SDNY grand jury subpoena to USAA Bank for Ghislaine Maxwell's records, June 29, 2020

EFTA00097029¶

JUN-29-2020 10:39¶

US ATTORNEY SDNY¶

2126372615	P.002

Grand Jury Subpoena¶

United States District Court¶

SOUTHERN DISTRICT OF NEW YORK¶

TO:	USAA Federal Savings Bank / USAA Savings Bank10750 McDermott FreewaySan Antonio,TX 78288Fax:800-531-5717

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: July 2, 2020¶

Appearance Time: 10 a.m.¶

to testify and give evidence in regard to alleged violations of federal criminal law, including: 18 U.S.C. § 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 Assistant U.S. Attorney at: U.S. Attorney’s Office, Southern District of New York, 1 St. Andrew’s Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶

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 June 29, 2020¶

/s (AR)¶

Assistant United States Attorney One St. Andrew’s Plaza New York, New York 10007¶

EFTA00097030¶

JUN-29-2020	10:40

US ATTORNEY SDNY¶

2126372615	P.003

RIDER¶

(Grand Jury Subpoena to USAA Federal Savings Bank / USAA Savings Bank, dated June 29, 2020)¶

Please provide from 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, for the period of November 1, 2019, to the present.¶

A. Please use the following identifiers:¶

NAME	GHISLAINE MAXWELL TERRAMAR PROJECT INC. ELLMAX LLC MAX FOUNDATION MAX HOTEL SERVICES CORP
DOB
SSN
ADDRESS		BOSTON, MA K, NY
PHONE
EMAIL
ACCOUNT NUMBER

B. Records to be produced should include but are not limited to the items listed below:¶

1. 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

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EFTA00097031¶

JUN-29-2020 10:40¶

US ATTORNEY SDNY¶

2126372615	P.004

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;

11. 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: username, 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 requested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorney’s Office, Southern District of New York, 1 St. Andrew’s Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶

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.¶

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| EFTA00097032 | | :--- | :---¶

JUN-29-2020 10:40¶

US ATTORNEY SDNY¶

2126372615	P.005

Declaration of Custodian of Records¶

Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:¶

___.¶

[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 Jury Subpoena, dated June 29, 2020, 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.¶

TOTAL P.005¶

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