UNITED STATES DISTRICT COURT· - WordPress.com...... (SDNY Rev. 05/10) Search and Seizure Warrant...
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AO 93 (SDNY Rev. 05/10) Search and Seizure Warrant
UNITED STATES DISTRICT COURT· for the
Southembistrict of New York·
In the Matter of the Search of (Briefly describe the property to be searched or identifY the person by name and address)
THE PREMISES KNOWN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE,
27TH FLOOR, NEW YORK, NY (AS ATTACHED)
) ) ) ) ) )
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
G2587
An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the SOUTHERN District of NEW YORK
· (identifY the person or describe the property to be searched and give its location): THE PREMISES KNOWN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NY (AS ATTACHED) (AND ANY LOCKED OR CLOSED CLOSETS, SAFES, CABINETS AND CONTAINERS THEREIN)
The person or property to be searched, described above, is believed to conceal (identifY the person or describe the
property to be seized);
SEE ATTACHED AFFIDAVIT, INCLUDING ALL ATTACHMENTS
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property.
YOU ARE COMMANDED to execute this warrant on or before
li?f in the daytime 6:00a.m. to 10 p.m. (not to extfeed 14 dayo)
0 at any time in the day or night as I find reasonable cause has been established.
Unless delayed notice is authorized below, you must give a copy of the wan·ant and a receipt for the property takeri to the person from whom, or from whose premises, the property was taken, or leave th~ copy ·and receipt at the place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventod' as required by law and promptly return this warrant and inventory to the Clerk of the Court. ·f~
&i'Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. _LJ_+-"-.. -'-( -'::._'---__ USMJ Initials
0 I find that immediate notification may have an adverse result listed in 18 U.S. C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor days (not to exceed 30).
Ountil, the facts justifying, the later specific date of ((' /)// ~CT"1 .v' ) ,; /}/ ~
Date and time issued: /1/t-vi::Vf/'.)~! /o/U ___ _.S'--/--~'--k-~----o---:-'/-:-f'--1_{_ "-----~-~-( Judge's signature
City and state: NEW YORK NEW YORK HONORABLE THEODORE H. KATZ, U.S.M.J. Pr(nted name and title
AO 93 (Rev 01/09) Search and Seizure Warrant (Page 2)
Return
Case No.: l Date and time warrant executed: I Copy of warrant and inventory left with:
Inventory made in the presence of :
·Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court.
Date: Executing officer's signature
Printed name and title
ATTACHMENT A (page 1 of 2)
THE PREMISES KNOWN AND DESCRIBED AS (A) THE OFFICES OF DAVID GANEK.t ANTHONY CHIASSON, AND INCLUDING ALL
COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR
IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN
ATTACHMENT B 1 •. ALL LOCATED AT LEVEL GLOBAL INVEST<?RS, 888 7TH AVENUEr 27TH FLOORr NEW YORKr NEW YORK
(A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND
111111111111, INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND
CELLULAR.TELEPHONES: All financial records, handwritten documents
and/or notebooks, letters and correspondence, photographs,
telephone and address books, identification documents, travel
documents, telephone records, computers and other electronic
devices, cellular telephones, and other records and documents
that constitute evidence of the commission of securities fraud,
wire fraud, money laundering, commercial bribery, conspiracy to
commit and aiding and abetting the commission of such ,crimes, or
are contraband and/or the fruits of violations of the federal
securities fraud, wire fraud, money laundering, and commercial
bribery laws, and/or are designed or intended as a m~ans of
violating the federal securities fraud, wire fraud, money
laundering, and commercial bribery laws, including any of the
above items that are maintained within other closed or locked
containers, including those that may be further secured by key
locks (or combination locks) of various kinds. These items will
be searched pursuant to the procedure set forth in Attachment B.
AND
ATTACHMENT A (page 2 of 2)
(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS,
(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS
WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND
PROCEDURE SET FORTH IN ATTACHMENT B.
ATTACHMENT B (page 1 of 2)
1. The Federal Bureau of Investigation ("FBI") will follow the following procedure with respect to the search of the servers listed in Attachment A at Level Global Investors.
First, personnel at the FBI will make a mirror image of all, or as much as feasible and necessary, of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event, once the servers have been imaged, they will be returned.
Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all, or as much as feasible and necessary, of the servers at Level Global Investors will be imaged.
Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches. of the imaged material from the servers:
(1) Search for all emails and documents authored by, sent to, and/or received from David Ganek, Anthony Chiasson, 111111111111111, and Sam Adondakis.
(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s)
(a) (b) (c) "my check" (d) consultant (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell (j) (k)
ATTACHMENT B (page 2 of 2)
2. For all other items listed in Attachment A (other than the servers which is covered by procedure #1 above}, the FBI will search the content in Attachment A for the following information:
1. Ganek, consultants,
Any and all Chiasson,
Broadband Research, and any
communications between and , Sam Adondakis 1
1 1 John Kinnuc thi~d-party consultant.
2. Any and all documents relating to, reflecting, and/or concerning information about public companies.
3. Any and all evidence reflecting communications about trading based on information about public companies.
avid
4. Any and all other evidence that will.assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidentiality and/or involved in trading based on material, nonpublic information.
5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United Stat~s Code, Sections 371, 1343, 1348, 1349, 1952 1 1956, Title 15. United States Code, Sections 78j (b) and 78ff, and Title 18, United States Code, Section 2 in connection with those offenses.
AO J06 (Rev. 06/09) Application for a Search Warrant
UNITED STATES DISTRICT COURT for the
Southern District of New York
In the Matter of the Search of (Briefly describe the property to be searched or identifY the person by name and address)
LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK
)
~ ) ) )
APPLICATION FOR A SEARCH WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (identifY the person or describe the
prf~g>'r:f~~Tg~'kf.J(SV()'f~/~fs6affEfuCRIBED AS 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK (AS ATTACHED) .
located in the _.......=S...--0...--U...--T...--H..:...E..:...:...:.R.-N __ District of ___ ..:...:...:.N...--E--W.---Y..:...O...--R..:...K--=--- , there is now concealed (identifY the
person or describe the property to be seized):
PLEASE SEE ATTACHED AFFIDAVIT AND ALL ATTACHMENTS.
The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):
~evidence of a crime;
~contraband, fruits of crime, or other items illegally possessed;
ri property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section 18 U.S.C, §§ 2, 3711 1343, 1348, 1349; 15 u.s.c. §§ 78j
Offinse Description Including but not limited to wire fraud , fraud 1n connection with securities, and money laundering, and conspiracy to commit the same.·
(b), 78ff
The application is based on these facts:
PLEASE SEE ATTACHED AFFIDAVIT AND RIDER.
~ Continued on the attached sheet.
0 Delayed notice of __ days (give exact ending date if more than 30 days: _____ )is requested under 18 U.S.C. § 31 03a, the basis of which is set forth on the attached sheet.
p/i nt 's srgnature
HOLLY J. TRASK, SPECIAL AGENT, FBI Printed name and title
Sworn to before me and signed in my presence.
Date: 11/21/2010 ( Judge's signature
j / 11! c_;....---? City and state: __ ,.&;""-""?iH_,· <...:.:.'1_d_i1-r..A/ __ ,_,?./_/_ v ,,__._ .. -'=C.L---' THEODORE H. KATZ
Printed name and title
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
IN THE MATTER OF THE APPLICATION OF THE UNITED STATES OF AMERICA
- - X
FOR A SEARCH WARRANT FOR THE PREMISES KNOWN AND DESCRIBED AS (A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND 111111111111, INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING A SPECIFIC PROCEDURE, ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK
- - - - X
FILED UNDER SEAL
AFFIDAVIT IN SUPPORT OF A SEARCH WARRANT
HOLLY J. TRASK, being duly sworn, deposes and says:
1. I am a Special Agent with the Federal Bureau of
Investigation ("FBI"). I make this Affidavit pursuant to Rule 41
of the Federal Rules of Criminal Procedure for the issuance of a
warrant to search THE PREMISES KNOWN AND DESCRIBED AS (A) THE
OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND
INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND CELLULAR
TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM
ADONDAKIS, AND (C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS'
SERVERS WHICH WILL THEN BE SEARCHED USING A SPECIFIC PROCEDURE,
(as set forth in this affidavit and its attachments) , ALL LOCATED
. AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK,
NEW YORK (the "PREMISES"). The grounds for my belief are as
follows.
2. I have been a Special Agent with the FBI for over
7 years. I have participated in numerous investigations of
fraudulent schemes, including wire fraud/ mail fraud, money
laundering, and securities fraud. Among other things, during
these investigations, I have participated in the execution of
search warrants. Through my training, education, and experience/
I have become familiar with the manner in which fraudulent
schemes, including illegal insider trading and wire fraud
schemes, are operated/ and the types of electronic records kept
in and maintained in connection with these fraudulent schemes.
3. This application is submitted in connection with
an investigation of wire fraud and illegal insider trading
schemes in which individuals have been receiving and then
transmitting to others material, nonpublic information .regarding
certain public companies' quarterly earnings releases and other
market moving events (the "Inside Information11) for the purpose
of executing profitable securities transactions, and in which the
Inside Information has been misappropriated by individuals in
violation of their fiduciary and other duties of trust and
confidence to their employers. For the reasons detailed below,
there is probable cause to believe that, in the PREMISES 1 there
exists evidence/ fruits, and instrumentalities of violations of
the following statutes: (a) wire fraud 1 in violation of Title 18 1
United States Code, Section 1343; (b) money laundering, in
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violation of Title 18, United States Code, 1956; (c) travel act,
commercial bribery, in violation of Title 18, United States Code,
Section 1952; (d) conspiracy to commit wire fraud, in violation
of Title 18, United States Code, Section 371; (e) conspiracy to
commit commercial bribery, in violation of Title ·18, United
States Code, Section 371; (f) conspiracy to commit money
laundering, in violation of Title 18, United States Code, 371;
(g) securities fraud, in violation of Title 18, United States
Code, Section 1348, and Title 15, United States Code, Sections
78j (b) and 78ff, and Title 17, Code of Federal Regulations,
Sections 240.10b-5 and 240.10b5-2; (h) conspiracy to commit
securities fraud, in violation of Title 18, United States Code,
Section 371, and Title 18, United States Code, Section 1349; and
(i) aiding and abetting the substantive offenses of wire fraud,
money laundering, travel act/commercial bribery, and securities
fraud, in violation of Title 18, United States Code, Sect}on 2
(hereinafter collectively referred to as "TARGET OFFENSES"), as
described below and in Attachments A and B to this A~fidavit.
4. Because this Affidavit is being submitted for the
limited purpose of establishing probable cause for a warrant to
search the PREMISES, I have not included every detail of every
aspect of the investigation. Rather, I have set forth only those
facts that I believe are necessary to establish probable cause.
The information contained in this Affidavit is based upon
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conversations with other law enforcement officers, cooperating
witnesses (as reflected below), my review of various documents
and records, my review of interceptions of wire communications as
a result of court-authorized wiretaps pursuant to Title 1&,
United States Code, Section 2518 and, where specified, my
personal observations and knowledge. Unless specific~lly
indicated, all conversations and statements described in this
Affidavit are related in substance and in part only.
THE INVESTIGATION
5. Since at least in or about 2009, I and ocher FBI
agents have been investigating the TARGET OFFENSES in(connection
with the use of third-party consultants hired by money managers,
including hedge funds, to provide Inside Information relating to
public companies. In certain circumstances, the investigation
has focused on third-party consultants like JOHN KINNUCAN who
operated his own firm called Broadband Research. Consultants
like KINNUCAN received money from money managers, including hedge
funds, for information that they obtained from, among other
sources, insiders at public companies. In other· circumstances,
the investigation has focused on third-party consultant firms
like who pay, among other
people, insiders at public companies to speak with and provide
information to their clients, including hedge funds.
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6. Since at least in or about 2009, I and other FBI
agents have determined that there is probable cause to believe
that certain third-party consultants, certain third-party
consultant firms, certain insiders at public companies, and
certain money managers, among others, have violated the TARGET
OFFENSES. During the course of the investigation, I an¢ other
FBI agents have obtained the cooperation of multiple participants
in these TARGET OFFENSES. In addition, under the direction of
the FBI, several of these cooperating witnesses have recorded
conversations with participants in these TARGET OFFENSES.
Moreover, I and other FBI agents have obtained court
authorization to intercept wire communications over the I
telephones used by multiple individuals.
7. From on or about October 7, 2009 through on or
about May 27, 2010, I and other FBI agents obtained court
authorization to intercept wire communications over two
conference lines used by to connect, among other things,
consultants who included insiders at public companies with
clients who included hedge funds. (In this affidavit I refer to
these telephone lines as Conference Line 1," Conference
Line 2," and collectively, the Conference Lines") Based on
these wire interceptions, I and other FBI agents learned that
numerous insiders at public companies were violating their
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fiduciary and other duties of trust and confidence to their
employers by disclosing Inside Information to 's clients.
8. Based on my review of summary line sheets and my
conversations with other FBI agents, I have learned that certain
wire interceptions over the conference lines included
conversations between SAM ADONDAKIS, an employee at the time with
a hedge fund called LEVEL GLOBAL INVESTORS, and consultants
who were insiders at public companies. I have further learned
that, during these conversations, ADONDAKIS knowingly received
Inside Information from these consultants who were violating
their fiduciary and other duties of trust and confidence to their
employers. The following are some examples of those
interceptions: 1
a. On or about November 6, 2009, at approximately
11:32 a.m., an incoming call was intercepted
Conference Lines, between SAM ADONDAKIS and
During the conversation, ADONDAKIS stated that he
In certain instances throughout this affidavit, I have included in parentheses my interpretation of certain abbreviations, words, and phrases used in the recorded communications quoted herein, and I have used ellipses (". .") to denote where I have omitted other recorded words, phrases, or other statements made within the passages quoted herein, These interpretations are based on my training, experience, my conversations with cooperating witnesses, my review of intercepted conversations, and my review of publicly available information.
learned conversations with
has been identified as
6
worked for Level Global Investors, that Level Global Investors
has $4 billion in assets and is based in New York, and that
ADONDAKIS covers computer hardware and semiconductors. During
the conversation, tated that he worked for which
is a business unit within llllllliiiJI
was involved with all of
and that his group
(Based on my review
of the wiretap application submitted by the FBI to intercept wire
communications over the Conference Lines (hereinafter "
Wiretap Application"), I have learned that
public company whose shares are traded on NASDAQ.)
further stated that he has "good visibility" into the
is a
semiconductor side of (Based on my review of
the Wiretap Application, I have learned that the
semiconductor side of accounts for
approximately 50~ of the company's overall revenue.)
stated that "from the semico~ductor side 1 I think I have a pretty
good idea of what is going on in terms of capital expenditure
from the outside world as we see it." ADONDAKIS responded:
"Great." urther stated that " ... technically my role
here is 1 I am a materials project manager/ but in order to do
what we do for projects that are wide (in) scope across the
company/ it requires us to have that vision of what is happening
in a more global sense." ADONDAKIS responded: "Sure, ok,
perfect." ADONDAKIS later stated that he thought that most
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companies who had reported (earnings) recently think thir).gs are
going well and that the order guidance was strong for the fourth
quarter. ADONDAKIS stated that recently there had been a couple
of reports that there was a chance that things could slow and he
would be curious to
continued," and how
quarters."
s take "if momentum has
the slope of the next few
responded: "Yeah, so hopefully you are hearing
that news from our competitors, because I am not seeing it the
same way. You know really what I am look at the fourth quarter,
of course, our earnings call will be next week, but, urn, the
fourth quarter from my viewpoint finished up what was a pretty
dismal year at least on a positive note, you know. I am looking
at about a 75% uptick from the previous quarter, although it was
down from the previous year, it was single digits down, right, so
7% below the previous year . and let me preface what I am
about to say with, urn, the information, what I look (at)
basically are, is, in a sense, kind of a build plan, so it gives
me a tick on what we are seeing coming in from our customer base.
Urn, typically, because it is more manufacturing oriented, the
future outlook is somewhat sketchy, I guess would be the best way
to put it. Urn, so it is not a real, there is not a real
scientific forecast that we have. Urn, so really what we see
comes down to the nuts and bolts of hard orders, urn, as we get
into real time. So you know, a month awayr two months way,
8
pretty good information, pretty much speculative as we go further
than that." A short time later, dded that "I am
expecting a first quarter uptick of at least 50~ on top of the
fourth quarter, and then right now the second quarter and the
third quarter are somewhat leveling out, and the reason I think
that is good news is because, right now, if we can say in the
first quarter 1 in early first quarter 1 that the second quarter
and the third quarter are leveling out, more than likely/ what we
have seen is a lot of that drop in demand come in clos~r to the
time, and we see the numbers increase. 11 ADONDAKIS responded: "I
see. 11 then stated: "So do I think we are leveling out? I
don 1 t think so. I think the numbers right now mathematically
would say that it is leveling 1 but I believe the way.'the momentum
is going right now is that we will see a continual rise/ at least
probably through the mid-part of 2010." (Based on my training,
experience/ and conversations with other agents, I believe that
the information that. rovided to ADONDAKIS would be
important to an investor in determining whether to buy and/or
sell securities, and that the information
regarding the growth of the semiconductor part of the business in
the fourth quarter of this year and the first 1 second 1 and third
quarters of next year, was nonpublic at the time.) Later in the
conversation/ ADONDAKIS asked: "When do you start to get, um, you
know/ very good confidence injthe next quarter? At what point? 11
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sponded: "Oh, I would say 1 you know, I mean obviously
the closer the better, but as we get within a month or S0 1 I
think we have a pretty good idea. We will see some ebbing and
flowing going on for a little while yet 1 but, like I say, because
we are where we are at, and the numbers that I am seeing for the
second quarter 1 even the third quarter 1 is what really makes me
feel a little bit more comfortable in saying that those are going
to be some pretty solid quarters for us. No obviously not going
to be at levels we were used to a couple of years ago( but
certainly( you know, reaching levels we were at in mid-2006.
Hold on a sec, I will tell you exactly where that falls in, yeah,
so 2005, mid-to-late 2005, was a bit of a lull 1 but we are
approaching those levels right now." ADONDAKIS asked: "OK, so
you are approaching levels of 2006 or 2005?" sponded:
"2005 1 yeah, 2006 really started to shoot up in the second
quarter 1 um 1 you know( way up there. We are not there yet. 11
(Based on my training( experience 1 and conversations with other
agents( I believe that the information that rovided to
ADONDAKIS about how the "numbers" looked·in the fourth quarter as
compared with the numbers in 2005 and 2006 would be important to
an investor in determining whether to buy and/or sell
ecurities.) Toward the end of the conversation 1
"As we near the end of the quarter is probably a
good time to get a little bit f·irmer numbers and see where things
10
are going, but you know, I leave that up to you, what makes sense
to you, so you just let me know and I can make it happen."
ADONDAKIS responded: "OK, perfect. Well, you know what; maybe I
will check in with you following, well I guess the e~rnings call
is next week, so maybe it makes sense for us to talk, uh, kind of
late November, later in the month, like uh, the last week of
November, the first week of December timeframe."
responded: "Sure."
b. On or about December 1, 2009, at approximately
12:04 p.m., an incoming call was intercepted over the
Conference Lines during which BOB NGUYEN, a employee, spoke
who stated that he previously worked at
and now worked at (Based on my review of the
Application, I have learned tha is
a public company whose shares trade on the New York Stock
During the conversation, NGUYEN stated that he was
~nstructed to speak with by "JESSE" [LNU] (who appears to be
client named JESSE TORTORA) and that he was interested in
learning about and NGUYEN mentioned
that he spoken with JESSE TORTORA and "SAM"
(whom I believe to be SAM ADONDAKIS) in the past, and that NGUYEN
was directed to speak with NGUYEN stated that JESSE
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TORTORA was at·a firm whose compliance has grown stronger, so
there might have been recent hesitation with JESSE TORTORA
reaching out to (Based on my training, experience, and
conversations with other agents, I believe that NGUYEN was
stating that JESSE TORTORA's compliance department did not want
JESSE TORTORA speaking directly with employees at public
companies and, as a result, JESSE TORTORA directed NGUYEN to
speak with and then provide the information to JESSE
TORTORA, as a means by which JESSE TORTORA would be able to get
around the compliance department's policies.) stated that
~he information he had provided was his read on the industry but
nothing confidential and now that s working at a private
company, there should be no conflict of interest. NGUYEN stated
that JESSE TORTORA told NGUYEN that
past was a good market indicator even
information in the
was not working at
the executive level. stated that he left
because it was a massive company, but was growing and
focusing on cellular wireless technology solutions. NGUYEN asked
interaction with and whether
was trying to sell its baseband group. said
yes, that was trying to sell. it, but that no
one was willing to pay for it right now so that they pulled it
back in-house. further stated that and
a supply agreement for the next ten years. said
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that was not buying any big companies. NGUYEN
still followed what was going on at
interacts with some of
that he hoped to continue that
relationship. stated that his wife worked for
as well. (Based on my training, experience, and
conversations with other agents, I believe that NGUYEN was asking
whether had access to Inside Information at
though no longer worked for that company,
and that stated in his response that he had access to
information as a result of his company's business relationship
with his continued access to executives at
and his wife's employment at
NGUYEN asked about the next couple of months and
quarters in the semiconductor industry, and responded that,
among other things, it would be until February before
could improve its lead times and that there were supply system
issues with that demand was still strong
into the end of the first quarter but who knew afterwards and
that, as far as double-booking, it was not a large concern right
now. (Based on my training, experience, and conversations with
other agents, I believe that the information that provided
NGUYEN relating to would be important to an
investor in determining whether to buy and/or sell
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securities, and that the information was not public.)
NGUYEN wondered whether was on a two-to-three
year downturn, and stated that inside management at
was short-sighted, that there was a lot of in-house
arguing, and that had lost share over the last
few quarters (according to an individual named
believe to be
based on my review of publicly available
information) . NGUYEN asked if will have
oversupply in the next year, and that he thought
s was still conservative at least for the next
few quarters. NGUYEN stated that he wanted to speak with
another month or two, and will ask about whether or not
"double-booking" will become an issue. NGUYEN asked if
in
needed help with anything, and tated that he was interested
in certain areas and if NGUYEN heard about any upcoming mergers
and acquisitions. (Based on my training, experience, and
conversations with other agents, I believe that NGUYEN was
offering to provide information to about other companies as
a way to obtain further information from about
in the future.) stated that some "M&A"
(referring to mergers and acquisitions) should happen but he did
not know of any right now. NGUYEN stated that he will send any
interesting notes that he has from a contact at AT&T and email
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them
that
NGUY~N stated that he will let JESSE TORTORA know
at a private company now.
c. On or about December 2, 2009, at approximately
3:05p.m., an incoming call was intercepted over the
Conference Lines in which SAM ADONDAKIS spoke with of
During the conversation, stated that they talked in
late October and that bookings was making a decent first quarter.
ADONDAKIS asked whe~her bookings were going to go up in the first
quarter, and stated that executives were
expecting things to slow down but it had not, and that this was
overall, not just analog or wireless. ADONDAKIS asked if
knew what the bookings were in the fourth quarter as compared to
the third quarter, and sponded "the bookings in Q4 (fourth
quarter) were, let's see, versus Q3 (third quarter) slightly up,
just slightly greater than one book-to-bill, but not drastically
better." ADONDAKIS asked about double-ordering, and tated
that there was not much of a concern, just a week and a half ago
when he talked to the guys, over double-ordering, and that it
looked like the first quarter was going to come in flat.
ADONDAKIS asked if there was anything else important, and
stated that lead times at had been pretty
consistent across the industry. (Based on my training,
experience, and conversations with other agents, I believe that
the information that ided to ADONDAKIS relating to
15
bookings and double-ordering would be important to an investor in
determining whether to buy and/or sell Texas Instruments
securities and that this information was not public at the time.)
ADONDAKIS thanked for the rundown, and stated that he will
check in with him on the December timeframe. stated that he
"will check in with some of the guys and try to get a read on how
things are, um, looking, rolling up, coming into mid-December,
they should have a good feel for how December is going to roll,
um, I'l-l see if I can get another datapoint for you." ADONDAKIS
responded: "Sounds good." They agreed to speak again in a couple
of weeks.
d. On or about January 15, 2010, at approximately
11:36 a.m., an incoming call was intercepted on the
Conference Lines, during which SAM ADONDAKIS spoke with
(Based on my conversations with other FBI agents, I have
learned that was one of several global supply managers for
Dell, Inc., during the relevant period.) During the
conversation, ADONDAKIS stated that he had spoken with "some
foH:s at distributors" who told him that they just had a really
hard time getting parts, that "they couldn't get anything and
they are all freaked out about it," and that in the last.two
weeks there was a sudden magical supply. ADONDAKIS asked whether
"heard anything like this or does this make ~ense on what
you are seeing?" esponded: "It does make sense because
16
my supply position right now and outlook is much better than it
was two months ago. Where I have been living on 1 to 3 days of
inventory to my to my forecast, I am now probably sitting on
almost 5 to 6 days, so things have drastically improved. I think
a lot of it is due to that both WD (Western Digital) and seagate
added some capacity and we are starting to see the fruitions of
that. Now on the demand side, demand continues to be relatively
healthy and strong. My forecast for December was what I think I
told you like maybe 2.2 or 2.3 (million notebooks) .'and I finished
at 2.1 (million), so you know we take that as a positive."
ADONDAKIS replied: "OK." continued: "Now January, my
forecast is sitting, I wanted to tell you, I probably told you,
like another 2.3 (million). And I am going to land anywhere
between 1.9 (million) and 2 (million), that might be down a
little bit but week one of January got off to a slow start. But
at the same time, there is a lot of people off during that time
period. So we are starting to see the hockey stick effect, as
far as we get towards our end of the quarter in January that we
are starting to see a good pickup. So we will probably land in
the 1.9 (million) to 2.0 (million) range. That is off a little
bit of the forecast of 2.3 (million), but we always put in a
little bit of hedge in there to kind of drive more ~upply, If
Toward the end of the conversation, stated: "Going forward
for notebooks, February is at 1.93 (million); March is at 1.97
17
(million); April is at 2.19 (million); and May is at 1.65
(million) . " ADONDAKIS replied: "OK." then stated: "With
my 2.1 (million) that I did in December, my Q4 ended at 6.1
(million). And if you were to compare that to what Q3 was/ my Q3
was at 5.4 (million). And so you know there was some' growth
there but at the same time, my company continues to l.ose market
share. And I think the IDC 1 or the data just came out/ I guess/
yesterday that we showed that we lost market share. Of course/
we have always been margin focused over the last nine months and
I think that is going to change a little bit, and I think we are
going to be going more for revenue and trying to get back some of
this market share. So I think that is the strategy from our
executives coming out here relatively soon." ADONDAKIS asked:
"OK. Do you think that means/ you know, taking action on
pricing?" I responded: "I would say yes. 11 later
explained that companies like Dell, HP, Acer, and especially
Apple are moving away from using the "5400" RPM (revolutions per
minute) and move toward the "7200" RPM, and that "it's higher
margin for us of sales and then also for the hard drive suppliers
themselves." ADONDAKIS replied: "Gotcha. Yeah. That definitely
is something that should benefit them. I would that both
companies will report earnings next week 1 and I would think that
these will be kind of blowout numbers. 11 stated, "right 1
yeah, and it will be interesting to see what they say is their
18
outlook." (Based on my training, experience, and conversations
with other agents, I believe that the information that
provided to ADONDAKIS relating to actual and projected Dell
notebook sales would be important to an investor in determining
whether to buy and/or sell Dellr Western Digitalr and Seagate
securities 1 and that the information was not public at the time.)
9. From on or about May 5 1 2010 1 through on or about
August 10 1 2010, I and other FBI agents obtained court
authorization to intercept wire communications over the cellular
telephone of JOHN KINNUCAN, an independent third-party consultant
who operated his own firm called Broadband Research. Based on
these wire interceptions, I and other FBI agents learned that
KINNUCAN obtained Inside Information from numerous insiders at
public companies who were violating their fiduciary and other.
duties of trust and confidence to their employers by disclosing
Inside Information to KINNUCAN. I and other FBI agents further
learned that KINNUCAN then provided the Inside Information that
he obtained from insiders at public companies to his hedge fund
clients.
10. Based on my review of summary line sheets and my
conversations with other FBI agents 1 I have learned that certain
wire interceptions over the cellular telephone of JOHN KINNUCAN
were between KINNUCAN and both ANTHONY CHIASSON and
of Level Global Investors. Based on my conversations with other
19
FBI agents, I know that CHIASSON is a co-founding partner and the
director of research for Level Global Investors and that
is an employee of Level Global Investors. Based on my
conversations with other FBI agents, I have further learned that 1
during the conversations intercepted between KINNUCAN and
CHIASSON and KINNUCAN provided Inside Information to
CHIASSON and and that KINNUCAN 1 S sources of Inside
Information violated their fiduciary and other duties of trust
and confidence to their employers by providing that information
to KINNUCAN. The following are some examples of those
interceptions:
a. On or about July 26, 2010, at approximately 10:29
a.m., an outgoing call was intercepted from the cellular
telephone of JOHN KINNUCAN to ANTHONY CHIASSON and
of Level Global Investors. At some point during the
conversation/ KINNUCAN stated that Apple was lining up Sony as a
second source on the camera sensor due to execution miscues by
Omnivision 1 and that Apple was getting pretty frustrated with
Omnivision 1 S execution. CHIASSON then asked whether KINNUCAN did
"primary research" or whether the information was from a "rumoru
that KINNUCAN was picking up. KINNUCAN told CHIASSON and
that he wanted to be very clear that he did not traffic in
"second hand and rumors 1 u that he does not repeat stuff that he
heard/ and that he only traffics in stuff that he has heard from
20
"my primary contacts. 11 CHIASSON then said okay/ and asked
whether this. would be somebody in Taiwan or someone speaking to
somebody over there. KINNUCAN then stated that/ "frankly/ his
source was the chief contract manufacturer building the stuff for
Apple. 11 (Based on my conversations with other FBI agents/ I have
learned that KINNUCAN 1S source of information about Apple was
who was working for the chief cont~act
manufacturer at a public company called
of putting cameras into certain Apple products.
in charge
I have further
learned that s violating his fiduciary and other duties
of trust and confidence to and 1 in turn 1 Apple by
disclosing Inside Information to KINNUCAN1 among others, in
exchange for money.) CHIASSON then asked KINNUCAN about the
impact on the near term and whether this was something to worry
about simply because it was going to be something that was a
product cycle down in the future. KINNUCAN responded that that
was absolutely true and that they were talking six months. Later
in the conversation, KINNUCAN provided information about
Broadcom. KINNUCAN stated that Broadcom was seeing very nice
upside over the course of the enterprise networking business
which had been a major source of concern. KINNUCAN further
stated that they may temper their guidance, and that all the high
profile names like Broadcom, Netlogic, cavium 1 and Acme Packet
will all be quite positive. KINNUCAN also stated that he will
21
get some more updates on Netlogic later that day and that
Netlogic is a favorite short of some funds. CHIASSON asked about
Sandisk, and KINNUCAN stated that he thought the market would
tighten in the next few weeks and that he is happy with his call
on sandisk.
b. On or about July 27, 2010, at approximately 11:33
a.m. , an outgoing call from JOHN KINNUCAN' s cellular t-elephone to
ANTHONY CHIASSON was intercepted. During the conversation,
KINNUCAN said that he was calling on Sandisk. CHIASSON said that
he had just stepped into a meeting. KINNUCAN then stated that
the long awaited tightening in the market finally appeared to be
happening.
c. On or about July 27, 2010, at approximately 2:13
p.m., an outgoing call from JOHN KINNUCAN to ANTHONY CHIASSON was
intercepted. During the conversation, KINNUCAN stated that flash
market was starting to_tighten up, that Apple was back in the
market asking for parts again after about a month off, and that
Cisco was cutting orders, the vast majority of which were never
being filled.
11. Based on my conversations with other FBI agents, I
have learned the following regarding SAM ADONDAKIS: During the
course of this investigation, in October 2010, two FBI agents
approached SAM ADONDAKIS _regarding his involvement in
participating in trades based on material nonpublic information
22
at Level Global Investors, and asked for his cooperation. By on
or about November 2, 2010, ADONDAKIS agreed to cooperate with law
enforcement in this investigation. Among other things, ADONDAKIS
has gdmitted his participation in obtaining Inside Information,
knowing that the Inside Information came directly and/or
indirectly from public employees who were violating a duty of
confidentiality that prohibited them from disclosing the
information, providing the Inside Information to DAVID GANEK,
ANTHONY CHIASSON, among others, at Level Global
Investors who then executed and caused others to execute
securities transactions based in part on the Inside Information,
and exchanging that Inside Information with other individuals. I
know from my conversations with other FBI agents that GANEK is
of Level Global Investors.
12. SAM ADONDAKIS, who has not yet been charged with
any crimes, is cooperating with the Government in the hope that
he will be able to provide substantial assistance to the
Government, enter into a cooperation agreement with the
Government, and receive a reduced sentence for his crimes.
Certain information provided by ADONDAKIS has proven to be
reliable and accurate through telephone records, recorded
conversations, and other information.
23
13. Based on my conversations with other FBI agents
who have spoken with SAM ADONDAKIS, I have learned, among other
things, the following:
a. ADONDAKIS was an analyst at Level Global Investors
and was asked to leave the hedge fund in or about March 2010.
b. ADONDAKIS worked analyzing and researching public
companies in the technology sector.
c. During his work as an analyst at Level Glqbal
Investors, ADONDAKIS obtained Inside Information from insiders at
public companies through third-party consultants, including
and from colleagues at other money managers,
including hedge funds. On certain occasions, ADONDAKIS provided
this Inside Information to DAVID GANEK, ANTHONY CHIASSON, and
, and GANEK, CHIASSON, and executed and
caused others to execute certain securities transactions based,
in part/ on the Inside Information, and that ADONDAKIS informed
GANEK, CHIASSON, and of the sources of the Inside
Information. Among other things, ADONDAKIS typed notes of his
conversations with insiders at public companies regar~ing the
Inside Information that he received from them. ADONDAKIS saved
these notes to the shared network drive at Level Global
Investors. These notes on the shared network drive wouid and
should be maintained and kept on the servers of Level Global
Investors.
24
d. During his work as an analyst at Level Global
Investors, ADONDAKIS exchanged Inside Information with several
colleagues at other money managers, including hedge fu~ds.
ADONDAKIS exchanged the Inside Information with these colleagues
by and through, among other means, email communications. Prior
to the arrests of Raj Rajaratnam, the founder of Galleon Group
hedge fund, and other individuals on insider trading charges on
or about October 16, 2009, ADONDAKIS used his email address at
Level Global Investors to exchange Inside Information with these
colleagues. At times, ADONDAKIS also forwarded certain emails
that he received from colleagues at other money managers
containing Inside Information to, among other people,. CHIASSON.
These email communications would and should be maintained and
kept on the servers at Level Global Investors. Following the
arrests on or about October 16, 2009, ADONDAKIS and certain
colleagues with whom he exchanged Inside Information at other
money managers stopped using their work email addresses and
started to use personal email addresses to communicate with each
other.
e. During his work as an analyst at Level Global
Investors, ADONDAKIS spoke with and provided Inside Information
to GANEK, CHIASSON, and and informed GA-NEK, CHIASSON,
and regarding the sources of the Inside Information.
25
These conversations would take place in, among other locations,
the offices of GANEK, CHIASSON, and
f. Level Global Investors is currehtly located on the
27th floor of the building at 888 7th Avenue in New York, New
York. Level Global Investors occupies the entire 27th floor of
the building. On the 27th floor, one enters Level Global
Investors by walking through big wooden double doors. Upon
walking through those doors, the receptionist desk is on the
right.
g. GANEK has an office on the 27th floor at 888 7th
Avenue in New York, New York. GANEK's office can be located by
passing the receptionist desk, making a right turn, and then
making an immediate left turn to GANEK's office. The door to
GANEK's office is a frosted glass door, GANEK has multiple
computer screens in his office connected to a computer tower.
GANEK also has a laptop computer.
h. CHIASSON has an office on the 27th floor at 888
7th Avenue in New York, New York. CHIASSON's office can be
located by passing the receptionist desk, making a right turn,
then making another right turn, and then walking down to the end
of the hallway to CHIASSON's office. The door to CHIASSON's
office is a clear sliding glass door. CHIASSON has multiple
computer screens in his office connected to a computer tower.
CHIASSON also has a laptop computer.
26
i. has an
Avenue in New York/
a laptop
computer.
j. ADONDAKIS still has possession/ custody/ and
control over his laptop computer from Level Global Investors.
While working at Level Global Investors on the 27th floor at 888
7th Avenue in New York 1 New York 1 ADONDAKIS also used a desktop
computer.
k. Level Global Investors maintains servers on the
27th floor at 888 7th Avenue in New York, New York. ADONDAKIS
does not know where the servers are located on the 27th floor.
All of the notes that ADONDAKIS took during his conversations
with third-party consultants, including those conversations with
inside~s at public companies who provided ADONDAKIS with Inside
Information/ would and should be stored on the servers of Level
Global Investors. Moreover/ all of ADONDAKI8 1 S emails from and
to his address at Level Global Investors/ and his emails from and
27
to GANEK, CHIASSON, and would and should be maintained
and kept on the servers of Level Global Investors. Following the
arrests of Raj Rajaratnam several individuals on October 16,
2009, ADONDAKIS was asked about several of these emails.
14. Based on my conversations with other FBI agents, I
have learned the following:
a. In or about October 2010, the FBI approached BOB
NGUYEN and asked him to cooperate with law enforcement in this
investigation. NGUYEN agreed to cooperate with law enforcement.
Among other things, NGUYEN admitted that he participated with
others at in obtaining Inside Information from
including insiders at public companies, and that
NGUYEN participated in helping clients obtain Inside
Information from NGUYEN, who has not yet been
charged with any crimes yet, is cooperating with the Government
in the hope that he will be able to provide substantial
assistance to the Government, enter into a cooperation agreement
with the Government, and receive a reduced sentence for his
crimes. Certain information provided by NGUYEN has proven to be
reliable and acdurate through telephone records, recorded
conversations, and other information.
b. In or about October 2010 and November 2010, the
FBI has approached certain (and others) who
worked as insiders at public companies. Certain
28
admitted that they had violated their fiduciary and other duties
of trust and confidence to their employers by providing Inside
Information to clients, including hedge funds, in exchange
for money. For example, admitted that he had violated
his fiduciary and other duties of trust and confidence to his
employer Dell by providing Inside Information to clients,
including Level Global Investors, in exchange for money.
who has not yet been charged with any crimes yet, is cooperating
with the Government in the hope that he will be able to provide
substantial assistance to the Government, enter into a
cooperation agre~ment with the Government, and receive a reduced
sentence for his crimes. Certain information provided by
to has proven to be reliable and accurate through telephone
records, recorded conversations, and other information.
15. Based on my review of the Wall Street Journal
("WSJ"), and other media, I have learned that, during the evening
hours of November 19, 2010, the WSJ published online an article
which appeared the next day on the front page of the print
edition, entitled "U.S. in Vast Insider Trading Probe." Among
other things, the article stated: •Federal authorities, capping a
three-year investigation, are preparing insider-trading charges
that could ensnare consultants, investment bankers, hedge-fund
and mutual-fund traders and analysts across the nation, according
to people familiar with the matter." The article further stated:
29
"One focus of the criminal investigation is examining whether
nonpublic information was passed along by independent analysts
and consultants who work for companies that provide 'expert
network' services to hedge funds and mutual funds. These
companies set up meetings and calls with current and former
managers from hundreds of companies for traders seeking an
investing edge. Among the expert networks whose consultants are
being examined, the people say, is Primary Global Research LLC, a
Mountain View, Calif., firm that connects experts with investors
seeking information in the technology, health-care and other
industries."
16. The November 20, 2010, WSJ article further
reported: "John Kinnucan, a principal at Broadband Research LLC
in Portland, Ore., sent an email on Oct. 26 to roughly 20
hedge-fund and mutual-fund clients telling of a visit by the
Federal Bureau of Investigation: 'Today two fresh faced· eager
beavers from the FBI showed up unannounced (obviously) on my
doorstep thoroughly convinced that my clients have ~een trading
on copious inside information,' the email said. '(They obviously
have been recording my cell phone conversations for quite some
time, with what motivation I have no idea.) We obviously beg to
differ, so have therefore declined the young gentleman's gracious
offer to wear a wire and therefore ensnare you in their devious
web.'"
30
17. Based on my conversations with other FBI agents, I
have learned that, following publication of the WSJ article on
the evening of November 19, 2010, a confidential source ("CS-1"),
who works at a hedge fund which used consultants, among other
people, to obtain Inside Information, informed the FBI that CS-
1's supervisor directed him to delete and discard evidence of
their participation in illegal insider trading and wire fraud
schemes. 3
18. Based on my training, experience, conversations
with other FBI agents, and knowledge of the actions taken by CW-
1's supervisor to discard and destroy evidence for purposes of
obstructing the Government's investigation, as well as the
actions that appear to be taken by JOHN KINNUCAN to obstruct the
Government's investigation through his email to his clients,
there is probable cause to believe that because, among other
things, GANEK, CHIASSON, and ceived and executed trades
based in part on Inside Information provided by ADONDAKIS (who
obtained the Inside Information from consultants and
ADONDAKIS's colleagues at other funds), and CHIASSON and
received Inside Information from KINNUCAN, this search warrant of
CS-1, who has not yet been charged with any crimes yet, is cooperating with the Government in the hope that CS-l will be able to provide substantial assistance to the Government, enter into a cooperation agreement with the Government, and receive a reduced sentence for CS-1's crimes. Certain information provided by CS-1 has proven to be reliable and accurate through telephone records, recorded conversations, and other information.
31
the PREMISES is not only necessary to obtain evidence, fruits,
and instrumentalities of the TARGET OFFENSES, but to preserve
such evidence.
32
ITEMS LIKELY TO BE FOUND AT THE PREMISES
19. Based upon my training, experience and
participation in investigations of fraudulent schemes,
particularly schemes relating to illegal insider trading and wire
fraud, as well as my conversations with other FBI agents, I know
the following:
a. Participants in fraudulent schemes, including
insider trading and wire fraud schemes, frequently maintain
documents in paper and electronic form that reflect their
communications relating to Inside Information, their
communications relating to trades executed based in part on
Inside Information, notes reflecting the receipt of Inside
Information, the location of fraudulent proceeds, the transfers
of money and other proceeds of the schemes, and other evidence of .. . the fraudulent schemes. Iri particular, based on the information
provided above, I believe that PREMISES will contain emails,
notes, and financial records that would constitute evidence,
fruits, and/or instrumentalities of the TARGET OFFENSES.
b. Participants in fraudulent schemes, including
insider trading and wire fraud schemes, also commonly maintain
addresses and telephone numbers in books and papers in both
electronic and paper form which reflect names, addresses 1
telephone numbers and/or paging numbers for their associates in
the schemes. Based on the information· provided above 1 I believe
33
that the PREMISES will contain telephone and address books and
other documents reflecting names and numbers in both paper and
electronic form and that such items would constitute evidence,
fruits, and/or instrumentalities of the TARGET OFFENSES.
c. Participants in fraudulent schemes, including
insider trading and wire fraud schemes, often use computers and
other electronic devices, including hand-held devices, for the
storage of documents and to send and/or receive email
communications. Based on the information above, I believe that
the computers and other electronic devices, including hand-held
devices, on the PREMISES are items that would constitute
evidence, fruits, and/or instrumentalities of the TARGET
OFFENSES. I further believe that the servers on the PREMISES
would contain evidence 1 fruits, and/or instrumentalities of the
TARGET OFFENSES.
d. Participants in fraudulent schemes, including
insider trading and wire fraud schemes, often use cellular
telephones to store contact information of other participants and
to send and receive text messages in furtherance of the schemes.
Based on the information above, I believe that cellular
telephones on the PREMISES are items that would constitute
evidence, fruits, and/or instrumentalities of the TARGET
OFFENSES.
34
e. Based on my training, experience and knowledge, as
well as conversations with other law enforcement agents and other
individuals, I have learned the following: Email is a popular
form of transmitting messages and/or files in an electronic
environment between computer users. When an individual computer
user sends email, it is initiated at the user 1 s computer,
transmitted to the subscriber's mail server, then transmitted to
its final destination. Typewritten documents on a computer can
be saved to the computer's hard drive and dedicated network which
is shared by many users. A "server" is a computer that is
attached to a dedicated network and serves many users. Emails
and other electronic data deleted on computers will often remain
stored on the server. In other words, if individuals
intentionally deleted certain emails and electronic.d~ta from
their own computers, the emails and electronic data will likely
remain on the server unless and until further actions are taken
to destroy the emails and data on the server.
20. Based on my training, experienc·e, conversations
with other FBI agents, review of wire interceptions, and
conversations with cooperating witnesses who have participated in
illegal insider trading and wire fraud schemes, I am familiar
with the practices and methods of persons committing the TARGET
OFFENSES, and the means by which such persons communicate with
each other and maintain documents and records in paper and
35
electronic form. In addition, based on my conversations with
other FBI agents who have spoken to SAM ADONDAKis; I know that
there is probable cause to believe that the PREMISES contains
certain electronic data relating to the TARGET OFFENSES.
21. Finally, based upon the facts set forth herein, I
request authorization to search and seize any of the above items
constituting the PROPERTY that are maintained within safes
(including but not limited to those referenced in this
affidavit), suitcases, containers, safe deposit boxes, and other
closed or locJ~ed containers, including those that may be further
secured by combination and/or key locks of various kinds.
22. Based on the foregoing, I believe that there is
probable cause to believe that the documents, records, computers,
hand-held devices, servers, and cellular telephones on the
PREMISES constitute evidence, fruits, and instrumentalities of
the commission of violations of federal laws, including the
TARGET OFFENSES.
SEARCH PROCEDURE
23. In order to ensure that agents search only the
PREMISES, the search warrant will direct Level Global Investors
to produce the items on the PREMISES as described in Attachment
A, and the FBI will conduct a search of the servers on the
PREMISES and the other items on the PREMISES in accordance with
the procedure and use of search terms set forth in Attachment B.
36
CONCLUSION
WHEREFORE, I respectfully request that a search warrant
issue, pursuant to Rule 41 of the Federal Rules of Criminal
Procedure, to search the PREMISES for the items and information
set forth in Attachment A, and following the procedure described
in Attachment B, all of which constitute evidence, fruits, and
instrumentalities of violations of the TARGET OFFENSES.
Dated: November 21, 2010 New York, New York
SO ORDERED:
HON 1 RABLE THEODORE H. KATZ UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK
HOLL~l/~ Special Agent Federal Bureau of Investigation
37
Request for Sealing
Since this criminal investigation is non-public and
ongoing, disclosure of the search warrant, this affidavit, and/or
this application and the attachments thereto will seriously
jeopardize the progress of the investigation. Accordingly, I
request that the Court issue an order that the search warrant,
this affidavit in support of application for the search warrant,
the application for the search warrant, and any attachment
thereto be filed under seal until further order of this Court.
Dated: November 21, 2010 New York, New York
SO ORDERED:
HON6RABLE THEODORE H. KATZ UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK
HOLLY J. T S Special Agent Federal Bureau of Investigation
38
THE PREMISES KNOWN AND
ATTACHMENT A (page 1 of ;2)
OFFICES OF DAVID GANEK, ANTHONY CHIASSON, INCLUDING ALL
COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES,. (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR
IMAGE OF LEVEL GLOBAL INVESTORS 1 SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN
ATTACHMENT B ,_ ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AvENUE, 27TH FLOOR, NEW YORK, NEW YORK
{A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND
INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND
CELLULAR TELEPHONES: All financial records, handwritten documents
and/or notebooks, letters and correspondence, photographs,
telephone and address books, identification documents, travel
documents, telephone records, computers and other electronic
devices, cellular telephones, and other records and documents
that constitute evidence of the commission of securities fraud,
wire fraud, money laundering, commercial bribery, conspiracy to
commit and aiding and abetting the commission of such crimes, or
are contraband and/or the fruits of violations of the federal
securities fraud, wire fraud, money laundering, and commercial
bribery laws, and/or are designed or intended as a means of
violating the fe~eral securities fraud, wire fraud, money
laundering, and commercial bribery laws, including any of the
above items that are maintained within other closed or locked
containers, including those that may be further secured by key
locks (or combination locks) of various kinds. These items will
be searched pursuant to the procedure set forth in Attachment B.
AND
ATTACHMENT A (page 2 of 2)
(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS,
(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS
WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND
PROCEDURE SET FORTH IN ATTACHMENT B.
ATTACHMENT B (page 1 of 2)
1. The Federal Bureau of Investigation ("FBI") will follow the following procedure with respect to the search of.the servers listed in Attachment A at Level Global Investors.
First 1 personnel at the FBI will make a mirror image of all 1 or as much as feasible and necessary/ of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event 1 once the servers have been ~maged 1 they will be returned.
Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all 1 or as much as feasible and necessary/ of the servers at Level Global Investors will be imaged.
Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches of the imaged material from the servers:
(1) Search for all emails and documents authored and/or received from David Ganek, Anthony Chiasson/
and Sam Adondakis.
(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s)
(a) (b) (c) "my check" (d) consultant (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell ( j ) (k)
ATTACHMENT B (page 2 of 2)
2. For all other items listed in Attachment A (other than the servers which is covered by procedure #1 above), the FBI will search the content in Attachment A for the following information:
1. Ganek, consultants, Broadband
and all communications between and Sam Adondakis,
John Kinnucan,
David
2. Any·and all documents relating to, reflecting, and/or concerning information about public companies.
3. Any and all evidence reflecting communications about trading based on information about public companies.
4. Any and all other evidence that will assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidential·ity and/or involved in trading based on material, nonpublic information.
5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United States Code, Sections 371, 1343, 1348 1 1349, 1952, 1956, Title 15, United States Code, Sections 78j(b) and 78ff, and Title 18, Uriited States Code, Section 2 in connection with those offenses.
.'
t\0 93 (SDNY Rev. 05/10) Scnrch nnd Seizure Wr.m111t
UNITED.STATES DISTRICT COURT for the
Southern District of New York
In the Maller of the Search of (Briefly describe the property to be searched or irhnt!!Y the person by name. and address)
THE I)I~EMISES I<NOVVN AND DESCRIBED /\S LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE,
27TH FLOOr::\, NEW YORI<, NY (AS ATTACHED)
) ) ) ) ) )
Case No. 1 D /Ja.g .2 587/
0 (2;:/c;;-J-;J Ill-/ SEARCH AND SEJZUHE WARRANT
To: Any authorized law enforcement officer
An application by n federal law enforcement officer or an anorney for the government requests the search of the following person or properly located in the ·soUTHERN -· District of --·---~_Y._Q_RJ\ -··· (idanll}j,tlw person or describr. tire prnpl!rty to he searched and give its /om/ion): THE. PREMISES l<NOVVN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 2TrH FLOOR, NEW YORI\, NY (AS ATTACHED) (AND ANY LOCI<ED OR CLOSED CLOSETS, SAFES, CAl31NETS AND CONTAINERS THEREIN) .
The person or properly to be searched, deseri bed above, is believed to coi1ccal (identify the person or dexr:rilw the
properly to be seir.ed):
SEE ATTACHED AFFIDAVIT, INCLUDING ALL ATTACHMENTS
J find that the afficlavit(s), or any recorded testimony, est8blish probable cause to scRrch and seize the person or property.
YOU ARE COlviiVIANDEb.to execute this warrant on or before l\J..D1L£a:f'lk:W\, cl i} \~0.\.J) _________ _ (11ol Ia exceed 14 days)
&1 in the claytinie .6:00a.m. to 10 p.m. IJ at any time in the clay or night as I find reasonable cause lws been established.
Unless clelayec(notice is authorized below, you must give a copy of the warrant and a receipt for the property takCii to the ·person from whom, or fi·om whose premises, t)lc properly was taken, or leave the copy and receipt at the
·· ··-plnce·whcre·the-property was·taken-.-·· · ·· --···· · ····-··-·-· ---·· : ........ ---····- -----· ··-·-···· ·-·--······ -·- · ··- ··· ······ ····-··
The oftlcer executing this wanant, or an ofiicer present clt1ring the execution of the warmnt, must prep~'"J )P invcntovf as required by law and promptly return this warrant and inventory to the Clerk of the Court. -7.- ~--
15ifUpon its reLurn, this wnrrnnt and inventory shol!ld be filed under seal by the Clerk of the Court.=~-~---~~ 1
USA·f.! Initials
0 I find that immediate notification may have an adverse result listed in 18 U.8.C. § 2705 (except for delay oftrinl), nnd authorize the offi~cr executing this warrant to delay notice to the person who, or·whose property, will be searched or seized (check the appropriate box) Ofor ___ days (not to exceed 30). ~
. )j}'!]'til, the ""' jt•tifyhtg, the J.t"· 'peoific bYf ~ . I)' o~o lr'/7 - /3/J- ·-. Date and time issued: L.lJ: ,;.eri« ;;Lf;. ~:!'../0 ~.;:;;t;!fo<.e.. ___ '_ "'~~-=--------
, J11dge 's signature •
·-------··_l::l.P_hlQRABl E THEODOI~E H. I<ATZ lJS.M.J ·--!'rinted name and title
AO 93 (RI'v. 0 1109) Search nnd Seizure Wnnrmt (Pnge 2) ·------------------Return
. ·: .. \.'
Certification
1 declare under pcnnlty of-perjury that this inventory is correct and was returned along with the original warrant to the Court.
·~~ftdl~ • 1 .
·------·--- '/-· -:- ((_ ·-· ~-----~-------~ r3t ling officers signlrfrrr~< J}_0 tl , .. -~ ·r , )/,~ , !) 11&1,
__ _ __ ( .. (LL{Jdf_;,.}__;_ __ _L_(vJ}c. '(f'C'f/ULJTf?&.Lt () 'i'rintud nama anr til/r- t-B I rr ..
<-----------------------
ATTACHMENT A (page 1 of 2)
THE PREMISES KNOWN AND DESCRI ICES OF DAVID GANEK, ANTHONY CHIASSON, AND INCLUDING ALL
COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR
IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN
ATTACHMENT B ,. ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK
(A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND
INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND
CELLULAR TELEPHONES; All financial records, handwritten documents
and/or notebooks, letters and correspondence, photographs,
telephone and address books, identification documents, travel
documents, telephone records, computers and other electronic
devices, cellular telephones, and other records and documents
that constitute evidence of the commission of securities fraud,
wire fraud, money laundering, commercial bribery, conspiracy to
commit and aiding and abetting the commission of such crimes, or
are contraband and/or the fruits of violations of the federal
securities fraud, wire fraud, money laundering, and commer·cial
bribery laws, and/or are designed or intended as a means of
violating the federal securities fraud, wire fraud, money
laundering, and commercial bribery laws, including any of the
above items that are maintained within other closed or locked
containers, including those that may be further secured by key
locks (or combination locks) of various kinds. These items will
be searched pursuant to the procedure set forth in Attachment B.
AND
ATTACHMENT A (page 2 of 2)
(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKISr
(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS~ SERVERS
WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND
PROCEDURE SET FORTH IN ATTACHMENT B.
ATTACHMENT B (page 1 of 2)
1. The Federal Bureau of Investigation ( "FBI'1 ) will follow the following procedure with respect to the search of the servers listed in Attachment A at Level Global Investors.
First, personnel at the FBI will make a mirror image of all, or as much as feasible and necessary/ of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event, once the servers have been imaged, they will be returned.
Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all, or as much as feasible and necessary, of the servers at Level Global Investors will be imaged.
Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches of the imaged material from the servers:
(1) Search for all emails and documents authored by, sent to/ and/or received from David Ganek, Anthony Chiasson,
and Sam Adondakis.
(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s):
(a) (b) (c) (d) (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell ( j ) (k)
ATTACHMENT B (page 2 of 2)
2. For all other items listed in Attachment A (.other than the servers which is covered by procedure #1 above), the FBI will search the content in Attachment A for the following information:
1. Ganek, An consultants, Broadband Rese
and all communications between and Sam Adondakis,
John Kinnucan, y consultant.
David
2. Any·and all documents relating to, reflecting, and/or concerning information about public companies.
3. Any and all evidence reflecting communications about trading based on information about public companies.
4. Any and all other evidence that will assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidentiality and/or involved in trading based on material, nonpublic information.
5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United States Code, Sections 371, 1343, 1348, 1349, 1952, 1956, Title 15, United States Code, Sections 78j (b) and 78ff, and Title 18, United States Code, Section 2 in connection with those offenses.
F'D-507 (Rev 8··11-'J4) P:>ge ____ J__of ___ .L __
UNlTED STATES DEPARTl'vfENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # 3 ~ )?\:>- \.J'-'1 - 3c.Y2.. 'j )-\ \,.
On (date) ---~----==-U::=.__....J.O-~~'-''--"''(__j):::.___l,_'O=----------
(Name) Uf:u£r_. (51-A f>G\!(......
item(s) listed below \Vere: 0 Received From 0 Returned To 0 R)X'eased To ~eized ~
~~ ? Ttrft'. . t>r I • L....-. . 1 (.1 () .tJ V (Street Address), __ ~~...l::)._---.-7-f---..-LJ~c....=::::......._+-_f'J~I;:;-/'-'V~--ff---"'=!-~>F-t'--...!......... _________ _
(City) _______________________________ _
Description of Item(s): ON"el0 .:56ft(Dth"J1 t-lDj) S(r-.J G, Vr!'/ 9rH 49 ~ {Lqcv.. Pc ( sq) ~~ ,) 5cfk b'rqj r-ron sj,-J C..,vtJ19 -rr~ t-+ ~~A ( sc..lb) ct'IBCt) 5~ t~p W C.v',V'iVXr-1 I+ ~ ~ u ( s:c::s) __ _ o~{,) ~ 1-FJ)J) j.!;J ~VM91J(.6:<; ~-~j) Lsc.-\.{~-~l') ~~ J)tCn~ rrDD S/;J WMPr<./~-2fdCt~S'9! ~
I~ ccei v,·,d I· rn1ll"
Page -------4/'---of __J_ UNITED STATES DEP AR Tl\1ENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION Receipt for Property Received/Returned/Released/Seized
File # -~ \.. \{,1;) - t-)'i - ~0 ::::{:t, ~\
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Received By: Received From: (Signature) (Signature)
FD'-597 '(R'~v 8-11-94) Page --'---of _ _!.__
UNITED STATES DEP"ARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # ?· I '? I)- N f - _s 0 2 <( 2 I
,-/"
item(s) listed below were: ~Received From O ~eturned To 0 · Released To 0 Seized
"/
( ,. ;:'V\ 0 ' (Name) ______ '--~=·-·~\_,_r_.~5----~~~~~-~~·:~,:~-v~~~~·~~-~----------------------------------
(Street Address), ____ ;;:;"-~-..c-'~'""-~·~'Y~---·'-z_-r_· _'· _:_1_\~v...:.<"___,J~~:...:· c...::.-,,----=2'---L.7_'_'_· _(!...._. _··.:....1 ::.:'··a::_;· ,....=---------------
(City) f\.J r -v "-.
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LG IS(~ 1 .1 c. T
FD-597 (Rev 8-11-94) Page _ _!__ __ of _ _,_____
UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # 316f) -IVY- . ;:.('j!
CJ -7-\k /, (Street Address) ( 18\?J 7_ AIJ!!"' V:<:.
(City) N <?\JI y.A. . /\/)' ~QOI"t\ 0
Received By: Received From: (Signature)
item(s) listed below were: 0 Received From D Returned To Q Released To
? Seized
t::: 1'~--11 ( ~
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(Signature)
FD-597 (Rev 8-11-94) Page _·..-~/ __ of __ _
File#
UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
5 I 8 I) - (\) IJ - 3u2 0 2 I 0 ( {' Oz b I
on (date) __ ___:_/_r_J_/ _2_2-----+/_,::---=7'-u_..;_/_u _________ _ I
item(s) listed below were: 0 Received From D Returned To 0 Released To
. /1 .~ Seized
(Name)_L_P~_e_!~G~/~u b~o"'--: _1----~.o"--'-f-L6..:..::c.--e~--"-c.>.!..-/~l).J::::...?/..::._V'_·/_. ~(j~tl.:.....:../l<?:::.___;t=/----(Street Address) tJ /:3 8 5 f>V17/lf1,_, At>...-?UQ r:/ 7 ~ F /-.Jur-
(City) ______ /~l!!.-/f=---w_7t/=---o=--r--'-/::...,--'. --,~...M~f vv'::.:.__-Tf6....l::():_:_r_:_k=-..· _:___ ________ _ / 17
Description of fiem0~ ~~~~~~~~~L~~P~f~J~~~~~~~~~~~~~~~~-~~~~~P~~~~)~~~~~.~~~~~~ 1/~ I f//JVPI.J.,.,'I?J
v e --!.."' . .) ,. I c r
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-~--.· Received From:. _ __,..__..:.::...-.:.·_.•r-7, .. ·..---:-";:.....,.----
(Signature) •,. : ;·
FD-5\)7 (Rr.v 8-ll-(H)
File#
UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Recei vcd/Retu rned/Released/Se ized
-~:L __ _
On (date) ,~-%re-M @.C7'S 7 '2- > ·2-- o I V item(s) listed below were: 0 Received From 0 Returned To g Relef)sed To i::fd- Seized
(Nnme) Le.,l S? ~ C?z\vm\ \6-.Jg,S)±bs.s;
(Street Acldress) ~B. 8f<,;J 'S c0;:.\c 1\\J Q\\u.Q. 1 dJ4.1r, 5j\oo\
(Ciry).~s:-·~~------------------------------
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UN1TED STATES DEPARTJ\.•IENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # :Si '3J) -A! Y - . .So :2.9 :z_.j
(Name) 6v£ZL c}L...i-1 8.41....- /rJ /t~TDR· (Street Address)~-p::j___A}~trb/ :.)€
item(s) listed below were: 0 Received From 0 Returned To Q Released To if Seized
rcir~') /J./€1... 1 Yd"R 1< 2 Nkb,L.~o~~'--------------------
Description of Item(s):
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UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
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Description of Item(s):
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UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATlON
Receipt for Property Received/Returned/Released/Seized
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