Court filing
Exhibit A (Vetted subpoena) — USA v. Merritts (Dkt. 35-1, D.D.C.)
Filed December 2, 2025 in USA v. Merritts; one of 82 filings from this case.
Record facts
| Court | U.S. District Court for the District of Columbia |
|---|---|
| Filed | 2025-12-02 |
U.S. District Court for the District of Columbia · No. 1:25-cr-00076-JMC · Doc. 35-1 · 2025-12-02 · Docket on CourtListener
Full text
U.S. Department of Justice
Matthew M. Graves
United States Attorney
District of Columbia
Patrick Henry Building
601 D Street N.W.
Washington, D.C. 20530
March 1, 2024
VIA Hand Delivery
Vetted Couriers and Logistics
Attn: Custodian of Records
Re:
Grand Jury Subpoena #GJ20240229114371
USAO #2023R00502
Dear Vetted Couriers and Logistics:
Pursuant to a criminal investigation being conducted by the United States Attorney’s Office, it is
required that you furnish the requested records as described in the attached subpoena.
In lieu of personally appearing before the Grand Jury on the date indicated, you may comply with
this grand jury subpoena by promptly providing the agent designated in the attachment with the requested
records. If you choose to provide the requested records voluntarily, please provide them in a non-
proprietary electronic format via FedEx, UPS or DHL. Also enclosed please find a blank “Declaration of
Custodian of Records” form. It may save time and costs if an appropriate person at your business could
complete the form and return it with the records. A properly completed “Declaration of Custodian of
Records” form will make it more likely that we could present the records at trial without requiring you or
another employee to come to court and testify.
Although you are not required to do so, you are requested not to disclose the existence of this
subpoena or the fact of your compliance. Any such disclosure could impede the investigation being
conducted and thereby interfere with the enforcement of the law. Thank you for your cooperation in this
matter.
Sincerely,
Matthew M. Graves
United States Attorney
By:
___________________________
Joshua S. Rothstein
Assistant United States Attorney
202-252-7164
/s/ Joshua Rothstein
USAO-004607
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 1 of 9
To:
AO 110 (Rev. 06/09) Subpoena to Testify Before a Grand Jury
UNITED STATES DISTRICT COURT
for the
District of Columbia
SUBPOENA TO TESTIFY BEFORE A GRAND JURY
Vetted Couriers and Logistics
Attn: Custodian of Records
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: U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
U.S. Courthouse, 3rd Floor Grand Jury #23-6
333 Constitution Avenue, N.W.
Washington, D.C. 20001
Date and Time:
Tuesday, March 19, 2024 at 9:00 AM
You must also bring with you the following documents, electronically stored information, or objects:
PLEASE SEE ATTACHMENT
In lieu of personally appearing before the Grand Jury on the date indicated, you may comply with this grand jury
subpoena by promptly providing the agent designated in the attachment with the requested records.
Date: March 1, 2024
The name, address, telephone number and email of the Assistant United States Attorney, who requests this subpoena,
are:
Joshua S. Rothstein, Assistant United States Attorney
United States Attorney’s Office for the District of Columbia
601 D Street N.W. Room #5.1523
Washington, DC 20530
Phone: 202-252-7164 Fax: 202-307-2304
Email: joshua.rothstein@usdoj.gov
Subpoena #GJ20240229114371
USAO #2023R00502
Preparer: LABBE
CLERK OF COURT
Signature of Clerk or Deputy Clerk
/s/ Joshua Rothstein
USAO-004608
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 2 of 9
ATTACHMENT TO GRAND JURY SUBPOENA
USAO # 2023R00502
Please read instructions below and provide records in non-proprietary electronic format when possible.
Contact FBI Special Agent Daniel A. Mehochko at 202-480-4912 or Damehochko@fbi.gov with any questions.
_________________________________________________________________________________________
| Subpoena Attachment
Issued to:
Vetted Couriers and Logistics
Method:
Hand Delivery
Time period for
requested documents:
January 1, 2018, to present
I.
INSTRUCTIONS
A.
In complying with this subpoena, you are required to produce all responsive documents,
records, information, and communications that are in your possession, custody, or control,
whether held by you or your past or present agent, employee, or representative acting on your
behalf. You are also required to produce documents that you have a legal right to obtain, that you
have a right to copy, or to which you have access, as well as documents that you have placed in
the temporary possession, custody, or control of any third party.
B.
No documents called for by this request shall be destroyed, modified, removed,
transferred, or otherwise made inaccessible to the grand jury. If you have knowledge that any
subpoenaed document has been destroyed, discarded, or lost, identify the subpoenaed document
and provide an explanation of the destruction, discarding, loss, or disposal, and the date at which
the document was destroyed, discarded, or lost.
C.
This subpoena is continuing in nature. Any document not produced because it has not
been located or discovered by the return date shall be provided immediately upon location or
discovery subsequent thereto with an explanation of why it was not located or discovered until
the return date.
D.
If you believe any responsive documents are protected by a privilege, please provide a
privilege log which (1) identifies any and all responsive documents to which the privilege is
asserted, (2) sets forth the date, type, addressee(s), author(s), general subject matter, and indicated
or known circulation of the document, and (3) states the privilege asserted in sufficient detail to
ascertain the validity of the claim of privilege.
E.
Production with respect to each document shall include all electronic versions and data
files from email applications, as well as from word processing, spreadsheet, database, or other
electronic data repositories applicable to any attachments, and shall be provided to the grand jury
where possible in its native file format and shall include all original metadata for each electronic
documents or data file.
USAO-004609
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 3 of 9
ATTACHMENT TO GRAND JURY SUBPOENA
USAO # 2023R00502
Please read instructions below and provide records in non-proprietary electronic format when possible.
Contact FBI Special Agent Daniel A. Mehochko at 202-480-4912 or Damehochko@fbi.gov with any questions.
_________________________________________________________________________________________
| Subpoena Attachment
II.
DEFINITIONS
A.
“Document” means any written, recorded, or graphic material of any kind that is in your
possession, custody or control. The term includes, but is not limited to: contracts; agreements;
letters; telegrams; interoffice communications; memoranda; notes; reports; analyses; worksheets;
spreadsheets; notebooks; surveys; lists; outlines; schedules; pamphlets; newsletters; flyers;
charts; logbooks; tabulations; compilations; studies; books; records; telephone books or
messages; visitor books; calendar or diary entries; desk or appointment calendars; drafts; business
cards; minutes or meetings or conferences; notes or memos or other records of telephone or other
conversations or communications; electronic transmissions (including emails, text messages,
instant messaging, chat rooms, electronic bulletin boards, and any communications using
applications such as WhatsApp or Signal); ledgers; financial statements; bank statements; check
images (front and back); bills or invoices; purchase orders; receipts; photographs; microfilm;
microfiche; audio and video tape or disc recordings; computer printouts; and communications. It
also includes electronically stored data and electronic files, stored on file servers, e-mail servers,
hard drives, or other electronic storage media within your control from which information can be
obtained either directly or by translation through detection devices or readers. Any such
document is to be produced in reasonably usable form, electronic and searchable, along with
instructions for reading the data. Any such electronically stored information must be preserved
in its native format. The term “document” includes the original (or a copy thereof if the original
is not available) and all copies that differ in any respect from the original or that bear any notation,
marking or information not on the original. “Document” shall also include all documents,
materials, transmissions and information, including Electronically Stored Information within the
meaning of the Federal Rules of Civil Procedure.
B.
“Electronically Stored Information” or “ESI” shall mean the complete original and any
non-identical copy (whether different from the original because of notations, different metadata,
or otherwise), regardless of origin or location, of any writings, drawings, graphs, charts,
photographs, sound recordings, images, and other data or data compilations stored in any
electronic medium from which information can be obtained either directly or, if necessary, after
translation by you into a reasonably usable form. This includes, but is not limited to, electronic
mail, instant messaging, videoconferencing, and other electronic correspondence (whether
active, archived, or in a deleted items folder), word processing files, spreadsheets, databases, and
video and sound recordings, whether stored on: cards; magnetic or electronic tapes; disks;
computer hard drives, network shares or servers, or other drives; cloud-based platforms; cell
phones, personal digital assistants (“PDAs”), computer tablets, or other mobile devices; or other
storage media.
C.
“Referring to” or “relating to” shall mean discussing, describing, reflecting, regarding,
containing, analyzing, studying, reporting, commenting on, evidencing, constituting, setting
forth, considering, recommending, concerning, or pertaining to, in whole or in part.
USAO-004610
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 4 of 9
ATTACHMENT TO GRAND JURY SUBPOENA
USAO # 2023R00502
Please read instructions below and provide records in non-proprietary electronic format when possible.
Contact FBI Special Agent Daniel A. Mehochko at 202-480-4912 or Damehochko@fbi.gov with any questions.
_________________________________________________________________________________________
| Subpoena Attachment
D.
The terms “including” and “includes” shall be construed broadly so that specification of
any particular type of document shall not be construed to exclude other types of documents that
are nevertheless responsive but not specifically identified.
E.
“Communications” refers to exchanges kept in any form, whether written, electronic, e-
mail, text, WhatsApp message, Signal message, telephone, or other, and is meant to be interpreted
broadly in accordance with Federal Law.
F.
Entities identified by name shall be construed broadly to include any subsidiary, affiliate,
successor-in-interest, or related corporate entity, as well as any employee, representative,
contractor, affiliate, or vendor.
III.
PRIVILEGES
If a document demanded by this subpoena is withheld under a claim of privilege, or is otherwise
withheld, provide the following information regarding the record: (1) its date; (2) the name and
title of its author(s); (3) the name and title of each person to whom it was addressed, distributed
and disclosed; (4) the number of pages; (5) an identification of any attachments or appendices;
(6) a description of its subject matter; (7) its present location and the name of its present
custodian; (8) the paragraph of this subpoena to which it is responsive; and (9) the nature of the
claimed privilege or other reason the document is withheld.
IV.
REQUEST FOR DOCUMENTS
For the period of January 1, 2018, through Present:
• All documents and communications related to Cortney Merritts’ May 30, 2020, application
for an Economic Injury Disaster Loan (EIDL) in the name of Vetted Couriers and Logistics.
• All business bookkeeping records and other financial records including General Ledger,
General Journals, all Subsidiary Ledgers and Journals, Gross Receipts and income records,
Cash Receipts and Disbursement records and/or Journals, sales and Purchase records
and/or Journals, Accounts Receivable and Payable Ledgers and records, Bad Debt records,
Cost of Goods Sold records, Loan Receivable and Payable Ledgers, Voucher Register and
all sales and expense invoices including all invoices documenting expenses paid by cash
(currency) or bank check (cashier or teller checks), retained copies of any bank checks
(cashier or teller checks.), payroll journals and ledgers, payroll check stubs, IRS Forms W-
4, IRS Forms W-2, IRS Forms 1099, and IRS Forms 1040 (Schedule C).
USAO-004611
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 5 of 9
ATTACHMENT TO GRAND JURY SUBPOENA
USAO # 2023R00502
Please read instructions below and provide records in non-proprietary electronic format when possible.
Contact FBI Special Agent Daniel A. Mehochko at 202-480-4912 or Damehochko@fbi.gov with any questions.
_________________________________________________________________________________________
| Subpoena Attachment
• Inventory records establishing beginning and ending inventories including inventory
sheets, work-papers, and valuation records. Records and work-papers reflecting the
purchase, basis and depreciable life of assets. Records and work-papers of sales of
corporate assets such records disclosing the dates of purchase and sale, cost and sales
price, records establishing or adjusting asset basis.
• Records related to employees, including communications with employees, personnel
files, time sheets, payroll, salary, compensation, and tax documents.
• Savings account records including passbooks or bank statements, records reflecting dates
and amounts of deposits, withdrawals, interest, debit and credit memos, deposit slips,
records reflecting the identity of checks deposited, withdrawal slips, and records
disclosing the disposition of withdrawals, Forms 1099, debit and credit memos. Records
of any certificates of deposit, money market certificates, U.S. Treasury Notes or Bills
purchased.
• Checking account records including bank statements, deposit slips, records revealing the
identity of checks drawn on the account, checks deposited, all debit and credit memos,
and Forms 1099 issued.
• Loan records including applications, financial statements, loan collateral, credit and
background investigations required, loan agreements, notes or mortgages, settlement
sheets, contracts, retained copies of checks issued for loans, repayment or forgiveness
records, including records revealing the date, amount and method of repayment or
forgiveness (cash or check), checks used to repay loans and a record disclosing the total
amount of discount or interest paid annually, records of any liens, loans correspondence
files and internal memoranda relative to these loans. Records on use of loan funds.
• Documents related to ownership, dominion, or control; the name and roles of officers,
executives, or employees; and compensation of officers, executives, or employees.
• Bylaws and/or operating procedures, policy manuals, training materials and employee
handbooks.
• Client lists, client contact information, and client communications.
•
All documents and communications with agents used to assist in preparation of loan
documents.
• All documents and communications with financial institutions where the loan was applied
to and/or received from.
USAO-004612
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 6 of 9
ATTACHMENT TO GRAND JURY SUBPOENA
USAO # 2023R00502
Please read instructions below and provide records in non-proprietary electronic format when possible.
Contact FBI Special Agent Daniel A. Mehochko at 202-480-4912 or Damehochko@fbi.gov with any questions.
_________________________________________________________________________________________
| Subpoena Attachment
• All documents and communications related to the use of the proceeds of funds provided
through the EIDL loan program.
• All documents and communications regarding SBA’s EIDL loan program.
Please provide responsive records in an electronic format and direct questions to:
Federal Bureau of Investigation
Attn: SA Daniel A. Mehochko / CR-15
Washington Field Office / NVRA
601 4th Street NW
Washington, D.C. 20535
Phone: (202)-480-4912
damehochko@fbi.gov
Questions may also be directed to FBI Forensic Accountant Brian C. Marchelewski at
bcmarchelewski@fbi.gov.
USAO-004613
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 7 of 9
INSTRUCTIONS FOR PRODUCTION OF RECORDS
I.
General:
a. Records existing as Electronically Stored Information (ESI) shall be produced in
non-proprietary electronic form and shall include text data and image data held:
i. In your record retention systems; and/or
ii. By your technology, data, or other service provider(s).
b. Records that do not exist as ESI may be produced in paper or other original format and
may be converted to image or text data and provided as ESI, unless originals are required.
II.
Text Data
a. Text data relating to transactions shall be produced within a data file:
i.
Using a delimited ASCII text data format; or
ii. Using software that can export to a commonly readable, non-proprietary file
format without loss of data.
b. Text data files relating to transactions shall include field descriptions (e.g., account
number, date/time, description, payee/payor, check number, item identifier, and amount).
III.
Image Data
a. Image data shall be produced in graphic data files in a commonly readable,
non-proprietary format with the highest image quality maintained.
b. Image data of items associated with transactions (e.g., checks and deposit slips) shall be:
i.
Produced in individual graphic data files with any associated endorsements; and
ii. Linked to corresponding text data by a unique identifier.
IV.
Encryption/Authentication
a. ESI may be transmitted in an encrypted container (e.g. flash drive, CD/DVD).
Decryption keys and/or passwords shall be produced separately at the time the data are
produced. Please do not encrypt individual file contents if the container is encrypted.
b. Authentication, such as hash coding, may be set by agreement.
c. Affidavits or certificates of authenticity may be included as part of the electronic
production.
USAO-004614
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 8 of 9
(Brief description of type of documents being subpoenaed)
DECLARATION OF CUSTODIAN OF RECORDS
Pursuant to 28 U.S.C. §1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration. I have knowledge of the record keeping system used by this business; this includes how
records are created and maintained.
I am in receipt of a United States District Court Subpoena #GJ20240229114371 dated
February 29, 2024, signed by Assistant United States Attorney Joshua S. Rothstein, requesting specified records
of the business named below.
Attached hereto are pages of records regarding
responsive to the subpoena. I
understand how these responsive documents were created. Pursuant to Rules 902(11) and 803(6) of the Federal
Rules of Evidence, I hereby certify that the records attached hereto:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity, in that the records were created and
preserved pursuant to established procedures, and were relied upon by an employee or this business; and
(3) were made as part of the regularly conducted business activity as a regular practice, in that the records
were created and preserved as part of routine reflections of the normal operations of this business.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on .
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
(business address)
Definitions of terms used above:
As defined in Fed.R.Evid. 803(6), “record” includes a memorandum, report, record, or data compilation, in any form, of acts, events,
conditions, opinions, or diagnoses. The term “business” as used in Fed.R.Evid. 803(6) and the above declaration includes business,
institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit.
USAO-004615
Case 1:25-cr-00076-JMC Document 35-1 Filed 12/02/25 Page 9 of 9File and source
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