EFTA00074432.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza Neu• York. Neu• York 10007 September 3, 2019 PayPaUVenmo 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 July. 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. By: Very truly yours, GEOFFREY S. BERMAN United States Attorney Assistant United States Attorney Southern District of New York EFTA00074432 Grand Jury Subpoena Pnitebr atates Piztritt auttrt SOUTHERN DISTRICT OF NEW YORK TO: PayPalNenmo 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 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 itivith any quest ons. 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 Assistant United States Attorney One St. Andrew's Plaza New York New York 10007 Federal Bureau of at 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 th r uested 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, telephom md (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 vith any questions. r Special Agent EFTA00074434 IMPORTANT: REOUEST 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 EFTA00074435 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 United States Attorney below. Pursuant to Rules that the records provided herewith and in response to the Subpoena: ena, dated September 3, 2019, and signed by Assistant requesting specified records of the business named an i : 1 (6) of the Federal Rules of Evidence, I hereby certify (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. EFTA00074436