Exhibit — USA v. Tisone (Dkt. 80.2)

Summary

Document 80-2, Exhibit B in USA v. Tisone, Case 2:22-cr-00039-SPC-NPM in the U.S. District Court for the Middle District of Florida, was filed February 14, 2023 and holds a July 13, 2022 letter from Michael R. Sklaire of Greenberg Traurig, LLP to the Federal Bureau of Investigation enclosing a Petition for Remission/Mitigation Form for Bank of Clarke County, with a July 7, 2022 letter to Trenton Reichling and Julie A. Simonsen of the United States Attorney's Office. That letter states that the bank loaned $1,500,000 to TEC Ventures, LLC under the Main Street Lending Program on a term note executed by Mr. Tisone on or about December 10, 2020, asks that funds seized from the TEC Ventures account at the bank be returned to it, and asks that the bank be identified as a victim of the alleged fraud.

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Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 1 of 7 PageID 536
EXHIBIT B
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 2 of 7 PageID 537
(Eaj GreenbergTraurig

Michael R. Sklaire
Tel 703.749 1308
Michael.Sklaire@gtlaw.com

July 13, 2022

Forfeiture Paralegal Specialist
Federal Bureau of Investigation
5525 W. Gray Street

Tampa, FL 33609

Re: Petition for Remission/Mitigation Form, United States v. Tisone, Case No. 2:22-cr-39
Dear Sir or Madam:

Attached is a Petition for Remission/Mitigation Form and a copy of a letter sent on July 7 to
Trenton Reichling and Julie A. Simonsen of the United States Attorney’s Offices in Ft. Myers,
FL and Tampa, FL respectively, with a copy to the FBI, regarding Asset ID Number 22-FBI-

Please let me know if I can provide any further information.
Sincerely,

AlQx

Michael R. Sklaire
Managing Shareholder

Greenberg Traurig, LLP | Attorneys at Law
1750 Tysons Boulevard | Suite 1000 | McLean, Virginia 22102 | T +1 703.749 1300 | F +1 703.749 1301

www gtlaw.com
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 3 of 7 PageID 538
PETITION FOR REMISSION/MITIGATION FORM

Note: There is no legal form or format required for filing a petition; this document is provided for your
convenience. Please visit i forfeiture. lin ti for more specific guidance on filing your
petition with the appropriate seizing agency.

Frivolous Petition Statement: A petition containing false information may subject the petitioner to criminal
prosecution under Title 18 United States Code Section 1004 and Title 18 United States Code Section 1621.

Privacy Act Notice: The Department of Justice Is collecting this information for the purpose of processing
your petition for remission and/or mitigation. Providing this information is voluntary; however, the information
is necessary to process your application. information collected is covered by Privacy Act System of Records
Notice Department of Justice (DOJ), DOJ-002-DOJ Computer Systems Activity & Access Records, Federal
Register (71 FR 29170). This information may be disclosed to contractors when necessary to accomplish an
agency function, to law enforcement when there is a violation or potential violation of law, or in accordance with
other published routine uses. For a complete list of routine uses, see the system of records notice listed above.

6E0NGE, Jame

Business/institution Name: (if applicable) Prisoner ID: (if applicable)

Bade & CLACKE Coun
Address: (include Street, City, State, and Zip Code)
OLD Ton GANTER

Uw MST ee VA 2242)
Social Security Number/Tax Identification Number: (Enter N/A if you do not have one)

Please provide an explanation why you do not have a Social Security Number, if above Is N/A:

Email: (optional)

Phone: (optional)

t &TTORNEY INEO MATIC

. "8 U ats evi | EN

Attorney Title: “
MAN AG i Wg LEA VWD{E

Firm Name: (if applicable
RAN Boa 6 tA i a oe
Attorney Address: (Include Street, City, State, and Zip Code)

(19D 4 Cws BLuy Sane | 009
Mclean, va 22/07

Are you an attomey filing this petition on behalf of your client? | Yes CJ No

Attorney Phone: (optional) Attorney Email: (optional)
73 2. 74 --/208 Mich ag] SKlxing S Phas Kons |
if any of this information changes, you are responsible for notifying the agency of the new information.
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 4 of 7 PageID 539
SECTION |i - ASSET LIST

You must identify which assets you are patitioning.

22 -FS J- OOLL SY

vo

Soy giz. 42m Fads ba honk a6ovar |
Pry lec k ex Zt It ofdirn re Acne
a "TE VE ils ZL

SECTION Ill - VICTIM PETITION

if you are filing this petition as a victim, please fill out the table below. The information must apply to all of the
assets you selected as a victim role in previous section. If you are not filing as a victim for any assets, you
may skip this section.

| am requesting remission of this forfeiture because | am a victim of the criminal offense underlying the

forfeiture of this property or am the victim of a related offense and | have suffered a pecuniary loss as a
result of that offense as described below:

SEE AED LETTER

Please provide the total pecunlary loss claimed. This is the total amount you claim to have lost.

if you have recovered any of your losses, pléase list the details below. If you have more than two
sources of recovery, please print multiple coples of this table to submit with the petition.

m ha ] . i'w) a rw , bone,
ries "RECOVERY (ifapplicable)—SSSSCSCSCSCSSS*SY
ee ~~ : : -

Source of Recovery 1: Amount of Recovery:

Source of Recovery 2: Amount of Recovery:

In the space below, please list any documents you are including in support of your victim petition. If
none are included, please explain why.

JEE Atty Che 5 lerreg
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 5 of 7 PageID 540
ON IV - ION AN ENTATION

The following declaration should be compteted by the petitioner. ifthe potitioner is represented by an attomey, the
atlomey may complete the daclaration as long as the petitioner completes the swom notice of representation.

| attest and declare under penalty of that my patition is not frivolous and the information provided ns rtof
my petilion Is true and correct ion Beat of my knowledge and belief provided In suppo

= LW. 9

* ~~ Signature
Miauaee QE La (AE
Date

Sworn Notice of Representation

This section must be completed only by petitioners who are representad by en attomey and whose affomey has
executed (he declaration provided above.

| have retained the above-named attorney who has fe ade to represent me in this matter. | have fully reviewed
the ioregoing petition and found that its contents are truthful an accurate in every respect. | declare under penally of
perjury that @ foregoing information is true and correct.

, a nature

Date

A patition containing false information may subject the petitioner to criminal prosecution under Title 18 United States
Code Section 100}and Title 18 United States Code Section 16214.
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 6 of 7 PageID 541
GreenbergTraurig

Michael R_ Sklaire
Tel 703 749 1308
sklairem@gtlaw com

July 7, 2022

VIA UPS OVERNIGHT

Trenton Reichling

United States Attorney’s Office
2110 First Street

Ft Myers, FL 33901

Julie A. Simonsen

Uniled States Attorney's Office
400 N. Tampa Street., Suite 3200
Tampa, FL 33602

Re: United States v. Tisone, Case No. 2:22-cr-39
Dear Mr. Reichling and Ms. Simonsen:

I represent Bank of Clarke County and am in receipt of a June 9, 2022 letter from the FBI
regarding a petition for remission concerning the matter United States v. Tisone, Criminal] Case
No. 2:22-cr-39 in the Middle District of Florida, and FBI Asset ID Number 22-FBI-002654. As
I mentioned during my telephone call with AUSA Simonson, the Bank of Clarke County loaned
$1,500,000 to TEC Ventures, LLC, evidenced by a term note executed by Mr. Tisone on or
about December 10, 2020. That term note was provided under the Main Street Lending
Program. It is believed that the $64,813,43 seized from the TEC Ventures bank account at Bank
of Clarke County is a part of that principal amount that was loaned to TEC Ventures, LLC and
should be repaid to the Bank of Clarke County, thus the request for a pardon of that property.

In addition, the Bank of Clarke County seeks restitution in the amount that currently exceeds
$1,500,000 based upon the principal, interest and fees, reflecting the monies owed to the Bank of
Clarke County as a payoff of the term note thal may be obtained by the Government in a
resolution or ultimate prosecution of the Tisone matter. The Bank of Clarke County seeks to be
identified as a victim of the alleged fraud. Please note that while the Federal Reserve Bank of
Boston (or its subsidiary) is a participant in the loan under the Main Street Lending Program,
Bank of Clarke County is the lead lender and thus has responsibility for all collection efforts in
connection with the loan.

We understand that the Government has capies of the note and corresponding loan documents,
but are willing to provide whatever additional documentation may be necessary to assert a claim
for the seized or anticipated forfeited proceeds. We look forward to hearing from you and your
Case 2:22-cr-00039-SPC-NPM     Document 80-2     Filed 02/14/23     Page 7 of 7 PageID 542
July 7, 2022

victim coordinator, and will cooperate in whatever manner necessary to bring this matter to a
resolution.

Please contact me if you have any questions or wish to discuss.

Sincerely,

Michael R. Sklaite
Managing Shareholder

CC: Federal Bureau of Investigation
Attn: Forfeiture Paralegal Specialist
5525 W. Gray Street
Tampa, Florida 33609


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