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U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Motto Building
One Saint Andrew's Plaza
New York. New York 10007
October 15, 2019
Bank of America N.A.
Legal Order Processing
Christiana IV
800 Samoset Drive
Newark, DE 19713
Mail code DE5-024-02-08
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
EFTA00019750
Grand Jury Subpoena
Pnitehatatez Pistrirt (Erfurt
TO:
Bank of America N.A.
Legal Order Processing
Christiana IV
800 Samoset Drive
Newark, DE 19713
Mail code DE5-024-02-08
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
October 29, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the re uested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephon
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
October 15, 2019
United States Attorney for the
EFTA00019751
RIDER
(Grand Jury Subpoena to Bank of America, dated October 15, 2019)
Please provide from account inception to the present any and all records pertaining to the following
accounts(s)/organization(s)/individuals(s), whether held jointly or severally or as trustee or
fiduciary as well as custodian, executor, or guardian. Please provide all images of documents in
Adobe PDF files on CDs.
A. Please use the following identifiers:
NAMES/ENTITIES
AKA:
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBER
B. Records to be produced should include but are not limited to the items listed below:
I. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting
additions and/or subtractions to the account and how the account balances are being satisfied
on a monthly basis;
2. Signature cards;
3. Proof of identification (including but not limited to copies of identification used to open the
account);
4. Location of withdrawals
3
EFTA00019752
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other
documentation provided by Customer;
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
II. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit
reports, applications, and payments made on loans;
15. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements;
16. Online banking information- All information regarding the electronic use of banking systems
to include the following: usemame, registration IP address, online account creation date,
online account status and IP logs/history, MAC addresses and online session times and
duration; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial
interests involving the individuals and/or entities identified in Section A.
N.B.: Personal appearance is not required if the re uested records are (1) produced by on or
before the return date to Special Agent
Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephon
and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
Please contact Forensic Accountant
with any questions.
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
4
EFTA00019753
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Ju
Subpoena, dated October 15, 2019, and signed by Assistant
United States Attorney
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00019754