EFTA00019615.pdf

TransUnion
Tel (312) 985-3978
Fax (312) 985-2030

September 1, 2020

Federal Bureau of Investigation
New York, New York 10278

RE: [REDACTED] et al

Attached are all credit reports responsive to your request.

I certify that I am employed by TransUnion and am authorized to make this declaration on behalf of TransUnion LLC. Attached hereto are credit report(s) identified in your request (also attached), for individuals listed in the subpoena/court order. This information was derived from information contained in TransUnion’s computer records as of the date indicated on the report(s). The information contained in the credit report(s) was compiled by TransUnion from various sources in the ordinary course of TransUnion’s business operations, and it is customary and routine for TransUnion to prepare such reports in the ordinary course of business. The report(s) were obtained from TransUnion’s computer records, using the consumers identifying information provided in the subpoena/court order and are the originals or exact copies thereof.

If you have any questions or need additional clarification regarding the information enclosed, please review the attached subpoena guidelines. If you have any further questions, please contact the TransUnion Subpoena Hotline at (312) 985-3978 or email [REDACTED] and reference the date of this letter and the information in the subject line.

Sincerely,
[REDACTED]
Litigation Support Department
Enclosure(s)
EFTA00019615

TransUnion
Subpoena Guidelines
TransUnion Accepts the Following Documentation:
> US Federal Grand Jury Subpoenas
> ALL OTHER SUBPOENAS - only if so ordered by a Judge or Magistrate and stamped by the Clerk
> Court Orders - must be signed by a Judge or Magistrate
> Search Warrants - must be signed by a Judge or Magistrate
> Summons - issued by the IRS
> Authorizations – must be signed by the subject of the credit report or subject consumer’s legal representative (e.g. Attorney)

Please submit the above to the attention of the TransUnion Subpoena Processing Team using ONE of the following:
Email: [REDACTED] Fax: (312) 985-2030 Mail: TransUnion 555 West Adams St. Chicago, IL 60661

REQUIRED INFORMATION on ALL Requests:
> First, middle & last name of consumer(s) whose credit report is being requested (alias names if applicable)
> Date of birth
> Social security number(s) (alias #’s if applicable)
> Current and/or last known address(s)
> City, state and zip code
Requests that do not contain the above information will be automatically rejected and will result in processing delays.

> If we are unable to complete your request(s) and you have included a check, it will be destroyed.
> TransUnion does not maintain credit information on businesses.
> The consumer report information provided pursuant to your request may not include all information in TransUnion’s database(s), such as prescreening inquiries, inquiries for account review purposes and inquiries relating to medical, utility or insurance services. If such information is required, please specify that “ALL inquiry information, including but not limited to prescreening inquiries, inquiries for account review purposes and inquiries relating to medical, utility or insurance services, found in the consumer’s file must be returned.”
> We may respond to your request via e-mail, fax, or US mail. Please be sure to include an e-mail address, fax number, or mailing address with your request.
> If sending via fax, hard copy is not required!

Instructions for delivery of documents
> Name of person to receive requested documents
> Name of agency/firm
> Address
> City, state and zip code
> E-mail, Fax number, or mailing address

REQUEST for FULL ACCOUNT NUMBER(S):
If requesting the "full account number(s)" for a consumer's account(s), please be aware that due to security requirements and evolving industry standards for treatment of highly sensitive Payment Card Information ("PCI"), full account numbers may not be displayed on TransUnion credit reports or disclosures, but may have one or more digits truncated, masked or obscured. Further, where full account numbers do appear, these may be scrambled or encrypted by the card issuer, furnisher of information, and otherwise may not reflect the actual account number.
Revised 8/8/19
EFTA00019616

Good afternoon,

Please find attached a grand jury subpoena. Feel free to reach out should you have any questions.

Regards,
[REDACTED]
Paralegal Specialist
U.S. Attorney’s Office | SDNY
1 St. Andrew’s Plaza
New York, NY 10007
Office: [REDACTED]
Cell: [REDACTED]
EFTA00019617

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

August 25, 2020

VIA EMAIL
Trans Union
Custodian of Records
555 West Adam Street
Chicago, Illinois, 60661

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.

If you intend to disclose the existence of this Grand Jury Subpoena request to a third party, please let me know before making any such disclosure.

Thank you for your cooperation in this matter.

Very truly yours,
AUDREY STRAUSS
Acting United States Attorney

By:
[REDACTED], Esq.
Assistant United States Attorney
EFTA00019618

Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK

TO: Trans Union
Custodian of Records
555 West Adam Street
Chicago, Illinois, 60661

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, 500 Pearl Street, Room 480 (via North elevators), 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 7, 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, 1343, 1346

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 [REDACTED] at: Federal Bureau of Investigation, 26 Federal Plaza, Squad C-4, New York, NY 10278, telephone: [REDACTED], or via email at [REDACTED] 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
August 25, 2020

AUDREY STRAUSS
Acting United States Attorney for the
Southern District of New York

[Signature Redacted]
Assistant United States Attorney
One St. Andrew’s Plaza
New York, New York 10007
Telephone: [REDACTED]
EFTA00019619

RIDER
(Grand Jury Subpoena to Trans Union, dated August 25, 2020)

Please provide any and all credit reports, fraud alerts, and related documents pertaining to the following individuals listed, including all known accounts and lines of credit, addresses and personal identifying information, and all credit inquiries regarding the individuals and the addresses provided at the time of said inquiry regardless of whether accounts were open.

1. Name: [REDACTED]
Date of Birth: [REDACTED]
SSN: [REDACTED]

2. Name: [REDACTED]
Date of Birth: [REDACTED]
SSN: [REDACTED]

3. Name: [REDACTED]
Date of Birth: [REDACTED]
SSN: [REDACTED]

Please forward the above requested information in electronic format to:
Special Agent [REDACTED]
Federal Bureau of Investigation
26 Federal Plaza, New York, NY 10278
Tel: [REDACTED]

Points of contact for this request:
FBI Special Agent [REDACTED]
FBI Special Agent [REDACTED]
EFTA00019620

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 Grand Jury Subpoena, dated August 25, 2020, and signed by Assistant United States Attorney [REDACTED], 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.
EFTA00019621

TransUnion
Subscriber Name: INHOUSE LAW
Subscriber Code/Market: Z 0005290 17 03
Results Issued: 8/31/20 15:21 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
SSN:
Name:
Current Address:
[REDACTED BLOCK]
EFTA00019622

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:21 CT
Page: 2 of 5
[REDACTED BLOCK]
EFTA00019623

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:21 CT
Page: 3 of 5
[REDACTED BLOCK]
EFTA00019624

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:21 CT
Page: 4 of 5
[REDACTED BLOCK]
EFTA00019625

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:21 CT
Page: 5 of 5
REPORT SERVICED BY
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve more™ with TransUnion
EFTA00019626

TransUnion
Subscriber Name: INHOUSE LAW
Subscriber Code/Market: Z 0005290 17 03
Results Issued: 8/31/20 15:20 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
SSN:
Name:
Current Address:
[REDACTED BLOCK]
EFTA00019627

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:20 CT
Page: 2 of 6
[REDACTED BLOCK]
EFTA00019628

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:24 CT
Page: 3 of 6
[REDACTED BLOCK]
EFTA00019629

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:24 CT
[REDACTED BLOCK]
EFTA00019630

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:24 CT
Page: 5 of 6
[REDACTED BLOCK]
EFTA00019631

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:24 CT
Page: 6 of 6
REPORT SERVICED BY
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve more™ with TransUnion
EFTA00019632

TransUnion
Subscriber Name: INHOUSE LAW
Subscriber Code/Market: Z 0005290 17 03
Results Issued: 8/31/20 15:27 CT
INPUT PARAMETERS FOR PRIMARY SUBJECT
Reference ID:
SSN:
Name:
Current Address:
[REDACTED BLOCK]
EFTA00019633

TRANSUNION CONSUMER CREDIT REPORT Results Issued: 8/31/20 15:27 CT
Page: 2 of 2
REPORT SERVICED BY
TRANSUNION
(800) 888-4213
P.O. BOX 1000, CHESTER, PA 19022
CONSUMER DISCLOSURES CAN BE OBTAINED ONLINE THROUGH TRANSUNION AT:
HTTP://WWW.TRANSUNION.COM
END OF TRANSUNION REPORT
Achieve more™ with TransUnion
EFTA00019634

IN THE MATTER OF
[REDACTED] ET AL

STATE OF Pennsylvania )
COUNTY OF Delaware )

CERTIFICATION AND WAIVER

My name is [REDACTED]. I am over 18 (eighteen) years of age, of sound mind, capable of making this affirmation, and am personally acquainted with the facts herein stated:

I am currently employed as a Representative II in the Litigation Support Department of Trans Union LLC, located at 1510 Chester Pike, Crum Lynne, PA 19022, and I am authorized to make this declaration on behalf of Trans Union LLC. I understand that I have an absolute right to appear personally before the Grand Jury in response to the subpoena, with expenses paid as provided by U.S. statutes, to testify under oath, and to produce the records called for by the subpoena. Nonetheless, I choose to waive that right.

Attached hereto are TransUnion credit reports for the individual(s) identified in your request attached hereto, as derived from information contained in TransUnion’s computer records as of the date of the credit report(s). The information contained in the credit report(s) was compiled by TransUnion from various sources in the ordinary course of TransUnion’s business operations, and it is customary and routine for TransUnion to prepare such reports in the ordinary course of its business. The report(s) was/were obtained from TransUnion’s computer records as of the date on the credit report(s), using the consumer’s identifying information provided in your request attached hereto. The documents attached hereto are the originals or exact copies of the originals.

[SIGNATURE REDACTED]
AFFIANT
September 1, 2020
DATE
EFTA00019635