Certification CN11.Bluevine — USA v. Lorquet (Dkt. 23.3)

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BlueVine Inc. 
401 Warren St, Suite 300 
Redwood City, CA 94063 
www.bluevine.com  
 legal@bluevine.com 
 
 
 
 
 
 
April 27, 2022 
VIA E-MAIL 
AUSA Jonathan Bailyn 
99 NE 4th St. Suite 602 
Miami, FL 33132  
jonathan.bailyn@usdoj.gov 
(786) 714-1973 
 
Re: Grand Jury Subpoena 2021R00182011 
 
Dear Jonathan Bailyn:   
 
I write in response to Grand Jury Subpoena 2021R00182011, dated April 15, 2022 (the 
“Subpoena”), which was submitted to BlueVine Inc. (“BlueVine”).  
 
BlueVine will produce copies of account information and copies of transaction activity of the 
subject of the Subpoena. 
 
Documents and/or information responsive to the Subpoena (the “Responsive Material”) have been 
made available via Box folder, https://bluevine.box.com/s/1bswn4u8rh05tmohpix9k65lqi24lyf0, as of the 
date of this letter. The Responsive Material is being produced pursuant to the Subpoena and with the 
understanding that it will be used solely in furtherance of the matter directly related to the Subpoena and 
will be kept confidential. By producing the documents and/or information, BlueVine reserves, does not 
waive, and does not intend to waive, any and all applicable objections, privileges, protections, and immunity 
from disclosure, including but not limited to the attorney-client privilege, work product doctrine, privacy-
related protections, protections relating to proprietary or commercial-sensitive material, and objections as 
to scope, relevance, and burden.  
 
If you have any questions, please contact me at Clare.Murphy@BlueVine.com 
 
Sincerely,  
 
             
               
Clare Murphy 
Compliance Analyst 
BlueVine Inc. 
Encl. 
 

 
BlueVine Inc. 
401 Warren St, Suite 300 
Redwood City, CA 94063 
www.bluevine.com  
 legal@bluevine.com 
 
 
 
 
 
 
 
EXHIBIT A 
DECLARATION OF CLARE MURPHY 
 
 
Pursuant to 28 U.S.C. § 1746, I, Clare Murphy, hereby declare that: 
 
 
1. I am over 18 years old, am an employee of BlueVine Inc., and am able and qualified to make this 
declaration as an authorized custodian of records. 
 
 
2. I hereby certify that, to the best of my knowledge, understanding, and belief, the documents 
provided in the identified Box folder are true and correct copies of records that were: 
(a) 
made at or near the time of occurrence and by, from, or based on information transmitted 
by a person with knowledge of those matters; 
(a) 
maintained in the course of regularly conducted business activity; 
(a) 
made in the regular course of business. 
 
I declare under penalty of perjury that the foregoing is true and correct.   
 
Executed on April 27, 2022. 
 
 
 
 
 
 
 
________________________ 
  
 
           
 
Clare Murphy 
 
 
 
Compliance Analyst 
 
BlueVine Inc.

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