The jury was told he took money he was not allowed to take, from a “sham-UN affiliate.” The motion answers with the contracts, the Government’s concessions, and the definition it never gave.
ASC 102 · Treasurer appointment, Nov. 1, 2016 · ECF 171-1 at 131When he joined in November 2016, WSA appointed him Treasurer: “You will be responsible for all matters dealing with the treasury of the WSAIGO, with the monetization of the assets of WSAIGO and with the funding of the WSAIGO and of each of its projects.” The letterhead lists UN DESA NGO Section and UN‑NGO‑IRENE among WSA’s partners. (ASC 102; ECF 171-1 at 131)
In closing the jury heard that his contract barred the payments: “he’s not allowed to take that money,” and “he did anyway, and then he lied about it.” (Tr. 1094) The motion says the Government showed page one and not page four.
Page one · § 1(a): compensation conditional on the first $2 million of seed capital · ECF 135 at 86
Page four · § 2(b)(ii), (iii), (v): expenses, equipment, moving · ECF 135 at 89
- Closing · Tr. 1094The contracts required WSA’s affiliated companies to be “revenue positive”; “he’s not allowed to take that money.”
- 2025 · ECF 146 at 21The Government concedes the contracts “did not use the term ‘revenue positive.’”
- Page one · § 1(a)(B)Only “the payment of compensation” waited on the first $2 million of seed capital. (ECF 135 at 86; Tr. 981–82)
- Page four · § 2(b)(ii)“The Company will pay or reimburse the Employee for all reasonable and necessary business expenses incurred or to be incurred.” (ECF 135 at 89)
- Page four · § 2(b)(iii), (v)Computer, server, software and phone; and “the reasonable expenses of moving” and “reasonable temporary living expenses.” (ECF 135 at 89)
- 2018 · GX 3101, 3102The later contracts removed the seed-capital condition entirely. (ECF 171-1 at 44–129)
GX 3101 · ECF 171-1 at 45 · the 2018 Commtrade agreement
GX 3102 · ECF 171-1 at 99 · the 2018 WSA agreementAddresses, phone numbers, emails, account numbers and signatures are blacked out. Tap a page to read it full size.
- The claimHis contracts required the companies to be “revenue positive,” or “he’s not allowed to take that money.”
- The accusation“[H]e did anyway, and then he lied about it.”
- Conceded · ECF 146 at 21No such “revenue positive” term appears in any contract.
- DX 29 § 1(a)Salary, and only salary, was conditioned on a $2 million seed round. (Tr. 981–82; ECF 135 at 86)
- DX 29 § 2(b)(ii)Mandatory reimbursement of “all reasonable and necessary business expenses incurred or to be incurred.” (ECF 135 at 89)
- DX 29 § 2(b)(iii), (v)Electronic equipment; moving and temporary-living expenses.
These figures are Saint Clair’s own summary (Exhibit E), prepared from the bank records underlying the Government’s forensic summaries, GX 2900 and GX 1500, and the pay terms in evidence (Fed. R. Evid. 1006; Saint Clair Decl. ¶ 16). The motion’s conclusion: “The Government prosecuted the organization’s largest creditor as its embezzler.”
Exhibit E · advanced vs. contractually due
PX 1 · ECF 150-1 at 6 · the 2019 agreement
GX 2900 at 2 · the Government’s deposit summary
GX 1500 · the Government’s payments summary, as shown to the juryAddresses, phone numbers, emails, account numbers and signatures are blacked out. Tap a page to read it full size.