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Federal Criminal Trialtrial-daytrial-dayJeff SchenkKevin M. Downeyclosing_argumentDay 46 - December 16, 2021Judge Davila limited jurors' use of CMS report excerpts before the prosecution argued that Holmes knowingly deceived investors and patients. The defense began its closing by portraying Theranos as a genuine business and disputing fraudulent intent before the court recessed with its argument unfinished.
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Day 46 - December 16, 2021

CMS Exhibit Limitation and Competing Closing Arguments

Judge Edward J. Davila
2Proceedings
2Pages
0Witnesses
147Lines
Day 46 of 51
Appearing:

Judge Davila limited jurors' use of CMS report excerpts before the prosecution argued that Holmes knowingly deceived investors and patients. The defense began its closing by portraying Theranos as a genuine business and disputing fraudulent intent before the court recessed with its argument unfinished.

Full day summary

Before closing arguments, Judge Edward Davila instructed jurors that Exhibit 4621, containing excerpts from the January 25, 2016 CMS report, could be considered only for Holmes's state of mind and not for the truth of its assertions. Prosecutor Jeff Schenk then argued that Holmes knowingly chose deception rather than allow Theranos to fail. He reviewed evidence concerning representations to investors, analyzer capabilities, company finances, pharmaceutical and military work, Walgreens, third-party devices, patient advertising, assay failures, quality-control problems, and laboratory warnings. He also addressed defense themes and argued that jurors could decide the fraud charges without resolving Holmes's allegations of abuse by Ramesh Balwani. Defense counsel Kevin Downey responded that Holmes was building a genuine but imperfect business, not a criminal enterprise. He cited pharmaceutical projects, technical reports, FDA dealings, outside reviews, public disclosures, reliance on scientists, and later remediation to support the defense position that Holmes acted in good faith and lacked fraudulent intent. The court recessed before the defense completed its closing argument, which was scheduled to resume the next morning.

1. Closing Argument by the Prosecution

Judge Davila addressed exhibit procedures and gave a limiting instruction on Trial Exhibit 4621 before prosecutor Jeff Schenk began the government’s closing argument.

Procedural
Pre-Argument Evidentiary and Exhibit Procedures

The court limited Exhibit 4621 to Holmes's state of mind, preserved the defense's request for a written instruction, and set courtroom-only playback for admitted audio and video exhibits.

Jury Instruction
Jury Limiting Instruction on Exhibit 4621

Judge Davila instructed jurors to consider Exhibit 4621 only for Holmes's state of mind, not for the truth of the CMS report's assertions.

Closing
Closing Argument by the ProsecutionJeff Schenk
60 lines

The prosecution argued that Holmes knowingly deceived investors and patients, linked the documentary and testimonial record to the conspiracy and wire-fraud elements, rebutted the principal defense themes, and requested guilty verdicts on all remaining counts.

Highlights

Jury Limiting Instruction on Exhibit 4621jury eventBefore closing arguments, Judge Davila instructed jurors that Exhibit 4621 could be considered solely for Holmes's state of mind, not for the truth of the CMS report's assertions. He noted that he had not given the instruction when evidence closed.Jury Limiting Instruction on Exhibit 4621“TRIAL EXHIBIT 4621, WHICH CONTAINS EXCERPTS OF THE JANUARY 25, 2016 CMS REPORT WAS ADMITTED FOR A LIMITED PURPOSE, THE LIMITED PURPOSE OF MS. HOLMES'S STATE OF MIND AND NOT FOR THE TRUTH OF THE MATTER ASSERTED.”— Edward J. DavilaThe court defined the limited evidentiary use jurors could make of the CMS report excerpts immediately before closing arguments.Closing Argument by the ProsecutionotherThe prosecution opened with its central theory that Holmes faced Theranos's financial decline and chose to deceive investors and patients rather than permit the company to fail.Closing Argument by the Prosecution“SHE CHOSE FRAUD OVER BUSINESS FAILURE.”— Jeff SchenkThis sentence stated the prosecution's central theory that the charged conduct was a deliberate alternative to permitting Theranos to fail.Closing Argument by the Prosecutionevidence eventThe prosecution synthesized investor evidence concerning analyzer capabilities, Theranos finances, demonstrations, Walgreens, military work, third-party devices, pharmaceutical validation, media articles, and the charged Fedwire transfers.Closing Argument by the Prosecutionevidence eventAfter the recess, Schenk addressed the patient counts through advertising claims, assay and quality-control records, HCG and PSA timelines, laboratory warnings, physician communications, and the interstate faxes and media-buy transfer.Closing Argument by the ProsecutionconfrontationThe prosecution rebutted defense themes concerning ordinary business failure, Holmes's experience, her decision not to sell stock, the government's asserted 'dirty lens,' defense witnesses, and Holmes's credibility, while telling jurors they need not resolve her abuse allegations to decide the charges.Closing Argument by the Prosecution“IF YOU RETURN A VERDICT OF GUILTY, YOU'RE NOT SAYING THAT WE, THE JURY, DO NOT BELIEVE MS. HOLMES'S CLAIMS OF ABUSE.”— Jeff SchenkThe prosecution argued that jurors could decide the fraud charges without resolving Holmes's allegations about abuse by Balwani.

2. Closing Argument by the Defense

Defense counsel argued that Holmes acted in good faith while leading a genuine but imperfect business, and the court recessed before the defense completed its closing argument.

Closing
Closing Argument by the DefenseKevin M. Downey
48 lines

The defense argued that Holmes acted in good faith, relied on scientific and regulatory feedback, disclosed material aspects of Theranos's operations, and lacked the fraudulent intent required for conviction.

Highlights

Closing Argument by the DefenseotherDefense counsel opened by characterizing Theranos as a genuine business rather than a criminal enterprise and contending that the complete evidentiary record presented a different picture from the prosecution's account.Closing Argument by the Defense“ELIZABETH HOLMES WAS BUILDING A BUSINESS AND NOT A CRIMINAL ENTERPRISE.”— Kevin M. DowneyThis sentence stated the defense's central theory that Theranos was a genuine commercial effort rather than a fraudulent scheme.Closing Argument by the Defenseevidence eventThe defense used pharmaceutical contracts, projects, witness testimony, and the chronology of report logos to argue that the prosecution presented an incomplete account of Theranos's relationships with Pfizer, GSK, Celgene, and Schering-Plough.Closing Argument by the DefenseotherCounsel emphasized the presumption of innocence, reasonable doubt, intent to defraud, willfulness, and good faith as the governing questions for the wire-fraud and conspiracy counts.Closing Argument by the Defense“IF SOMEONE IS ACTING IN GOOD FAITH, YOU HAVE NO REASON TO FIND THEM GUILTY, EVEN IF THE OTHER ELEMENTS OF AN OFFENSE ARE FOUND.”— Kevin M. DowneyCounsel made good faith the principal bridge between the evidence and the requested not-guilty verdicts.Closing Argument by the Defenseprocedural actionThe court ended the trial day while the defense argument remained unfinished and directed jurors to avoid outside information before closing arguments resumed the next morning.
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