct?
Kelly: Numerically, correct. However, those figures reflected charge applications across overlapping jurisdictions, not twenty-three separate underlying criminal acts.
8. Defense: In that same original filing, the Bureau requested fifteen years of imprisonment and a ten million dollar fine, correct?
Kelly: Correct.
9. Defense: The Bureau later clarified that this case proceeds as four main charges, correct?
Kelly: Correct. The case proceeded on four underlying charges from the outset. The numerical figures previously referenced represented evidentiary quantities and charge applications, which had already been explained before.
10. Defense: Since that clarification, has the Bureau submitted any reduced punishment recommendation to reflect the four-charge structure?
Kelly: No. The requested penalties were already based upon the same four underlying charges later clarified before the Court.
Respectfully submitted,
Mike Kelly
Special Agent
Federal Bureau of Investigation
May 11th, 2026