Court filing, 2019-10-08

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¶

October 8, 2019¶

JP Morgan Chase Bank N.A. And All Affiliates¶

National Subpoena Processing¶

7610 West Washing Street¶

Indianapolis, Indiana 46231-1335¶

Fax Number: 317-757-7421¶

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¶

By:¶

Assistant United States Attorney Southern District of New York¶

| EFTA00097253 | | :--- | :--- |¶

This is a simple Markdown document with no headings or paragraphs. It contains just one line of text.¶

Grand Jury Subpoena¶

United States District Court¶

SOUTHERN DISTRICT OF NEW YORK¶

TO:	JP Morgan Chase Bank N.A. And All Affiliates National Subpoena Processing7610 West Washing StreetIndianapolis, Indiana 46231-1335Fax Number: 317-757-7421

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 22, 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 Special Agent Federal Bureau of Investigation, 26 Federal Plaza, New York, NY 10278, telephone (212) 384-1000, and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please contact Forensic Accountant 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 8, 2019¶

GEOFFREY S. BERMAN¶

United States Attorney for the¶

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

EFTA00097254¶

RIDER¶

(Grand Jury Subpoena to JP Morgan Chase, dated October 8, 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, to include all open and closed accounts. Please provide all images of documents in Adobe PDF files on CDs.¶

A. Please use the following identifiers:¶

NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBER - Bear Stearns and Co(US)

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);

3¶

| EFTA00097255 | | :--- | :--- |¶

This is a simple Markdown document with no headings or paragraphs. It contains just one line of text.¶

4. Location of withdrawals

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. “Quick Pay” transaction detail including counterparty information;

9. Safe deposit records, including applications, signature cards, and sign-in records;

10. Trust accounts;

11. Monthly statements;

12. Credit card statements;

13. Bank, travelers, or cashier checks drawn on account or purchased with an account check;

14. Prepaid debit cards, certified checks, cashiers’ checks, money orders, and traveler’s checks;

15. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans;

16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements;

17. 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

18. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (17), 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 Special Agent Federal Bureau of Investigation, 26 Federal Plaza, New York, NY 10278, telephone (212) 384-1000, and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶

Please contact Forensic Accountant Mark Lubin at (212) 384-8531 with any questions.¶

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¶