Verification status — November 5, 2026

Result

Verification is PARTIAL. The current operative indictment and complete current docket were not obtained. No authenticated PACER/CM-ECF session was used, no paid docket retrieval was performed, and no claim is made that there is no superseding indictment. Public-search silence does not prove the absence of later filings.

Established and unresolved

• Official Docket 114, dated September 15, 2025, identifies Docket 3 and the May 21, 2025 indictment. It confirms the historical description of the conspiracy counts, not the present charging posture. Official court order.
• Local filename and inventory searches and the English audit's identity/charges discussion did not establish possession of a complete authenticated operative indictment. The audit itself says the official complete charging instrument was not found in the reviewed discovery and describes reliance on an unauthenticated public copy.
• “Five counts” conflicts with the audit's list “1, 2, 5, 18–22.” Neither is certified here. “05Garcia” is not proof of a fifth conspiracy or a five-count indictment.
• A CourtListener public search could not be accessed through the available web tool. No complete updated docket was recovered through the public searches performed.
• Official federal rules, First Circuit opinions, statutes, and the Maine-hosted First Circuit pattern manual were consulted. The Puerto Rico court lists a February 2024 manual, but its PDF link returned an error; the retrieved Maine edition is dated December 8, 2023 and is not represented as the newest available edition.
• A 2026 First Circuit decision, Omoruyi, required a specific warning against casually treating the old § 1349 model commentary as current or conclusively omitting an overt-act issue. Current comprehensive citator treatment has not been completed.

Required before filing

Obtain Docket 3, any corrected charging instrument or superseding indictment, the current docket report, relevant dismissal/plea/severance orders, the scheduling order, and the government's actual exhibit and statement proffers. Confirm remaining defendants and counts. Resolve all bracketed fields and substantive legal/evidentiary issues in the drafts.

Delivery boundary

The two English documents are substantive attorney-review drafts with explicit verification gates, not filing-ready pleadings or a certified legal opinion. They have not been filed, served, or uploaded to Cloudflare. The underlying audit and source evidence were not changed. No fabricated exhibit, affidavit, case citation, witness promise, or court deadline has been inserted.