Legal & Investigative Analysis
Case: United States of America v. Christian Sanon, No. 22-20104-CR-BECERRA
U.S. District Court, Southern District of Florida
Trial scheduled to begin: September 28, 2026
This article analyzes federal court filings in the prosecution of Christian Sanon arising from the July 7, 2021 assassination of Haitian President Jovenel Moïse. Sanon is presumed innocent unless and until the government proves the charges against him beyond a reasonable doubt.
The question is no longer whether federal prosecutors are merely preserving the option of presenting evidence involving former First Lady Martine Moïse.
The government now says it intends to call her as a witness.
In its Government Final Trial Witness List, filed August 20, 2026, federal prosecutors identified 57 anticipated witnesses for their case-in-chief against Christian Sanon. The filing expressly states that the witnesses are intended for the trial scheduled to begin September 28, 2026.
Near the end of that list appears one of the most consequential names in the entire prosecution:
48) Martine Moise
Immediately after her is:
49) Jomarlie Moise
That changes the analysis substantially.
The government’s earlier exhibit list showed that prosecutors possessed Martine Moïse’s Jackson Memorial Hospital records and a bullet fragment associated with her treatment. But an exhibit list alone did not establish that she would personally testify.
The newly filed witness list does.
Subject to the government’s reservation that circumstances may change, federal prosecutors currently intend to put Martine Moïse on the witness stand in the prosecution of Christian Sanon.
And that could make her one of the most important witnesses of the trial.
The Government Has Built a 57-Witness Case
The witness list reveals the architecture of what prosecutors are preparing to present to the jury.
The first portion is heavily populated by federal investigators. Prosecutors list numerous FBI special agents, an FBI forensic accountant, an intelligence analyst, Homeland Security Investigations personnel and a Customs and Border Protection cargo official.
Then comes an unusually large group of digital-forensics specialists.
The government identifies FBI Senior Digital Forensic Examiners Bryan Jordan, Elizabeth Riddell, Easton Schlueter, David Mingarelli and Ricardo Soto, along with other current, former and retired FBI and HSI digital-forensics personnel.
That alone tells us something important about the prosecution’s strategy.
This is not going to be merely an eyewitness case.
It appears designed as a reconstruction case built from:
phones, messages, financial records, travel, digital extractions, forensic evidence, participant testimony and surviving witnesses.
Then Come the Participants
Perhaps the most consequential section of the government’s witness list begins at witness number 38.
The government says it intends to call:
Mario Antonio Palacios Palacios
German Alejandro Rivera Garcia
Joseph Joel John
Joseph Vincent
Frederick Bergmann Jr.
Rodolphe Jaar
Jacob Israel
Keegan Harricharan
Several of those names are especially significant because the government’s exhibit list separately includes plea agreements, factual proffers or judgments associated with them.
For example, the government’s proposed exhibits include the plea agreement, factual proffer and judgment of Joseph Joel John.
The same type of material is listed for Frederick Bergmann Jr.
And the government identifies plea-related records for Rodolphe Jaar, Joseph Vincent, Mario Antonio Palacios Palacios and German Alejandro Rivera Garcia.
This suggests that the Sanon trial will feature not simply government agents reconstructing events from documents, but people with direct knowledge of portions of the alleged conspiracy.
For prosecutors, those witnesses could provide the narrative linking meetings, money, travel, personnel and planning.
For the defense, they may become some of the most aggressively cross-examined witnesses in the case.
Martine Moïse Is Witness Number 48
After investigators, forensic specialists and alleged participants, the government turns to medical and civilian witnesses.
The sequence is striking:
46) Dr. Jean RC Armel Demorcy, Haiti Medical Examiner
47) Dr. Stephen Kalandiak, M.D., Jackson Memorial Hospital
48) Martine Moise
49) Jomarlie Moise
That ordering may or may not reflect the actual order in which the government will call witnesses, but it reveals a logical evidentiary grouping.
Dr. Demorcy is the Haitian medical examiner whose anticipated testimony concerns the autopsy of President Jovenel Moïse.
The government’s expert disclosure says Dr. Demorcy will testify that he performed the president’s autopsy on July 10, 2021; that Jovenel Moïse suffered 12 gunshot wounds; that he showed signs of asphyxia; and that he died as a result of the gunshot wounds. The government says Demorcy also recovered four bullet fragments from the president’s body.
Immediately following him on the witness list is a Jackson Memorial Hospital physician.
Then Martine Moïse.
That sequence is potentially important.
The Government Has Martine Moïse’s Medical Records and the Bullet Removed From Her Body
The government’s exhibit list already identified:
Government Exhibits 105A and 105A-1 — Martine Moise Certified Medical Records, Jackson Memorial Hospital
and
Government Exhibit 105B — Martine Moise Medical Evidence — sealed evidence bag containing one bullet fragment.
Now we know that the government also intends to call both a Jackson Memorial physician and Martine Moïse herself.
That creates a potentially powerful evidentiary chain.
The physician can potentially explain the medical treatment and recovery of physical evidence.
Martine Moïse can potentially describe what she personally experienced.
And the forensic experts can address what the physical evidence means.
Those are three different evidentiary functions.
What Could Martine Moïse Be Asked?
The witness list does not provide the substance of Martine Moïse’s expected testimony.
That limitation should be emphasized.
We do not yet have a filed witness summary saying exactly what prosecutors intend to ask her.
But based strictly on her position as a surviving witness and on the exhibits identified by the government, several subjects would be obvious areas prosecutors could seek to establish, subject to the judge’s evidentiary rulings.
She could potentially testify about her presence at the presidential residence, events she personally observed or heard during the attack, her own injuries, her subsequent medical treatment and other facts within her personal knowledge.
What she cannot automatically establish, however, is Christian Sanon’s criminal intent simply because she survived the attack.
That distinction could become one of the central issues of the trial.
Martine Moïse Can Describe the Crime — But Can She Connect Sanon to It?
This is where the legal significance of her testimony becomes more complicated.
Martine Moïse may be able to give jurors an intensely personal account of the attack that killed her husband and wounded her.
But the ultimate question in this particular trial is not simply:
Was President Jovenel Moïse assassinated?
The jury must determine whether the government has proven Christian Sanon’s own criminal responsibility for the charged offenses beyond a reasonable doubt.
If Martine Moïse did not personally observe Sanon participating in planning conversations or giving instructions, then her testimony about the physical attack would not by itself establish what Sanon knew or intended before the attack.
That is why prosecutors need the other witnesses.
Martine Moïse can potentially explain the endpoint.
Other witnesses must help establish the path that prosecutors contend led to that endpoint.
That Makes the Alleged Co-Conspirator Witnesses Critical
The government appears positioned to build that bridge through individuals who can potentially describe earlier events.
Consider the composition of the witness list again:
Palacios.
Rivera.
Joel John.
Vincent.
Bergmann.
Jaar.
Israel.
Harricharan.
The government can potentially use such witnesses to establish meetings, conversations, agreements, financing, travel arrangements, personnel decisions or changes in the alleged mission.
The defense, meanwhile, will likely focus intensely on credibility.
Any witness who entered a plea agreement or received some potential benefit from cooperation can ordinarily expect questions concerning bias, motive, prior inconsistent statements and what that witness hopes to obtain from the government.
That is standard adversarial testing in a criminal trial.
A jury may therefore have to decide not only what happened, but whom to believe.
The Government Is Preparing to Corroborate Human Witnesses With Phones
That is where the unusually large digital-forensics team becomes significant.
The government’s expert disclosure says FBI examiner Bryan Jordan worked on or assisted with forensic extraction or analysis of numerous phones, including three devices attributed to Christian Sanon.
Those include two Apple iPhones and a Motorola Stylus phone.
Digital devices attributed to other participants are also identified throughout the disclosure.
For prosecutors, phone evidence can serve a critical purpose:
corroboration.
A cooperating witness might say:
“We met.”
Phone-location information may potentially corroborate whether two devices were in the same place.
A witness might say:
“He sent me instructions.”
A message extraction may confirm, contradict or complicate that account.
A witness may remember an approximate date.
Travel records, calls, messages and financial transactions can establish a more precise timeline.
The government’s enormous investment in digital-forensics testimony suggests prosecutors do not intend to ask jurors simply to trust memories.
They intend to put electronic records beside those memories.
The Financial Evidence Could Be Just as Important
The government’s exhibit list contains extensive financial records, but one group stands out.
Government Exhibits 92A-D are described as master financial summaries addressing:
Funding Sources
Fund Draw Requests
Tactical Gear & Vests
Travel & Lodging
That sounds like the blueprint for a prosecution narrative.
Where did the money originate?
Who requested it?
What was purchased?
Who traveled?
Where did they stay?
How did personnel and equipment reach Haiti?
The financial witnesses—including the FBI forensic accountant listed as witness number 13—could therefore become crucial to tying together the testimony of the human participants.
Theodore Chavez Will Bring Ballistics Into the Case
The government’s first listed witness is FBI forensic examiner and physical scientist Theodore Chavez.
His expert disclosure says his specialty includes firearm and toolmark identification, gunshot-residue distance determination and shooting reconstruction.
That becomes particularly important when considered alongside the physical evidence recovered from Jovenel and Martine Moïse.
The exhibit list contains:
four bullet fragments recovered during Jovenel Moïse’s autopsy
and
one bullet fragment associated with Martine Moïse’s medical treatment.
Prosecutors can therefore present the jury with evidence operating on several different levels:
the victims;
the wounds;
the recovered projectiles;
the weapons evidence;
and the forensic methodology used to compare them.
Martine Moïse Will Not Be Testifying in Isolation
Another important name appears immediately after hers:
Jomarlie Moise
She is witness number 49.
The witness filing does not describe what testimony the government expects from her, so it would be irresponsible to speculate about its contents.
But her inclusion confirms that prosecutors intend to present more than one witness bearing the Moïse name during their case-in-chief.
That could add another eyewitness or contextual dimension to the government’s presentation, depending on the foundation ultimately established at trial.
A Witness List Is Not a Guarantee
There is one significant qualification.
Although the filing is titled the “Government Final Trial Witness List,” prosecutors expressly reserve the right to:
call additional witnesses,
update the witness list,
or
refrain from calling a listed witness.
Therefore the legally precise statement is:
The government currently intends to call Martine Moïse.
It is not accurate to say that her testimony is absolutely guaranteed until she actually takes the stand.
Trial strategy changes.
Witness availability changes.
Evidentiary rulings can alter the government’s presentation.
Stipulations can eliminate the need for certain testimony.
But this is now far more than speculation.
Her name appears on the government’s final trial witness list.
The Trial Could Now Have an Extraordinary Human Moment
Much of United States v. Christian Sanon threatens to be technically overwhelming.
Jurors may hear about Cellebrite extractions.
Bank accounts.
Wire transfers.
Flight manifests.
Corporate registrations.
Export-control regulations.
Ballistic comparisons.
Phone numbers.
Travel routes.
Financial summaries.
Dozens of individuals whose names may initially mean little to an American jury.
Martine Moïse changes that dynamic.
If she takes the witness stand, the assassination is no longer represented solely through diagrams, photographs and forensic reports.
A survivor of the attack will be sitting before the jury.
That has tremendous emotional power.
But Judge Becerra will still instruct jurors to decide the case from admissible evidence and the law.
Emotion cannot replace proof of Sanon’s individual guilt.
The Defense Faces a Difficult Strategic Decision
Cross-examining Martine Moïse will require exceptional care.
Defense counsel has both the right and the obligation to test prosecution testimony.
But there is also an obvious courtroom danger in appearing unnecessarily aggressive toward a woman who survived the attack in which her husband was assassinated.
The defense therefore may try to make a narrow legal distinction:
Martine Moïse can testify about the attack.
But:
What does she personally know about Christian Sanon’s alleged role before the attack?
Those are not necessarily the same thing.
A disciplined cross-examination could attempt to establish that distinction without challenging facts that are not genuinely contested.
The Most Important Question for Sanon May Come Before July 7
The government’s physical evidence can potentially establish what happened during the assassination.
Its medical witnesses can establish what happened to President and Mrs. Moïse.
Its forensic experts can interpret bullets, phones and other evidence.
But the prosecution still has to connect Christian Sanon to the criminal conduct alleged in the indictment.
That likely makes the months and weeks before July 7, 2021 crucial.
Who met whom?
Who said what?
Who knew what the mission was?
Did the objective change?
If it changed, when?
Who knew about that change?
Who paid for personnel and equipment?
Who authorized expenditures?
What did Sanon understand?
What did Sanon intend?
Those questions may ultimately matter more to Sanon’s criminal liability than who fired which weapon.
The Government Appears to Have Designed the Case in Layers
Reading the witness list together with the exhibit list reveals what looks like a carefully layered prosecution.
Layer One: Federal Investigators
FBI and HSI agents explain the investigation and evidence collection.
Layer Two: Digital Evidence
A large team of forensic examiners authenticates and explains phones and computers.
Layer Three: Money
A forensic accountant and financial records reconstruct financing.
Layer Four: Participants
Palacios, Rivera, Joel John, Vincent, Bergmann, Jaar, Israel and others potentially describe events from inside portions of the alleged operation.
Layer Five: Forensic Medicine
Dr. Demorcy explains President Moïse’s autopsy.
A Jackson Memorial physician can address medical evidence concerning Martine Moïse.
Layer Six: Survivors and Moïse Witnesses
Martine Moïse and Jomarlie Moise appear on the witness list.
Layer Seven: Corroboration
Maps, photographs, drone footage, financial summaries, weapons evidence, phone extractions, travel records and physical exhibits reinforce or challenge the human testimony.
That combination could create a formidable circumstantial and testimonial case.
But the jury still must evaluate every link.
Martine Moïse Is Now Officially Part of the Government’s Trial Plan
The most important correction to our earlier analysis is therefore straightforward.
Before the witness list became available, the government’s exhibits showed that Martine Moïse was part of the evidence.
Now the government’s own filing establishes that she is also intended to be part of the testimony.
Her name appears as Witness No. 48 on the government’s final trial witness list.
That raises the stakes considerably.
For prosecutors, she can potentially put a survivor’s voice behind physical evidence that otherwise exists only in hospital records and sealed evidence bags.
For the defense, her appearance presents both a constitutional opportunity for cross-examination and a delicate strategic problem.
For Haitians following the case, her testimony could represent something still larger.
More than five years after gunmen entered the presidential residence and Jovenel Moïse was killed, his surviving widow may finally recount portions of that night before a U.S. federal jury in a trial arising directly from the alleged conspiracy.
But after she leaves the witness stand, the central legal question will remain unchanged:
What does the evidence prove about Christian Sanon?
Not simply about the assassination.
Not simply about the men who entered the residence.
Not simply about the political chaos surrounding Haiti in 2021.
But about Sanon’s knowledge, intent, agreements and actions.
That is the question the government must prove beyond a reasonable doubt beginning September 28.
And the newly disclosed witness list shows that prosecutors intend to answer it with virtually every type of evidence available:
participants, investigators, experts, phones, money, medicine, ballistics—and now, Martine Moïse herself.
