USA v. Kumar

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
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No. 2:25-cr-20032-SHL-1	v.
SANJEEV KUMAR,
Defendant.
ORDER ON OBJECTIONS TO TESTIMONY OF EMILY SELLS
Except for the sustained objections listed below, all objections to the recorded testimony
of Emily Sells on November 20, 2025, are overruled, and the objections themselves are to be
redacted from the recording. The Court notes that the AI-generated transcript provided by the
Government to the Court failed to highlight a few objections. The Government is directed to
thoroughly search the document for all instances of the word “object” for redaction.
For the sustained objections listed below, the portions of the recording surrounding the
sustained objections are to be redacted according to the timestamps. To the extent there is any
conflict with the timestamps and the testimony referenced here, it is the responsibility of the
Parties to raise the conflict with the Court by the close of court on Monday, December 15, 2025.
SUSTAINED OBJECTIONS
Part One Redactions
47:20–53:01
01:01:09–01:12:43
Gov’t continuing objection “to any questions
regarding [Sells’] health and/or why we are
doing the deposition”
01:25:20–01:27:22
01:29:13–01:30:06
Gov’t objection to Kumar Exhibit B, not
provided in reciprocal discovery and not
produced until the day of the testimony
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2
01:35:21–01:37:51 (leaving in Chapman’s
comment, “Alright. . . .”)
Gov’t objection to foundation
01:39:09–01:39:52 	Gov’t objection to foundation
01:43:07–01:46:06 	Gov’t objection to Kumar Exhibit B, not
provided in reciprocal discovery and not
produced until the day of the testimony
2:00:42 (after Sells’ statement, “I don’t”)–end 	Gov’t objection to Kumar Exhibit D, not
provided in reciprocal discovery and not
produced until the day of the testimony
Part Two Redactions
00:00–03:14 (including “Um, you, I’ll just
phrase it in a different way,” and leaving
in the next question, starting with “You
believe . . . ?”)
08:11–08:26 (through “Yes”)
09:06–09:32
Gov’t objection to Kumar Exhibit D, not
provided in reciprocal discovery and not
produced until the day of the testimony
09:42–21:50 (leaving in “You said earlier you
don’t recommend signing off or you don’t
recall signing off on a chart?”)
22:25 (including “And this is a perfect
example of”)–23:17
Gov’t objection to Kumar Exhibit B, not
provided in reciprocal discovery and not
produced until the day of the testimony
The segment 23:18–24:41 requires several pinpoint redactions due to the sustained objection
above. Redact the bold, stricken phrases below:
[11:46 AM / 23:18]
Defense Attorney Ron Chapman: Uh, was there a protocol that said that told
you not to document your patient visits after treatment in a note like this?
[11:47 AM / 23:29]
Emily Sells: No.
[11:47 AM / 23:30]
Defense Attorney Ron Chapman: Okay. What about failing to document on a
soap note like this, this electronic note? What about that made you feel like
your license was in jeopardy?
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3
[11:47 AM / 23:41]
Emily Sells: Um, what do you mean?
[11:47 AM / 23:42]
Defense Attorney Ron Chapman: You said I was worried about I being called
into court.
[11:47 AM / 23:46]
Emily Sells: Correct.
[11:47 AM / 23:46]
Defense Attorney Ron Chapman: What about your documentation made you
feel like you'd be called into court?
[11:47 AM / 23:50]
Emily Sells: Um, that there wasn't, uh, an official, um, you were taught in PA
school to have an HPIA physical exam? Um, a an objective section, a, um,
assessment and plan all in a note laid out nicely as they are in the pages that
you just showed me. Um,
[11:47 AM / 24:11]
Defense Attorney Ron Chapman: Okay. So you believe that your license is in
jeopardy because you didn't lay it out in the proper format?
[11:47 AM / 24:17]
Emily Sells: Because if anybody were to look at this new patient face sheet
from what I have written in this, uh, exam portion or diagnoses portion, um,
nobody knows what my little scribble of an X means except for myself. So to
me, this is documented to completeness to a court a X doesn't mean anything to
them.
31:59–33:10 (leaving in Chapman’s question,
“And you intended to move to Michigan,
correct?”)
Gov’t objection to relevance
35:02–35:15 (leaving in Chapman’s question,
“Okay. And when did you first learn that
you would move to Michigan?”)
Gov’t objection to relevance
35:38–35:48 (leaving in Chapman’s question,
“Okay. Did you author that letter?”)
Gov’t objection to relevance
42:14–43:39 	Gov’t objection to Kumar Bates 3305, not
provided in reciprocal discovery
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4
58:06 (after Chapman’s statement, “Um, at
this time I don’t have any further
questions.”)–01:00:38
Redact portion of redirect concerning Kumar
Exhibit D, objected to earlier by Gov’t
ADDITIONAL REDACTIONS
Part One Redactions
01:38:05–01:38:24 (through Chapman’s
comment, “That explains why nothing
was charging,” but leaving in his question,
“You were aware that after a procedure is
done . . . ?”)
Lawyers’ conversation about charging
electronic devices
Part Two Redactions
46:59–48:06 	Lawyers’ discussion of exhibits
52:34–52:52 	Lawyers’ conversation about an overruled
objection
57:28–58:05 	Lawyer statement without an answer that
follows
1:00:53–end 	Final housekeeping items
DOCUMENTS EXCLUDED
All documents produced by Kumar on the day of Emily Sells’ testimony for the first time
are excluded from evidence, including Kumar’s Exhibits A–E.
IT IS SO ORDERED, this 12th day of December, 2025.
s/ Sheryl H. Lipman
SHERYL H. LIPMAN
CHIEF UNITED STATES DISTRICT JUDGE
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