EFTA00151247.pdf

CLAIMFOX. INC. 905 MARCONI AVE RONKONKOMA. NY 11779 P. 631.205.1200 K. 631.205.1211 CLAIMFOX.COM CLAIMFO,/ CONSIDER IT DONE Prohibition of Pe-Disclosure ClaimFox, Inc. makes every effort possible to protect our clients' confidential claimant information. As claims files may contain a portion of the claimant's medical record, ClaimFox follows the same standards and guidelines set forth for releasing patient medical records, as outlined in the I-IIPAA Security and Privacy Act. The attached or enclosed information may have been disclosed to you from records whose privacy is protected from disclosure by federal and state law including, as applicable, 45 CFP Part 16O (I-IIPAA), 42 CFP Part 2 (alcohol and drug treatment) and other state laws. The applicable law or laws may prohibit you from making any further disclosure without the specific written authorization by the individual to whom it pertains or their authorized representative, or as otherwise permitted or required by law. A general authorization for release of information is not sufficient for this purpose unless it conforms to the specific requirements of the applicable law or laws. Further disclosure not in accordance with applicable federal and state law may result in civil and/or criminal penalties. Based upon guidelines outlined by the American Wealth Information Management Association, these records should be destroyed after the stated need has been fulfilled. All claims files that have been disclosed to you have been carefully reviewed to assure that proper disclosure is made only to the authorized requestor. If you have any questions, please contact ClaimFox at: Toll Free: (844) CLAIM FOX Direct: (631) 2O5-12OO Ext 555 inquiry@claimfox.com EFTA00151247 N n • / IGINDflOA Wat i0SOF INVESTIGAIDN LAZA Neneginstfe To SUBPOENA PROCESSING USAA FEDERAL SAVINGS BANK 10750 MCDERMOTT FREEWAY Ch? DTE. tiDECii 1 NNW - 131liSENDER \ awl SAN ANTONIO TX78288 REF: USAAFEMS W Om ill EU glitinagitnnOMMIMINIE ten w Lu3Pica) 661 Fe: ' , lfl a fig Sy 2 a THU - 12 DEC 3:00P STANDARD OVERNIGHT E:I:w3 1369 8675 1151 DSR 78288 XH U SXA SAT 111111111111111 • , i; : I I. • , • —" ."."'""T IT'lla --Ili I ! •• • . w.,•••••;(4...C....sasiTV9frOr SINIMAIII 'TT ..,•t••• tli Lea il Ile lilletViiii.! itl d • ki; of • 2' EFTA00151248 USAA121219899002729500023• U.S. Department of Justice United States Attorney Southern District of New York ' the Silvio J. Mono Building. ' One Saint Andrew Y Plcca New York New York /0007 OeCember 11, 2019 • USAA Federal Savings Bank / USAA Savings Bank 10750 McDermott Freeway • San Antonio, TX 78288 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 areunder 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 EFTA00151249 219699002729600024 Grand Jury Subpoena AttitEhatiTtEIN glifftrid arturt SOUTHERN DISTRICT OF NEW YORK TO: USAA Federal Savings Bank / USAA Savings Bank • 10750 McDermott Freeway San Antonio, TX 78288 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: December 27, 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. § 2423(a) 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 nested 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 and (2) accompanied by an executed copy of the attached Declaration o u iI•m re contact Forensic Accountant • a 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 December 11, 2019 cf,teee, GEOFFREY S. BERMAN United States Attorneyfor the Southern District efNewYork Assistant United States Attorney One St. Andrew's Plaza New York, NMI, Telephone: EFTA00151250 U AA12121957JUCT2729700025 RIDER (Grand Jury Subpoena to USAA Federal Savings Bank / USAA Savings Bank, dated December 11, 2019) Please provide from inception to the present any and all records pertaining to the following accounts(s)/orgapization(s)rmdividuals(s), whether held jointly or severally or as trustee or fiduciary as well as custodian, executor, or guardian. Please provide all images of documents in Adobe PDF files on CDs. A. Please use the following identifiers: NAME • OHISLATNIE MAXWELL • . TERRAMAR PROJECT INC. ELLMAX !IC . . MAX FOUNDATION . L SERVICES CORP DOB SSN ADDRESS : OSTON, MA NEW YORK, 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); EFTA00151251 JSAAI 21219599002729800026 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. 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 re nested records are (1) produced by on or before the return date to Special Agen Federal Bureau of Investi ation, 26 Federal Plaza, New York, NY 10278, telephon and (2) accompanied by an executed copy of the attac a ec ara ono us o ran o ecords. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. Please contact Forensic Accountan 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. EFTA00151252 19 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 a dated December 11, 2019, and signed by Assistant United States Attorney , requesting specified records of the business named below. Putsuant 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 EFTA00151253 JSAA 219399302/30O0O%8 The Silvio J. kfollo Building One Saint Andrew's Pico New York, New York 10007 U.S. Department of Justice United States Attorney Southern District of New York Dear Sir/Madam: This letter describes the procedure for requesting reimbursement for subpoenaed records.. 12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section 1115 of the Right to Financial Privacy Act (12 U.S.C. 3415), sets the rates and conditions for reimbursement of costs directly incurred by financial institutions in assembling or providing customer financial records to a government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a partnership comprised of more than five individuals. If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance permission is necessary from-at If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the following address: U.S. Attorney's Office - SDNY Accounts Payable 86 Chambers Street, 3id floor New York NY 10007 Please send your invoice to the above address within 60 days of the submission of the subpoenaed records. If no invoice is received within 120 days, fiords will not be available to pay the invoice. Thank you, Account Pa able Department EnclOsure: OBD- 211 EFTA00151254 J 2' 219S99002730100029 FORM OBD 211 - INSTRUCTIONS ATTORNEYS: 1. Fill in blocks 2, 3, 4 (name only), 8, 9, and 10. 2. Mail the subpoena and the OBD 211 to the financial institution. 3. Send a copy of the OBD 211 and the subpoena to Anthony Baker in the Budget Office. FINANCIAL OFFICIAL COMPLETE THE FOLLOWING: 1. Complete block 4. 2. Either complete block 11 or write "see attached invoice" and attach to the OBD 211. 3. Blocks 12 and 13 must be completed. Note carefully the certification. 4 Send completed OBD 211 and attached invoice, if applicable, to: U.S. Attorney's Office - SDNY Accounts Payable 86 Chambers Street - 3"1 Floor New York, NY 10007 EFTA00151255 USAA121219S99001/30200030 Form OBD 211 U.S. Department of Justice Reottest for Financial Information (Authorization. Purchase Order, Receiving Report) This form shall only be used when requesting financial records of individuals and partnerships of five or fewer individuals. I Purchase Order Number/DC Number 2 Date Order Prepared: 3 Case Number: 2019RCIII88 Section A —Authorization and Purchase Order 4 Name and Address of Financial Institution/Tax ID thNarne & Phone N of Contact Person SunTrust Bank 5 Deliver To: See attached subpoena for delivery instructions. 6 Return Date: See attached. 7 Remarks/Invoice N Account Number: I. If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance permission is necessary fro 2. See attached subpoena and rider for account information and delivery instructions. 8 Name of Requestor/Assistant U.S. Attorney 9 Telephone Number: 10 Date of Request: 12/11/19 Section B - Financial Institution Invoice No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached. 11 Service/Financial Records Provided: I la Billed To: Quantity Unit Price Amount Cost Per I hereby certify that the services above were not performed relative to any corporation, joint ventures, etc., and pertain only to accounts (checking, savings, share, loan, or credit card) of individual(s) or partnership(s) of five or fewer partners. 12 Signature of Financial Institution Official: 13 Date Signed: Total Amount Claimed By Financial Institution: Section C - Receiving Report 16 Disallowance 14 1 certify that the articles and services listed were received: 15 Date Received 17 Net To Financial Institution 18 Right to Financial Privacy Act — Public Law 95-630 (12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only) OBJECT CLASS 03404 Customer Authorization 2540 o 3405 Administrative Subpoena or Summons 2541 a 3406 Search Warrant 2542 o 3407 Judicial Subpoena 2543 03408 Formal Written Request 2544 0 3413 Grand Jury Subpoena 2545 0 3414 Special Procedures 2546 19 Signature of Approving Official 20 Accounting Classification Code FY FC 1 2 3 4 5 PROJ. 21 Schedule and Voucher Number EFTA00151256 Declaration of Custodian of Records Pursuant to 28 U.S.C. § 1746, I, the imdersigned, hereby declare: My name is Isabel Luna • (name‘of declarant) ant a.United States citizen and I am over eighteen years of agC. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my pissition with. • the business mined belowtomake this declaration. . I am in receipt of a Grind Ju • Sub oena, dated December 11, 2019, and signed by Assistant United States Attorney requesting specified records of the business named below. Parisuant 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. Ideclare under penalty of perjury that the foregoing is true and correct. Executed on December 19, 2019 (date) ‘Ak,. (signature of declarant) Isabel Luna (name and title of declarant) USAA Federal Savings Bank (name of business) 10750 McDermott Freeway, San AnTio, Texas 78268 (business address) . Definitions of terms used above: As defined in Fed. it Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, inany.form, of acts, events;conditions, opinions, or diagnoses.. The term "business" as used in Fed. R. Evid. O3(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit. EFTA00151257 Form Code: 82706 Member Number: 007813821 Date Recieved: 04/15/2012 07:37:54 AM Address: Email: Subject: Online Application For: 007813821 FraudPhonelndicator = No FraudEmployerlndicator = No FraudAddresslndicator = No RecommendedApplicationAction = PROCEED AppSubmitter = Member PrimaryAppName = SCOTT<>O<>BORGERSON<> PrimaryAppAddrLinel PrimaryAppCity PrimaryAppState PrimaryAppZip PrimaryAppSSN PrimaryAppDOB PrimaryAppPriEmailAddr PrimaryAppPhysAddrLinel PrimaryAppPhysAddrCity = PrimaryAppPhysAddrState PrimaryAppPhysAddr Zip PrimaryAppPhysAddrCountry = USA PrimaryAppCountryofCitizenship = U.S. PrimaryAppUSCitizen = Yes DepositAccountType = USAA Four Star Checking Account DebitRewardType = NR WantDirectDeposit = No NewAccountNumber FundingMethod = Initial Funds Transfer FundDepositTransferUSAAFundsAcctNbr FundingAccountNumber = TotalFundingAmount = 1000.00 CheckingFundingAmount = 1000.00 EFTA00151258 WantWebBillPay = No WBPEmailFlag = No WBPTermsConditionsFlag = N WantOverdraftProtection = Yes OverdraftProtectionAccountType = Performance First Savings OverdraftProtectionAccountNbr = OverdraftDisplayAcctNum = WantDebitOrATMCard = Yes OriginationState = TX ResponsibleState = TX StateCd_TaxWli = MA ApplicationType = Individual NbrCoApplicant = 0 EFTA00151259 IN USAA FEDERAL 1140. SAVINGS USAA ' BANK PAGE 1 SCOTT BORGERSON OR GHISLAINE MAXWELL 301 SUMMER ST MANCHESTER MA 01544-1540 0 18 AOCOUNT NUMBER AccaINTTWE STATEMENT PERIOD USAA CLASSIC CHECKING 10/16/18 • 11/16/18 BALANCE LAST STATEMENT N0OF DEBITS PAID TOTALAMUNT OF DEBITS PAID NO. OF DEP TOTALAMOUNT OF DEPOSITS MADE SERVICE CHARGES BALANCE THIS STATEMENT 78,894.52 11 23,849.47 2 40.53 .00 55,085.58 Plots mon. into lllll •nd i•pect If u......v v ne co n la •••••3••• wing, 41 iliky• lid, coins lllll • wing. NONSUFFICI TOTAL RILFUNDS(NSF) OVERTOTAL 9ligigNICO 'MISSTATEMENT n nn A AA THISYEARSSTATEMENTS 0.00 0.00 0040 by WM4 will nm lllll m. IOW* OA uu Cb.b.1. DEPOSITS AND OTHER CREDITS DATE AMOUNT. TRANSACTION DESCRIPTION 10/22 40.00 DEPOSIT @ MOBILE 11/16 0.53 INTEREST PAID CHECKS DATE..CHECK NO AMOUNT DATE..CHECK NO AMOUNT 10/18 995328 10.00 11/09 995332* 10.00 OTHER DEBITS DATE AMOUNT. TRANSACTION DESCRIPTION 10/17 45.55 ACH DEBIT 101718 USAA.COM PAY INT LIFE 1739 10/24 16,775.15 USAA CREDIT CARD PMT CREDIT CARD ENDING IN 8171 10/29 188.55 USAA INSURANCE PAYMENT 10/30 381.85 ACH DEBIT NATIONAL GRID ONLINE PMT 4POS 11/01 205.10 USAA FUNDS TRANSFER DB TO Scott Borgerson CHECKING CONF# 1753250533 11/01 5,500.00 USAA FUNDS TRANSFER DB TO Scott Borgerson CHECKING S CONF@ 1753291865 11/06 276.57 ACH DEBIT 110618 COMCAST ONLINE PMT 4POS 11/14 157.82 ACH DEBIT 111418 COMCAST ONLINE PMT 4POS 11/16 250.00 USAA FUNDS TRANSFER DB TO Scott Bor CHECKING CONF@ 1773324275 FDIC INSURED 93526.0814_05 BM1FRT EFTA00151260 USAA FEDERAL SAVINGS BANK 10750 McDermott Freeway San Antonio. TX 78288-0544 800-531.8722 PLEASE EXAMINE THIS STATEMENT AT ONCE. IF NO ERROR IS REPORTED IN 60 DAYS, THIS STATEMENT WILL BE CONSIDERED CORRECT. ALL ITEMS ARE CREDITED SUBJECT TO PAYMENT. In Case of Errors or Questions About Your Electronic Transfers. Telephone us or Write us at the address and number listed at the top of this page as soon as you can. if you think your statement or receipt is wrong or if you need more information about a transfer on the statement or receipt. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. • Tell us your name and account number (if any). • Describe the error or the transfer you are unsure about. and explain as clearly as you can why you believe it is an error or why you need more information. Tell us the dollar amount of the suspected error. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this, we will credit your account for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. THIS FORM IS PROVIDED TO HELP YOU RECONCILE THIS STATEMENT BALANCE TO YOUR CHECKBOOK BALANCE. CHECKS OUTSTANDING (Those written which have not been charged to your account) CHECK# AMOUNT TOTAL BANK BALANCE (1) BALANCE THIS STATEMENT (SHOWN ON FRONT PAGE) (2) ADD DEPOSITS NOT SHOWN ON THIS STATEMENT (IF ANY) (3) SUBTOTAL (4) SUBTRACT TOTAL OF CHECKS OUTSTANDING (IF ANY) (5) ADJUSTED BANK BALANCE YOUR BALANCE (6) CHECK REGISTER BALANCE (7) ADD CREDITS WHICH APPEAR ON THIS STATEMENT THAT HAVE NOT BEEN RECORDED IN YOUR REGISTER (IF ANY) (8) ADD INTEREST CREDITED TO YOUR ACCOUNT (IF ANY) (9) SUBTRACT OTHER CHARGES (IF A ) (10) ADJUSTED CHECK REGISTER BALANCE • Be sure to record in your check register. Line 5 and Line 10 should now agree. If not, check the following items in your register: -Are all deposits accounted for? -Are all amounts entered correctly? -Are all automatic transactions accounted tor? -Are all additions and subtractions accurate? tag TERMS AND CONDITIONS: All transactions are subject to the USAA Federal Savings Bank Depository Agreement. 126405.O714 BMIBCK EFTA00151261 USAA FEDERAL 1544 .- BANK SAVINGS PAGE 2 SCOTT BORGERSON OR GHISLAINE MAXWELL 301 SUMMER ST MANCHESTER MA 01944-1540 0 16 ACCOUNT BALANCE DATE SUMMARY BALANCE DATE BALANCE 10/16 78,894.52 10/30 61,524.94 10/17 78,844.53 11/01 55,819.84 10/18 78,834.53 11/06 55,542.87 10/22 78,874.53 11/09 55,532.87 10/24 62,095.38 11/14 55,335.05 10/29 61,906.83 11/16 55,085.58 INTEREST PAID INFORMATION YOUR INTEREST PAID WAS CALCULATED USING YOUR DAILY BALANCE FOR 31 DAYS FOR AN ANNUAL PERCENTAGE YIELD EARNED OF 0.01%. THIS BRINGS YOUR YTD INTEREST PAID TO 3.44. 105846-0814_06 BMFRIA EFTA00151262 Ines PAYKOIT ....AS. 12.1. ' 11010 =am.- mom AYH teli.......••••• 9( 1 0.“ w. nOtar. 0.0 1 54.. 4, • 06 I WI...dwavw Check: Amount:10.00 „,..„,a_w_w4111 41" .V4 • ln <ft Nile...11 lel ill ....elf Ati 1. 41 . ...IV `lath . % pew three,est ma ming woo A. goo I.- Sp...wag, In nwsw • ••• woo w•ovws of we some Check: Amount:10.00 EFTA00151263 EFTA00151315 EFTA00151316 EFTA00151317 EFTA00151318 EFTA00151319 EFTA00151320 EFTA00151321 EFTA00151322 EFTA00151323 EFTA00151324 EFTA00151325 EFTA00151326 EFTA00151327 EFTA00151328 EFTA00151329 EFTA00151330 EFTA00151331 EFTA00151332 EFTA00151333 EFTA00151334 EFTA00151335 EFTA00151336 EFTA00151337 EFTA00151338 EFTA00151339 EFTA00151340 EFTA00151341 EFTA00151342 EFTA00151343 EFTA00151344 EFTA00151345 EFTA00151346 EFTA00151347 EFTA00151348 EFTA00151349 EFTA00151350 EFTA00151351 EFTA00151352 EFTA00151353 EFTA00151354 EFTA00151355 EFTA00151356 EFTA00151357 EFTA00151358