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Court filing · Sept. 3, 2019

Court filing, 2019-09-03

U.S. Department of Justice

United States Attorney Southern District of New York

The Silvio J. Mollo Building

One Saint Andrew’s Plaza

New York, New York 10007

September 3, 2019

PayPal/Venmo

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,

GEOFFREY S. BERMAN

United States Attorney

Assistant United States Attorney Southern District of New York

EFTA00074432

Grand Jury Subpoena

United States District Court

SOUTHERN DISTRICT OF NEW YORK

TO: PayPal/Venmo

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: September 17, 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 (1) produced by on or before the return date to Forensic Accountant Federal Bureau of Investigation, 26 Federal Plaza, New York, NY 10278, telephone and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please contact Forensic Accountant Special Agent at 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 September 3, 2019

GEOFFREY S. BERMAN

United States Attorney for the Southern District of New York

Assistant United States Attorney

One St. Andrew’s Plaza

New York, New York 10007

EFTA00074433

RIDER

(Grand Jury Subpoena to PayPal/Venmo, dated September 3, 2019)

For the time period of account inception to the present, please provide any and all records, including but not limited to account holder information and transaction records, relating to the following email:

Account holder and transaction information to include:

  • User ID History

  • Name

  • Phone Number

  • Address

  • Billing Address

  • Shipping Address

  • E-mail Address

  • IP Address

  • Transaction details

  • Bank account information

  • Credit card account information

  • Debit card account information

  • Money sent

  • Money received

  • Checks requested

  • Venmo account information and transactions

  • PayPal Credit account information and transactions

  • PayPal Working Capital account information and transactions

  • PayPal MyCash account information and transactions

  • PayPal Cash account information and transactions

  • Xoom account information and transactions

  • Braintree account information and transactions

N. B.: Personal appearance is not required if the requested records are (1) produced by on or before the return date to Forensic Accountant Federal Bureau of Investigation, 26 Federal Plaza, New York, NY 10278, telephone and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN NATIVE, ELECTRONIC FORMAT IF POSSIBLE.

Please contact Forensic Accountant

with any questions.

or Special Agent

3

EFTA00074434

IMPORTANT: REQUEST FOR NON-DISCLOSURE

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

Court filing, 2019-09-03

Court filings

DOJ Epstein Files, Data Set 9 · Sept. 3, 2019

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 September 3, 2019 PayPal/Venmo 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 ar…