Exhibit A — USA v. Thomas et al (Dkt. 994.1)

Summary

Exhibit A, filed 05/08/24 as Document 994-1 in Case 1:20-cr-00296-JPB-CMS, is Carla Jackson's response to a federal grand jury subpoena for Management Resource Services, with a cover sheet to the Grand Jury Clerk dated 7/20/2020, the subpoena and the U.S. Attorney's business records certification letter. The response states that a PPP application was not submitted, that PPP funds were not used by Management Resource Services or Carla Jackson, and that payments were not made to the individuals listed in section H.

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Record facts

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Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 1 of 11
COVER SHEET

To: Grand Jury Clerk From: Carla Jackson

Email USAGAN.GrandJury@usdoj.gov Mgmt Resource Svcs
Phone: Phone: Fo

No. Pages: 30 Date: 7/20/2020

Subject: Production Request — Carla Jackson & MRS

Comments:
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 2 of 11
7/19/2020

To Whom It May Concern:

In response to the production request:

Reference Attachment A (Tax return for Management Resource Services and Carla Jackson)
Records for Wells Fargo Account 9317161207 are electronic and inaccessible due to account
closure.

A PPP application was not submitted; therefore, no record(s) exists.

PPP funds were not utilized by Management Resources Services or Carla Jackson.

Reference ‘Attachment A’(Tax returns for Management Resource Services and Carla Jackson).
Reference ‘Attachment A; (Tax returns for Management Resource Services and Carla Jackson).
Payments were not made to the individuals listed within section ‘H’.

Payments were not made to any of the individuals listed in section H. Money was transferred to
Management Resource Services.

in-person communications were held with Andre Gaines/Gaines Reservation and Travel LLC.
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 3 of 11
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U.S. Department of Justice
United States Attorney
Northern District of Georgia

Richard Russell Federal Building Teleph (404) 581-6000
75 Ted Turner Dr. S.W., Suite 600 Fax: (404) 581-6181
Atlanta, Georgia 30303

Custodian of Records
Re: Certification of Authenticity of Business Records
Dear Sir or Madam:

The attached federal grand jury subpoena directs your business to produce certain
business records and/or information for use in a federal investigation. At some point in the
future, it may be necessary to offer some or all of the documents as evidence in a federal trial in
the United States District Court for the Northern District of Georgia. In the past, unless both
parties stipulated to the admissibility of business records, it was necessary for a witness from
the business to physically appear at trial and testify that the records were authentic, within the
meaning of Rule 902 of the Federal Rules of Evidence, and that they were business records,
within the meaning of Rule 803(6) of the Federal Rules of Evidence.

Effective December 1, 2000, Federal Rules of Evidence Rules 803(6) and 902 were
amended to permit the foundation requirements of Rule 803(6) and the authenticity
requirements of Rule 902 to be satisfied under certain circumstances without the expense and
inconvenience of producing witnesses. I have attached a Business Record Certification form for
a qualified representative of your business to sign. Please review the Certification to determine
whether it is an accurate statement with regard to the referenced business records. If the
Certification is accurate, please sign and return the original Certification along with the
subpoenaed records to the grand jury clerk as directed by the subpoena. There is no guarantee
that your business’ custodian of records will not have to appear at trial to authenticate the
business’ records and lay the proper business record foundation. However, when appropriate,
the United States Attorney’s office will make every effort to use the Business Record
Certification attached instead of the testimony of your custodian of records.

If you have any questions, please do not hesitate to contact me at (404) 581- 6069
Sincerely,

BYUNG J. PAK
UNITED STATES TTORNEY

/s/ Tal Chaiken

ASSISTANT U.S. ATTORNEY
Enclosures

\ Ne
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 4 of 11
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CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO
FEDERAL RULES OF EVIDENCE 902(11) AND 902(13)

(| hla \aalcs Cv ~— __, under penalties of perjury by the laws of the

United States of America pursuant to 28 U.S.C. § 1746, attest that the information contained in
this certification is true and correct. I am employed by Ma nage ment (2ESUN ve Sve
(“Company”), and my title is Own on . | am qualified to

authenticate the records attached hereto because I am familiar with how the records were created,
managed, stored, and retrieved. I state that the records attached hereto are true duplicates of the

original records in the custody of Company. The attached records consist generally of
reauest ed Cy-tornacd; onl . | further state that:

1. i records attached to this ee i were made at or near the time of the occurrence of
the matter set forth by, or from information transmitted by, a person with knowledge of
those matters, they were kept in the ordinary course of the regularly conducted business
activity of Company, and they were made by Company as a regular practice; and

2. To the extent the records were generated by an electronic process or system, such records
were generated by Company’s electronic process or system that produces an accurate result,
to wit:

a. The records were copied from electronic device/s, storage medium/s, or file/s in the
custody of Company in a manner to ensure that they are true duplicates of the
original records; and

b. The process or system is regularly verified by Company, and at all times pertinent

to the records certified here the process and system functioned properly and
normally.

I further state that this certification is intended to satisfy Federal Rules of Evidence 902(11)

and 902(13).

7/22 oa (J

Date / Signature (
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 5 of 11
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AO 110 (Rev. 06/09) Subpoena to Testify Before a Grand Jury

UNITED STATES DISTRICT COURT
for the
Northern District of Georgia

SUBPOENA TO TESTIFY BEFORE A GRAND JURY

To: Management Resource Services Inc.
Attn: Carla J. Jackson
4683 Darlene Way
Tucker, Georgia 30084

YOU ARE COMMANDED to appear in this United States district court at the time, date, and place shown
below to testify before the court’s grand jury. When you arrive, you must remain at the court until the judge or a court
officer allows you to leave.

Place: Date and Time:
GJ #4-19
United States Courthouse July 21, 2020
75 Ted Turner Dr. SW, Room 2037, Atlanta, GA 30303
Xx You must also bring with you the following documents, electronically stored information, or objects (blank if not
applicable):

See Attachment
Although the law does not prohibit disclosure, it is requested that you do not disclose the existence of this subpoena. Any such
disclosure could impede the investigation being conducted.

CLERK OF COURT

Date: June 26, 2020

of Clerk or Deputy Clerk

The name, address, e-mail, and telephone number of the United States attorney, or assistant United States attorney, who
requests this subpoena, are:

Tal Chaiken

75 Ted Turner Dr. SW Suite 600 Atlanta, GA 30303

Tal.Chaiken@usdoj.gov
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 6 of 11
AO 110 (Rev. 06/09) Subpoena to Testify Before Grand Jury (Page 2)

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PROOF OF SERVICE

This subpoena for (name of individual or organization) Management Resource Services Inc.

was received by me on (date) June 26, 2020

I served the subpoena by delivering a copy to the named person as follows:

on (date)

; or

© Ireturned the subpoena unexecuted because:

I declare under penalty of perjury that this information is true.

Date: June 26, 2020

Server's signature

Joseph D. Stites

Printed name and title

2635 Century Parkway NE Atlanta, GA 30345

Server's address

Additional information regarding attempted service, etc:
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 7 of 11
To:

Management Resource Services Inc.
Attn: Carla J. Jackson

4683 Darlene Way

Tucker, Georgia 30084

ATTACHMENT 1

I. DEFINITIONS

A. “Document(s)” means, without limitation, any handwritten, printed, typed,
photographed, recorded, transcribed, taped, filmed, or otherwise reproduced or stored
communication or representation, whether comprised of letters, words, numbers, pictures, sounds
or symbols, or any combination thereof. This definition includes copies or duplicates of
documents contemporaneously or subsequently created which have any non-conforming notes
or other markings, including any additions, deletions, alterations, or notations, as well as the
backsides of any communication or representation which contain any of the above. “Document”
also includes all attachments, enclosures, or other matter affixed to or incorporated by reference
within documents responsive to the Document Requests set forth below, including, but not limited
to, any pages that show who reviewed, approved or rejected a particular document.

By way of example, “document(s)” includes, but is not limited to: writings; correspondence;
memoranda; notes; drafts; records; files; letters; envelopes; messages; electronic mail; electronic
messages; analyses; agreements; accounts; working papers; reports and summaries of
investigations; trade letters; press releases; comparisons; books; ledgers; journals; bills;
vouchers; checks; statements; worksheets; summaries; notices; drawings; diagrams; graphic
presentations; instructions; manuals; calendars; diaries; telephone message records or logs;
routing slips; activity reports; articles; magazines; newspapers; brochures; guidelines; notes or
minutes of meetings or of other communications of any type, including inter- and intra-office or
Company communications; reports; plans; questionnaires; forecasts; briefing materials; surveys;
charts; graphs; diagrams; compilations; computations; photographs; films or videos; tapes; discs;
data cells; databases; spreadsheets; software; bulletins; voice mails; information stored or
maintained by electronic data processing or word processing equipment; electronic claims filings;
invoices; computer and network activity logs; all other data compilations from which information
can be obtained including electromagnetically sensitive stored media such as floppy disks, hard
disks, hard drives and magnetic tapes; Web pages; any preliminary versions, drafts or revisions
of any of the foregoing; and all attachments to any of the items set forth in this paragraph.

B. “Email” includes but is not limited to: written communications between one or more
persons that are sent electronically, via data lines or by wireless technology, instant messages
(whether external, i.e., Yahoo! Messenger or internal applications), SWIFT free form text
messages (including but not limited to any series x99), electronic messages saved on the hard
drives of the computers used by an individual sending or receiving the messages, and messages
stored on company servers, internet service provider (“ISP”) servers, backup tapes, handheld
devices (e.g. a Blackberry), as well as anything necessary to extrapolate data from any of these
sources, such as an index, electronic key, or encryption software. “Email” is also defined to include
any documents attached to the email.

C. “You” or the “Company” means any and all of the following:
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 8 of 11
E. Manner of production: All documents produced in response to this subpoena shall
comply with the following instructions:

1. You shall conduct a search for responsive documents in a manner sufficient to
identify the source and location where each responsive document is found.

2. All documents produced in response to this subpoena shall be segregated and
labeled to show the document request to which the documents are responsive
and the source and location where the document was found.

3. To the extent that documents are found in file folders, computer disks, hard
drives and/or other storage media which have labels or other identifying
information, the documents shall be produced with such file folder and label
information intact.

4. To the extent that documents are found attached to other documents, by means
of paper clips, staples or other means of attachment, such documents shall be
produced together in their condition when found.

E: In the event there are no documents responsive to a particular subpoena request,
please specify that you have no responsive documents.

G. If you know of documents you once possessed or controlled, but no longer possess
or control, which would have been responsive to this subpoena, state what disposition was made
of such documents, including identification of the persons who are or are believed to be in
possession or control of such documents currently.

H. To facilitate the handling and return of any non-electronic documents, please

mark each page with an identifying logo or the first three letters of your company’s name and
number each page sequentially beginning with “000001,” preferably in red or blue ink so that the
originals can be easily distinguished from copies. The marks should be placed in the lower right
hand corner of each page but should not obscure any information on the document. All
documents should be numbered sequentially. All documents should be produced in enclosures
bearing the name of your company, the date of the subpoena and the paragraphs of the subpoena
to which the documents. Pursuant to this instruction, you shall produce a log stating the source
of documents that either corresponds to the numbers placed on the documents (if the documents
are non-electronic documents) or that otherwise indicates the source of the documents (that, a
log identifying the office and file or other document repository in which each document was
located). Use of the foregoing procedure will preserve the identity of all documents submitted by
your company and assure their accurate and expeditious return at the conclusion of this
investigation or of any proceeding arising from it.

I. If you have knowledge of any document that would have been responsive to this
subpoena but has been lost, destroyed, discarded or subject to removal or alteration, you shall
identify to the extent possible each such document and provide an explanation of the loss,
destruction, discarding, removal or alteration (including identification of each person authorizing
or having knowledge of the loss, destruction, discarding, removal or alteration).
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 9 of 11
No document called for by this subpoena shall be destroyed, modified, redacted,

or otherwise made inaccessible, except insofar as documents are withheld under claim of
privilege in compliance with the instructions above.

Please note that you are instructed to provide copies of the production to Assistant

United States Attorney Tal C. Chaiken via email at tal.chaiken@usdoj.gov or via mail at:

Tal C. Chaiken

Assistant United States Attorney
U.S. Attorney's Office

75 Ted Turner Drive S.W., Suite 600
Atlanta, GA 30303

Phone: 404-581-6069

Email: tal.chaiken@usdoj.gov

APPLICABLE TIME PERIOD

Unless otherwise specified, the applicable time period covered by this subpoena is

January 1, 2019, to the present.

V.

PRODUCTION REQUESTS

. All records, books of account and other documents or papers relative to financial

transactions of the Company. This includes, but is not limited to, financial records,
including receipts, checks, bank and savings and loan records of deposit, withdrawal
and wire transfer, statements and other bank records, letters of credit, credit card
statements, money orders, cashier’s checks, passbooks, cancelled checks, certificates
of deposit, loan records, customer account information, income and expense
summaries, cash disbursement journals, and financial statements.

. All records related to Wells Fargo account 9317161207.

. All records related to Paycheck Protection Program applications submitted by the

Company. This includes loan applications, documents submitted with the loan
applications, and internal and external correspondence related to the applications.

. All records related to Paycheck Protection Program funds received by the Company,

including records detailing how funds were utilized.
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 10 of 11
E. All records related to individuals employed by the Company, including timesheets,
dates of employment, and employee files. This includes records in the Company’s
possession from any and all payroll management entities.

F. All federal, state and local tax documentation specifically related to the Company
and Carla Jackson, including but not limited to IRS Forms 1099, income and
payroll tax returns, state sales tax returns and amended tax returns.

G. All payments made to the following individual and/or entities:

Dartez Daniel;

Carla Jackson;

Elite Executive Services Inc.;

10. ATL Promotions Group Inc.;

11. Transportation Management Services Inc.;
12. Gaines Reservation and Travel LLC;

13. Lee Operations LLC;

14. Impact Creations LLC; and

15. Bellator Phront Group Inc.,

1. Kahlil Green, aka Khalil Green;
2. Bern Benoit, aka Burn Benoit;
3. Andre Gaines;

4. Darrell Thomas;

5. Meghan Thomas;

6. Edward Lee;

‘Le

including payments made or received directly or through third parties.

H. All communications with the following individual and/or entities:

Dartez Daniel;

Carla Jackson;

Elite Executive Services Inc.;

10. ATL Promotions Group Inc.;

11. Transportation Management Services Inc.;
12. Gaines Reservation and Travel LLC;

13. Lee Operations LLC;

14. Impact Creations LLC; and

15. Bellator Phront Group Inc.,

1. Kahlil Green, aka aka Khalil Green;
2. Bern Benoit, aka Burn Benoit;

3. Andre Gaines;

4. Darrell Thomas;

5. Meghan Thomas;

6. Edward Lee;

qi
Case 1:20-cr-00296-JPB-CMS     Document 994-1     Filed 05/08/24     Page 11 of 11
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NORTHERN DISTRICT OF GEORGIA

GRAND JURY NO. 4-19
GRAND JURY PROCEEDINGS

WAIVER OF APPEARANCE
AND
DOCUMENT RECEIPT

Carla Sauksm of Tuten GA

have custody and control of the documents requested in the attached subpoena. I would prefer

that:

(_ ) I will mail the requested documents via USPS mail or FedEx to:

Attn: Grand Jury, U.S. Attorney’s Office, Suite 600, 75 Ted Turner Drive SW, Atlanta,
Georgia 30303

( ) Iwill email the requested documents to Assistant United States Attorney

( XR I will email the requested documents to the Grand Jury Clerk at
USAGAN.GrandJury@usdoj.gov.

in lieu of actual appearance by myself. Submission of the requested documents is fully complied

with, this Oday of ae 20 20

SIGNATURE OF PERSON SUBMITTING DOCUMENTS

1/20/2020

DATE * SIGNATURE OF PERSON RECEIVING DOCUMENTS

DATE SIGNATURE OF GRAND JURY FOREPERSON


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