Court filing
Exhibit A - 9/6/2023 letter — USA v. RIVERA et al (Dkt. 54.1)
Filed January 14, 2025 in USA v. RIVERA et al; one of 67 filings from this case.
Record facts
| Court | U.S. District Court for the District of New Jersey |
|---|---|
| Filed | 2025-01-14 |
U.S. District Court for the District of New Jersey · No. 1:24-cr-00267-KMW · Doc. 54-1 · 2025-01-14 · Docket on CourtListener
Full text
Exhibit A
Case 1:24-cr-00267-KMW Document 54-1 Filed 01/14/25 Page 1 of 3 PageID: 425
U.S. Department of Justice
United States Attorney
District of New Jersey
PHILIP R. SELLINGER
401 Market Street, Fourth Floor
United States Attorney
Camden, New Jersey 08101-2098
DANIEL A. FRIEDMAN Direct Dial: 856.968.4867
Assistant United States Attorney
Email: Daniel.friedman2@usdoj.gov
September 6, 2023
Via Email Attachment
TROY A. ARCHIE, ESQ.
AFONSO ARCHIE LAW P.C.
21 Route 130 South
Cinnaminson, N.J. 08077
Re:
U.S. v. Adrienne Ponzo
Dear Mr. Archie:
The Government is providing certain discovery relating to the Government’s case against your
client, Adrienne Ponzo, in the above-referenced matter. The Government is making the discovery
available via the USAfx portal. A link will be provided under separate cover. Please be advised that
these materials are being provided pursuant to a Protective Order that has been entered in this case.
Disclosure by the Government
The discovery materials include the following:
1. Economic Injury Disaster Loan (“EIDL”) application and loan documents for King of Aces
Barbershop LLC; Visionworks Group of America LLC; and KMGB Holdings LLC.
2. Communications regarding the conspiracy to submit fraudulent PPP and EIDL loan applications,
including:
a. Messages between Eric Rivera and Adrienne Ponzo;
b. Messages between Yasha Barjona and Adrienne Ponzo;
c. Messages between Eric Rivera, Adrienne Ponzo, and Lisa Smith;
d. Messages between Eric Rivera, Adrienne Ponzo, and
;
e. An email between Lisa Smith, Eric Rivera, and Adrienne Ponzo.
This Disclosure Is Voluntary and Not Complete
Please note that our Office is providing this pre-indictment discovery to you voluntarily. Neither
Federal Rule of Criminal Procedure 16 nor any statute or rule requires that our Office make discovery
to a person unless and until that person has been indicted. Although the Government is under no legal
obligation to provide the enclosed material before the filing of an indictment, see United States v.
Sgarlat, 705 F. Supp. 2d 347, 355 (D.N.J. 2010), we are willing to do so here to facilitate plea
Case 1:24-cr-00267-KMW Document 54-1 Filed 01/14/25 Page 2 of 3 PageID: 426
2
negotiations. Also, please be advised that the disclosure of this evidence does not imply that our Office
has made, or will make, complete pre-indictment discovery to you. Should your client ultimately be
indicted, you will receive all of the discovery to which your client is entitled. However, should you
desire to receive and/or review any other evidence or materials relevant to the investigation and/or
prosecution of your client, please feel free to make a request, and we will consider each such request as
it is made.
* * *
If you have any questions about the enclosed materials, please do not hesitate to contact me.
Once you have had an opportunity to review the enclosed information with your client, please contact
me regarding disposition of this matter.
Very truly yours,
PHILIP R. SELLINGER
United States Attorney
/s/ Daniel A. Friedman
By:
DANIEL A. FRIEDMAN
JASON M. RICHARDSON
Assistant U.S. Attorneys
Case 1:24-cr-00267-KMW Document 54-1 Filed 01/14/25 Page 3 of 3 PageID: 427File and source
- File
- gov.uscourts.njd.546707.54.1.pdf
- Size
- 162,342 bytes
- SHA-256
- 7c9ea56e82d8917574a84c07e3eacff1aa97420d1f6d5ac5c9faf0e3300d1b68
- Our copy
- gov.uscourts.njd.546707.54.1.pdf
- Original
- PACER (login required)