Grand Jury

United States Department of Justice United States Attorney District of Connecticut Connecticut Financial Center (203)821-3 700 157 Church Street, 25th Floor Fax (203) 773-5376 New Haven, Connecticut 06510 February 4, 2019 City of Bridgeport Attn: Of?ce of the City Attorney 999 Broad Street, 2nd Floor Bridgeport, CT 06604 Re: Non?Disclosure of Subpoena Dear Custodian of Records: The attached grand jury subpoena issued on February 4, 2019 is returnable on February 12, 2019 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 the Attachment A. In lieu of appearing before the grand jury, the Custodian of Records may comply with the subpoena by producing the responsive records SA Paul M. Takla, Federal Bureau of Investigation, 1000 Lafayette Boulevard, Suite 306, Bridgeport, CT 06604, on or before the grand jury date. Title 12, United States Code, Section 34 l3(i), exempts subpoenas issued by a Federal Grand Jury from the disclosure provisions of the Right to Financial Privacy Act of 1978. 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 Special Agent Takla at 203-382?6667. 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, (I) 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 tran5mitted 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 signi?cantly reduce the chances that you will be called as a witness at any ?iture trial, where these documents might be offered as evidence. Very truly yours, JOHN H. DURHAM US. DEPARTMENT OF JUSTICE UNITED ST ATTORNEY FEDERAL BUREAU OF INVESTIGATION NATHAN N. FRANCIS Paul M. Takla ASSISTANT UNITED STATES ATTORNEY Special Agent Telephone: (203) 382-6667 1000 Lafayette Blvd. Cell: (646) 341-0467 Suite 306 Bridgeport, CT 06604 Email: paul.takla@ic tbigov AD (Rev. 06:139) Subpoena to Testify Before-a Grand Jury UNITED STATES DISTRICT COURT for the GI (34) District of Connecticut Paul Takla, FBI SUBPOENA T0 TESTIFY BEFORE A GRAND JURY City of Bridgeport . Ann: Office of the City Attorney To. 999 Broad Street, 2nd Floor Bridgeport, CT 06604 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 of?cer allows you to leave. Date and Time: Grand Jury Room Place: Robert N. Giaimo Federal Building 150 Court Street. Room 125 New Haven? CT 06510 February 12, 2019 at 9200 3.111. You must also bring with you the following documents, electronically stored information, or objects (blank ifnor applicable) 2 See Attachment A. . Magi Note." Ptease include a copy subpoena with any matertais or recurds ?219.15? . produced. In lieu afloat-retrain: appearing. these records may be provided to SA A, r. Paul M. Tahiti. Federal Bureau of Investigation. 3900 Lafayette Boulevard ?w 41' Suite 306. Bridgeport, 06604. teiephone number (203) 382u66t57. e?mai! 33% address pmrakia?c?fbigov, before the Grand Jury dare. Date: 02/04/2019 CLERK OF 1 . Signatu :3 {be -- mm) - The name, address, e-mail, and telephone number of the United States attorney, or assistant United States attorney, who requests this subpoena, are: Jonathan N. Francis, Assistant Unit States ttemey US. Attomey's Office, District of onnectieut 157 Church Street, 25th Fl. New Haven, CT 06510 Tel. 203-8214; 700 Control No. 1135 ATTACHMENT A - GRAND JURY Page 1 of 1 TO: City of Bridgeport Attn: Of?ce of the City Attorney 999 Broad Street, 2nd Floor Bridgeport, CT 06604 RECORDS REQUESTED: 1. For the period January 1, 2015 to November 8, 2018, please provide any and all documents, records and communications related to the sale of the City of Bridgeport?s scrap metal. This includes reports, complaints, contracts, agreements, bids, invoices, receipts, payments, records of meetings, emails, text messages, voicemaiis, and other correspondence. Please do not include in your response any materials from the Labor Relations Department?s investigative ?les or that were created during the investigation undertaken by Senior Labor Relations Of?cer Philip J. White after October 2018, including any reports, communications, or interview notes or recordings. 2. For the period January 1, 2015 to the present, please provide ail records and communications concerning the following: a. G. Pic and Sons Construction Company; b. Seaview Equipment Sales Rental; and c. Vaz Quality Works LLC. This includes reports, complaints, contracts, agreements, bids, invoices, receipts, payments, records of meetings, emails, text messages, voicemails, and other correspondence. RECORDS FORMAT: Records are requested in the form of electronic media. Please see attached instructions for Production of Electronically Stored Records. IN LIEU OF YOUR PERSONAL APPEARANCE BEFORE THE GRAND JURY, subpoenaed materials may be sent to SA Paul M. Takla, Federal Bureau of Investigation, 1000 Lafayette Boulevard, Suite 306, Bridgeport, CT 06604, telephone number (203) 382-6667, e- mail address gov. CERTIFICATE OF RECORDS hereby certify that: I am the custodian of records at (?the Company?), located at I have examined the records of the Company, and they contain the attached documents, each of which is the original or the duplicate of the original records, described more particularly as These records were made at or near the time of the occurrence of the matters set forth therein, by a person with knowledge of these matters or from information transmitted by such a person. These records were kept in the course of a regularly conducted activity of the Company. Making these records was a regular practice of that activity. I certify under penalty of peljury that the foregoing is true and correct. Executed on in (date) (State) (City) Name: Address: Telephone number: United States Department of Justice United States Attorney District of Connecticut INSTRUCTIONS FOR PRODUCTION OF ELECTRONICALLY (DIGITAL) STORED RECORDS This document details the data formatting speci?cations required for data submitted to the US. Attomey?s Of?ce (USAO) in response to litigation. The Government currently uses Concordance 10.06) and IPRO (ver 8.6). ANY VARIAN CE FROM THESE STANDARDS MUST BE FEE-APPROVED. A. MEDIA All data and image deliveries must be made on CD, DVD, or USB 2.0 external hard drive. B. DATA FORMAT Data should be delivered in one of two formats: 1. As a Concordance database (.dcb) In most instances, the StartBates should be the Image Key ?eld unless another ?eld has been designated the key ?eld by the Government. All ?elds should be indexed. Note: [fth is method is chosen, and there will be more than one production, please con?rm the database ?elds and structure remain consistent between data deliveries. 2. As an ASCII delimited text ?le (.dat) If this method is chosen, please adhere to the following: The ?rst line of the text ?le must contain the ?eld names. 4? The delimiters used should be the Concordance standards, of: comma (ASCII character 020), quote (ASCII character 254), and newline (ASCII character 174). Produce a page header indicator in the following format, <<batesno>>, on a separate line for every page Page I C. DELIVERED FIELDS The database or load ?le provided must contain, at minimum, the ?rst and last Bates number for each document, and all applicable OCR text. OCR text should be incorporated directly in either the Concordance database or the ASCII load ?le, and not delivered in separate text ?les. D. IMAGEICROSS REFERENCE FILE GUIDELINES I. IMAGE FORMAT 1. TIFF Single page (Preffered) 0R '3 Documents should be scanned at 300 dpi, as single-page CCITT Group IV TIFF ?les. Til-3F ?le names should match the assigned Bates number of the underlying document page, should be unique, and sequentially numbered. PDF ?les will be accepted only after a consultation between the provider and USAO technical SUpport staff. Multi-page TIFF ?les are strongly discouraged. Bates numbers should be electronically ?endorsed? onto images. The ?le name assigned to the image should match the underlying document?s Bates number. Bates numbers should be alpha- numeric, with the numeric portion of the stamp being ?zero-?lled?. As an example, an assigned Bales numbered series of documents such as would be unacceptable, whereas is preferred. 0 0 Images should be placed on delivered media in a master folder named XIMAGES. 2. PDF Multi-page (text searchable) II. CROSS-REFERENCE FILE 1. Tiff ?les must be accompanied with an image ?cross-reference preferably in .lfp format. This ?le associates each bates number with its corresponding single- page TIFF file name and indicates its location on the media provided. The ?le should contain one line for every page in the collection, and must contain the document Bates number and the full DOS path to the image, beginning with the media volume. Below is a sample ?le: Page 2 E. NATIVE FILES With the exception of spreadsheets, electronic ?les should not be provided in their original or ?native? format, but should be put through an electronic conversion (e-conversion) process, in which single-page TIFF images are created from all underlying document pages, and all text and applicable metadata from these ?les is extracted. Data, images, and image cross? reference ?les resulting from this process should follow the formatting speci?cations detailed in the sections above. Spreadsheets (such Microsoft Excel or Lotus 1-2-3) should be provided in both 6? converted and native format. F. SECURITY All submissions of electronic data to the USAO must be free of computer viruses. In addition, any passwords protecting ?les or media must be removed or provided. Rev. October 2013 Page 3 RECORDS REQUESTED: 1. For the period January 1, 2015 to November 8, 2018, please provide an}.r and all documents, records and communications related to the sale of the City of Bridgeport?s scrap metal. This includes reports, complaints, contracts, agreements, bids, invoices, receipts, payments, records of meetings, emails, text messages, voicemails, and other correspondence. Please do not include in your response any materials from the Labor Relations Department?s investigative ?les or that were created during the investigation undertaken by Senior Labor Relations Of?cer Philip J. White after October 2013, including any reports, communications, or interview notes or recordings. 2.. For the period January i, 2015 to the present, please provide all records and communications concerning the following: a. G. Pie and Sons Construction Company; h. Seaview Equipment Sales Rental; and c. Vast Quality Works LLC. This includes reports, complaints, contracts, agreements, bids, invoices, receipts, payments, records of meetings, emails, text messages, voicemails, and other correspondence. 'v FR HEEST 5 THE no A. MEDIA All data and image deliveries must be made on CD, DVD, or USB 2.0 external hard drive- B. DATA FORMAT Data should be delivered in one of two formats: I. As a Concordance database (.dcb) In most instances, the StartBates should be the Image Key ?eld unless another ?eld has been designated the key ?eld 6 All ?elds should be indexed. Nate: ?rst: method is chosen, and (here wit? be more than one production, please con?rm the database ?elds and structure remain consistent between data deliveries. 2. As an ASCII delimited text ?le (.dat) If this method is chosen, please adhere to the following: The ?rst line of the text ?le must contain the ?eld names. The delimiters used should be the Concordance standards, of: comma (ASCII character 020), quote (ASCII character 254), and newline (ASCII character 174). Produce a page header indicator in the following fonnat, <<batesno>>, on a separate line for every page of OCR. Page 1 C. number for each document, and all a directly in either the Concordance DELIVERED FIELDS The database or load file provided must contain, at minimum, the ?rst and last Bates pplicable OCR text. OCR text should be incorporated atabase or the ASCII load ?le, and not delivered in separate text ?les. D. I. II. REFERENCE FILE GUIDELINES IMAGE FORMAT 1. TIFF Single page (Preffered) OR Documents should be scanned at 300 dpi, as single-page CCITT Group IV TIFF files. TIFF file names should match the assigned Bates number of the underlying document page, should be unique, and sequentially numbered. PDF ?les will be accepted onlyr after a consultation between the provider and- technical support staff. Multi-page TIFF files are strongly discouraged. Bates numbers should be electronically ?endorsed? onto images. The ?le name assigned to the image should match the underlying document?s Bates number. Bates numbers should be alpha? numeric, with the numeric portion of the stamp being ?zero?tilled?. As an example, an assigned Bates numbered series of documents such as would be unacceptable, Whereas is preferred. Images should be placed on delivered media in a master folder named XIMAGES. 2. PDF Mul?-page (text searchable) CROSS-REFERENCE FILE Tiff ?les must be accompanied with an image ?cross-reference preferably in .lfp format. This file associates each hates number with its corresponding single? page TIFF ?le name and indicates its location on the media provided. The ?le should contain one line for every page in the collection, and must contain the document Bates number and the ?ill DOS path to the image, beginning with the media volume. Below is a sample file: I I Page 2 E. NATIVE FILES With the exception of spreadsheets, electronic ?les should not be provided in their original or ?native" format, but should be put through an electronic conversion (e-conversion) process, in which single-page TIFF images are created from all underlying document pages, and all text and applicable metadata from these files is extracted. Data, images, and image cross- reference ?les resulting from this process should follow the formatting speci?cations detailed in the sections above. Spreadsheets (such Microsoft Excel or Lotus 1?2-3) should be provided in both e- converted and native format. F. SECURITY All submissions of electronic data must be free of computer viruses. In addition, any passwords protecting ?les or media must be removed or provided. Rev. October 2013 Page 3 CERTIFICATE OF RECORDS I, hereby certify that: 1. I am the custodian of records at (?the Company?), located at 2. I have examined the records of the Company, and they contain the attached documents, each of which is the original or the duplicate of the original records, described more particularly as 3. These records were made at or near the time of the occurrence of the matters set forth therein, by a person with knowledge of these matters or from information transmitted by such a person. 4. These records were kept in the course of a regularly conducted activity of the Company. 5. Making these records was a regular practice of that activity. I certify under penalty of perjury that the foregoing is true and correct. Executed on in (date) (State) (CitY) Name: Address: Telephone number: