Exhibit B — USA v. Thomas et al (Dkt. 994.2)

Summary

Document 994-2, filed 05/08/24 in Case 1:20-cr-00296-JPB-CMS in the U.S. District Court for the Northern District of Georgia, collects grand jury papers for Gaines Reservation and Travel LLC: a subpoena dated June 26, 2020 to testify before Grand Jury 4-19 on July 21, 2020, a fax cover sheet dated 07/21/2020 and a 7/19/2020 letter from Andre Gaines responding to the production requests. The letter states that the PNC bank account is frozen and the company's financial records are not accessible, that payments were not made to the individuals listed in section H and that money was transferred to Management Resource Services; a waiver of appearance and a certificate of authenticity are also included.

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Case 1:20-cr-00296-JPB-CMS     Document 994-2     Filed 05/08/24     Page 1 of 6
COVER SHEET

Tet Grand Jury Clerk FROM: Andre Gaines
EMAIL: USAGAN.GrandJury@usdoj.gov EMAIL:AGGA

INESS54@GM

AIL.COM
PHONE: PHONE: Po
PAGES: 20 DATE: 07/21/2020

COMMENTS: Production Request-Andre Gaines & Gaines Reservation and Travel LLC
Case 1:20-cr-00296-JPB-CMS     Document 994-2     Filed 05/08/24     Page 2 of 6
7/19/2020

To Whom It May Concern:

Re: Production Request

|, Andre Gaines, owner of Gaines Travel and Reservation, am writing this letter in response to the
production requests:

A. The company’s financial records are not accessible; the PNC bank account is frozen.

B. |do not have a business account with Bank of America.

C. The PNC bank account is frozen and I’m unable to access the electronic bank statements.

D. Reference ‘Attachment A’.

E. Reference ‘Attachment B’.

F:

G. The tax period for 2020 is incomplete; documentation can be provided upon completion of the
tax year.

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

|. Communications were in-person with representatives from Management Resource Services
therefore | have no document to produce.

Regards,

Gib. Keine

Andre Gaines
Case 1:20-cr-00296-JPB-CMS     Document 994-2     Filed 05/08/24     Page 3 of 6
2020R00536 - 008

NORTHERN DISTRICT OF GEORGIA

GRAND JURY NO. 4-19

GRAND JURY PROCEEDINGS
WAIVER OF APPEARANCE
AND
DOCUMENT RECEIPT
I, Ande ai fay, , of Gui nes Tepve| aed pee V4 how ;

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

that:

( ) Iwill 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

© I will email the requested documents to Assistant United States Attorney

( ) Iwill 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 /Y day of .)y)| Y , 2015.
Lender. Kovne

SIGNATURE OF PERSON SUBMITTING DOCUMENTS

DATE SIGNATURE OF PERSON RECEIVING DOCUMENTS

DATE SIGNATURE OF GRAND JURY FOREPERSON
Case 1:20-cr-00296-JPB-CMS     Document 994-2     Filed 05/08/24     Page 4 of 6
; 2020R00536 - 008

CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO
FEDERAL RULES OF EVIDENCE 902(11) AND 902(13)

L, Andve Gai Nes , 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 (pines (Lave Potsecicho

(“Company”), and my title is CED . I 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

. I further state that:

1. All records attached to this certificate 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).
7119 [A6A6 Lie. Dees
Date Signature
Case 1:20-cr-00296-JPB-CMS     Document 994-2     Filed 05/08/24     Page 5 of 6
2020R00536 - 008

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: Gaines Reservation and Travel LLC
Attn: Andre Gaines
85 Rosemont Court
Hiram, GA 30141

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 994-2     Filed 05/08/24     Page 6 of 6
2020R00536 - 008

AO 110 (Rev. 06/09) Subpoena to Testify Before Grand Jury (Page 2)

_ —— — Tt ————
—— —— — i ——

PROOF OF SERVICE

This subpoena for (name of individual or organization) Gaines Reservation and Travel LLC
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

CI returned 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:


File and source

File

gov.uscourts.gand.279867.994.2.pdf

Size

1,203,340 bytes

SHA-256

b0836b193889a9547092c484ff2d5889c136f01bbeae5757d241d6a0a6ec74d7

Our copy

gov.uscourts.gand.279867.994.2.pdf

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