Rick V. Haas
Custodian of Records
Experian Consumer Affairs
!pperian.
701 Experian Parkway
Allen, Texas 75013
www.experian.com
EFTA01654843
Grand Jury Subpoena
Aniteb „Stain j13istrict (Itnurt
TO:
Experian Infonnation Solutions, Inc.
701 Experian Parkway
Allen, TX 75013
Attn: Subpoena Compliance Dept.
GREETINGS:
WE COMMAND YOU that ail 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, Ncw York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 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 requested records are (I)
produced by on or before the return date to Special Agent
Investigation, 26 Federal Plaza, New York, NY 10278, telcphon
and (2) accompanied by an executed co
of the attached Declaration o
usto Ian o Records. Please
contact Forensic Accountant
or Special Agent
at
with any quest ns.
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
August 16, 2019
ira
El „or
e>inr
osea de,/n
GEO FriEY S. BERMAN
United States Attorney for the
Southern DIstrictif New York
nt61j-
4 es
tg• nyet--att,'•:
•
EFTA01654844
RIDER
(Grand Jury Subpoena to Experian, dated August 16. 2019)
Please provide any and all credit reports, fraud alerts, and related documentipertaining to the
following individuals listed, including all known accounts and lines of credit, addresses and
personal identifying information, and all credit inquiries regarding the individuals and the
addresses provide at the time of said inquiry regardless of whether accounts were open.
Please utilize the identifiers below:
NAME
' GHISLAINE MAXWELL
DOB
SSN
ADDRESS
PHONE
NAME
DOB
N.B.: Personal appearance is not required if the requested records arc (1) produced by on or
before the return date to Special Agent Amanda Young, Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone (212) 384-1000,
[email protected]; and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
Please contact Forensic Accountant Mark Lubin at (212) 384-8531 or Special Agent Amanda
Young at (212) 384-1000 with any questions.
Duc 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.
3
EFTA01654845
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746. I, the undersigned. hereby declare:
My name is
flick V. Naas
(name of declarant)
I am a United States citizen and 1 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.
am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant
United States Attorney Maurene Comey, requesting specified records of the business named
below. Pursuant to Rules 902(1i) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(I) 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)
aaikz.. V. 14—a...4.44.—
(signature of declarant)
ckto-bott,tv. a- Ile tot-4t
(name and title of declarant)
yte rah
(name of business)
101 EXeektsivk
(business address)
Alkyl TX —1S-1) 13
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.
EFTA01654846
Credit Profile from Experian Inc.
Page 1 of 2
(E„
!experian.
TTX2 RI at
PAGE 1
DATE 8-27-2019 TIME
LAST SUB: 1229200
RPTD: 7-16 U
RPTD: 5-16 TO 6-16 U 1X
•GHISLAINE BORGERSON
16:43:08 V301 THAI
PH:I
GEO:
UC
1120
INPUT
FROM
FROM
PH:
SS:
DOB:
DEMOGRAPHICS
RPTD: 1-96 I
RPTD: 1-95 I
UR
PH:
SSN ISSUED 1990-1993
5-01-19 INQ COUNT FOR SSN-0
5-01-19 INQ COUNT FOR ADDRESS-0
SUBSCRIBER
SUB.
KOB TYP TRM
ACCOUNT 0
OPEN
ECOA BALDATE
LAST PD
UR
TRADES
AMT-TYPI
AMT-TYP2 ACCTCOND
PYMT STATUS
BALANCE
MONTH PAY
BY MONTH
•BANK OF AMERICA
C CRC REV
COUNT CLOSED AT
3-09
1 10-12-11
9-11
CONSUMER'S
$6,000-L
$0
$47-A
REQUEST
$1,679-H
10-11
CLOSED
CURR ACCT
(30) BCCCCCCCC---C
CC
CCCCC
'UBS BANK USA
2-14
$35,000-L
83,151-H
PAID
CURR ACCT
BB FSC REV
1 7-25-19
7-19
165) BCCCCC00000CC
5-19
CC0000CCCCCC
• •
•• ACCOUNT CLOSED AT CREDIT GRANTOR'S REQUEST
JPMCB CARD
1-96
$12,200-L
$12,644-H
PAID
CURR ACCT
BC CRC REV
1 3-08-15
3-15
(99) BCCCCCCCCCCCC
3-14
CCCCCCCCCCCC
•ELAN FINANCIAL SERVICE
10-04
$23,000-L
PAID
CURR ACCT
ailligEV
1 7-31-12
7-12
( 1) B
•• ACCOUNT CLOSED AT CONSUMER'S REQUEST
Intps://ea2.ec.experiannet.com/jAccess/inquity
8/27/2019
EFTA01654847
- • • Credit Profile from Experian Inc.
Page 2 of 2
*AMEX
10-91
$19,504 -H
MOBBOBIMBC CRC
1
1 10-02-10
** ACCOUNT CLOSED AT CONSUMER'S REQUEST "
*AMEX
5-91
619,184-H
10-10
PAID
( 1)
PAID
CURR ACCT
B
CURR ACCT
BC CRC
1
1 7-02-10
7-10
( 1) B
•' ACC
AT CONSUMER'S REQUEST *"
'CAP1/SAKS
6-15
$40,000-L
$3,292-H
OPEN
CUR WAS 30
REV
1 8-15-19
$0
2-16
(50) OCCCCCCCCCCCC
5-19
$31
1-16/1 CCCCCCCCCCCC
Amex
7-91 $102,243-H
OPEN
CORR ACCT
BC CRC
1
1 8-18-19 $102,243
8-19
(99) CCCCCCCCCCCCC
UNK
CCCCCCCCCCCC
'OSAA SAVINGS BANK
4-12
$35,000-L
$32,899-H
OPEN
CURR ACCT
BC FSC REV
3 7-26-19
$5,892
7-19
(88) CCCCCCCCCCCCC
7-19
$22,307-A
CCCCCCCCCCCC
" ACCOUNT PREVIOUSLY IN DISPUTE - INVESTIGATION COMPLETE,
REPORTED BY DATA FURNISHER "
INQUIRIES
CITIBANK NA., BEST BUY 2-17-19 nil
701 EXPERIAN PARKWAY, PO BOX 2002, ALLEN, TX 75013 888.397.3742
END -- EXPERIAN
DIRECT CHECK
TELEPHONE
ADDRESS
CITY
ST ZIP
1229200 AMEX
800.874.2717 PO BOX 297871
FORT LAUDER FL 33329
1230206 BANK OF AMERICA
800.421.2110 PO BOX 982238
EL PASO
TX 79998
1195162 CAP1/SAKS
800.221.8340 3455 HIGHWAY 80 W
JACKSON
MS 39209
2145203 CITIBANK NA., BES BYMAILONLY
701 E 60TH ST N
SIOUX FALLS SD 57104
2205270 ELAN FINANCIAL SE 800.755.4080 PO BOX 108
SAINT LOUIS MO 63166
3182310 JPMCB CARD
800.945.2000 PO BOX 15298
WILMINGTON DE 19850
1922551 UBS BANK USA
801.741.0310 299 S MAIN ST STE 2 SALT LAKE C UT 84111
3271200 USAA SAVINGS BANK BYMAILONLY
PO BOX 47504
SAN ANTONIO TX 78265
IsaAragg astatfataggED
C' Copyright Expexian Information Solutions, Inc. All rights reserved.
https://ea2.ec.experiannet.com/jAccess/inquiry
8/27/2019
EFTA01654848