Subpoena

United States Department of Justice United States Attorney District of Connecticut (203)821-3700 Fax (203) 773-5378 www.justice.gov/usao/ct State of Connecticut Minority Business Initiative Re: Non-Disclosure of Subpoena Dear Custodian of Records: The attached grand jury subpoena issued on July 31, 2025 is returnable on August 19, 2025 before the federal grand jury sitting that date in New Haven, Connecticut. The subpoena requests that the Custodian of Records produce certain documents described in Attachment A to the subpoena. In lieu of appearing before the grand jury, the Custodian of Records may comply with the subpoena by producing the responsive records to Special Agent Brian Conklin, Federal Bureau of Investigation (FBI), 600 State Street, New Haven, Connecticut 06511, telephone (203) 630-5940, email: [email protected], on or before the grand jury date. You are requested not to disclose the existence of this subpoena or its contents. Disclosure of the subpoena, or its contents, may impede an ongoing federal grand jury investigation into the possible commission of a felony, and consequently may interfere with the enforcement of federal law. Therefore, before you disclose the existence and/or the contents of this subpoena, please contact SA Conklin. We also request that the Custodian of Records at your institution complete the attached declaration for any business records that are produced pursuant to this subpoena, to the extent that such records meet the conditions set forth in the declaration–that is, (1) that the records were made at or near the time of the occurrence of the matters set forth in the records, by a person with knowledge of those matters or from information transmitted by such a person, and (2) that these records are made, and are kept, as a regular practice in the ordinary course of business. Completion of this declaration will significantly reduce the chances that you will be called as a witness at any future trial, where these documents might be offered as evidence. Very truly yours, DAVID X. SULLIVAN UNITED STATES ATTORNEY JONATHAN N. FRANCIS ASSISTANT UNITED STATES ATTORNEY JNF:sel Enclosure Connecticut Financial Center 157 Church Street, 25th Floor New Haven, Connecticut 06510 July 31, 2025 AO 110 (Rev. 06/09) Subpoena to Testify Before a Grand Jury UNITED STATES DISTRICT COURT for the __________ District of __________ SUBPOENA TO TESTIFY BEFORE A GRAND JURY To: YOU ARE COMMANDED to appear in this United States district court at the time, date, and place shown below to testify before the court’s grand jury. When you arrive, you must remain at the court until the judge or a court officer allows you to leave. Place: Date and Time: You must also bring with you the following documents, electronically stored information, or objects (blank if not applicable): Date: CLERK OF COURT Signature of Clerk or Deputy Clerk The name, address, e-mail, and telephone number of the United States attorney, or assistant United States attorney, who requests this subpoena, are: F COURT Signature of Clerk or Deputy Clerk ttorney or assistant United States attorn District of Connecticut 07/31/2025 GJ N-24-1-260 (186) SA Brian Conklin, FBI State of Connecticut Department of Economic and Community Development Robert N. Giaimo Federal Building 150 Court Street, Room 125 New Haven, CT 06510 Grand Jury Room August 19, 2025 at 9:00 a.m. See Attachment A. Note: Please include a copy of this subpoena with any materials or records produced. In lieu of personally appearing before the Grand Jury, these records may be provided to Special Agent Brian Conklin, Federal Bureau of Investigation (FBI), 600 State Street, New Haven, Connecticut 06511, telephone (203) 630-5940, email: [email protected], on or before the Grand Jury date. Jonathan N. Francis, Assistant United States Attorney U.S. Attorney's Office, District of Connecticut 157 Church Street, 25th Fl. New Haven, CT 06510 Tel. 203-821-3700 ATTACHMENT A – GRAND JURY MATTER N-24-1-260 (186) – Page 1 of 3 TO: State of Connecticut Minority Business Initiative I. INSTRUCTIONS A. In complying with this subpoena, you are required to produce all responsive documents that are in your possession, custody, or control, whether held by you or your past or present agent, employee or representative acting on your behalf. You are also required to produce documents that you have a legal right to obtain, that you have a right to copy, or to which you have access, as well as documents that you have placed in the temporary possession, custody or control of any third party. B. No documents called for by this request shall be destroyed, modified, removed, transferred, or otherwise made inaccessible to the grand jury. If you have knowledge that any subpoenaed document has been destroyed, discarded or lost, identify the subpoenaed document and provide an explanation of the destruction, discarding, loss, or disposal, and the date at which the document was destroyed, discarded, or lost. C. This subpoena is continuing in nature. Any document not produced because it has not been located or discovered by the return date shall be provided immediately upon location or discovery subsequent thereto with an explanation of why it was not located or discovered until the return date. D. If you believe any responsive documents are protected by a privilege, please provide a privilege log which (1) identifies any and all responsive documents to which the privilege is asserted, (2) sets forth the date, type, addressee(s), author(s), general subject matter, and indicated or known circulation of the document, and (3) states the privilege asserted in sufficient detail to ascertain the validity of the claim of privilege. E. Production with respect to each document shall include all electronic versions and data files from email applications, as well as from word processing, spreadsheet, database, or other electronic data repositories applicable to any attachments, and shall be provided to the grand jury where possible in its native file format and shall include all original metadata for each electronic documents or data file. II. DEFINITIONS A. “Document” means any written, recorded or graphic material of any kind that is in your possession, custody or control, including communications. B. “Communications” refers to transmittal of information in any form, whether written, electronic, e-mail, text, telephone, or other, and is meant to be interpreted broadly in accordance with Federal Law. C. “Concerning” means relating to, discussing, describing, reflecting, regarding, containing, analyzing, studying, reporting, commenting on, evidencing, constituting, setting forth, considering, recommending, or pertaining to, in whole or in part. ATTACHMENT A – GRAND JURY MATTER N-24-1-260 (186) – Page 2 of 3 D. Any entity or party identified by name shall be construed broadly to include any parent, subsidiary, affiliate, successor-in-interest, joint venture, or related corporate entity, as well as any employee, representative, agent, contractor, affiliate, or vendor. E. The terms “all,” “any,” and “each” must each be construed as encompassing any and all. F. The connectives “and” and “or” must be construed either disjunctively or conjunctively as necessary to bring within the scope of the request all responses that might otherwise be construed to be outside of its scope. G. The use of the singular form of any word includes the plural and vice versa. III. DOCUMENTS REQUIRED: For the period January 1, 2020 to the present: 1) All documents concerning any grants, loans, or funding from the recipient to any of the following entities: Blue Hills Civic Association Inc.; Girls For Technology Inc.; Upper Albany Neighborhood Collaborative, Inc.; Society of Human Engagement and Businesses Alignment, LLC; SHEBA, LLC; SHEBA Resource Center Inc.; SHEBA Consulting LLC; The Prosperity Foundation Inc.; The Legacy Foundation of Hartford Inc.; HEDCO Inc.; YMCA of Greater Hartford; and KTH Advisors LLC. 2) All communications between the recipient (including but not limited to current and former members of the Minority Business Initiative Advisory Council) and any of the following: Douglas McCrory; Sonserae Cicero￾Hamlin; Vicki Gallon-Clark; Mary Young; Kevin T. Henry; Sabrina Tucker-Barrett; Anthony Barrett; Howard K. Hill; Greg Jones; Kim Hawkins; and Ira Revels. 3) All communications with Douglas McCrory with respect to Sonserae Cicero-Hamlin, Society of Human Engagement and Businesses Alignment, LLC, SHEBA, LLC, SHEBA Resource Center Inc., or SHEBA Consulting LLC. 4) All documents concerning any personal or non-professional relationship between Douglas McCrory and Sonserae Cicero-Hamlin. 5) All documents concerning any factual misrepresentation or omissions used to obtain or attempt to obtain grants, loans, or funding of which the recipient is aware. 6) All documents concerning any violations of federal law of which the recipient is aware, including but not limited to violations of Title 18, United States Code, §§ 371 (conspiracy), 666 (bribery concerning programs receiving Federal funds), 1343 (wire fraud), 1346 (honest services wire fraud), 1349 (conspiracy), 1951 (interference with commerce by threat of economic harm or under color of official right), and 1956 (money laundering). 7) Documents, such as organizational charts, reflecting current and former members of the Minority Business Initiative Advisory Council. 8) All agendas and minutes of Minority Business Initiative Advisory Council meetings. ATTACHMENT A – GRAND JURY MATTER N-24-1-260 (186) – Page 3 of 3 RECORDS FORMAT: Records are requested in the form of electronic media. Please see attached instructions for Production of Electronically Stored Records. Note: Please include a copy of this subpoena with any materials or records produced. IN LIEU OF YOUR PERSONAL APPEARANCE BEFORE THE GRAND JURY, subpoenaed materials may be produced to Special Agent Brian Conklin, Federal Bureau of Investigation (FBI), 600 State Street, New Haven, Connecticut 06511, telephone (203) 630-5940, email: [email protected], or any other duly authorized Special Agent of the Federal Bureau of Investigation on or before the date of the grand jury session. AO 110 (Rev. 06/09) Subpoena to Testify Before Grand Jury (Page 2) PROOF OF SERVICE This subpoena for (name of individual or organization) was received by me on (date) . u I served the subpoena by delivering a copy to the named person as follows: on (date) ; or u I returned the subpoena unexecuted because: . I declare under penalty of perjury that this information is true. Date: Server’s signature Printed name and title Server’s address Additional information regarding attempted service, etc: CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO FEDERAL RULES OF EVIDENCE 902(11) AND 902(13) I, _________________________________, declare, under penalties of perjury by the laws of the United States of America pursuant to 28 U.S.C. § 1746, that the information contained in this certification is true and correct. I am employed by ______________________________ (hereinafter the “entity”), and my title is ______________________________. I am qualified to authenticate the records attached hereto because I am familiar with how the records were created, managed, stored, and retrieved. I state that the records attached hereto are true duplicates of the original records in the custody of the entity. The attached records consist of ______________ ____________________________________________________________. I further state that: a. all records attached to this certificate were made at or near the time of the occurrence of the matter set forth by, or from information transmitted by, a person with knowledge of those matters, they were kept in the ordinary course of the regularly conducted business activity of the entity, and they were made by the entity as a regular practice; and b. such records were generated by the entity’s electronic process or system that produces an accurate result, to wit: 1. the records were copied from electronic device(s), storage medium(s), or file(s) in the custody of the entity in a manner to ensure that they are true duplicates of the original records; and 2. the process or system is regularly verified by the entity, and at all times pertinent to the records certified here the process and system functioned properly and normally. I further state that this certification is intended to satisfy Rules 902(11) and 902(13) of the Federal Rules of Evidence. Executed on: Date Signature Name Company Title Generally describe records (Pages/CDs/DVDs/Drives/Megabytes) USAO-DCT-Production Specs-2021.pdf Specification Modifications Any modifications may be done only with the express permission of the government. Any questions about these production specifications should be raised with the government prior to the first production. The cover letter associated with the production should list the Bates range of the documents provided on the production media. Also included in the cover letter should be a sentence stating what time zone the documents were processed. If technology-assisted review (TAR) or artificial intelligence software (of any kind), will be used in order to categorize data into relevant and non-relevant groups for the purposes of responding to the Government’s demand, please disclose your intentions to the Government before proceeding. Document Numbering – Page level Bates numbering • All pages of a document must be assigned a unique and sequential Bates number. • The Bates number must be endorsed on the image. • Native filesmust be assigned a single Bates number and the file will be named asthat number; the image placeholder will have the same number endorsed on the image. • Bates numbers must consist of a prefix, leading zeros, and sequential numbering at the pagelevel. • Numbering should be padded out 8 digits, e.g., ABC00000001; If there will be rolling productions the number of digits should never change. • Please NO spaces between the prefix and numbers; underscores ( _ )and hyphens ( - )are allowed. • If the maximum number will be reached (e.g., ABC9999999), then notify the Lit Tech PM todiscuss how to proceed. • If suffixing is necessary, a period will be used as the separator and all pages of the document will have the same number as the first page: ABC0000001 ABC0000001.001 ABC0000001.002 Deliverables • Data should be provided on CD, DVD, or an external hard drive/USB thumb drive. • We will provide accessto our file sharing site (USAfx) for use in uploading smaller productions (please contact the paralegal on the case to be set up). USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT AUGUST 2021 USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 2 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Images • All images must be provided as Bates endorsed single page TIFF Group IV format for black and white or single page JPG for color. o Photos and graphic files (JPG, GIF, PNG, etc.) should be provided in color. o Document file types (doc, pdf, msg, ppt, etc.) should be provided black and white. • Images for a document must not span multiple folders. • The maximum number of images in a folder should be limited to 10,000 per folder • Provide the native file for each document. • Native file names must match the BEGBATES for the record, which will match the number endorsed on the image of the first page. • The maximum number of native filesin a subfoldershould be limited to 10,000 perfolder. Text • Must be document level. • Extracted text should be provided with all records where possible, otherwise OCR text should be provided (e.g., hard copy, redacted, image files). • The text file should be named after the BEGBATES number of the associated record. • The document text should not be included within the load file, only the path to the text file will be provided in the load file. Load File Formats • Metadata Load file – .dat file – One line for every record; First row contains field headers. Field order must remain consistent in subsequent productions Field Separator ¶ (ASCII 020) Text Qualifier þ (ASCII 254) New Line ® (ASCII 174) Multi-value Separator ; (ASCII 059) o See Attachment 1 - Table of Requested Fields for Electronic Documents list for required metadata/database fields to be included in the .dat file (page 5). • Image Load file – .LFP or .OPT – one line for every page Email, Attachments, Calendar Items, and Contacts • Email must be produced as image files (see Images section above) with related searchabletext, metadata. • The parent/child relationships must be preserved. • When providing Lotus Notes as native, convert to MHTML. Attachments • Preferred method (processing software permitting), graphic objects embedded in emails and other documents such as logos, letterheads or backgrounds, must remain as part of the document and not be extracted as attached separate documents. • Be sure the parent/child relationship is reflected in the BATESBEGATT and BATESENDATT fields. USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 3 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Electronic Documents • Electronic documents include any user-generated files (word-processing documents, PDFs etc.) and all other electronic files not specifically discussed elsewhere. These files must be produced as image files (see specs above) and natives with metadata and searchable text for the entire document. • Hidden Text – All hidden text (track changes, hidden slides, notes, etc.) will be expanded and rendered in the image file. Spreadsheets and Presentations • Spreadsheets and presentations (e.g., XLS, PPT, etc.) must be produced in native format, with associated metadata and searchable text for the entire document. A Bates endorsed placeholder image for each spreadsheet must be provided. The data load file should include a relative path to the native file. The native file will be named as the BEGBATES number. • Presentations should be imaged, with speaker notes showing. Multimedia Files • Multimedia files (e.g., MP3, MP4, AVI, etc.) must be produced in native format with associated metadata. A Bates endorsed placeholder image for each multimedia file must be provided. The native file will be named as the BEGBATES number. Time Zone • Process the documents in the local time zone and populate that value in the TimeZoneProcessed field. De-duplication Method • De-duplication should be performed globally, across all custodians and documents using the MD5 Hash value. • Emails and their attachments should be kept together when de-duping (keep families together). No loose files should be deduped against email attachments. • All files and metadata for the duplicate documents excluded during de-duplication must be preserved and available for production upon request. Custodian Overlay – Duplicates • A Custodian overlay file isto be provided when de-duping globally and data is being produced on a rolling basis. • Fields to include in the overlay file provided with every production after the first where de￾duplication has occurred: BATESBEGIN BATESBEGIN for each document being updated DUPE_CUSTODIANS All Custodians who had the document before de-duplication DUPE_FILEPATHS All Filepaths of the document before de-duplication DUPE_FOLDERS All Folders (email folder) of the document before de-duplication USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 4 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Text Messages Preferred Format: One Excel spreadsheet per conversation thread, which includes the metadata fieldslisted in Attachment 2 - Text Field List file (page 7). Acceptable Format: Single page text with the Body and all metadata fields included on the image or text file produced. Conversation texts and attachments must be in date/time order Not Acceptable: Screenshots of texts or texts without metadata fields detailing all parties, dates, timestamps, delete status, read status, tags and Thread ID. These fields are necessary in order to understand the entire conversation (original text and all replies). Proprietary Software Cellebrite • Provide as .UFDR file Social Media • Prior to producing any Social Media (Facebook, Instagram, Twitter, etc.), please contact the Lit Tech PM assigned to the case. Workplace Apps • Priorto producing any workplace chat messaging apps(Skype, Telegram, Slack, Zoom, MS Teams, WhatsApp, etc.), please contact the Lit Tech PM assigned to the case. o Preferred format isthreaded conversations withmetadata (To, From, Date, Time, message content, attachments). Structured Data/Relational Data • Prior to producing any structured database (e.g., Oracle, SQL, Access, QuickBooks, Call Center / Audio databases), please provide a field and table list, the assigned Lit Tech PM will reach out to discuss further. Audio/Video • Proprietary audio or video (e.g., HAWK, RealPlayer, jail calls, pole cam, etc.) should be converted to appropriate file types such as .wav, .mp3, .mp4, containing all timestamps, etc. Exception Logs • An exception log will be provided which documents any processing issues. • Any documents unable to be imaged will be slip sheeted with a Bates endorsed image containingthe error message and included as natives. • If no text can be extracted for un-imaged documents, the text provided must contain the error message. Privilege Logs • Will be provided to the team in electronic format, such as Excel, as well as within an email to the team and/or on the media containing the production. USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 5 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Paper Documents • Scan and provide: o single page, Bates stamped TIFF Group IV format images o document level OCR text o .DAT containing the fields provided in the attached Paper Fields Chart 2 o .LFP or .OPT for loading images. USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 6 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Attachment 1 – Table of Requested Fields for Electronic Documents: Field Name Description BatesBegin Start Bates (including prefix) -- No spaces or special characters. MUST BE UNIQUE. BatesEnd End Bates (including prefix) -- No spaces or special characters. BatesBegAtt BEGDOC value (including prefix) of the parent document in the family group, populated for all records in the family group. Empty for any records NOT in a family grouping. BatesEndAtt ENDDOC value (including prefix) of the last document in the family group. Populated for all records in the family group. Empty for any records NOT in a family grouping. Custodian Individual Custodian Name/Shared Resource Name --format: Last, First or ABC Dept. Use consistent naming and formatting across all productions. FileName File name of electronic file (loose electronic files or attachments to Email). FilePath The local path to the original file from where it was collected; e.g. C:\My Documents\Sales Info\ACME Author Author field value extracted from the metadata of an electronic file. LastAuthor Last Saved By field value extracted from metadata of an electronic file. FileExt File extension of an electronic file. NativePath Path to the Exported / Processed Native File. Application Application used to create the electronic file (e.g., Excel, Outlook, Word). FileDescription Description of electronic file type; e.g. MS Word. RecordType lists the type of record for each file; e.g. Loose Email; Email; Edoc; etc. DateCreated Date the electronic file was created; MM/DD/YYYY TimeCreated Time the electronic file was created. DateLastMod Date the electronic file was last modified; MM/DD/YYYY TimeLastMod Time the electronic file was last modified. DateLastPrnt Date the electronic file was last printed; MM/DD/YYYY TimeLastPrnt Time the electronic file was last printed. DupeCustodians Names of custodians containing duplicate versions of the original file. DocTitle Title of the electronic document. MailStorePath Original path to the mailstore location DateSent Date the Email or Calendar item was sent; MM/DD/YYYY TimeSent Time the Email or Calendar item was sent. DateRcvd Date the Email or Calendar item was received; MM/DD/YYYY TimeRcvd Time the Email or Calendar item was received. To Recipients of the Email or Calendar Item (as formatted on the original). From Author of the Email or Calendar item (as formatted on the original). CC The complete list of all names and emails of all individuals contained in the "CC" field of the email. USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 7 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Field Name Description BCC The complete list of all names and emails of all individuals contained in the "BCC" field of the email. EmailSubject Email or calendar item subject. AttachCount The number of attachments any given item possesses (email attachments, zip file contents). AttachNames List of attachment file names Headers Contents of the header in an email message. Conversation Email Thread Identification generated by the email application (Outlook). MessageClass Outlook Email - Mail item class (Note, Report, Meeting, etc.); e.g. IPM.note MessageID Email message id Company_Properties Company field extracted from the electronic files metadata Categories_Properties Categories field extracted from the electronic files metadata Comments_Properties Comments field extracted from the electronic files metadata Keywords_Properties Keyword field extracted from the electronic files metadata FileSize File size in Bytes (integer value only - do not include unit of measure, thousands character, or decimal places PageCount Number of images for the electronic file. Revision Revision number extracted from metadata of electronic file. ProdVolume Production volume number; PROD001 DupeFilePaths File path to each duplicate version of the original record. MD5Hash Document MD5 hash value (used for deduplication). Sha1Hash Document SHA1 hash value DupStatus Dedupe status; N = Not a dup; G = Global-level Duplicate; P = Parent Duplicate Encrypted e.g. Y, N TextPath Folder path to the extracted or OCR text files Source Entity name of producing party (not law firm or vendor name). DocSubject Subject field value extracted from metadata of electronic file. TimeZoneProcessed Time zone the electronic files were processed in. SubResponseNum Subpoena number(s) which the electronic file is in response to USAO District of Connecticut Production Specifications UNITED STATES ATTORNEY’S OFFICE – DISTRICT OF CONNECTICUT ~ 8 ~ USAO-DCT-Production Specs-2021.pdf AUGUST 2021 Attachment 2 – Text Field List: Field Name Example Device Name / ID Ex: iPhone 8, S/N # Message / Chat ID Similar to a BatesBegAttach field Direction Ex: Incoming /Outgoing Start Time: Date Start Time: Time Last Activity: Date Last Activity: Time Participants Number of Attachments Deleted - Chat Ex: Yes Tag Note - Chat From Ex: Phone # & name To Ex: Phone # & name Subject Body Status Ex: read / sent/ deleted Location Timestamp: Date Timestamp: Time Delivered: Date Delivered: Time Read: Date Read: Time Attachment #1 Ex: File name Attachment #2 Deleted - Instant Message Tag Note - Instant Message Starred Message