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Defendant.
_____________________________/
Introduction
On July 13, 2018, defendant Dean Reynolds filed a Reply to the government’s
opposition to bond pending sentencing. Since then, the case agent, FBI SA Robert
defendant’s non-attorney jail calls made from the St. Clair County jail. The calls
revealed that the defendant deceived the Court about having been diagnosed with
kidney cancer and his mother being placed in hospice care. Equally clear from
released from custody stems not from an urgent medical need, but rather from a
desire to be released in order to try to save his troubled, fledgling marriage. Another
troubling discovery in the defendant’s jail calls is the fact that the defendant is still
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in constructive possession of firearms and plans to actually possess them if the court
Reynolds Lied Under Oath About Having Been Diagnosed with Cancer
Attached to the defendant’s initial motion for reconsideration for bond were
medical records that failed to show that Reynolds had been diagnosed with cancer.
And the new records he attaches to his reply are equally unavailing.
One record shows that his initial MRI back in October of 2017 gave doctors
cause for concern. It stated that the mass appearing on the MRI was “diagnosed as
likely renal cell carcinoma.” (Defendant’s Reply, p. 4). That initial concern for
cancer was assuaged when, after part of Reynolds’ kidney was removed and biopsied
in the spring of this year, the pathology report concluded “no malignancy found on
partial nephrectomy specimen.” The conclusion that Reynolds did not have cancer,
at least as for the part of the kidney that was tested, occurred on April 16, 2018.
Thus, Reynolds knew three months before his trial began in June that he did not have
a cancer diagnosis. Yet, he had no hesitation in boldly lying to the court and
committing perjury.1
On June 13, 2018, prior to jury selection, the Court held a hearing concerning
1
Even the letter the defendant submitted from Dr. Reaume dated July 18,
2018, calls it “possible cancer of the kidney.” (Reply, p. 3).
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under oath. During the hearing, the Court asked Reynolds about parts of the
financial affidavit he did not complete, including when he was last employed and
how much he was earning. In answer to the Court, the defendant stated:
RT: 6/13/18; p. 4 (Exhibit A). The Court asked if he was referring to October of
Of 2017, that’s correct. And then the business itself ran out of funds in
February of this year. And per month, how much per month? Approximately
$6,500 per month is what I would take in. I also developed over that time, I
was diagnosed with kidney cancer, which is another issue that happened
with working. I went through and received surgery for that cancer, and
unfortunately, that was unsuccessful. So I still have cancer and unable to
find employment.
RT: 6/13/18; pp. 4-5 (Exhibit A). Reynolds knew from the April 16 pathology
report that he was not “diagnosed with cancer” and he knew that he did not “still
have cancer.”
Reynolds’ recorded jail calls over the past 30 days2 reveal that Reynolds has
been scheming to try to get a doctor to say that he had cancer in order to convince
2
The recording system at the St. Clair County jail was not able to provide
SA Beeckman with an exact date of the recorded calls, only a time range. All of
the calls he listened to occurred between June 21, 2018 and July 17, 2018.
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In one call to his wife earlier this month, Reynolds discusses needing his wife
Reynolds: You know, I was thinking about it, and you may not want to say
this but…if they [the doctor’s office] don’t want to write the, you
know, diagnosis can- kidney cancer, is, you might have to just
come out and tell them you need it for an attorney because I’m
in jail and they, I need to be –
Wife: Right
Wife: I’m-
Wife: Uh huh.
Reynolds: Did you tell them that uh, the letter needs to say that I was
diagnosed with kidney cancer?
Reynolds: Okay.
Wife: So, I don’t know what they are gonna put on there.
***
Reynolds: So, but, but the letter’s got to say that I was diagnosed with
kidney cancer.
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There was even a call between Reynolds and his father where his father reads
Reynolds a letter his father obtained from Reynolds’ physician about Reynolds’
condition and Reynolds instructs his father to throw out the letter because it states
Father: Ok, I went over there [to Reynolds’ doctor’s office], twice.
Reynolds: Yeah?
Reynolds: Ok.
Father: [Reading] ‘To whom it may concern: Dean Reynolds has been
a patient of our since 2014 for secondary polycythemia.’
Reynolds: Right.
Father: ‘In March of 2018, a mass was found in the right kidney. A
partial ne- operation was performed by Doctor,’ what’s his
name?
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The defendant was not happy with the letter and promptly instructed his father to
In addition to lying to the Court under oath about his cancer, the defendant
essentially perpetrated a wire fraud scheme in the spring of 2018 to get money. He
claimed on the funding website youcare.com that he had “stage 3 kidney cancer”
and needed to raise $10,000. (Exhibit B, Macomb Daily article by Mitch Hotts,
April 12, 2018). Reynolds’ medical records reveal, however, that Reynolds has
never been diagnosed with stage 3 kidney cancer. Instead, his physician indicated
Reynolds lied to his attorney and the Court about his mother being placed in hospice
***
Reynolds: Oh.
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Father: Okay.
Father: About the same but she’s, she’s alright. She can talk and
everything. Just very weak.
Father: I hope you do too. Uh, did you tell your attorney she’s
[Reynolds’ mother is] in, in, uh, home care?
Reynolds: No. Because that’s not what - when I left she was going into
hospice. So I asked, I asked Fraser for a letter stating that they
discontinued the, the chemo and the radiation. And they
recommended hospice. Because that’s what I was told and that’s
what I told them….So that’s…the letter that I asked for.
Reynolds also attempted to conceal from his attorney, Mr. Rabaut, the fact
that his mother had been moved to a hospital where she was receiving medical
treatment. This is because it did not fit Reynolds’ narrative of needing to get out of
custody to visit his dying mother in hospice. The subterfuge was revealed in this
Reynolds: Ok, well what I wanted to tell you was, when you talk to my
attorney [Mr. Rabaut]-
Father: Yes.
Reynolds: Don’t, don’t get into detail on mother. Don’t say she’s in the
hospital or anything. Just, you know, just say she’s getting
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concealing facts about his mother’s medical treatment to protect his justifications
for bond. His initial claim that his mother is actually in hospice is just false.
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Reynolds’ conviction. In them, he talks with family and friends. SA Beeckman can
attest that there are two central themes running through all of the calls: one is
Reynolds’ non-stop attempts to get his family members and friends to put money on
his jail account and to handle his unpaid bills; the other is the defendant’s desperation
to get out of custody so he can attempt to repair his marriage. It is quite telling that
Reynolds does not do or say anything that indicates he is worried about an imminent
threat to his physical condition requiring medical attention. This stands to reason,
as the defendant’s claim of having been diagnosed with cancer, at least to date, is a
false one.
The U.S. Marshals Service Can Accommodate Any Real Medical Needs
Even if the defendant had an urgent medical condition, the U.S. Marshals
have assured the government that they could bring him to a location to receive
treatment. Moreover, the defendant could move to expedite his sentencing and
In one disturbing jail call, the defendant, frantic to raise money, reveals that
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is asking his Uncle Bob to give his wife $1,000 and suggests that he will pay him
Bob: What?
Reynolds: I don’t know the right but, you gotta do it.
Bob: What Dean?
Reynolds: I, you gotta, you gotta, can you come up with a thousand bucks
to give Melissa [Reynolds’ wife] this week? And if you can
wait ‘til I get out, I can sell, I can sell some stuff. I can sell
some guns and stuff to pay you back.
***
Reynolds: What I’ll, what I’ll do—
Bob: Uh-huh.
Reynolds: If you can give her the thousand dollars, I think I can get a
thousand out of my guns. I’ll call my father up and I’ll ask
him if he’ll go try to sell them this week for me.
Bob: Uh-huh.
Reynolds: And that way I can get the money back this week. I don’t know.
I mean, if I was there I could take care of it, but I’m not there.
was on bond before and during the trial in direct violation of his conditions of
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in jail, and his proposed conduct of actually possessing them if the court grants him
bond, is both a felony violation of 18 U.S.C. § 922(g) and a further violation of his
bond conditions.
Conclusion
The defendant lied about his cancer diagnosis to the Court under oath. He
lied to his attorney and concealed facts about his mother’s health to gain his freedom.
multiple firearms in violation of federal law which he plans to possess if the court
releases him on bond. For a myriad of good reasons, including public safety and the
statutory presumption for detention, the Court should deny his motion for
reconsideration of bond.
Respectfully submitted,
MATTHEW SCHNEIDER
United States Attorney
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CERTIFICATE OF SERVICE
I hereby certify that on July 26, 2018, I electronically filed the foregoing
document with the Clerk of the Court using the ECF system, which will send
Stephen Rabaut
Attorney for Dean Reynolds
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