Court filing
MOTION for downward departure by Daniel Joseph Tisone — USA v. Tisone (Dkt. 90)
Record facts
| Court | U.S. District Court for the Middle District of Florida |
|---|---|
| Filed | 2023-02-20 |
U.S. District Court for the Middle District of Florida · No. 2:22-cr-00039-SPC-NPM · Doc. 90 · 2023-02-20 · Docket on CourtListener
Summary
A defendant's sentencing memorandum in support of a motion for a downward variance from the United States Sentencing Guidelines, filed February 20, 2023 as Document 90 in United States of America v. Daniel Joseph Tisone, Docket No. 2:22-cr-39-SPC-NPM, in the U.S. District Court for the Middle District of Florida. The memorandum asks the court to weigh the factors in 18 U.S.C. § 3553(a) and to impose a sentence below the guidelines range. It recounts the defendant's background, states that he was arrested March 30, 2022 in relation to loan applications under PPP, EIDL and MSLP, and states that he takes responsibility. It reports that $1.5 million in MSLP loan proceeds were used to rent, renovate and sell homes and lists scheduled interest payments made on that loan. The filing runs 244 pages with numbered attachments, including transcripts, reference letters and settlement statements.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
UNITED STATES OF AMERICA)
)
vs.
)
DOCKET NO. 2:22-cr-39-SPC-NPM
)
)
DANIEL JOSEPH TISONE
)
)
Defendant.
)
)
DEFENDANT’S SENTENCING MEMORANDUM IN SUPPORT OF MOTION
FOR DOWNWARD VARIANCE FROM THE UNITED STATES SENTENCING
GUIDELINES AND RECOMMENDED SENTENCE
By and through his counsel of record, Daniel Joseph Tisone (“Daniel”) respectfully
submits the following sentencing memorandum for this Court’s consideration prior to the
imposition of sentence herein. Mr. Tisone submits this memorandum in order to provide
information to assist the Court with fashioning a sentence that is “sufficient but not
greater than necessary” to achieve the statutory purposes of punishment and a just
sentence. Mr. Tisone also respectfully requests the Court to consider the multiple factors
pursuant to 18 USC §3553(a)(1)-(7) that would warrant a variance and a sentence
significantly below the guidelines range.
I. INTRODUCTION
Daniel Tisone is a 35-year-old devoted father of a newborn boy, loving fiancée, business
owner, and valued member of the Naples community. When he was young, Daniel’s mom
struggled with extremely long work hours to provide for Daniel and his older sister and
raised both children as a single mother as his father was absent. When his father did come
into the picture he was both verbally and physically abusive towards Daniel, his sister
and his mother.
As a consequence of his father’s abuse, Daniel started to run away from home, skip
school, got involved with drugs and alcohol and ran with a rough crowd towards the end
of high school and beginning of college. He was involved in a physical altercation with
another student, who was a drug dealer. He stole Mr. Tisone’s laptop while Mr. Tisone
LAW OFFICES OF MARK EIGLARSH
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was a 19-year-old sophomore in college. Mr. Tisone went to trial, and was subsequently
convicted and sentenced to 6 years in prison and 5 years parole. He served 4 years and 8
months of his prison term before being released.
Daniel was released from prison in 2012 to his mother’s house in Fairfax, Virginia. From
day one, he started working with his mother saving money to start his own business,
“RUB A DUB,” which started as a car detailing service operating from the parking lots of
commercial office buildings. He worked long hours building his business while also
helping his mother’s business and put himself through community college in the evening.
He earned a 4.0 GPA, achieving the designation, “presidential scholar.”1
While in school and working, Mr. Tisone volunteered at Project SAFE, a counseling
center for troubled youth.2 After finishing two years at community college while building
his business, he applied to Georgetown University in Washington DC. He was offered a
full scholarship only to have it rescinded by the board of admissions after learning of his
criminal conviction from when he was 19 years old.
He went to the Project SAFE counseling center where he volunteered and explained how
his actions from years ago shut doors for him no matter how hard he works and
regardless of what he achieves in an attempt to overcome his past. A young boy shared
Mr. Tisone’s story with his father, who happened to be the Dean of Students at Catholic
University. He then called Project SAFE and informed the owner that he wanted to meet
with Mr. Tisone.
Mr. Tisone was admitted to the Catholic University of America and enrolled in an honor’s
dual degree program for International Economics and Finance, where he took an overload
of courses with special permission from the Dean of the Program while continuing to
build his business, RUB A DUB.3
Daniel is an extremely hard worker who takes great pride in his work. He put his heart,
soul and all his resources into building a successful business that, pre-Covid, was in in
many commercial office complexes in Washington DC, Maryland and Virginia and
See Attachment 1 : NVCC Transcript
1
See Attachment 2 : Letter by Gayle Alexander, Project SAFE
2
See Attachment 3 : Letter by Andreas Widmer, Catholic University Professor / CUA Transcript
3
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Florida operating from office buildings with some of the largest developers in
Washington DC. , , , , ,
4 5 6 7 8 9
Unlike many others who engage in similar fraud, Daniel had legitimate businesses. His
businesses, operating from commercial office buildings primarily in Washington DC,
Maryland and Virginia were shut down during the pandemic due to office buildings being
vacated by “work from home orders.”
From the loss of his business and the uncertainty of the world, Daniel was desperate to
obtain funds and resorted to manufacturing payroll and tax documents in order to qualify
as he did not have proper payroll and accounting systems in place paying the majority of
his workers in cash as they did not have access to traditional banking systems as a letter
from a co-worker of Mr. Tisone, as well as a letter from Skill Source Group provided by
the prosecutions discovery also attests to.
Daniel did use a portion of the Covid relief funds he obtained to pay employees, payroll
taxes and operate a business. , , He used the MSLP loan proceeds, in the amount of
10 11 12
$1.5 million, to rent, renovate and sell homes, which netted Mr. Tisone’s business
significant returns in the amount of $1.9 million profit in 2021 alone. , . The P&L of his
13 14
business does not reflect that income as it was deferred using a 1031 exchange.
Daniel planned and intended to repay all loans pursuant to the loan terms. Prior to his
arrest, he made scheduled interest payments on the MSLP loan on 1/10/2022 ($4,072.49),
02/10/2022 ($4,067.05), and 03/10/2022 ($3,687.67). Post arrest, after his accounts were
frozen, he continued to make a payment on 05/16/2022 in the amount of $4,469.93 to
See Attachment 4 : JVA w/ Atlantic Services Group
4
See Attachment 5 : Discovery letter to Trent Riechling from Brandywine Realty Trust
5
See Attachment 6 : Reference letter by Edward Strittmatter from Brandywine Realty Trust
6
See Attachment 7 : COI requests from Tower Companies properties
7
See Attachment 8 : Reference letter from Matt Coursen, Managing Director, JLL Properties
8
See Attachment 9 : Letter from William Akridge RE: Akridge Properties
9
See Attachment 10 : Gusto Payroll
10
See Attachment 11 : VRBO Rent Roll - 796 Ketch Dr
11
See Attachment 12 : Contractor Invoices
12
See Attachment 13 : Settlement Statements - Purchase / Sale of 796 Ketch Dr
13
See Attachment 14 : Settlement Statements - Purchase / Sale of 1530 Mandarin Rd
14
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Bank of Clarke County and worked to arrange a deferment on future payments which was
granted.
15
As stated in his letter to the Court, Mr. Tisone takes full responsibility for the fraud and
deeply regrets his actions. He respects the court and took full responsibility without a
trial. He deeply regrets ever taking any funds from the government and is extremely
remorseful for the devastating consequences his actions had on his family and now the
second business he has lost in addition to the victims of the offense.
He stands before the Court as an individual with sincere remorse, embarrassment, and
regret for making poor decisions that now overshadows decades of diligence and hard
work, including building both a family and a successful business that was fortunate
enough to grow and employ so many within the community. , ,
16 17 18
II. ANALYSIS OF STATUTORY FACTORS AS APPLIED TO THIS CASE
A. Nature and Circumstances of the Offense, 18 U.S.C. §3553(a)(1)
Mr. Tisone was arrested on March 30, 2022, in relation to loan applications pursuant to
PPP, EIDL and MSLP. He immediately accepted responsibility and never disputed the
facts within the original indictment.
Mr. Tisone deeply regrets his decision to obtain funds fraudulently and is remorseful
regarding any victims.
Mr. Tisone had operating businesses pre-Covid and used a great portion of the
fraudulently obtained Covid relief funds to operate legitimate businesses within the spirit
and intent of the program, paying employees, paying both state and federal payroll taxes
and making sound business decisions that generated significant profits and economic
activity.
The hundreds of criminal cases charged nationwide over the past year include overtly
fraudulent statements on multiple PPP and/or Economic Injury Disaster Loan (“EIDL”)
applications with fraudulent shell companies, fake farms and many created bogus
businesses. In contrast, Mr. Tisone’s companies were legitimate, operating businesses that
See Attachment 15 : Letter from Valera Belcher, Bank of Clarke County
15
See Attachment 16 : Letter from Grant Brosseau
16
See Attachment 17 : Letter from Matt Parish
17
See Attachment 18 : Letter from Tanya Costa
18
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See Attachment 19 : Accountant Invoices
19
See Attachment 20 : Lawyer Invoices for Company Mergers, Loan Review
20
See Attachment 21 : Payment Receipts for Mortgages, 550 Starboard Sales Contract
21
See Attachment 22 : Mortgage Balance
22
See Attachment 23 : Sale of Vessel
23
See Attachment 24 : Sale of Lincoln Aviator Receipt
24
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B. Characteristics of the Defendant, 18 U.S.C. §3553(a)(1)
Mr. Tisone does have a prior criminal history from when he was a teenager and, apart
from those offenses, has led an exemplary life since those convictions over 15 years ago.
He grew up in the Fairfax, Virginia area and currently resides in Naples with his fiancée
and newborn son.
Mr. Tisone worked with troubled youth at a counseling center named Project SAFE ,
25
operated a local business, and has volunteered and served on advisory boards at his alma
mater, Catholic University , as well as volunteering with at-risk youth in Orange, NJ .
26
27
Mr. Tisone is dedicated to his fiancée and newborn son. He adores his child and spends
an immense amount of time with him. Mr. Tisone is also very passionate about giving
back to his community as the letters from multiple individuals attest to.
When Mr. Tisone is not spending time with his family, he is at work. He has been
working on multiple businesses since he was a kid. By all accounts, Mr. Tisone is an
extremely driven, resilient individual who works incredibly hard to overcome his past
decisions. Prior to Covid, he spent the past 6 years dedicating a massive amount of time,
energy, and resources into growing successful businesses.
Mr. Tisone’s entities were more than just a job. They were Mr. Tisone’s only hope in the
professional arena since he was a convicted felon. He started his business not on a whim,
but out of necessity due to being shunned by all employers who rejected him due to his
criminal history. He grew his business to be in a multitude of office buildings of major
developers where he caught the attention of Ford Motor Company with which he
28
subsequently entered into a deal to provide his services to them through a software
integration. , , .
29 30 31
25 Refer to Attachment 2 : Letter from Gayle Alexander from Project SAFE
26 Refer to Attachment 3 : Letter from Andreas Widmer, Professor at Catholic University
27 See Attachment 25 : Letter from Father Andrew DeSilva
28 Refer to Attachments 6 through 9
29 See Attachment 26 : April 30, 2019 Ford Motor Company Article - https://medium.com/
cityoftomorrow/flipping-the-script-how-ford-is-bringing-more-services-directly-to-your-car-
de468615e798
30 See Attachment 27 : April 30, 2019 Forbes Article RE: Ford / RUB A DUB - https://
www.forbes.com/sites/samabuelsamid/2019/04/30/ford-joins-the-in-car-delivery-movement-
gets-more-connected-services/?sh=30e395bd3ade
31 See Attachment 28 : Executed Ford Digital Services Agreement signed by Brett Wheatley
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In late 2019, Ford Motor Company was in discussions to purchase Mr. Tisone’s company,
flying him to Detroit, MI and Palo Alto, CA to meet with key executives. Once Covid
32
arrived, those discussions were tabled and subsequently, Mr. Tisone lost everything he
had worked so hard to build, through no fault of his own.
The multiple letters from Mr. Tisone’s previous employees depict Mr. Tisone as a
thoughtful, considerate and compassionate man who cares greatly for others. The letters
33
from property owners and vendors show that Mr. Tisone has an exceptional reputation in
the construction community for his hard work, integrity and technical skills.
34
In addition to his work, Mr. Tisone is also passionate about giving back to the community
and helping others as many have attested to.
Daniel also provided a payment advance to another of his employees so she could
continue paying her rent and avoid eviction as well as obtaining furniture for her
home after it was decimated by Hurricane Ian. Additionally, he also purchased
35
educational courses for his employees so that they could increase their skills.
36
Whether Mr. Tisone is volunteering his time to counsel troubled youth, renovating
homes, providing jobs to disadvantaged workers , offering his help to a woman to
37
prevent her from being evicted, gathering furniture donations for a victim of Hurricane
Ian, giving a friend a job, or paying for educational courses to an employee so they can
further their career, the one theme that runs through the letters of support provided to the
Court is Mr. Tisone’s generosity, kindness, and service to his community.
38
He is a man who has made mistakes and poor choices but by all accounts, is a good
person who contributes greatly to his community, his company, and his family. Mr.
Tisone’s desire to give back did not start at the inception of this case and it will not end
after his sentencing.
32 See Attachment 29 : Amended Letter from Ford Legal Counsel detailing the verification of
discussions regarding an acquisition
33 Refer to Attachments 2,16, 17 and 18
34 Refer to Attachments 6, 8, 9 and 16
35 Refer to Attachment 18 Letter from Tanya Costa
36 See Attachment 30 : Cash App Payment to Milan Vasich for Real Estate Broker Course
37 See Attachment 31 : Discovery Letter to Trent Reichling from Skill Source Group
38 See Attachment 32 : Letter from Katie Vincent
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C. To reflect the seriousness of the offense, to promote respect for the law, and to
provide just punishment for the offense. 18 U.S.C. § 3553(a)(2)(A).
Mr. Tisone understands the seriousness of his offenses. In assessing a “just” punishment,
the Court should consider that these were non-violent offenses committed by a man
facing the loss of his business through no fault of his own and significant barriers to
gainful employment due to his past criminal history. Furthermore, a majority of the loans
will be paid back resulting in a significantly reduced loss amount.
Mr. Tisone has worked diligently to pay off his debts and has taken extraordinary steps to
make the loans whole, marketing and placing the property at 550 Starboard Drive under
contract, so that he could pay off the existing mortgage and a large portion of the loans
that he had received to minimize any financial risk to the bank or the government. He
also marketed his office at 1001 10th Ave South. That property was unfortunately
decimated by the recent hurricane. It has since been seized by the government.
Mr. Tisone has also been working to keep his family afloat. His property management
business was once highly successful, but he can no longer operate it himself due to the
repetitional harm and extensive negative press coverage. With regard to his contracting
business, there are many factors involved in the decline including the damage to the
Daniel’s reputation from the criminal case , . Mr. Tisone sold nearly all of his assets
39 40
and is working diligently to ensure that he is able to generate an income.
The loss of his business that he spent the last 8 years of his life building, the inevitable
loss of his ability to obtain business funding through banks, the significant amount of
money paid in forfeiture and restitution, the loss of his home and office, and the
substantial harm through extensive media coverage of this case resulting and the damage
to his reputation are all significant punishments.
D. To afford adequate deterrence to criminal conduct. 18 U.S.C. §3553(a)(2)(B).
The prosecutions brought against Mr. Tisone have devastated him personally,
professionally, and financially. The charges and intense negative media coverage
surrounding the case have had a severe detriment on the business and on Mr. Tisone and
his fiancée. Mr. Tisone already had to work overtime in order to provide for himself since
he was a previously convicted felon that no employer wanted to hire. Rather than turn to
crime, Mr. Tisone did everything in his power to live his life in a productive manner and
give back to his community.
Refer to Attachment 17 : Letter from Matt Parish
39
See Attachment 33 : Letter from Samantha Leigh Ford
40
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A lengthy jail sentence is not necessary in this case and would not further the statutory
goals of sentencing. As a result of this widely-reported case, the public now understands
what can happen when the full prosecutorial force of the United States government is
brought down upon an individual, and would-be violators have been deterred from
engaging in similar conduct.
E. Protecting the public from further crimes. 18 U.S.C. § 3553(a)(2)(C)
Mr. Tisone does not present a risk of recidivism. His age, track record of improving
himself, supportive family, and self-employment history show there is an extremely low
risk that he will repeat the conduct that led to his arrest. Mr. Tisone took responsibility
immediately for his actions and also took extraordinary steps to ensure full restitution
was paid.
Mr. Tisone made a poor decision in obtaining loans, but the fact that he did pay
employees and contractors during the covered period and use the funds for business
purposes is significant. Unlike the majority of PPP prosecutions nationwide, where fake
farms were made up, along with completely fictitious businesses and the funds
squandered, Mr. Tisone’s entities certainly qualified for some sort of Covid relief and he
did use a large portion of the funds for the operation of a business.
41
Furthermore, his cooperation with the Government by offering substantial assistance
further supports the argument that he no longer intends on committing any future
offenses. The Court can consider the low risk of recidivism when fashioning its sentence.
F. Kinds of Sentences Available, 18 U.S.C. §3553(a)(4)
The guideline imprisonment range calculated in the PSR is not commensurate to the
crimes. Since Mr. Tisone is ineligible for probation, he could receive several sentences
that would allow Mr. Tisone to continue to be there for his son and his fiancé.
The Court could impose a sentence of 12 months home confinement with work
restrictions, along with numerous community service hours service to reach a just
sentence.
Due to the devastation from Hurricane Ian, Mr. Tisone’s previous experience with home
renovations and construction, he would be able to give back to his community in a more
productive manner than sitting in a prison by performing community service with Habitat
for Humanity.
Refer to Attachments 10, 11, 12, 13, 14, 16 through 18, 19, 20 and 33
41
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This suggestion is not one to nullify Mr. Tisone’s conduct, but to ensure that Mr. Tisone’s
son and fiancée do not fall prey to the same fate as did Mr. Tisone by his father’s absence
from his life as a young boy. Also, a period of incarceration would result in Mr. Tisone
unable to provide for his family.
A sentence as recommended above would allow Mr. Tisone to pay further forfeiture and
continue to be a contributing member of society without being a financial burden to his
fiancée and newborn baby.
This type of sentence is not uncommon. On July 7, 2017, Judge Corrigan gave a sentence
of time served with 5 years of supervised release to Rashaad Simar Jones, a co-defendant
in a drug conspiracy case that involved the trafficking of multiple kilograms of cocaine,
who faced an applicable guideline range of 70 to 87 months. See United States v. Jones,
et al, 3:16-cr-00104. Judge Corrigan also required Mr. Jones to participate in a 365 day
home detention program.
This sentence was given absent a 5K motion for downward departure, which was filed in
Mr. Tisone’s case. This variance was granted based upon Mr. Jones’ good character and
the Court found that this sentence that was sufficient, but not greater than necessary, to
achieve the statutory purposes of punishment and a just sentence.
G. Need to Avoid Unwarranted Sentencing Disparities
We would ask the Court to take into consideration not only the sentences that have been
given in the few Covid Relief Fraud cases that have been prosecuted, but also the
Government’s disparate charging decisions. In researching PPP cases and sentences
across the nation, the undersigned has yet to find a case that can plausibly be analogized
to Mr. Tisone’s case.
The criminal cases charged nationwide include overtly fraudulent statements on multiple
PPP loan and EIDL applications including fraudulent shell companies, fake farms and
proceeds being completely squandered on depreciating assets and shopping sprees.
In stark contrast, Mr. Tisone’s companies were legitimate companies greatly affected by
Covid work from home orders. Mr. Tisone’s companies also paid its employees a large
portion of the loan amount on allowable expenses during the covered period. Yet, Mr.
Tisone’s sentencing guidelines are starkly disparate from the PPP cases recently
sentenced:
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United States v. Crowther, No. 2:20-cr-00114-JLB-MRM, Middle District of Florida
•
Defendant received twelve (36) months imprisonment of which he served (12)
months.
•
Defendant did not accept responsibility, taking his case to trial and being found
guilty.
•
Defendant did not cooperate with the government or receive a 5K.1 motion
•
Defendant sought and received more than $2 million in a Payroll Protection
Program (PPP) loans
•
Within days of receiving the PPP funds, Crowther used a portion of the funds to
purchase a 2020 40-foot catamaran boat for approximately $689,417
•
Crowther created dozens of fake employees to whom he purportedly paid wages
for whom he obtained fake identification documents -- including Social Security
cards
United States v. Tarik Jaffaar, No. 1:20-cr-185-CMH, Eastern District of Virginia
•
Defendant received twelve (12) months imprisonment.
•
Mr. Jaffaar submitted eighteen (18) PPP loan applications to twelve financial
institutions for four businesses, which were merely shell companies.
•
The PPP loan applications included fake employment tax returns and payroll
documents which claimed the business had a number of employees.
•
Of the approximately $6.6 million sought, the financial institutions disbursed
approximately $1.4 million.
•
Additionally, between April 7, 2020, and April 15, 2020, the defendant and his
wife submitted two EIDL loan applications for two of the shell entities to the SBA.
As a result, one $10,000 EIDL advance was obtained from the SBA.
The defendant and his wife were arrested in the parking garage across from
Terminal 7 of John F. Kennedy International (“JFK”) airport with 18 bags. The
defendant had both his United States and Moroccan passports on his person. Ms.
Jaworska had her United States and Polish passports on her person. In the various
bags, law enforcement found $49,875.65 in cash, approximately 14 cell phones,
and multiple laptops.
•
The defendant did not pay any payroll with funds received
United States v. Shahank Rai, No. 1:21:cr-00009, Eastern District of Texas
•
Defendant received twenty-four (24) months imprisonment.
•
The defendant filed 2 PPP loan applications seeking $10 million and $3 million
respectively.
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•
The defendant claimed to have 250 employees earning wages in each application
when, in fact, no employees worked for his purported business.
•
The defendant did not pay any payroll with funds received.
United States v. Latoya Stanley and Johnny Philus, No. 1:21-cr-20067, Southern District
of Florida.
•
Defendants were sentenced to eighteen (18) and thirty (30) months respectively.
•
The defendants filed four (4) PPP and EIDL loan applications claiming
nonexistent employees and payroll and received $1.1 million.
•
The defendants resurrected defunct corporations to file applications and used
fraudulent bank statements in support of the application.
•
The defendants also filed EIDL loans claiming non-existent farming land.
•
Investigators found notebooks full of personal identification information and over
70 credit cards in the names of third parties.
•
The defendant did not pay any payroll with funds received.
United States v. Julio Lugo and Rosenide Venant, No. 8:21-mj-01295, Middle District of
Florida (Tampa)
•
Julio Lugo received 42 months imprisonment.
•
He submitted at least seventy (70) false and fraudulent loan applications seeking
PPP and EIDL funds.
•
The fraudulent loan applications requested more than $5.8 million, including for
shell companies established by Lugo, Venant, and their relatives.
•
The conspirators also secured coronavirus relief funds for a defunct tax-
preparation company that Lugo had previously used to perpetrate a tax fraud in or
around 2015.
•
The defendant paid off a luxury vehicle, spent more than $62,000 at casinos, and
for other personal purposes. Additionally, the conspirators withdrew at least
$320,000 in cash. Lugo publicized the misuse of the SBA funds in a Facebook
video featuring a hotel room littered with $100 bills and at least $5,000 in
merchandise from Louis Vuitton.
The defendant did not pay any payroll with funds received.
United States v. Nadine Consuelo Jackson, No. 3:20-cr-00112-MJN, Southern District of
Ohio
•
Defendant received twenty-four (24) months imprisonment.
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•
Ms. Jackson applied to First Home Bank for a PPP loan of $1,315,491.12
(received $1,021,300) and also applied for an EIDL loan.
•
Submitted false Wage and Tax Reports and false personal tax returns.
•
Submitted a second PPP loan application for $1,236,817.
•
The defendant did not pay any payroll with funds received.
The Justice Department has also used prosecutorial discretion when prosecuting
legitimate companies. On January 12, 2021, the District of California entered into a civil
settlement with SlideBelts, Inc., an internet retail company who lied about bankruptcy on
its PPP application. https://www.justice.gov/usao-edca/pr/eastern-district-california-
obtains-nation-s-first-civil-settlement-fraud-cares-act. The company and Brigham Taylor,
the company’s president and CEO, have agreed to pay the United States a combined
$100,000 in damages and penalties to resolve allegations that they committed fraud.
H. Restitution
Mr. Tisone, through restitution already obtained, as well as forfeited assets, is able to pay
nearly every lender and loan back should he be allowed to continue to work. Mr. Tisone
is asking the court to allow him to remain at home under confinement and perform
extensive community service to assist with the damage from Hurricane Ian.
I. Good works, pursuant to U.S.S.G. §§5H1.6 and 5H1.11
The defendant should receive a downward departure due to his prior civic service. The
defendant's commitment to serving his community prior to the criminal activity in
question demonstrates a genuine desire to contribute positively to society and shows that
his actions were an aberration, rather than a pattern of criminal behavior.
The defendant has a long history of volunteering for various civic organizations,
including local troubled adolescent groups (Project SAFE), his alma mater (Catholic
University) and for church groups (Orange, NJ Church Group) as previously mentioned.
Mr. Tisone has spent countless hours helping others and giving back to the community.
His record of civic service is a testament to his character and demonstrates that he is a
person of good moral character who is committed to making a positive impact on the
world.
Furthermore, the defendant's civic service has directly benefited many people in the
community. His work with troubled youth and community organizations has helped to
deter criminal activity, provide advice for young teens facing hardship, and those seeking
jobs. The defendant has been a role model and mentor to many young people in the
LAW OFFICES OF MARK EIGLARSH
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community, inspiring them to give back and make a difference in the world.
While the defendant's criminal conduct cannot be excused or condoned, it is important to
consider their prior civic service when imposing a sentence. A downward departure is
appropriate in this case because it recognizes that the defendant's criminal behavior is not
indicative of their character or values, but rather a momentary lapse in judgment.
In addition, a downward departure in this case would serve the interest of justice by
promoting rehabilitation and reducing the likelihood of recidivism. The defendant has
expressed remorse for his actions and has shown a willingness to take responsibility for
his wrongdoing. A sentence that considers his prior civic service would help to reinforce
the importance of community involvement and encourage the defendant to continue to
give back to society.
J. DEPENDENCE UPON CRIMINAL ACTIVITY FOR A LIVELIHOOD pursuant
to U.S.S.G. §5H1.9
Another mitigating factor for the Court to consider is Mr. Tisone’s dependence on
criminal activity for a livelihood, as outlined in the §5H1.9 of the U.S. Sentencing
Guidelines.
Because of Mr. Tisone’s prior criminal conviction, which has made obtaining legitimate
employment extremely challenging if not impossible, he has struggled to find gainful
employment in spite of his criminal record. Despite efforts to reform and turn his life
around, he found limited options to provide for himself and his family. Therefore, he built
a business from scratch over the span of 6 years while studying as a full time college
student in an extremely difficult dual degree honors program at Catholic University.
The Covid-19 pandemic only exacerbated his situation, causing widespread economic
disruption and leading to a significant loss of employment opportunities, particularly for
individuals with criminal records. Mr. Tisone's business, which he had started as a means
of supporting himself and his family, was significantly impacted by the pandemic and
ultimately was closed completely.
In the face of mounting financial pressures and limited options for employment, my client
turned to covid relief funds and criminal activity as a means of providing for himself and
his family. Although this is not a justifiable excuse for his actions, it is a mitigating factor
that should be taken into consideration in the sentencing process.
V. ADVISORY GUIDELINES CALCULATIONS
As the Court is aware, pursuant to United States v. Booker, 543 U.S. 220 (2005), the
guidelines are solely advisory in nature. See, e.g., Moore v. United States, 871 F. 3d 72,
LAW OFFICES OF MARK EIGLARSH
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74 (1st Cir. 2017) (noting that Booker made the guidelines advisory). Some of the items
that aren’t considered in the current sentencing guidelines in this matter include:
1) Mr. Tisone’s financial status continues to change because of supply chain interruptions
and material shortages in the construction industry. This is a direct result of the pandemic
that has had (and is continuing to have) a devastating financial impact on Mr. Tisone’s
business and his ability to finish projects and collect accounts receivable in addition to
being fired from projects upon the clients seeing the extensive media coverage in this
case.
2) The loss amounts should be calculated as the “actual loss”. Intended loss is defined as
"pecuniary harm that the defendant purposely sought to inflict." Following the 2015
amendment, that specifically includes a subjective element. USSG App. C, amend. 792
(effective Aug. 1, 2015). In this context, “[o]btaining a loan fraudulently is different from
stealing property outright, because defendants who fraudulently obtain loans often intend
to repay them in full.” United States v. Harris, 597 F.3d 242, 254 (5th Cir. 2010) (citing
United States v. Henderson, 19 F.3d 917, 928 (5th Cir. 1994)). Thus, “where the
defendant intends to repay the loan or replace the property, the intended loss is zero.” Id.;
United States v. Kraus, 656 Fed. Appx. 736, 739 (6th Cir. 2016) (“[i]n the context of
loan-related fraud, ‘intended loss is the amount the defendant subjectively intended not to
pay.’”) (citations omitted); United States v. Haddock, 12 F.3d 950, 963 (10th Cir. 1993)
(government failed to prove intended loss where evidence suggested the defendant
intended to repay loans); United States v. Monk, No. 2:20-CR-22-WKW, 2020 U.S. Dist.
LEXIS 121489 *22 (M.D. Ala. July 10, 2020) (no intended loss where government
presented no evidence of intended loss and, moreover, the evidence established that
the defendant intended to benefit the victim by using loan proceeds to delay
reporting of separate loan losses, in the hopes that the delay would buy the victim
time to increase its assets to cover is losses); United States v. Hughes, 775 F. Supp.
348, 351-52 (E.D. Cal. 1991) (refusing sentencing enhancement where falsified loan
applications resulted in no loss, because “’[g]ross receipts are not the same thing as
‘loss.’”).
All evidence shows that Mr. Tisone always intended to repay the loans provided. There
is no evidence, much less a preponderance of the evidence, to suggest otherwise. As a
result, there is no intended loss. Similarly, there is evidence that the actual loss will be
much less due to the sale of assets Mr. Tisone arranged prior to sentencing. A large
number of the loans received are able to be paid back through the successful sale of Mr.
Tisones assets as well as through the forfeiture of his office condo.
Any such loss should be further reduced by the value of Mr. Tisone’s previous loan
payments. See United States v. Near, 708 Fed. Appx. 590, 603-604 (11th Cir. 2017);
LAW OFFICES OF MARK EIGLARSH
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(affirming finding of no loss, despite misuse of federal grant money, where value of
defendant’s services exceeded the amount of any loss suffered by the government); see
also U.S.S.G. 2B1.1 n.3(E)(i) (“Loss shall be reduced by the following: The money
returned, and the fair market value of the property returned and the services rendered, by
the defendant or other persons acting jointly with the defendant, to the victim before the
offense was detected”).
3) Mr. Tisone deserves acceptance of responsibility reductions for his plea.
4) Mr. Tisone cooperated extensively with the government and a motion for a 5K
reduction has been filed. Mr. Tisone will be requesting that the Court reduce Mr.
Tisone’s sentence commiserate with his cooperation.
VI. CONCLUSION
Mr. Tisone respectfully request that this Court sentence Mr. Tisone to a period of 12
months home confinement along with significantly community service and other non-
prison sanctions that this Court deems appropriate.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via CM/ECF to: United States Attorney’s Office, AUSA Trenton Reichling and Probation
Officer Nick Stevens, this 20th day of February, 2023.
Respectfully submitted,
LAW OFFICES OF MARK EIGLARSH
3107 Stirling Road
Suite 207
Fort Lauderdale, Florida 33312
Telephone: (954) 500-0003
Facsimile: (305) 674-0102
Email: Mark@EiglarshLaw.com
BY: _/S/_MARK EIGLARSH______________
MARK EIGLARSH
Florida Bar No.: 956414
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Attachment 1
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658
Page 1 of 3
VCCS Credit Unofficial Transcript
Name: Tisone,Daniel Joseph
Student ID: 5227455
Birthdate:
04/02/1987
Student Address:
7514 Gresham St
Springfield, VA 22151-2911
Institution Info:
Northern Virginia Community College
4001 Wakefield Chapel Road
Annandale, VA 22003
Institution ID:
232946
Print Date:
12/29/2022
Test Credits
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
COMPASS
NV COMPASS Pre-Alg
17.00
08/25/2005
MTH
PAR1
OK for MTH 1 & 2
0.000 PT
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
COMPASS
NV COMPASS Rdg
93.00
08/25/2005
ENG
RR5 OK for ENG 111 Honors if
WR5
0.000 PT
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
COMPASS
NV COMPASS Wrtng
92.00
08/25/2005
ENG
WR4
OK for ENG 111 if RR3+
0.000 PT
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
Self ACT
Composite
19.00
08/22/2005
0.000
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
Self SAT
MSAT
480.00
08/22/2005
0.000
Posted 2005 Fall
Test
Test Component
Score
Date
VCCS Course
Description
Units
Grade
Self SAT
VSAT
500.00
08/22/2005
0.000
Credit Record
2005 Fall
Academic Plan:
Non-Degree Transfer Student Non-Curricular
Course
Description
Attempted
Earned
Grade
Points
BIO
101
General Biology I
0.000
0.000
W
0.000
ENG
111
College Compositn I
0.000
0.000
(F)
0.000
Repeated Course
HIS
121
U.S. History I
0.000
0.000
(F)
0.000
Repeated Course
ITE
115
Intro Computer Appl/Concepts
0.000
0.000
(F)
0.000
Repeated Course
SPD
110
Intro to Speech Comm
0.000
0.000
W
0.000
Attempted
Earned
GPA Units
Points
Term GPA
0.000 Term Totals
0.000
0.000
0.000
0.000
Cum GPA
0.000 Cum Totals
0.000
0.000
0.000
0.000
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 18 of 244 PageID
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Page 2 of 3
VCCS Credit Unofficial Transcript
Name: Tisone,Daniel Joseph
Student ID: 5227455
Academic Standing Effective 01/03/2006: Academic Warning
2013 Spring
Academic Plan:
AA-Liberal Arts Major
Academic Plan:
AS-Business Administration Major
Course
Description
Attempted
Earned
Grade
Points
ACC
211
Prin. of Acctg. I
3.000
3.000
A
12.000
BUS
100
Intro to Business
3.000
3.000
A
12.000
ECO
201
Princ of Macroecon
0.000
0.000
W
0.000
PED
116
Fitness And Wellness
2.000
2.000
A
8.000
Attempted
Earned
GPA Units
Points
Term GPA
4.000 Term Totals
8.000
8.000
8.000
32.000
Cum GPA
4.000 Cum Totals
8.000
8.000
8.000
32.000
Academic Standing Effective 05/16/2013: Academic Probation
Academic Standing Effective 05/16/2013: Good Standing
Academic Standing Effective 05/29/2013: Good Standing
Academic Standing Effective 10/01/2013: Good Standing
2013 Summer
Academic Plan:
AA-Liberal Arts Major
Academic Plan:
AS-Business Administration Major
Course
Description
Attempted
Earned
Grade
Points
ACC
212
Prin. of Acctg. II
3.000
3.000
A
12.000
ECO
201
Princ of Macroecon
3.000
3.000
A
12.000
ECO
202
Prin of Microecon
3.000
3.000
A
12.000
ENG
112
Coll Composition II
3.000
3.000
A
12.000
GOL
135
Field Stdies in Geol
1.000
1.000
A
4.000
Topic: BldgStons,HistQuar,OutcrpsBALT
HIS
122
U.S. History II
3.000
3.000
A
12.000
Attempted
Earned
GPA Units
Points
Term GPA
4.000 Term Totals
16.000
16.000
16.000
64.000
Cum GPA
4.000 Cum Totals
24.000
24.000
24.000
96.000
Academic Standing Effective 08/15/2013: Good Standing
2013 Fall
Academic Plan:
AA-Liberal Arts Major
Academic Plan:
AS-Business Administration Major
Course
Description
Attempted
Earned
Grade
Points
ENG
236
Intro to the Short Story
3.000
3.000
A
12.000
MTH
151
Math For Lib Arts I
0.000
0.000
W
0.000
Attempted
Earned
GPA Units
Points
Term GPA
4.000 Term Totals
3.000
3.000
3.000
12.000
Cum GPA
4.000 Cum Totals
27.000
27.000
27.000
108.000
Academic Standing Effective 01/02/2014: Good Standing
2014 Spring
Academic Plan:
AA-Liberal Arts Major
Academic Plan:
AS-Business Administration Major
Course
Description
Attempted
Earned
Grade
Points
MTH
151
Math For Lib Arts I
0.000
0.000
W
0.000
PED
100
Pilates
0.000
0.000
W
0.000
PED
111
Weight Training I
0.000
0.000
W
0.000
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 19 of 244 PageID
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Page 3 of 3
VCCS Credit Unofficial Transcript
Name: Tisone,Daniel Joseph
Student ID: 5227455
Attempted
Earned
GPA Units
Points
Term GPA
0.000 Term Totals
0.000
0.000
0.000
0.000
Cum GPA
4.000 Cum Totals
27.000
27.000
27.000
108.000
2016 Summer
Academic Plan:
AA-Liberal Arts Major
Academic Plan:
AS-Business Administration Major
Course
Description
Attempted
Earned
Grade
Points
SPA
201
Inter Spanish I
3.000
0.000
F
0.000
Attempted
Earned
GPA Units
Points
Term GPA
0.000 Term Totals
3.000
0.000
3.000
0.000
Cum GPA
3.600 Cum Totals
30.000
27.000
30.000
108.000
Academic Standing Effective 08/11/2016: Academic Warning
Milestones
Phi Theta Kappa - International Honor Society
Status:
Completed
End of VCCS Credit Unofficial Transcript
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Page 1 of 1
VCCS Non-Credit Unofficial Transcript
Name: Tisone,Daniel Joseph
Student ID: 5227455
Birthdate:
04/02/1987
Student Address:
7514 Gresham St
Springfield, VA 22151-2911
Institution Info:
Northern Virginia Community College
4001 Wakefield Chapel Road
Annandale, VA 22003
Institution ID:
232946
Print Date:
12/29/2022
End of VCCS Non-Credit Unofficial Transcript
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Attachment 2
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663
Project SAFE: Strategies Aimed at Family Empowerment
635 S Washington St
Alexandria VA 22314
www.projectsafe4u.com
To Whom It May Concern:
February 15, 2023
I am writing on behalf of Daniel Tisone. I have known Daniel since he was 16 years old. Daniel
has Attention Deficit Disorder, combined type ICD-10 F90.2 which greatly effected his ability to
do well in school. He was an athlete which helped him feel successful. However, his father
never understood the disorder and often yelled and harshly punished Daniel. Daniel’s father
was an inconsistent parent who used anger and conditional love as motivators. Daniel vowed to
be different from his father and his abusive parenting style.
Daniel started college at Hofstra playing lacrosse. This did not end well due to his inability to
focus, difficulty with organization and time management, and his impulsivity in decision
making. All of these unmanaged ADD traits created challenges that impeded his academic
success. Later on, due to life circumstances and poor decisions, Daniel developed Post
Traumatic Stress Disorder ICD-10 F43.12.
Daniel has always been an out of the box creative thinker with a heart toward people. He is
always looking to lift people up especially anyone he employs. Since Daniel did not complete his
degree, it was a priority for him to continue. When he came back to Virginia his great desire
was to finish his college education. He advocated and work hard to get himself into The Catholic
University. Furthermore, he was a guest speaker in a High School Boys Therapy Group at Project
SAFE to share his story with other troubled teens, many of whom also had ADD. Daniel did such
a great job that he continued to volunteer at Project SAFE attending the weekly therapy group
as an “older” mentor to these boys. He openly gave of himself.
Dan got into Catholic and was finally able to complete his education with a business degree.
After he graduated, he tried to find the right job. There were numerous rejections and
disappointments but this path led him to open his own business. This was where Daniel thrived.
His creative mind coupled with his fantastic managerial style opened doors. Daniel felt he was
finally making his way. Then COVID-19 hit. This devastated his business and the people who
worked for him. COVID was the unexpected disaster of our century. Many people suffered loss,
emotional distress and fear of the future. Now that things are turning a corner for the better,
Daniel’s hope is to continue to forge his path forward in order to take care of his family.
I hope this letter sheds some light on who Daniel Tisone is, a truly remarkable human being.
Warm Regard,
Gayle Alexander LPC, ACS, MA
VA # 0701004236
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Attachment 3
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November 7. 2022
Honorable Sheri Polster Chappell
Middle District of Florida
THE CATHOLIC
UNIVERSITY
OFAMERICA
Re: sentencing of Daniel Joseph Tisone, Case#: 2:22-cr-00039-SPC-NPM
Your Honor:
I am writing with regard to Daniel Joseph Tisone. Daniel was my student six years ago, in 2016,
when he was pursuing his Bachelors degree in Business Administration at The Catholic
University of America. During that time, I came to know Daniel as an intelligent and positive
person. He actually started his company RubaDub during his time as a student, and as I was his
entrepreneurship professor, I advised him early on in his endeavor. In my observation of
Daniel, he was a person of character. I was especially impressed by his concern for others. He
volunteered to help other students, agreed to get involved in our extracurricular activities as the
owner of a startup business after he graduated, and in general approached others with an
attitude of cheerful helpfulness and sincerity. While I did not have access to his overall academic
performance, I can say that he excelled in my classes and behaved himself honorably and
always looked out for others during the semester.
I learned with great joy that he has recently become a dad, but also, painfully, that he was
facing the charges that are now in front of you. While it is not my place nor competence to
speak of the situation you have to decide on, I would like to put in a good word for Daniel and
for his little son.
I always thought that Daniel would become a great dad. He exemplified the behaviors I believe
are so important in a good dad: a good character, readiness to sacrifice for others, the ability to
show vulnerability, and most importantly the readiness to commit and to love. As a professor,
I've observed over the years how often the students in my classes who struggle with their
studies and struggle with life in general also have absent fathers. Absent fatherhood is
unfortunately a vicious cycle that often repeats itself, and it's painful to watch, as I'm sure I don't
have to tell you. I would therefore like to plea for leniency on behalf of Daniel, whom I've known
to be a good person, but most especially on behalf of his son, that he get to have his father,
Daniel, present as he grows up.
Respectfully yours,
,A.~~
Andreas Widmer
Professor of Entrepreneurship
620 Michigan Ave., N.E. Washington. DC 20064
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Unofficial Transcript
Name: Daniel Tisone
Student ID: 2569043
Page 1 of 3
Birthdate:
04/02
Print Date:
12/29/2022
Send To:
Degrees Awarded
Degree:
Bachelor of Science
Confer Date:
01/31/2017
Major:
International Economics and Finance - Honors (BS)
Beginning of Undergraduate Record
Fall 2014 (08/25/2014- 12/13/2014)
Program:
School of Business & Economics
Major:
Marketing (BSBA)
Course
Description
Attempted
Earned
Grade
Points
MATH
108
Elementary Functions
3.000
3.000
B
9.000
Instructor: Anita M. Shagnea
MGT
199
SuperCurriculum & Career Dev
0.000
0.000
P
0.000
Instructor: Marykate Conroy
MGT
323
Management - Theory & Practice
3.000
3.000
A
12.000
Instructor: Robert F. Powers
MGT
345
Marketing Management
3.000
3.000
A
12.000
Instructor: John Wesley Yoest
PHIL
201
The Classical Mind
3.000
3.000
A-
11.100
Instructor: Jeffrey Dirk Wilson
Transfer Credit from Northern Virginia Community College, VA
Applied Toward School of Business Program
Course
Description
Attempted
Earned
Grade
Points
ACCT
305
Introductory Accounting
3.000
3.000
T
0.000
ACCT
306
Introductory Managerial Acctg
3.000
3.000
T
0.000
ECON
101
Principles of Macroeconomics
3.000
3.000
T
0.000
ECON
102
Principles of Microeconomics
3.000
3.000
T
0.000
ENG
101
Writing: Logic and Rhetoric
3.000
3.000
T
0.000
MGT
218
Vocation of Business
3.000
3.000
T
0.000
Course Trans GPA:
0.000
Transfer Totals:
18.000
18.000
0.000
Transfer Credit from North Country Comm College, NY
Applied Toward School of Business Program
Course
Description
Attempted
Earned
Grade
Points
ART
201
Drawing & Composition I
3.000
3.000
T
0.000
DR
205
Intro to Speech Communications
3.000
3.000
T
0.000
HIST
280
The US in the 19th Century
3.000
3.000
T
0.000
MATH
114
Probability and Statistics
3.000
3.000
T
0.000
Course Trans GPA:
0.000
Transfer Totals:
12.000
12.000
0.000
Attempted
Earned
GPA
Units
Points
Term GPA
3.675
Term Totals
12.000
12.000
12.000
44.100
Transfer Term GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined GPA
3.675
Combined Totals
42.000
42.000
12.000
44.100
Attempted
Earned
GPA
Units
Points
Cum GPA
3.675
Cum Totals
12.000
12.000
12.000
44.100
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.675
Combined Totals
42.000
42.000
12.000
44.100
Spring 2015 (01/12/2015- 05/09/2015)
Program:
School of Business & Economics
Major:
International Economics and Finance - Honors (BS)
Course
Description
Attempted
Earned
Grade
Points
CLAS
313
Roman Lit in Translation
3.000
3.000
B
9.000
Instructor: Joseph F. O'Connor
MATH
111
Calculus for Social-Life Sci I
3.000
3.000
A
12.000
Instructor: Anita M. Shagnea
MGT
299
SuperCurriculum & Career Dev
0.000
0.000
P
0.000
Instructor: Marykate Conroy
MGT
301
Ethics in Business and Econ
3.000
3.000
A-
11.100
Instructor: Andreas Widmer
PHIL
202
The Modern Mind
3.000
3.000
D
3.000
Instructor: Jeffrey Dirk Wilson
TRS
201
Faith Seeking Understanding
3.000
3.000
A
12.000
Instructor: Lawrence J King
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 26 of 244 PageID
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Unofficial Transcript
Name: Daniel Tisone
Student ID: 2569043
Page 2 of 3
Attempted
Earned
GPA
Units
Points
Term GPA
3.140
Term Totals
15.000
15.000
15.000
47.100
Transfer Term GPA
Transfer/Test/Other Totals
0.000
0.000
0.000
0.000
Combined GPA
3.140
Combined Totals
15.000
15.000
15.000
47.100
Attempted
Earned
GPA
Units
Points
Cum GPA
3.378
Cum Totals
27.000
27.000
27.000
91.200
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.378
Combined Totals
57.000
57.000
27.000
91.200
Summer 2015 (05/11/2015- 08/15/2015)
Program:
School of Business & Economics
Major:
International Economics and Finance - Honors (BS)
Course
Description
Attempted
Earned
Grade
Points
MGT
226
Financial Management
3.000
3.000
A-
11.100
Instructor: Reza Saidi
TRS
280
The Religious Quest
3.000
3.000
B
9.000
Instructor: Christopher J. Born
TRS
306
War and Violence in the OT
3.000
3.000
B-
8.100
Instructor: David A Bosworth
Attempted
Earned
GPA
Units
Points
Term GPA
3.133
Term Totals
9.000
9.000
9.000
28.200
Transfer Term GPA
Transfer/Test/Other Totals
0.000
0.000
0.000
0.000
Combined GPA
3.133
Combined Totals
9.000
9.000
9.000
28.200
Attempted
Earned
GPA
Units
Points
Cum GPA
3.317
Cum Totals
36.000
36.000
36.000
119.400
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.317
Combined Totals
66.000
66.000
36.000
119.400
Fall 2015 (08/31/2015- 12/19/2015)
Program:
School of Business & Economics
Major:
International Economics and Finance - Honors (BS)
Course
Description
Attempted
Earned
Grade
Points
ECON
241
Intermed Macroeconomic Theory
3.000
3.000
C
6.000
Instructor: Michael Barker
ECON
242
Intermed Micro Theory
3.000
3.000
C+
6.900
Instructor: Ernest M. Zampelli
ECON
363
Principles of Econometrics
3.000
3.000
A-
11.100
Instructor: Ava Gail Cas
FIN
332
Investment Analysis
3.000
3.000
A
12.000
Instructor: Jamshed Yunas Uppal
FIN
389
International Corp Finance
3.000
3.000
A-
11.100
Instructor: Luanne Zurlo
MATH
112
Calculus for Social-Life Sc II
3.000
3.000
C+
6.900
Instructor: Jonathan A. Huang
Attempted
Earned
GPA
Units
Points
Term GPA
3.000
Term Totals
18.000
18.000
18.000
54.000
Transfer Term GPA
Transfer/Test/Other Totals
0.000
0.000
0.000
0.000
Combined GPA
3.000
Combined Totals
18.000
18.000
18.000
54.000
Attempted
Earned
GPA
Units
Points
Cum GPA
3.211
Cum Totals
54.000
54.000
54.000
173.400
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.211
Combined Totals
84.000
84.000
54.000
173.400
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 27 of 244 PageID
668
Unofficial Transcript
Name: Daniel Tisone
Student ID: 2569043
Page 3 of 3
Spring 2016 (01/11/2016- 05/07/2016)
Program:
School of Business & Economics
Major:
International Economics and Finance - Honors (BS)
Course
Description
Attempted
Earned
Grade
Points
ECON
243
Intermed Macroecon II
3.000
3.000
B-
8.100
Instructor: Michael Barker
ECON
244
Inter Microeconomic
3.000
3.000
B-
8.100
Instructor: Kevin F. Forbes
ECON
481
International Finance
3.000
3.000
B+
9.900
Instructor: Martha C. Cruz-Zuniga
FIN
336
Corporate Finance II
3.000
3.000
A-
11.100
Instructor: Reza Saidi
FIN
342
Fincl Markets & Institutions
3.000
3.000
A
12.000
Instructor: Jamshed Yunas Uppal
FIN
498
Undergraduate Comps
0.000
0.000
P
0.000
PHIL
311
Contemporary Moral Issues
3.000
3.000
B
9.000
Instructor: Angela McKay Knobel
Attempted
Earned
GPA
Units
Points
Term GPA
3.233
Term Totals
18.000
18.000
18.000
58.200
Transfer Term GPA
Transfer/Test/Other Totals
0.000
0.000
0.000
0.000
Combined GPA
3.233
Combined Totals
18.000
18.000
18.000
58.200
Attempted
Earned
GPA
Units
Points
Cum GPA
3.217
Cum Totals
72.000
72.000
72.000
231.600
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.217
Combined Totals
102.000
102.000
72.000
231.600
Fall 2016 (08/29/2016- 12/17/2016)
Program:
School of Business & Economics
Major:
International Economics and Finance - Honors (BS)
Course
Description
Attempted
Earned
Grade
Points
HIST
222
Mod Euro History, 1789-Present
3.000
3.000
B+
9.900
Instructor: Arpad Stephan Attila Von Klimo
HIST
235
Medieval World
3.000
3.000
C
6.000
Instructor: Katherine L. Jansen
MKT
349
Personal Selling
3.000
0.000
F
0.000
Instructor: Patrick F. Mcglynn
MKT
350
Digital Marketing
3.000
0.000
W
0.000
Instructor: Timothy J. McGovern
Instructor: Gabriella G Herrera
Attempted
Earned
GPA
Units
Points
Term GPA
1.767
Term Totals
12.000
6.000
9.000
15.900
Transfer Term GPA
Transfer/Test/Other Totals
0.000
0.000
0.000
0.000
Combined GPA
1.767
Combined Totals
12.000
6.000
9.000
15.900
Attempted
Earned
GPA
Units
Points
Cum GPA
3.056
Cum Totals
84.000
78.000
81.000
247.500
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.056
Combined Totals
114.000
108.000
81.000
247.500
_______________________________________________________________________________________________________
Undergraduate Career Totals
Cum GPA:
3.056
Cum Totals
84.000
78.000
81.000
247.500
Transfer Cum GPA
Transfer/Test/Other Totals
30.000
30.000
0.000
0.000
Combined Cum GPA
3.056
Combined Totals
114.000
108.000
81.000
247.500
End of Unofficial Transcript
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Attachment 4
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670
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Loc
Address
PM Name
Position
Company
Phone
Email
Office Address
28 5454 Wisconsin Ave.
Danielle Lowther
Property Manager
Carr Properties
301-656-5653
dlowther@carrprop.com
1255 23rd Street NW, Suite 100, Washington DC 20037
38 A & 3rd, NE
Security Officer
Security
Supreme Court
202-479-3341
39-A 3325 Toledo Road
Sandy Camp-Riegel
Property Manager
The Bernstein Company
202-546-2080
scampriegel@tbco.biz
39-B 6509 Belcrest Road
Wendy Emanuel
Property Manager
Berman
301-775-0396
wemanuel@bermanenterprises.com
39-3 6252 Belcrest Road
Paul F. Urciolo
Property Manager
The Bernstein Company
202-203-8147
pfu@utcmail.net
6527 Belcrest Road Hyattsville, MD 20782
40 5640 Nicholson Lane
Tyler Luckett/Jack Galvan
Property Managers
The JBG Companies
240-333-3880
tluckett@jbg.com/jgalvan@jbg.com
Chase Tower 4445 Willard Ave, Suite 100, Chevy Chase, MD 20815
45 1901 N. Fort Myer
Rickey Willaims
Property Manager
The JBG Companies
703-527-7400
riwilliams@jbg.com
1911N. Ft. Myer Drive, Suite 122, Arlington, VA 22209
47 615 Slaters Lane
Andrew Kunisch
Property Manager
ELV Associates
202-595-3580
akunisch@elvassoc.com
1776 Massachusetts Avenue, NW, Suite 410, Washington, DC 20036
53 5635 Fishers Lane
Kerri Gates
Property Manager
The JBG Companies
301-468-0200
kgates@jbg.com
5635 Fishers Lane, Suite 200, Rockville, MD 20852
56 1201 M St.
April Finotti
Property Manager
COPT
202-548-3840
April.Finotti@COPT.com
1201 M Street, SE, Suite 60, Washington, DC 20003
62 1900 M St.
Selene Argueta
Associate Vice President
Rockrose Development Dorp.
202.803.5664
selene.argueta@rockrose.com
1140 19th St, NW, Suite 650, Washington, DC 20036
64 1133 East West Hwy
Andrew Dytyniak
Property Manager
Equity Residential
301-495-9595
adytyniak@erq.com
1133 East West Highway, Silver Spring, MD 20190
65 1300 Spring St.
Lisa Mahoney
Property Manager
The Bernstein Company
202-478-7529
lmahoney@tbco.biz
6525 Belcrest Road Hyattsville, MD 20782
70 3300 Whitehaven
Diane Smith
Property Manager
202-687-4732
nocksmid@gerogetwon.edu
3299 K Street, NW, Ste. 700, Washington, DC 20007
72 975 F St.
Shannon Nieman
Property Manager
Akridge
202-624-8652
snieman@akridge.com
601 Thirteen Street, NW, Suite 300, Washington, DC 20005
73 1500 Wilson Blvd
Jillian Donatelli
Property Manager
Penzance
202-286-5410
jdonatelli@pzre.com
1555 Wilson Blvd, Arlington, VA 22209
74 2000 N. 14th St.
Jillian Donatelli
Property Manager
Penzance
202-286-5410
jdonatelli@pzre.com
1555 Wilson Blvd, Arlington, VA 22209
75 3865 Wilson Blvd
Clarence Claybourne
Property Manager
Cushman & Wakefield
240-401-9291
clarence.claybourne@cushwake.com
810 First St, NE Washington DC 20002
76 4200 Wisconsin Ave.
Carley Kam
Property Manager
BMS Realty
202-204-4938
ckam@bmsres.com
4201 Connecticut Ave, NW Suite 407 Washington, DC 20008
78 Wisc & Mass Ave.
Katherine T. Nassor
Governance Officer
Washington Nat'l Cathedral
202-537-6283
knassor@cathedral.org
3101 Wisconsin Avenue NW, Washington DC 20016
79 1200 New Jersey Ave.
Lesley Morrison
Sr. Property Manager
The JBG Companies
202-863-4460
lmorrison@jbg.com
4445 Willard Avenue, Suite 400, Chevy Chase, MD 20815
81 505 9th St.
Mike Mahesh
Property Manager
Cushman & Wakefield
703-845-1057
mike.mahesh@cushwake.com
2900 South Quincy Street, Suite 450 Arlington VA 22206
82 5515 Security Ln.
Chirag Shah
Property Manager
Hines
240-483-5230
chirag.shah@hines.com
11400 Rockville Pike, Suite C10, Rockville, MD 20852
84 901 F St.
Dawn Thompson
Property Manager
Corner Stone
202-955-6009
dawn.thompson@tfcornerstone.com
1620 Eye Street, NW, Suite 520, Washington, DC 20005
87 1620 S. Capitol St.
Norman Jemal
Owner
Douglas Development
202-638-6300
Njemal@douglasdev.com
702 H Street, NW, Suite 400, Washington, DC 20005
88 8075 Leesburg Pike
Jennifer Wrenn
Sr Property Manager
Vornado/ Charles E. Smith
703-821-2050
jwrenn@vno.com
8075 Leesburg Pike, LL Suite 70 Vienna VA 22182
94 1990 K St.
Sandy Camp-Riegel
Property Manager
The Bernstein Company
202-478-7553
scampriegel@tbco.biz
6525 Belcrest Road Hyattsville, MD 20782
95 1399 New York Avenue
Carrie Alano
Property Manager
Vornado
202-887-6035
calano@vno.com
96 409 3rd St.
Mark Smith
Sr. Property Manager
Lincoln Properties Co
202-646-0325
mark.smith@lpc.com
300 D Street, SW, Ste. C-21, Washington, DC 20024
97 1150 Higgins Place
Zabrina Watkins
Sr. Property Manager
The JBG Companies
301-770-4440
zwatkins@jbg.com
102 1200 East West Hwy
Morgan Faulkner
Community Director
UDR
301-588-4971
mfaulkner@udr.com
1201 East West Highway, Silver Spring, MD 20910
104 1 Paseo Drive
Jessica Hendrix
General Manager
Bozzuto Management
301-907-3817
jhendrix@bozzuto.com
4445 Willard Avenue, Suite 400, Chevy Chase, MD 20815
105 12370 Parklawn Drive
Peggy White
Property Manager
The JBG Companies
301-468-0650
pwhite@jbg.com
4445 Willard Avenue, Suite 400, Chevy Chase, MD 20815
106 7900 Wisconsin Avenue
Tyler Luckett/Jack Galvan
Property Managers
The JBG Companies
240-333-3880
tluckett@jbg.com/jgalvan@jbg.com
Chase Tower 4445 Willard Ave, Suite 100, Chevy Chase, MD 20815
108 2301 Constitution Ave.
Roxie Johnson
Property Manager
US Institute for Peace
202-457-1700
rjohnson@USIP.org
2301 Constitution Avenue, NW, Washington, DC 20037
120 1555 Wilson Blvd.
Nick Shay
Assistant Property Manager
Penzance
202-386-5121
nshay@pzre.com
1555 Wilson Blvd, Arlington, VA 22209
121 6555 Rock Spring Drive
Glen Graubart
Property Manager
Lincoln Properties Co
ggraubart@lpc.com
122 2020 K St.
Natasha Evstigneeva
Property Manager
JLL
Natasha.Evstigneeva@am.jll.com
123 1152 15th St.
Jarett Haring
Property Manager
Carr Properties
202-223-9737
jharing@carrprop.com
1152 15th St, NW Washington DC 20005
124 One Preserve Parkway
Shelley James
Associate Vice President
Cushman & Wakefield
703-618-8196
shelley.james@cushwake.com
13200 Woodland Park Road Herndon, VA 20171
127 3901 N. Fairfax Drive
Christopher J. Lukawski
Partner-Development
Crimson Partners
703-547-6829
cjl@crimsonpartners.net
455 Sprinkpark Pl, Ste 100 Herdon, VA 20170
128 3201 New Mexico Avenue
Carley Kam
Property Manager
BMS Realty Services, LLC
202-204-4938
ckam@bmsres.com
4201 Connecticut Ave, NW Suite 407 Washington, DC 20008
129 6010 Executive Blvd.
Kathleen A. McCallum
Controller
Ronald D Paul Co., Inc
301-951-7222
kmccallum@ronaldpaulcos.com
4416 East West Hwy., Ste. 300, Bethesda, MD 20814
131 1011 North Capitol Street, NE
Pamela Charles
Property Manager
National Facilities Services
301-680-4126
Pamela.R.Charles@kp.org
11921 Bournefield Way, Suite A, Silver Spring, MD 20904
132 7830 Old Georgetown Road
Kathleen A. McCallum
Controller
Ronald D Paul Co., Inc
301-951-7222
kmccallum@ronaldpaulcos.com
4416 East West Hwy., Ste. 300, Bethesda, MD 20814
134 1820 N. Ft. Myer Drive
Bill Lillis
Property Manager
Virginia Management Inc.
703-358-0022 ext 25
bill.lillis@virginiamanagement.com
4600 N. Fairfax Drive, Ste. 1002, Arlington, VA 22203
135 601 13th St., NW
Kaitlin Brokaw
Property Manager
Akridge
202-756-3087
kbrokaw@akridge.com
601 Thirteenth Street, NW, Suite 300 North, Washington, DC 20005
136 1776 Massachusetts Ave, NW
Andrew Kunisch
Property Manager
ELV Associates
202-595-3580
akunisch@elvassoc.com
1776 Massachusetts Avenue, NW, Suite 410, Washington, DC 20036
137 3636 16th Street, NW
Joe Milby
Property Manager
Woodner Limited Partnership
202-328-2800
jmilby@woodner.com
3636 16th Street, NW, Washington, DC 20010
139 641 S St, NW
Tim Roberts
Property Manager
Douglas Development
202-638-6300
timroberts@douglasdev.com
702 H Street, NW, Suite 400, Washington, DC 20005
140 901 E St, NW
Marjorie Atya
Property Manager
The Pew Charitable Trusts
202.540.6659
MAtya-Temp@pewtrusts.org
901 E Street, NW | LL10 | Washington DC, 20004
141 99 H Street, NW
Ryan Pettigrew
Walmart Manager
Walmart
202-697-1421
ryan.pettigrew@walmart.com
99 H St, NW Washington, DC, 20001
142 950 North Glebe Road
Brandy Prudencio
Assistant Property Manager
The JBG Companies
703-243-2783
bprudencio@jbg.com
950 N. Glebe Road, suite 110, Arlington, VA 22203
143 1155 F Street, NW
Keith MacWhorlor
Property Manager
Tishman Speyer
703-548-9388
kmacwhor@tishmanspyer.com
144 1501 K Street, NW
Jason Green
Property Manager
Vornado/ Charles E. Smith
jgreen@vno.com
147 1831/1861 Whiele Ave
Stefanie Brescia
Property Manager
The JBG Companies
sbrescia@jbg.com
148 1200 17th St, NW
Conor Jeffers
VP Property Manager
Akridge
202-624-8634
cjeffers@akridge.com
1200 17th St, NW Washington DC
149 1050 17th St, NW
Mona Liza Agravante
Property Manager
Lenkin Company
301-654-2100
magravante@lenkin.com
2201 Wisconsin Avenue Northwest, Washington, DC 20007
151 4040 North Fairfax Drive
Jillian Donatelli
Property Manager
Penzance
202-286-5410
jdonatelli@pzre.com
1555 Wilson Blvd, Arlington, VA 22209
152 1701 N. George Mason Drive
Charles Fletcher
Associate VP
Virginia Hospital Center
703-558-6030
cfletcher@virginiahospitalcenter.com
1701 N. George Mason Drive, Arlington, VA 22205
153 275 N Washington St
Elizabeth Young
Property Manager
The JBG Companies
301-545-5102
eyoung@jbg.com
7613 Medical Center Drive, Rockville MD 20850
155 900 16th St, NW
Heena Feeney
Sr. Property Manager
The JBG Companies
202-775-9697
hfeeney@jbg.com
1233 20th St, NW, Suite 505, Washington, DC 20036
156 1800 Rockville Pike
Donna Ben-Moshe
Property Manager
The JBG Companies
240-333-3220
dbenmoshe@jbg.com
4445 Willard Avenue, Suite 400, Chevy Chase, MD 20815
158 6401 American Blvd
Maura Bulger
Property Manager
Echo Realty
240-497-0526
MBulger@echorealty.com
701 Alpha Drive, Pittsburgh PA 15238
160 1323 S. Capitol St., SW
Stanley Marks
RDP Management
301-229-9724
smarks@ronaldpaulcos.com
161 1812 N Moore St
John Torres
Director of Operations
Monday Properties
703-247-0764
jtorres@mdistrictpark.com
1000 Wilson Blvd, Suite 700, Arlington VA 22209
162 1200 Wilson Blvd
John Toress
Director of Operations
Monday Properties
703-247-0764
jtorres@mdistrictpark.com
1001 Wilson Blvd, Suite 700, Arlington VA 22209
163 1101 K St, NW
Lisa Pannell
Sr. Propert Manager
Lincoln Properties Co
202-589-0214 ext 16
lpannell@lpc.com
1030 15th St., NW Suite 250 West Washington DC 20005
165 1525 Church St, NW
Paul Edenbaum
Director - Parking Ops
VNO
703-769-1144
pedenbaum@vno.com
166 5028 Wisconsin Ave, NW
Vincent Sgueo
Sr. Property Manager
BMC Properties
202-537-0787
VSgueo@bmcproperties.com
3301 New Mexico Ave., NW Suite 115 Washington DC 20016
167 6862 Elm Street
Brandy Prudencio
Assistant Property Manager
The JBG Companies
703-243-2783
bprudencio@jbg.com
950 N. Glebe Road, suite 110, Arlington, VA 22203
168 1690 Old Meadow St
Sonia Zamora
Senior Property Manager
Akridge
202-207-3928
szamora@akridge.com
601 Thirteenth Street, NW, Suite 300 North, Washington, DC 20005
169 600 H St, NE
Claire Feely
General Manager
Bozzuto Management
202-684-7664
cfeeley@bozzuto.com
510 H St, ,NE Washington DC 20002
170 1800 N. Lynn St
171 2000/2002 Edmund Halley Dr
172 414/416 Hungerford Drive
Syed Ali
Property Manager
The JBG Companies
301-545-5102
sali@jbg.com
9613 Medical Center Drive, Suite A, Rockville, MD 20850
173 950 24th St, NW
Wendy Wright
Property Manager
Varsity on K
888-500-9512
wendy@varsityonk.com
950 24th St NW, Washingotn DC 20032
174 1550 7th St, NW
Tiffany Patterson
Property Manager
Jag Management
202-462-1550
tpatterson@jagmgt.com
1550 7th Street NW Washington, D.C 20001
Atlantic Parking Locations
(Property Managers)
1
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Attachment 5
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 49 of 244 PageID
690
From:
"Edward Strittmatter" <Edward.Strittmatter@bdnreit.com>
To:
"Reichling, Trenton (USAFLM)" <Trenton.Reichling@usdoj.gov>
"Michael McCalley" <Michael.McCalley@bdnreit.com>
"Bruno, Grace Marie \(TP\) \(FBI\)" <GMBRUNO@FBI.GOV>
Date:
4/13/2022 3:30:14 PM
Subject:
[EXTERNAL EMAIL] - RE: Brandy Wine Lease
Good afternoon Trent – per our discussion yesterday, attached are photos of Rub A Dub’s storage cabinet, signage, commercial
vacuum, and tracking information from the vacuum’s packaging.
Please let me know if there is anything additional you need.
Thank you,
EJ Strittmatter
From: Reichling, Trenton (USAFLM) <Trenton.Reichling@usdoj.gov>
Sent: Tuesday, April 12, 2022 12:55 PM
To: Edward Strittmatter <Edward.Strittmatter@bdnreit.com>; Michael McCalley <Michael.McCalley@bdnreit.com>; Bruno, Grace
Marie (TP) (FBI) <GMBRUNO@FBI.GOV>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov>
Subject: RE: Brandy Wine Lease
Feel free to call me now. My number is 239-461-2221. Thanks!
From: Edward Strittmatter <Edward.Strittmatter@bdnreit.com
>
Sent: Tuesday, April 12, 2022 12:52 PM
To: Reichling, Trenton (USAFLM) <TReichling@usa.doj.gov
>; Michael McCalley <Michael.McCalley@bdnreit.com
>; Bruno, Grace
Marie (TP) (FBI) <GMBRUNO@FBI.GOV >
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>
Subject: [EXTERNAL] RE: Brandy Wine Lease
Good afternoon Trent – my afternoon is wide open, let me know what time is best for you and I can give you a call.
Thanks,
EJ
From: Reichling, Trenton (USAFLM) <Trenton.Reichling@usdoj.gov
>
Sent: Tuesday, April 12, 2022 12:50 PM
To: Michael McCalley <Michael.McCalley@bdnreit.com
>; Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>; Edward Strittmatter <Edward.Strittmatter@bdnreit.com
>
Subject: RE: Brandy Wine Lease
Thank you Michael.
E.J., let me know if you are available later today for a phone call.
Thanks,
Trent
From: Michael McCalley <Michael.McCalley@bdnreit.com
>
Sent: Tuesday, April 12, 2022 12:48 PM
To: Reichling, Trenton (USAFLM) <TReichling@usa.doj.gov
>; Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>; Edward Strittmatter <Edward.Strittmatter@bdnreit.com
>
Subject: [EXTERNAL] RE: Brandy Wine Lease
Trent:
E.J. will reach out to you directly.
Please let me know if you have any questions.
Regards,
Michael
Michael McCalley
Associate General Counsel
t 610.832.5645
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m 856.371.4698
e michael.mccalley@bdnreit.com
BRANDYWINE REALTY TRUST
Cira Centre | 2929 Arch Street | Suite 1800 | Philadelphia, PA 19104
NYSE:BDN | www.brandywinerealty.com
From: Reichling, Trenton (USAFLM) <Trenton.Reichling@usdoj.gov
>
Sent: Friday, April 8, 2022 3:24 PM
To: Michael McCalley <Michael.McCalley@bdnreit.com
>; Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>
Subject: RE: Brandy Wine Lease
Good Afternoon Michael,
I had a follow up request. We received information that the target of our investigation, Daniel Tisone, met with Edward
Strittmatter (Brandywine employee) on or about February 26-27, 2021 at your 1676 International Drive office. The purpose of the
meeting was to discuss a “universal EV initiative,” per Tisone. Rather than contact Mr. Strittmatter directly, I figured it would be
best to contact you to reach out to Mr. Strittmatter to confirm if this meeting actually happened. If so, could we schedule a call to
speak with Mr. Strittmatter next week to discuss the substance of the meeting. If you have any questions, my direct line is 239-
461-2221 and my cell is 305-546-9246.
Thanks and have a great weekend,
Trent Reichling
Assistant United States Attorney
United States Attorney’s Office
Middle District of Florida – Fort Myers Division
Office Phone: (239) 461-2200
Fax: (239) 461-2219
E-mail: Trenton.Reichling@USDOJ.gov
From: Michael McCalley <Michael.McCalley@bdnreit.com
>
Sent: Tuesday, March 29, 2022 4:21 PM
To: Reichling, Trenton (USAFLM) <TReichling@usa.doj.gov
>; Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>
Subject: [EXTERNAL] RE: Brandy Wine Lease
Mr. Reichling:
Please see below and let me know if you have any questions.
First, the lease term is from June 1, 2015 to June 1, 2021. Is it common for Brandywine to execute a 6 year lease with a commercial
tenant?
Multi-year leases are common. However, we have our own form of lease. The attached is not our standard form. It would be
highly unusual for us to use a form that was not our own.
Moreover, I could not find any record of our leasing team negotiating a lease with Rub a Dub in our leasing files.
Second, the lease is purported to have been signed by Sean Byars on June 1, 2015. Can you confirm that Sean Byars was not
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692
employed by Brandywine on June 1, 2015 and provide the date of his resignation/termination?
Sean Byers left Brandywine on 7/18/2014, according to our HR department.
Also, can you confirm that Sean Byars title while working at Brandywine was Regional Property Manager and not Director?
Correct, he was Regional Property Manager.
I have also attached the list of properties that was included as an attachment to the lease. I have reviewed the Facility Use
Agreements that you emailed us. Are there any other Facility Use Agreements out there for these other properties included on
the attached list that were executed with Rub a Dub?
Please see attached. Per our current Senior Property Manager, we also had similar agreements to operate at 1900
Gallows, 3130 and 3141 Fairview, but we no longer own those properties. Rub a Dub provided an amenity service to tenant
sin our offices, but they have not been active at any properties since COVID-19. In October 2021, Rub a Dub provided our
Senior Property Manager a proposal to expand their footprint, but we did not come to an agreement.
Regards,
Michael McCalley
Associate General Counsel
t 610.832.5645
m 856.371.4698
e michael.mccalley@bdnreit.com
BRANDYWINE REALTY TRUST
Cira Centre | 2929 Arch Street | Suite 1800 | Philadelphia, PA 19104
NYSE:BDN | www.brandywinerealty.com
From: Reichling, Trenton (USAFLM) <Trenton.Reichling@usdoj.gov
>
Sent: Sunday, March 27, 2022 3:44 PM
To: Michael McCalley <Michael.McCalley@bdnreit.com
>; Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>
Subject: RE: Brandy Wine Lease
Good Afternoon Michael:
Thank you for getting back to us so quickly. I had a few quick follow up questions. I will attach the lease that Grace previously
emailed as reference, since my questions will pertain to a few things in the lease. These questions are geared towards
establishing the fictitious nature of the lease. First, the lease term is from June 1, 2015 to June 1, 2021. Is it common for
Brandywine to execute a 6 year lease with a commercial tenant? Second, the lease is purported to have been signed by Sean
Byars on June 1, 2015. Can you confirm that Sean Byars was not employed by Brandywine on June 1, 2015 and provide the date of
his resignation/termination? Also, can you confirm that Sean Byars title while working at Brandywine was Regional Property
Manager and not Director?
I have also attached the list of properties that was included as an attachment to the lease. I have reviewed the Facility Use
Agreements that you emailed us. Are there any other Facility Use Agreements out there for these other properties included on
the attached list that were executed with Rub a Dub?
Thanks again for all your help on this,
Trent Reichling
Assistant United States Attorney
United States Attorney’s Office
Middle District of Florida – Fort Myers Division
Office Phone: (239) 461-2200
Fax: (239) 461-2219
E-mail: Trenton.Reichling@USDOJ.gov
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From: Michael McCalley <Michael.McCalley@bdnreit.com
>
Sent: Tuesday, March 22, 2022 1:20 PM
To: Bruno, Grace Marie (TP) (FBI) <GMBRUNO@FBI.GOV
>
Cc: Reichling, Trenton (USAFLM) <TReichling@usa.doj.gov
>; Heister, Megan Katherine (TP) (FBI) <mkheister@fbi.gov
>
Subject: [EXTERNAL] RE: Brandy Wine Lease
Special Agent Bruno:
The Space Lease/Use Agreement does not look like our form and I could find no record of it in our system.
The Facility Use Agreements, however, do look like our old form. It seems we may have contemplated using Rub a Dub Eco Wash
at the parking facilities at a few of our offices. This would have been viewed as an amenity service for our office tenants (i.e.,
they could get their car washed and detailed while it was parked). According to our current Property Manager, Rub a Dub provided
the service pre-COVID at our Tysons office locations - 1676 International, 8260 Greensboro, & 8521 Leesburg Pike. Our property
manager was able to locate two such agreements. See attached.
Sean Byars was a former Brandywine employee that oversaw those properties, but he is no longer with Brandywine.
I did find one invoice from Rub a Dub and a copy of the payment. But this appears to relate to car washing they performed for us.
I have asked our IT Department to run a search of our archives and will let you know if anything else pops up.
Michael McCalley
Associate General Counsel
t 610.832.5645
m 856.371.4698
e michael.mccalley@bdnreit.com
BRANDYWINE REALTY TRUST
Cira Centre | 2929 Arch Street | Suite 1800 | Philadelphia, PA 19104
NYSE:BDN | www.brandywinerealty.com
From: Grace Bruno <GMBRUNO@FBI.GOV
>
Sent: Tuesday, March 22, 2022 10:32 AM
To: Michael McCalley <Michael.McCalley@bdnreit.com
>
Cc: Trenton.Reichling@usdoj.gov
; Megan Heister <mkheister@fbi.gov
>
Subject: Brandy Wine Lease
Sir,
As discussed, please advise as to the extent of Mr. Tisone’s relations with Brandywine. Attached is the lease which appears to
be signed by a former regional director, Sean Byers.
Thanks in advance.
V/R,
Grace Bruno
Special Agent
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Attachment 6
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 56 of 244 PageID
697
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 57 of 244 PageID
698
Attachment 7
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 58 of 244 PageID
699
THE TOWER BUILDING
1101 Wootton Parkway
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“Tower-Dawson, LLC, Tower Construction Group, LLC, Tower MD Holdings, LLC,
Tower Property Holdings, LLC, Tower Real Estate Group, LLC, the Landlord, Its
Owners, Partners, Managers, Employees, Agents, Subsidiaries, Affiliates, Property
Managers, Lenders, Members, Officers and Directors are additional insureds. Insurer
shall agree to a Waiver of all rights of Subrogation. This will cover any and all ongoing
work, as well as completed operations at 1101 Wootton Parkway, Rockville, MD
20852.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 59 of 244 PageID
700
2000 Tower Oaks Boulevard
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“2000 Tower Oaks Boulevard, LLC, Tower-Dawson, LLC, Tower Construction Group,
LLC, Tower Oaks Phase II Holdings, LLC, Tower MD Holdings, LLC, Tower Property
Holdings, LLC, Tower Real Estate Group, LLC, the Landlord, Its Owners, Partners,
Managers, Employees, Agents, Subsidiaries, Affiliates, Property Managers, Lenders,
Members, Officers and Directors are additional insureds. Insurer shall agree to a
Waiver of all rights of Subrogation. This will cover any and all ongoing work, as well as
completed operations at 2000 Tower Oaks Boulevard, Rockville, MD 20852.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 60 of 244 PageID
701
1707 L Street, NW
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
The Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“L Street, LLC, Tower Construction Group, LLC, Tower D. C. Holdings, LLC, Tower
Holdings, LLC, Tower Property Holdings, LLC, Tower Real Estate Group, LLC, the
Landlord, Its Owners, Partners, Managers, Employees, Agents, Subsidiaries, Affiliates,
Property Managers, Lenders, Members, Officers and Directors are additional insureds.
Insurer shall agree to a Waiver of all rights of Subrogation. This will cover any and all
ongoing work, as well as completed operations at 1707 L Street, NW, Washington, DC
20036.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 61 of 244 PageID
702
1828 L Street, NW
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
The Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“1828 L Street Associates, LLC, Tower Construction Group, LLC, Tower D. C. Holdings,
LLC, Tower Holdings, LLC, Tower Property Holdings, LLC, Tower Real Estate Group,
LLC, the Landlord, Its Owners, Partners, Managers, Employees, Agents, Subsidiaries,
Affiliates, Property Managers, Lenders, Members, Officers and Directors are additional
insureds. Insurer shall agree to a Waiver of all rights of Subrogation. This will cover
any and all ongoing work, as well as completed operations at 1828 L Street, NW,
Washington, DC 20036.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 62 of 244 PageID
703
Millennium Building
1909 K Street, NW
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
The Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“Nina Jo Associates, LLC, Tower Construction Group, LLC, Tower D. C. Holdings, LLC,
Tower Holdings, LLC, Tower Property Holdings, LLC, Tower Real Estate Group, LLC,
the Landlord, Its Owners, Partners, Managers, Employees, Agents, Subsidiaries,
Affiliates, Property Managers, Lenders, Members, Officers and Directors are additional
insureds. Insurer shall agree to a Waiver of all rights of Subrogation. This will cover
any and all ongoing work, as well as completed operations at 1909 K Street, NW,
Washington, DC 20006
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 63 of 244 PageID
704
Aspen Hill Shopping Center
13501 – 13781 Connecticut Avenue
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“Aspen Hill Venture, Tower Construction Group, LLC, Abramson-Reich, LLLP, Tower
MD Holdings, LLC, Tower Property Holdings, LLC, Tower Real Estate Group, LLC, the
Landlord, Its Owners, Partners, Managers, Employees, Agents, Subsidiaries, Affiliates,
Property Managers, Lenders, Members, Officers and Directors are additional insureds.
Insurer shall agree to a Waiver of all rights of Subrogation. This will cover any and all
ongoing work, as well as completed operations at the Aspen Hill Shopping Center,
13501-13781 Connecticut Avenue, Wheaton, MD 20906.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 64 of 244 PageID
705
All Blairs
The Blairs (Blair Towers, Blair House, Blair Plaza, Blair East,
Blair Towns, The Pearl, Blair Shopping Center, Blair Stores
and Blair Office Building)
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“Blair Towers, LLC, Blair House Holdings, LLC, Blair East Holdings, LLC, Blair Plaza
Holdings, LLC, Blair Pearl Holdings, LLC, Blair Stores, LLC, Blair Shopping Center,
LLC, Blair Office Building, LLC, Tower Construction Group, LLC, Tower MD Holdings,
LLC, Tower Property Holdings, LLC, Tower Real Estate Group, LLC, the Landlord, Its
Owners, Partners, Managers, Employees, Agents, Subsidiaries, Affiliates, Property
Managers, Lenders, Members, Officers and Directors are additional insureds. Insurer
shall agree to a Waiver of all rights of Subrogation. This will cover any and all ongoing
work, as well as completed operations at Blair Towers, LLC, The Pearl – 180 High Park
Lane, Blair Towers – 8101-8107 Eastern Avenue, Blair House – 8201 16th Street, Blair
Plaza – 1401 Blair Mill Road, Blair East – 1220 East West Highway, Blair Towns –
8300, 8310, 8320 Colesville Road, Blair House/Park Garage – 8316 Colesville Road,
Blair Shopping Center and Blair Stores - 1280-1316 East West Highway, Blair Office
Building - 8380 Colesville Road, Silver Spring, MD 20910.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 65 of 244 PageID
706
2250 Tower Oaks Boulevard, LLC
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“2250 Tower Oaks Boulevard, LLC, Tower Oaks Phase 2 Holdings, LLC, Tower-
Dawson, LLC, Tower Construction Group, LLC, Tower MD Holdings, LLC, Tower Real
Estate Group, LLC, the Landlord, Its Owners, Partners, Managers, Employees, Agents,
Subsidiaries, Affiliates, Property Managers, Lenders, Members, Officers and Directors
are additional insureds. Insurer shall agree to a Waiver of all rights of Subrogation.
This will cover any and all ongoing work, as well as completed operations at 2250
Tower Oaks Boulevard, Rockville, MD 20852.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 66 of 244 PageID
707
Tower Oaks Property Owners Association
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“Tower Oaks Phase 2 Holdings, LLC, Tower-Dawson, LLC, Tower Oaks Property
Owners Association, Inc., Tower Construction Group, LLC, Tower MD Holdings, LLC,
Tower Property Holdings, LLC, Tower Real Estate Group, LLC, the Landlord, Its
Owners, Partners, Managers, Employees, Agents, Subsidiaries, Affiliates, Property
Managers, Lenders, Members, Officers and Directors are additional insureds. Insurer
shall agree to a Waiver of all rights of Subrogation. This will cover any and all ongoing
work, as well as completed operations at Preserve Parkway, Tower Oaks Boulevard,
Wootton Parkway from Preserve Parkway to Tower Oaks Boulevard, Rockville, MD
20852.”
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 67 of 244 PageID
708
Verizon Building
1133 19th Street, NW
Requirements for Certificates of Insurance
The following should be listed as the Certificate Holder:
The Tower Companies
2000 Tower Oaks Boulevard
9th Floor
Rockville, MD 20852
Please list the following under “Description of Operations /Locations/Vehicles”:
“1137 19th Street Associates, LLC, Tower Construction Group, LLC, Tower D. C.
Holdings, LLC, Tower Holdings, LLC, Tower Property Holdings, LLC, Tower Real Estate
Group, LLC, the Landlord, Its Owners, Partners, Lenders, Members, Officers and
Directors are additional insureds. Insurer shall agree to a Waiver of all rights of
Subrogation. This will cover any and all ongoing work, as well as completed operations
at 1133-1137 19th, NW, Washington, DC 20036
Please mail Original Certificate, Endorsements, Renewals and Cancellation
Endorsements to:
The Tower Companies
Attention: Property Management
2000 Tower Oak Boulevard
9th Floor
Rockville, MD 20852
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 68 of 244 PageID
709
Attachment 8
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 69 of 244 PageID
710
To whom it may concern,
This letter is to serve as a testimonial and a letter of recommendation for Rub-A-Dub Eco Wash.
They started servicing our new JLL regional headquarters building at 2020 K Street, NW in
Washington, DC about 5 months ago, and so far, they are providing excellent service. The
reliability of Shawn and his team has been exceptional, and I would recommend them heartily to
anyone looking for a convenient, cost effective way to clean their automobiles in a garage or
parking lot setting.
Consistently, Shawn and his team go above and beyond to ensure that our needs are exceeded on
each job, and as they become better known to the JLL employees, I am certain they will grow
their client base even further.
I can say without reservation that Shawn and his team at Rub-A-Dub are the best car washing
and detailing service I have ever used, and I would be happy to speak to anyone considering
hiring them in the future to further vouch for them.
Sincerely,
Matthew A. Coursen
JLL
Managing Director
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 70 of 244 PageID
711
Attachment 9
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 71 of 244 PageID
712
1/23/23
BY ELECTRONIC MAIL
Re: Daniel Tisone
To Whom It May Concern,
I met Daniel when he applied to the venture capital firm, where I was working, for his startup company,
RUB A DUB, around 2018-2019. When I initially met with him, he divulged his past to me and was
forthcoming regarding his criminal conviction as a teenager.
My background is in finance, though my family owns, operates, and manages commercial real estate
buildings in the Washington, DC area. Based on our conversations at the time, Daniel’s company, RUB A
DUB, was operating from several of my family’s properties through a partnership with a parking
management company in the DMV.
Based on my conversations with Daniel, Covid made his business hard to operate rendering the business
plan unviable, as few people were parking in office building parking lots, who would be potential
customers for RUB A DUB.
Furthermore, when the Akridge real estate company was issued a subpoena, Andy Pace, the company’s
general counsel, approached the entire senior management staff at the company, who could have had
knowledge of RUB A DUB performing services within Akridge’s buildings. He received replies from all of
the senior management that they had no knowledge of Daniel or RUB A DUB, hence Andy Pace’s letter
was accurate. My business is separate and apart from the Akridge real estate business, so he had no
reason to come to me at the time. Most importantly, the relationships that Daniel relayed to me were
with the parking companies themselves and not the Akridge real estate company, so it is entirely
understandable that Akridge real estate company employees would not have heard of Daniel or RUB A
DUB.
All in all, I believe Daniel to be a good person with good intentions. I hope for the best for him.
Sincerely,
William Akridge
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 72 of 244 PageID
713
Attachment 10
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 73 of 244 PageID
714
Payroll Journal Summary by Employee
Per Employee Summary for pay days that fall between 01/01/2021 and 12/31/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$20,984.62
$3,302.31
$1,836.33
$17,682.31
Tisone, Daniel
$43,153.84
$10,014.40
$3,532.27
$33,139.44
Tisone, Albert
$43,153.84
$10,014.40
$3,532.27
$33,139.44
Tisone, Doreen
$43,723.06
$11,325.66
$3,575.81
$32,397.40
Totals
$151,015.36
$34,656.77
$12,476.68
$116,358.59
Employee Earnings
Off Cycle Payroll Pay day: 01/08/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$4,000.00
$643.92
$438.00
$3,356.08
Tisone, Albert
$8,250.00
$1,947.88
$862.13
$6,302.12
Tisone, Daniel
$8,250.00
$1,947.88
$862.13
$6,302.12
Tisone, Doreen
$7,000.00
$1,840.87
$766.50
$5,159.13
Payroll Totals
$27,500.00
$6,380.55
$2,928.76
$21,119.45
Off Cycle Payroll Pay day: 01/19/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Tisone, Albert
$8,249.99
$1,947.87
$631.12
$6,302.12
Tisone, Daniel
$8,249.99
$1,947.87
$631.12
$6,302.12
Tisone, Doreen
$6,999.99
$1,840.86
$535.50
$5,159.13
Payroll Totals
$23,499.97
$5,736.60
$1,797.74
$17,763.37
Payroll period: 05/01/2020 - 05/31/2020 Pay day: 02/12/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$4,000.00
$643.92
$405.00
$3,356.08
Tisone, Albert
$8,250.00
$1,947.87
$631.12
$6,302.13
Tisone, Daniel
$8,250.00
$1,947.87
$631.12
$6,302.13
Tisone, Doreen
$7,000.00
$1,840.87
$535.50
$5,159.13
Report generated by
Payroll Journal Report
Date Range: 01/01/2021 - 12/31/2021 Report Created On: 02/17/2023
TEC Ventures LLC
222 Harbour Dr
507
Naples, FL 34103
1/2
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 74 of 244 PageID
715
Payroll Totals
$27,500.00
$6,380.53
$2,202.74
$21,119.47
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Payroll period: 06/01/2020 - 01/31/2021 Pay day: 03/18/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$923.08
$70.61
$70.61
$852.47
Tisone, Albert
$1,903.85
$275.03
$145.65
$1,628.82
Tisone, Daniel
$1,903.85
$275.03
$145.65
$1,628.82
Tisone, Doreen
$1,615.38
$246.37
$123.57
$1,369.01
Payroll Totals
$6,346.16
$867.04
$485.48
$5,479.12
Payroll period: 02/01/2021 - 02/28/2021 Pay day: 03/25/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$4,000.00
$643.92
$306.00
$3,356.08
Tisone, Albert
$8,250.00
$1,947.88
$631.13
$6,302.12
Tisone, Daniel
$8,250.00
$1,947.88
$631.13
$6,302.12
Tisone, Doreen
$7,000.00
$1,840.87
$535.50
$5,159.13
Payroll Totals
$27,500.00
$6,380.55
$2,103.76
$21,119.45
Payroll period: 04/01/2020 - 04/30/2020 Pay day: 03/25/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Tisone, Doreen
$7,107.69
$1,874.95
$543.74
$5,232.74
Payroll period: 04/01/2020 - 04/30/2020 Pay day: 03/25/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$4,061.54
$656.02
$310.72
$3,405.52
Payroll period: 03/01/2021 - 03/31/2021 Pay day: 04/12/2021
Employee Name
Total Earnings
Employee Taxes
Employer Taxes
Net Pay
Ford, Samantha Leigh
$4,000.00
$643.92
$306.00
$3,356.08
Tisone, Albert
$8,250.00
$1,947.87
$631.12
$6,302.13
Tisone, Daniel
$8,250.00
$1,947.87
$631.12
$6,302.13
Tisone, Doreen
$7,000.00
$1,840.87
$535.50
$5,159.13
Payroll Totals
$27,500.00
$6,380.53
$2,103.74
$21,119.47
2/2
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716
Attachment 11
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717
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 77 of 244 PageID
718
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 78 of 244 PageID
719
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 79 of 244 PageID
720
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721
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722
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 82 of 244 PageID
723
Attachment 12
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 83 of 244 PageID
724
No Job Too Small * Reasonable Rates
Email - info@estatesls.com
www.estatesls.com
Follow us
License # LLC20170001151 Insurance # NNP1471058
Estates Land-Scraping
Land Clearing & Clean up
Gravel Driveways, Dirt, Rock, Grading
239-287-2895
June 9, 2021
1530 Mandarin Rd
Daniel Tisone
daniel@tecventuresllc.com
239-703-635-9362
Hello Daniel
Below is a detailed scope of work as I understand it. I appreciate the opportunity to quote you
and your patience.
Scope of Work - $11,725.
• Remove Ficus hedge surrounding property cut to ground and grind below grade for
plantings
• Keep only trees shown in Green X
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 84 of 244 PageID
725
No Job Too Small * Reasonable Rates
Email - info@estatesls.com
www.estatesls.com
Follow us
License # LLC20170001151 Insurance # NNP1471058
• All other vegetation on premises; yellow illustrates the scope of ALL other vegetation to
be removed.
• Install approximately 20 ft of root barrier after cutting root trench and removing roots
from Oak on north side of back yard.
• Pull stump in front yard to north by driveway
• Allocate 4 loads of clean fill dirt to level ground from all trees being removed ($1,000)
• Haul out all vegetation allocation of 8 loads @450 ea / $3,600.
Demolition - $9,870.00
• Remove swimming pool and plumbing.
• Remove wooden fencing along property line and across w/gate
• Remove all wood decking and atriums front and back, and dispose of wood, dig out post
footers
• Permitting (3 weeks) as we will need county and city demo (County fee’s not included)
Recommend driveway refresh using P89 stone, when job is completed and driveway
modification to garage area has been established AFTER landscaping. If you need a landscaper,
I have two that I can send you to bid.
Final Expectation
Please check us out on Facebook and previous customer testimonials with photos of previous
jobs, we accept all major credit cards, fully licensed and insured. NOTE: ground will be
flattened as much as possible (not a hand rake finish grade). Client is aware that sprinklers will
get damaged.
If you wish to proceed, kindly reply to the email.
Sincerely,
Grant Brosseau
239-253-6141
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 85 of 244 PageID
726
Document ID: 467F840D-73E5-4171-9184-AFCBFB87239C
Page 1 of 2
Sales Representative
Joshua Foree
jforee@epicroofs.com
Epic Roofing (License# CCC1331242)
9990 Coconut Rd
Bonita Springs, FL 34135
(239) 214-3445
Daniel Tisone
1530 Mandain Rd
Naples, FL 34102
Claim#
E S T I M A T E
Estimate #
5036
Date
6/29/2021
Item
Description
Qty
Price
Amount
All Permits Included
Re-Roof County or City Permit
1.00
$0.00
$0.00
Tear off, haul away, deck prep
Includes property protection, shingle tear off,
dispose of old material, clean up.
1.00
$0.00
$0.00
Plywood Replacement
We replace all damaged/rotted wood. First 3
sheets $30, any plywood used after the 3 is $75
each.
1.00
$0.00
$0.00
Drip Edge
Installed around whole perimeter of roof. Color
options available (White,Brown,Black)
1.00
$0.00
$0.00
Re-nail roof deck to code
Deck re-nail up to current Florida building code
1.00
$0.00
$0.00
Peel & Stick Underlayment
Install self adhering shingle peel and stick
underlayment. This serves as a secondary water
barrier.
1.00
$0.00
$0.00
Lead pipe boots
Re-move and replace all lead boot penetrations.
1.00
$0.00
$0.00
Vents
Remove and replace all gooseneck vents on roof.
1.00
$0.00
$0.00
Valley Metal
Remove and Replace valley metal
1.00
$0.00
$0.00
Ventilation
Remove and replace current roof ventilation vents
1.00
$0.00
$0.00
Flat Roof Replacement
Tear off old flat roof, replace any damaged/rotted
wood. Apply water tight Polyglass Base sheet,
then apply granulated Polyglass Cap sheet. Front
and back Flat
9.00
$500.00
$4,500.00
shingles
Install Dimensional shingles: Atlas Prolam, Iko
Cambridge, or Owens Corning Oakridge. Based
on availability.
1.00
$0.00
$0.00
Total Cost
Total Cost including permitting, parts, labor and
cleanup
24.00
$372.00
$8,928.00
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 86 of 244 PageID
727
Document ID: 467F840D-73E5-4171-9184-AFCBFB87239C
Page 2 of 2
S P E C I A L I N S T R U C T I O N S
Sub Total
$13,428.00
Total
$13,428.00
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 87 of 244 PageID
728
www.carter-fence.com
3490 Shearwater St
Naples, FL 34117
(239) 353-4102
Joe@carter-fence.com
Estimate #33617
Date Created: Wed Jun 30, 2021
Customer
Point of Contact
Service Location
Billing Address
Parish, Mathew: Parish, Mathew
1530 Mandarin Rd
Naples, FL 34102-5138
715-302-0922
Mathew Parish
mparishcontracting@gmail.com
715-302-0922
1530 Mandarin Rd
Naples, FL 34102-5138
Billing Address:
Item(s)
Qty
Name
Description
1
Clear Path
Please have at minimum a 3' wide path cleared prior to installation. All
brush/foliage/refuse/debris must be cleared or we will not be able to install.
1
Mobilization: Collier
County
1
Residential Permit:
Collier County
Carter Fence permit cost & processing fee.
**Survey to be supplied by customer to initiate permitting process**
316
Remove & Replace
Remove: Existing wood fence
Replace with: White vinyl 6'H
316
Vinyl Fence: 6'H
Manufacturer: ActiveYards/PolyVinyl
Grade: Commercial
Style: Dogwood
Color: White
Post Size: 5"x5"x108"
Panel Width: 8' Wide
1
Vinyl Gate: 6'H
Manufacturer: ActiveYards/PolyVinyl
Type: Single Swing
Opening: 5'
Grade: Haven
Style: Dogwood
Color: White
Post Size: 5"x5"
Hinges: Self Closing
Latch: Self Latching
**All gates include a welded aluminum frame**
1
Industry Pricing
Due to COVID-19, industry pricing is fluctuating rapidly. Therefore, this
estimate is only good for (2) weeks after it has been issued to customer.
Please allow time for estimator to review pricing again if the estimate is older
than (2) weeks. Thank you for your patience.
1
Layout Agreement
By Accepting This Quote You Are Agreeing To Attached Layout
IF THERE IS AN OPTION LISTED ON THE PROPOSAL, PLEASE SIGN YOUR INITIALS NEXT TO THE LINE ITEM
TO CONFIRM YOU WOULD LIKE TO PROCEED WITH THIS OPTION
Total
$12,276.00
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 88 of 244 PageID
729
Estimate Notes
remove wood - replace with vinyl
Signature
Date
Print Name:
For all customers we require a 50% deposit from you before any installation date can be given. If a Contract or Purchase Order is provided then a
50% deposit is not required. Payment Methods Accepted: Cash, Check or Credit Card. If you would like to make a payment on our website using a
credit card, please go to the following link: https://carter-fence.com/transaction-form/ (Please note: A 3% convenience fee will apply)
Introducing to you our new FIVE YEAR WARRANTY! We stand behind our workmanship by offering this to you.
Thank you for your business. We look forward to working with you!
TERMS AND CONDITIONS
BY SIGNING OR GIVING WRITTEN CONSENT TO MOVE FORWARD WITH THIS CONTRACT, WE (I) AGREE TO PAY FOR THE SERVICES
NOTED ABOVE AND ALL THE SERVICES HERETOFORE OR HEREAFTER PURCHASED OR ORDERED FROM YOU TOGETHER. CARTER
FENCE CO. INC. WARRANTS THE FENCE AGAINST DEFECTS IN MATERIALS FOR A PERIOD OF ONE YEAR AND WORKMANSHIP FOR A
PERIOD OF FIVE YEARS FROM THE DATE OF COMPLETED INSTALLATION. IF ANY DEFECT EXISTS AND IS REPORTED TO CARTER FENCE
CO. INC. WITHIN ONE YEAR, CARTER FENCE WILL REPAIR OR REPLACE ANY DEFECT WITHOUT CHARGE DURING NORMAL WORKING
HOURS. IF ANY DEFECT EXISTS AND IS REPORTED ON POOR WORKMANSHIP, CARTER FENCE WILL REPAIR AND REPLACE ANY DEFECT
WITHOUT CHARGE DURING NORMAL WORKING HOURS. BUYER AUTHORIZES WORK TO COMMENCE AND AGREES TO PAY PRICE
DESCRIBED. IF ADDITIONAL MATERIALS OR LABOR IS PERFORMED THERE WILL BE ADDITIONAL CHARGES ON FINAL INVOICE. IF WE
QUOTED YOU MORE MATERIAL THAN NEEDED, WE WILL DEDUCT THIS ON YOUR FINAL INVOICE. PAYMENT IS DUE UPON COMPLETION
OF WORK. IF PAYMENT IS DELINQUENT AFTER 10 DAYS, A 1.5% MONTHLY FINANCE CHARGE WILL BE BILLED ON THE BALANCE DUE. ALL
COSTS INCURRED TO COLLECT A DELINQUENT ACCOUNT WILL BE ADDED TO THE BALANCE DUE AND ARE THE RESPONSIBILITY OF THE
OWNER. CUSTOMER HEREBY ASSUMES FULL RESPONSIBILITY FOR LOCATING FENCES LINES AND ALL UNDERGROUND CABLES, LINES,
AND PIPES. CARTER FENCE CO. INC. IS NOT RESPONSIBLE FOR DAMAGES TO UNDERGROUND UTILITIES NOT IDENTIFIED BY OWNER.
ESTIMATES ARE ONLY VALID FOR 10 DAYS AFTER THE DATE THEY ARE CREATED. CARTER FENCE CO. INC. REQUIRES 48 HOURS FOR
ANY CANCELLATION OR RESCHEDULING PRIOR TO THE INSTALLATION DATE THAT IS GIVEN VIA EMAIL. PLEASE NOTE A $500 FEE WILL
BE ADDED TO THE FINAL INVOICE IF THESE TERMS ARE NOT MET.
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 89 of 244 PageID
730
Omax Home Inc.
1946 Dana Dr.
Fort Myers, FL 33907 US
239-344-9230
omaxhome@gmail.com
omaxhome.com
Estimate
ADDRESS
ESTIMATE #
DATE
1424
07/30/2021
JOB NAME
DOOR STYLE/COLOR
1530 Mandarin Rd
US Series White Shaker *Framed
ACTIVITY
QTY
RATE
AMOUNT
Cabinet:SB36
36" Sink Base
1
0.00
0.00T
Cabinet:3DB30
3 Drawer 30" Base
3
0.00
0.00T
Cabinet:B33
33" Base Cabinet
1
0.00
0.00T
Cabinet:B30
30" Base
1
0.00
0.00T
Cabinet:BLS33
33" Lazy Susan Base Cabinet
1
0.00
0.00T
Cabinet:UC189024
Pantry/Utility Cabinet 18 x 90 x 24
2
0.00
0.00T
Cabinet:W361824
36x18x24 Wall Cabinet
1
0.00
0.00T
Cabinet:W3036
30x36 Wall Cabinet
1
0.00
0.00T
Cabinet:W3020
30x20 Wall Cabinet
1
0.00
0.00T
Cabinet:W0936
9x36 Wall Cabinet
1
0.00
0.00T
Cabinet:WDC2436
24 x 36 Wall Diagonal Corner
1
0.00
0.00T
Cabinet:W2436
24x36 Wall Cabinet
2
0.00
0.00T
Cabinet:W1836
18x36 Wall Cabinet
1
0.00
0.00T
Cabinet:F336
3x36 Wall Filler
3
0.00
0.00T
Cabinet:DW2435
Dishwasher Panel 24 x 35
1
0.00
0.00T
1530 Mandarin Rd
Naples, FL 34102
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 90 of 244 PageID
731
ACTIVITY
QTY
RATE
AMOUNT
Cabinet:PNL4896
48x96 Panel
1
0.00
0.00T
Cabinet:ACM8
Crown Moulding
4
0.00
0.00T
Cabinet:TKC8
Toe Kick
3
0.00
0.00T
Sales
Total for above cabinets and materials.
1 6,905.64
6,905.64T
Labor:Installation
Installation Charge for all cabinets and materials described above.
1 2,320.00
2,320.00
Cabinet:Counter Top
Level 3 quartz - per customer selection. Color to be determined. Price
includes material, install, sink cut out, 4" backsplash where needed,
choice of 5 standard edge profiles. NOTE: Material prices subject to
change due to template and/or material choice.
1 4,536.25
4,536.25T
Subtotal: 13,761.89
KITCHEN SINK:OACS 3219
Single bowl handmade undermount sink 16 gauge Stainless Steel; 32 x 19
x10
1
245.00
245.00T
KITCHEN FAUCET Sensor Technology:OAF 9102-5C
Sensor Kitchen faucet, chrome or nickel
1
250.00
250.00T
Subtotal: 495.00
Misc:Disclaimer
By signing this estimate, the customer confirms 100% responsibility for
checking and confirming that ALL PRODUCT SIZES, STYLES & COLOR
are correct before submitting payment. Omax Home Inc is not responsible
for any drywall, tile or paint repairs. Any additional job requested &
approved by the customer is subject to charge. Each additional trip for
extra work that is not on the contract requires a $150 fee.
1
0.00
0.00T
Payment Terms
*20% DISCOUNT APPLIED*
1st payment due at contract signing;
2nd payment due upon materials arriving at warehouse;
3rd payment due upon installation;
Final payment due upon completions.
*Countertop payment is due in full before installation*
1
0.00
0.00
SUBTOTAL
14,256.89
TAX
766.38
SHIPPING
299.00
TOTAL
$15,322.27
Accepted By
Accepted Date
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 91 of 244 PageID
732
Materials Only
Materials & Installation
Licenses: FL #:SCC131151654
Palm Beach:U-21987
Broward:14-G-19135
Office: 954-451-5601
4830 NE 10th Ave. ● Oakland Park, FL 33334
Email: Sales@LatitudeWindows.com
Website: www.latitudewindows.com
Contractor:
Rep Initials:
Owner / Agent:
Job-Site Address:
Unit Number:
Legal Description:
Folio / PCN:
Mailing Address:
Misc. Info:
Phone Number:
E-Mail:
Additional Info:
Alt E-Mail:
The following products and/or services are covered by this proposal *
Permit Included:
Year Built:
* Pleaseseeterms&conditionsofthisproposal/contractpages2-4.
I understand and accept this proposal. I have had the opportunity to read and ask questions
Total Price 1
about all four (4) pages of this contract before signing. I acknowledge that payments other than
cash/check/eCheck will be subject to a processing fee.
Total
Owner/Agent:
Payment Schedule
Signature
Print Name:
Deposit(Dueuponcontractsigning) :
SecondPayment(DuewhenmaterialisdeliveredtoJobSite) :
Date:
Final(Dueuponapprovaloffinalinspection) :
Sales Rep:
Notes
1Cash/checkprice
Officer Signature:
Latitude Windows, Inc.
Sales Rep:
READ BEFORE SIGNING - BUYER'S RIGHT TO CANCEL:"Ifthisisahomesolicitationsale,andifyoudonotwantthegoodsorservies,youmay
cancelthisagreementbyprovidingwrittennoticetothesellerinperson,bytelegram,orbymail.Thisnoticemustindicatethatyoudonotwant
thegoodorservicesandmustbedeliveredorpostmarkedbeforemidnightofthethirdbusinessdayafteryousignthisagreement.Ifyoucancel
thisagreement(withinthethreedays)thesellermaynotkeepallorpartofanycashdownpayment."
Page1of4
Rev.Contract_A07
Daniel Tisone
1530 Mandarin Rd
Naples
FL 34102
COQUINA SANDS UNIT 2 BLK A LOT 6
06280120005
daniel@tecventuresllc.com
703-635-9362
Owner is Daniel Tisone
NO
1967
Supplying and Installing
Impact windows and doors as per attached inventory pages (all openings are included).
Frame color to be white kynar, all glass tinted gray. Bathroom window to have privacy glass.
Latitude to secure building permit from Naples. Building permit cost to be added to second payment.
3.00%
27,540.00
Stewarts General Services
13,540.00
11,000.00
3,000.00
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 92 of 244 PageID
733
Attachment 13
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 93 of 244 PageID
734
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 94 of 244 PageID
735
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 95 of 244 PageID
736
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 96 of 244 PageID
737
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 97 of 244 PageID
738
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 98 of 244 PageID
739
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 99 of 244 PageID
740
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 100 of 244 PageID
741
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 101 of 244 PageID
742
The undersigned hereby certify that they have carefully reviewed the Closing Disclosure or other settlement statement form and
they approve and agree to the payment of all fees, costs, expenses and disbursement as reflected on the Closing Disclosure or
other settlement statement form to be paid on their behalf. We further certify that we have received a copy of the Closing
Disclosure or other settlement statement.
Acknowledgement
_____________________________Date_________
Nilesh Vyas, as Trustee of the
Nilesh A. Vyas Trust dated 8/23/2017
_____________________________ Date_________
Marianne Vyas, as Trustee of the
Nilesh A. Vyas Trust dated 8/23/2017
796 Ketch LLC
a Florida limited liability company
By: TEC Ventures, LLC
a Virginia limited liability company
By: ___________________Date_________
Daniel Tisone
Manager
(Corporate Seal)
I have reviewed the Closing Disclosure, the settlement statement, the lender's closing instructions and any and all other forms relative
to the escrow funds, including any disclosure of the Florida title insurance premiums being paid, and I agree to disburse the escrow
funds in accordance with the terms of this transaction and Florida law.
HENDERSON, FRANKLIN, STARNES & HOLT, P.A.
By:
Note: POC B: Paid Outside Closing by the Borrower/Buyer, POC S: Paid Outside Closing by the Seller, PBO: Paid by Other.
Copyright 2015 American Land Title Association
All rights reserved
File THG 38462-1
Page 3 of 3
DoubleTime®
APPROVE:
1031 EXCHANGE CONNECTION
BY:_______________________________
Nace Cohen
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 102 of 244 PageID
743
Attachment 14
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 103 of 244 PageID
744
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 104 of 244 PageID
745
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 105 of 244 PageID
746
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 106 of 244 PageID
747
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 107 of 244 PageID
748
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 108 of 244 PageID
749
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 109 of 244 PageID
750
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 110 of 244 PageID
751
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 111 of 244 PageID
752
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 112 of 244 PageID
753
Attachment 15
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 113 of 244 PageID
754
Friday, February 17, 2023 at 17:58:49 Eastern Standard Time
Page 1 of 2
Subject:
Re: MSLP Payment
Date:
Monday, May 16, 2022 at 11:04:07 AM Eastern Daylight Time
From:
Daniel Tisone
To:
Valera Belcher
AEachments: image001.png, image002.jpg, image003.jpg, image004.jpg, image005.jpg
Valera,
I plan on sending a wire today. I will email you as soon as it’s sent.
Regarding future payments, what happened to the funds that were in the account for TEC Ventures LLC at
Bank of Clarke? Are those no longer available?
I am dealing with the government currently and have worked out a deal to sell assets in order to pay off the
enFre loan from BofC which should be done within the next 90 days.
Is there a way to get forbearance on payments unFl I am able to do this?
Thank you,
Daniel
From: Valera Belcher <vbelcher@bankofclarke.com>
Date: Monday, May 16, 2022 at 11:00 AM
To: Daniel Tisone <daniel@tecventuresllc.com>
Subject: RE: MSLP Payment
Thank you for contacFng me, this amount is for April payment only and May was due on 5/16/22. Our
incoming wire fee is $15.00, please send your wire for $4,469.93 for April, our wire instrucFons are:
Bank of Clarke County
RouFng No. 051402518
To Account No. 1100467
Reference Tec Ventures LLC, No. 7200054
When do you anFcipate sending your May payment? If I can be of further assistance, please let me know.
Thank you
Respectfully,
Valera Belcher
Valera Belcher | AVP/Collection Officer
Bank of Clarke County
202 North Loudoun Street, Winchester, VA 22601
Desk: (540) 545-4931 | Mobile: (540) 664-5416
(800) 650-8723 (Toll Free)
Email: vbelcher@bankofclarke.com
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 114 of 244 PageID
755
Page 2 of 2
Web: www.bankofclarke.bank
From: Daniel Tisone <daniel@tecventuresllc.com>
Sent: Monday, May 16, 2022 10:41 AM
To: Valera Belcher <vbelcher@bankofclarke.com>
Subject: MSLP Payment
Valera,
I am in receipt of your le_er regarding payment of $4,454.93 (The Amount Past Due) by May 18th, 2022.
What is the best way to get this payment to you? Wire?
Thank you,
Daniel
CONFIDENTIALITY NOTICE
This electronic mail message, including any and/or all a_achments, is for the sole use of the intended recipient(s), and may contain confidenFal and/or privileged informaFon, pertaining to business
conducted under the direcFon and supervision of the sending organizaFon. All electronic mail messages, which may have been established as expressed views and/or opinions (stated either within the
electronic mail message or any of its a_achments), are lef to the sole responsibility of that of the sender, and are not necessarily a_ributed to the sending organizaFon. Unauthorized intercepFon, review,
use, disclosure or distribuFon of any such informaFon contained within this electronic mail message and/or its a_achment(s), is (are) strictly prohibited. If you are not the intended recipient, please contact
the sender by replying to this electronic mail message and delete this message from your system, including any a_achments.
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 115 of 244 PageID
756
Attachment 16
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 116 of 244 PageID
757
December 26, 2022
RE: Daniel Trisone
To Whom it May Concern,
I was asked if I would be willing to write a letter of reference for Daniel based on my experiences with
him on a professional level. As a college professor for three universities I have and do work with a lot of
people from many walks of life and diversities which has made me a good judge of character. I have
been told by my colleagues that I have six sense to peoples characteristics and ethics.
I first met Daniel about 2 years ago when I was contracted to remove some dead trees, broken down
fence from hurricane Erma. We discussed the scope of what started out to be simple and straight
forward, turned into more than we agreed upon because of unforeseen rocks and trash. I ask Daniel to
meet on site and discuss the required changes, he did. He was understanding and explained he wasn’t
looking for anything extra from me just a complete job.
He proceeded to tell me about his parking garage charging stations business and how COVID was taking
a toll on his business with the forced stay at home mandate by CDC which is why we he now doing home
renovations in an effort to keep things going and hopefully transition his business model to house
flipping as Naples is a prime market to do this.
We continued our scope of work as agreed, while our deadline for completion approached we has to
work on Sunday to finish the job for Monday so the sprinkler people and lawn crew could finish the
yard. At the end of the day Daniel was happy with the job and appreciate the added time and effort to
keep the scheduled finish date by working Sunday. He bought me lunch an we spent time talking about
everything and nothing, and I got to know Daniel as a person.
Daniel is a man of integrity, honesty and ethics; he had a few opportunities to hold me to our written
agreement which would have saved him money, instead he said,” he respects a business that stands by
their word and appreciation for an honest days work” and how a lot of people would walk off the job
and we didn’t. I observed Daniel with other workers and his MO was always the same, above board,
honest and ethical. I interacted with Daniel over several weeks and feel in my heard he is a man of
strong character which to this day trust Daniel inexplicably.
Sincerely
Grant Brosseau
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 117 of 244 PageID
758
Attachment 17
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 118 of 244 PageID
759
To whom it may concern,
I met Daniel soon after moving to Southwest Florida, through mutual friends. Soon after
learning I was a contractor; I began helping him out with some of his residential renovations on
the homes he owned.
I referred sub-contractors and laborers to his projects to help him with the different parts of
the construction process. Some of those laborers were likely undocumented, but most required
cash payments for their labor, which is not uncommon in the construction industry. Daniel
hired painters, drywallers, demolition, and stucco crews for his projects in 2020 and 2021,
paying the majority of them in cash.
Daniel and I began a renovation project a few months ago in Naples. Upon learning of
Daniel’s charges, the homeowner no longer allowed him to be apart of the project, without
giving him a chance to explain the situation. I did not believe the consequence was fair,
considering he had gone far out of his way to help the customer. He has also referred me to
other projects, not wanting to be involved because the negative press could affect the
relationship and trust with the customer.
I have spent a lot of time with Daniel and his family, and have bare witness to the amount of
stress and anguish this situation has brought on him, and Samantha. As someone in the
construction industry that understands the situation, as someone who has witnessed Daniel’s
work ethic, and as a father like Daniel, I hope that he is given mercy and an opportunity for
redemption.
Regards,
-
Matthew Parish
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 119 of 244 PageID
760
Attachment 18
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 120 of 244 PageID
761
Cape Coral, December 2022
My name is Tania Costa, I currently live in Cape Coral and I have been working for Daniel
Tisone since May 2020. Since that time, Daniel Tisone has blessed me by offering several
cleaning services at his house, and has also blessed me economically. He knows I'm a single
mother, and I need to work to support my daughters.
In December 2021, Daniel gave me $3000.00 to help me rent the house where I currently
live, here in Cape Coral. I didn't have all the money for the rent, which totaled $6000.00,
including the 1st and the last months, and the deposit fee.
In other words, I am and will forever be grateful to Daniel for always helping me.
In the period after Hurricane Ian, Daniel and Samantha Ford also helped me with food and
furniture as I, unfortunately, lost everything I had in my house.
I deeply admire and respect Daniel and his family for everything they have been doing,
helping people greatly.
Unfortunately, these days it's not easy to find people like that, who really care about others.
Daniel is different from those people. He is always blessing someone with his simplicity.
Thanks,
Tania Costa.
(TRANSLATED VERSION)
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 121 of 244 PageID
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Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 122 of 244 PageID
763
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 123 of 244 PageID
764
Attachment 19
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 124 of 244 PageID
765
Friday, February 17, 2023 at 18:03:42 Eastern Standard Time
Page 1 of 2
Subject:
ACH Transfer
Date:
Thursday, October 21, 2021 at 9:15:48 AM Eastern Daylight Time
From:
Daniel Tisone
To:
Jonathan Rothman
CC:
Muhammad Shahzaib Saleemi
ADachments: Image.jpeg
Jon,
Can you send an ACH for $6,400 from TEC Ventures 9323 to the a>ached account informaAon :
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 125 of 244 PageID
766
Attachment 20
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 126 of 244 PageID
767
View this invoice online at www.upcounsel.com
Related Job: Assist with Tax Filings
Invoice #
Sent Date
Attorney
00002
11/05/2020
David Weaver
Payment Summary
Date
Payment Method
Amount
12/09/2020
Visa (7477)
$777.60
Receipt
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 127 of 244 PageID
768
View this invoice online at www.upcounsel.com
Related Job: Draft Profit Share Agreement
Invoice #
Sent Date
Attorney
00485
06/02/2021
Lara Lavi
Payment Summary
Date
Payment Method
Amount
06/03/2021
Visa (5805)
$270.00
Receipt
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 128 of 244 PageID
769
Attachment 21
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 129 of 244 PageID
770
,
EXHIBIT A
U.S. De11Brlmen1 or Justice
United Stntes Marshals Service
Asset Fo1fi111re Dii'isio11
ADDENDUM TO REAL ESTATE PURCHASE CONTRACT
This Addendum to Real Estate Purchase Contract ("AddendumƏ) is made pan of that certain
Real Estate Purchase Contract ("Contract") dated theƐ day of February 2023
between the United States of America, acting by and through the United States Marshals Service
("Seller") and Daniel T. Schwaller & Margaret H. Sch_w_e_ll_er ____ _
("Purchaser-) for the purchase of the propeny corr.manly known as CATS ID: 22-FBl-003172
Address: 550 Starboard Drive I Naples, FL 34103
. ( .. Property'').
Purchase Price:
Deposit
Amount financed
Balance due at closing
$3,600,000
$ 180,000
$0.00
$3,420,000
FOR GOOD AND VAlUABLE CONSIDERATION, the receipt and sufficiency of which are
hereby acknowledged, Seller and Purchaser agree as follows:
L
EgJja; Agrrsrosut• lN THE EVENT OF ANY CONFLICT BETWEEN THIS ADDENDUM
AND THE CONTRACT OR ESCROW INSTRUCTIONS OR NOTICE OF OTHER
DOCUMENTS A TT ACHED TO THE CONTRACT, THE TERMS OF THIS ADDENDUM
SHALL PREVAIL.
2.
l
Purchase Prjcc. The Purchase Price for the Property shall be paid to Seller by certified or
cashier's check or by wired funds at the closing. Funds over $25,000 will only be accepted by
wire.
f:aroest Mousy. Immediately following Seller's acceptance of the Con1rac1, escrow shall be
opened with an escrow agent designated by Seller or 01herwise acccplable to Seller. The earnest
Un11N Scatu MJ.tSl\&11 Scrvu:c
Jtc,.1 f1(a1, S'wc:hu.c A41.ko01.1,,
Page I of 10
Purchasers Initials ..t;-
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 130 of 244 PageID
771
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Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 132 of 244 PageID
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TEC Ventures LLC, a Virginia Limited Liability Company
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 139 of 244 PageID
780
"AS IS" Residential Contract For Sale And Purchase
THIS FORM HAS BEEN APPROVED BY TiiE FLORIDA REALTORS AND TiiE FLORIDA BAR r
Realtors
,.
2•
J •
s
6 ,.
PARTIES:
("Setler"),
and
TEC Ventures LLC, a Virginia Limited Liability Company
Daniel T. Schwcller & Margaret A. Schwdler
("Buyer"),
agree that Seller shall sel l and Buyer shal buy lhe foffov.ing dewibed Real Property and Personal Property
(conectively "Property") pursuant 10 the terms and conditions of this AS IS Residential Conlract For Sale And Purchase
and any riders and addenda ("Conlract"):
1.
PROPERTY DESCRIPTION:
••
9•
(a) Street address, city, zip: 550 Slarboard Drive I Naples, PL 34103
(b) Located in: Colliers
County, Florida. Property Tax ID #: . ....,1"'2"'98
:..1:.:5:.:600=00
=----------
(c) Real Property: The legal description is
MOORINGS UNIT 6 BLK FLOT 5
10
II
12
I) ..
IS
16
17
together wtth all existing Improvements and fixtures, including buih-in appliances, builtμn furnishings and
attached wall•to-wall carpeting and floonng ("Real Property") unless specofically excluded In Paragraph 1 (e) or
by other terms of this Contract
"
l9
20
21 •
n
(d) Personal Property. Unless exduded 1n Paragraph 1(e) or by olher terms of this Contract. the folowtllg items
which are owned by Seller and exisUng on the Property as of lhe date of the Initial olfe r are Included In tho
purchase: range(s)/oven(s), relrigeralor(s), dlshwasher(s), disposal, ceiling fan(s). lighl fiνture(s), drapery rods
and draperies. blinds, window traatmenls. smoke detector(s). garage door opener{s), thermostat(s), doorbel(s),
television wall mounl(s) and television mounting hardware. security gate and olher access devices. maabox
keys, and slorm shutters/storm proleC1lon Items and hardware ("Personal Property").
Other Persona l Property Items inducled In this purchase are:. ________________ _
23
Personal Property is included in the Purchase Price, has no contributory value, and shall be left for the Buyer
2••
(e) The following llems are excluder! from the purchase:. __________________ _
2S
26
PURCHASE PRICE ANO CLOSING
21•
2.
PURCHASE PRICE (U.S. currency): ......................................................................................... -..... $ 3.600.000
2e•
(a) Initial deposit to be held in escrow In the amount of (chocks subject to Collection) ...... -..... $
180.000
211
The initial deposit made payable and delivered to "Escrow Agenl" named below
,o •
(CHECK ONE): (i) !Kl accompanies offer or (ii) 0 is to be made within __ (if left blank,
31
then 3) days after Elfectiva Date. IF NEITHER BOX IS CHECKED. THEN OPTION (11)
l2
SHALL BE DEEMED SELECTED.
JJ•
Escrow Agent Name . .,.,.,K=
as,,s""S"'
hu::,lc.,,,;..• P:...:·:..:"-------ξ--ĐĐο-----
34 •
Address: I SOS N Florido Avcnu, I Tampa. Florida )360π
Phone:
(81 l) 22?•0?00
35 •
Email:
wgardna@kuslaw,com
Fax:
(81ll 2l?-3H3
36 •
(b) Additional deposit to be delivered to Escrow Agent within ____ (if left blank, then 10)
37 •
days after Effectiva Dale .................................................................................................... -.... $ . .,o"",00
=. ___ _
)I
(A ll deposits paid or agreed to be paid. are collectively referred to as the "Deposit")
19•
(c) Financing: Express as a doUar amount or percentage ("loan Amount") see Paragraph 8 ......... ρs,..o.,.oo
,,_ __ _
,o•
(d) Other.
................ $,_,0,,.,.00
"'-----
••
(e) Balance to close (not including Buyer's closing costs. prepalds and proratlons) by wire
,2•
transfer or other Co llected funds (See STANDARD S) ............................................................. $ 3 420,000
o
3.
TIME FOR ACCEPTANCE OF OFFER ANO COUNTER-OFFERS; EFFECTIVE DATE:
«
(a) If not signed by Buyer and Se ller, and an executed copy delivered to all parties on or before
•s•
__________ . this offer shall be deemed withdrawn and the Deposit. If any. shall be retumed to
,i;
Buyer. Unless olherwise stated, time for acceptance of any counter-Oilers shan be within 2 days after lhe day
,,
Iha counter•offer is delivered.
,a
(b) The effective date of this Contract shall be the date when the last one of the Buyer and Seller has signed or
fll
mltlalecl and delivered this offer or final counter-<>frer ("Effective Date").
!O
4.
CLOSING; CLOSING DATE: The closlng of this lransaction shall occur when all funds required for closing are
s,
received by Closing Agent and Co llected pursuant to STANDARD S and a ll closing documents required to be
S2
furnished by each party pursuant to this Contract are delivered ("Closing"). Unless modified by other provisions of
Buyef's lnolJals \l 1._A -ti!_
P- 1 al 12
S•1et•• lnollalS __
Florid4Rnllonlf'+,6 Rev 10121 C 2021 Flooda Roa- 1111<1 The Flo,kla S,,. All rigl'AS rt&etVeG
Thie aoftwaς• i■ lieenaed σo {Keid.1 Bl•il •
DP Realty LLCJ www.tr.nsactiondeek.con. n
T«AHS.A.CIIONS
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 140 of 244 PageID
781
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782
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786
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787
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788
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789
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790
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791
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792
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793
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794
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795
PropMy- 55-0 SU>rbomi Ori•• I Napks. F'Ʈ 34103
ACKNOWLEDGEMENT FOR REAL ESTA TE PURCHASE AND SALE CONTRACT
(''CONTRACT .. ) BETWEEN TEC Ventures LLC, a Virginia Limited Liability Company.
( .. SE:.LER")
AND Daniel T. Schwcllcr & Morgare: H. Schwclltr
("PURCHASER")
I.
Purc:hucr acknowledges that concurremly with their accution of the contract, and s11bmission or
lhe contract package. they have delivered the Earnest Money to the Senlcmcnl Agent.
2.
Purchaser acknowledges that the Eamw Money will be released 10 Seller within 48 hours of the
cxU"Ution of the contract by Seller. The Earnest Money will be applied to the Purchase Price al
closing
3.
If contract is 1crm1na1cd before the inspection period expires. Earncs1 Money shall be refJndcd to
Purchaser.
4.
Pro,H'rly is sold "AS-IS". It is the responsibility of Purchaser to inspect the properly the week
of escrow closing. Once escrow closes, Purchaser waives any and all possible future claims they
may have.
All OIMr terms and condi1ions contain(d in the Contract, any Addenda, exhibits and ancillary docJmcnts
executed in connection with the Property. shall remain lhe same.
PURCHASER
,
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 155 of 244 PageID
796
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797
Attachment 22
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798
2/17/23, 6:10 PM
Account Information Summary
Page 1 of 1
https://www.spservicing.com/Services/AccountInformationOverview?…zaIP1LvXrF7l70sbV1atYNc7zGIXmhK0BT5daR1oQzs00sg1hBC9JsmQEcZEnnj
My Account
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Statements & Letters
Documents
SPS
Account Information Summary
Print
*If the account has an adjustable or step interest rate feature, the interest rate shown above may not be the current interest rate in effect on the account, but rather, it
is the interest rate in effect as of the date through which the account is paid. Please contact us regarding any questions you may have regarding the interest rate or
other aspects of the account.
Need further information, please Contact Us
Account Information
Account Number
0030629273
Borrower Name
DANIEL J
TISONE
Co-borrower
Name
Origination Date
6/2/2021
Original Loan
Amount
$1,999,500.00
Loan Type
Conventional
Without PMI
ARM
Last Payment
Received
Scheduled
Payment
A payment has not been received in the last 90
days.
Current Balances
Year-To-Date
Balances
Principal
$1,999,500.00
Escrow
-$39,810.62
Late Charges
$0.00
Total Fees
$0.80
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Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 158 of 244 PageID
799
Attachment 23
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 159 of 244 PageID
800
BILL OF SALE FOR A VESSEL
This is to certify that I have sold the following listed vessel/trailer/motor to:
Name of Purchaser (s):
on this
day of
, 20
for the sum of $
Name Entered In Error:
(if applicable).
*IF THE SELLING PRICE INCLUDES A BOAT, TRAILER, AND AN OUTBOARD MOTOR, ENTER THE
PORTIONS OF THE PRICE FOR EACH COMPONENT BELOW:
Boat $
Trailer $
Outboard Motor $
DESCRIPTION OF VESSEL
Make
Year
Identification Number
Length
Registration Number
Title Number
DESCRIPTION OF TRAILER
Make
Year
Identification Number
Empty Weight
DESCRIPTION OF OUTBOARD MOTOR
Make
Year
Identification Number
If this vessel has never been registered or titled in Florida, or any other state, give the specific reason (s) below:
Under penalties of perjury, I declare that I have read the
foregoing document and that the facts stated in it are true.
Signature of SELLER
Address:
Signature of PURCHASHER
Address:
Signature of CO-SELLER
Address:
Signature of CO-PURCHASER
Address:
NOTE: All vessels manufactured 1974 or later must establish ownership by furnishing along with this bill of sale, a
manufacturer's statement of origin, title certificate or other document in accordance with Florida Statute 327.
UDS300 rev112211 ba
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 160 of 244 PageID
801
Matthew John Holtan
23
June
22
153,402.00
153,402.00
NA
NA
Tiara
2019
SSUKC007L819
34
FL0523SS
SIGN
SIGN
550 Starboard Dr
Naples, FL 34103
SIGN
SIGN
266 Egret Ave
Naples, FL 34108
Attachment 24
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 161 of 244 PageID
802
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 162 of 244 PageID
803
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804
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 164 of 244 PageID
805
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806
Attachment 25
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 166 of 244 PageID
807
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 167 of 244 PageID
808
Attachment 26
Case 2:22-cr-00039-SPC-NPM Document 90 Filed 02/20/23 Page 168 of 244 PageID
809
2/18/23, 11:28 AM
From Package Deliveries to Mobile Car Washes, Ford Brings New Services to Your Connected Car | by Ford Motor Company | City of Tomorrow | Medium
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Published in City of Tomorrow
Ford Motor Company
Apr 30, 2019 · 4 min read ·
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From Package Deliveries to Mobile Car Washes,
Ford Brings New Services to Your Connected
Car
y Lorin Kennedy, FordPass Ecosystem Business Leader, Ford Motor
Company
Ford Motor Company
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ord is teaming up with Amazon to bring its Key by Amazon In-Car delivery service to eligible Ford and Lincoln
vehicles.
or more than a century, Ford has powered people’s ability to get where they
eed to go with safe, reliable cars.
Now, we think it’s time to flip the script. Instead of using our vehicles solely
o get us to our destinations, what if we used them as beacons to bring
onvenient and secure services to us?
hanks to advancements in wireless technology, we now are easily
onnected to the goods and services we want. With the internet, we’ve been
ble to save time by shopping online instead of leaving the house for
verything from food and clothing, to electronics and more. And the results
ave been undeniable. Last year alone, the United States Postal Service
elivered close to 6.2 billion packages — double the amount it delivered
lmost a decade ago.
f h
k
fi
l i
ilb
b
d b
g
y
Text to speech
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ome of these packages fit snugly into our mailboxes or can be accepted by
uilding staff, but a lot of them end up sitting outside on porches and front
toops — vulnerable to bad weather or going missing. So, it’s easy to get
nxious about your deliveries when you aren’t home to receive them.
hat’s why we’re teaming up with Amazon to bring its Key by Amazon In-Car
elivery service to eligible Ford and Lincoln vehicles. Through In-Car
elivery, eligible Ford and Lincoln owners now can have their Amazon
rime packages delivered to their vehicles. It’s a convenient, secure way to
nsure your packages are delivered directly to you when you are out for the
ay, anticipating bad weather or wondering if your package is safe.
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ey by Amazon in-car delivery is available for select Ford 2017 and later
model year vehicles equipped with FordPass Connect, and for Lincoln 2018
nd later model year vehicles equipped with Lincoln Connect. In-Car
elivery will be available virtually anywhere that Amazon offers the service,
which is currently in several U.S. cities and surrounding areas.
o use the in-car service you need to download the FordPass or Lincoln Way
pp, create an account, and activate your car for in-car delivery. Amazon Key
pp enables in-car deliveries by linking your Amazon Prime account with
our FordPass or Lincoln Way account.
ou’ll receive notifications throughout the delivery process, including a
ead’s up right before delivery takes place and a confirmation that delivery is
omplete and your car has been securely locked. And for added peace of
mind, the delivery driver verifies that your vehicle has been successfully
elocked before proceeding with the next delivery. Plus, you are always in
ontrol, so if you change your mind the day of delivery, you can block access
o your car; delivery will be made to the building where your car is parked or
ou can reschedule the delivery to the following day.
nd while this service alone is pretty exciting, Key In-Car delivery is just the
rst wave of what’s possible. Through our Ford connected vehicle services,
ther businesses are able to integrate their apps with Ford and Lincoln
onnected vehicles. This will allow us to deliver additional new services to
ur customers’ vehicles that improve their daily lives.
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p
y
or example, in addition to Key by Amazon, we’re also working with several
ifferent on-demand car wash services through FordPass and Lincoln Way,
o give people the option to purchase eco-friendly car washes from Spiffy,
UB A DUB and Sparkl wherever these services are available.
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Ford is also working with several on-demand car wash services like Spiffy.
ust think — instead of driving to a car wash and waiting in line, these
ompanies can come straight to your car with a number of different
ervices, including water-saving car washes and detailing service. And with
he new functionality, they can unlock and lock your vehicle to clean the
nterior too, even removing pet hair that’s dug its way into your seats and
oors.
piffy is finalizing the launch of their Ford and Lincoln connected vehicle
ervices for on-demand car washing in Atlanta, Charlotte, Dallas, Los
ngeles, and Raleigh. Sparkl recently launched their on-demand car
washing experience in the Chicago metro area, and Rub A Dub will launch
ater this year.
eliveries. Car washes. You can imagine the many on-demand services that
re coming to your Ford and Lincoln vehicle. After all, people everywhere
re actively looking for ways to simplify their lives. The on-demand economy
s attracting more than 22.4 million consumers annually and $57.6 billion in
pending, according to the Harvard Business Review, and that is only
xpected to grow. At Ford, we are committed to working with these service
roviders to bring valuable, convenient options directly to our customer —
r at least their car.
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Note: FordPass Connect™/Lincoln Connect™ service is required (see App Terms for
more information) and connected service and related feature functionality is
ubject to compatible AT&T-network availability. Evolving technology/cellular
etworks may affect functionality and availability, or continued provision of some
eatures, prohibiting them from functioning. Message and data rates may apply.
Delivery
Connectivity
Automotive
On Demand
50
2
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Ford Joins The In-Car Delivery Movement, Gets More Connected Services
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https://www.forbes.com/sites/samabuelsamid/2019/04/30/ford-joins-t…ar-delivery-movement-gets-more-connected-services/?sh=30e395bd3ade
A lifetime in the car business, first engineering, now communicating
TRANSPORTATION
Ford Joins The In-Car
Delivery Movement, Gets
More Connected Services
Sam Abuelsamid Senior Contributor
Follow
Apr 30, 2019, 09:00am EDT
This article is more than 3 years old.
FORD
Owners of 2017 and 2018 model Ford and Lincoln vehicles with Fordpass Connect or Lincoln
Way LTE... [+]
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Ford was a relative latecomer to the connected vehicle party. Other
automakers have been installing cellular data modems in cars for the
better part of the past two decades starting with the 1996 debut of
GM’s OnStar. Meanwhile relatively few Ford vehicles aside from
some Lincolns and plug-in vehicles have done the same. In the past
two years the narrative has shifted and by the end of this year, all
new Fords and Lincolns in North America will be connected and
offering new services enabled by data such as Key by Amazon.
Connected vehicles and services are rapidly becoming ubiquitous in
most markets. In North America and Europe virtually all new
vehicles sold will have data connectivity within the next few years. By
the late 2020s, nearly 115 million vehicles a year are expected to
have either LTE or 5G connectivity built in.
NAVIGANT RESEARCH
Projected annual light duty vehicles sales with built-in cellular connectivity - 2019-2028
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From the 2007 introduction of SYNC, Ford had focused on a bring
your own device strategy that enabled drivers to connect phones and
media players to the car and manage them by voice or dashboard
controls. SYNC 3 is still with us to enable Android Auto, Apple
CarPlay and AppLink-enabled phone apps.
However, thanks to the embedded LTE-modems going into all new
models, Fordpass Connect can now let drivers join GM and Volvo
customers in getting their Amazon packages delivered directly to the
cargo hold of their vehicle. Ford and Lincoln owners can link the
Amazon app to their Fordpass or Lincoln Way account and select in-
car delivery when they make a purchase.
The in-car connectivity will let the delivery driver know where the
vehicle is parked and owners will get notifications as the delivery
approaches. When the delivery driver arrives, the owner can use the
app to unlock the trunk or tailgate so the package can be deposited.
The delivery driver will send a notification to confirm the delivery
and relock the vehicle. Customers can get their packages delivered to
a secure location rather than being left on an open doorstep or
making a side trip to find an Amazon locker.
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While other package delivery companies aren’t yet participating in
these programs, there is nothing technologically preventing them
from doing so. Ford has a developer program that originally
launched in 2013 to enable smartphone app developers that wanted
to take advantage of SYNC AppLink to get access to the software
development kit and submit apps for approval.
The developer program (accessible at https://developer.ford.com/)
has expanded into other areas including application programming
interfaces (APIs) for the Fordpass Connect telematics system. Ford
previously announced partnerships with parking providers that
enabled drivers search for, reserve and pay for parking before
arriving at a destination.
The latest service available through Fordpass and Lincoln Way is
access for mobile car washing and detailing. Sparkl is the first
vendor to join the on-demand washing program in and around its
Chicago area base. For customers that just want an exterior scrub
down, the crew will arrive and take care of everything. Drivers that
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want interior detailing as well will get a notification like the one
provided by Amazon so they can use the Fordpass app to unlock the
car. Mobile wash services Spiffy and Rub A Dub will be joining the
program later this year.
“These are the first offerings that we have,” said Lorin Kennedy,
FordPass Ecosystem Business Leader. “We're working hard with a
lot of third parties around the pickup and delivery category. There
are a lot of other companies who are looking at ways to increase the
convenience and security of delivering packages, also curbside.”
“Because there's a great opportunity to work with retailers, when you
want to do a pickup it’s really easy then to identify the location of the
vehicle.”
FORD
Spiffy, Sparkl and Rub a Dub mobile car wash and detailing services will soon be available
through... [+]
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Until consumers start ditching their own vehicles for shared
automated vehicles, a broad range of new services are expected to be
launched that leverage the location information and connectivity
built in. Kennedy emphasized that before any applications or service
providers are approved, they are carefully vetted by Ford to ensure
data security and privacy.
In addition to providing convenience for its customers, connected
services also provide potential new revenue streams for automakers.
Kennedy declined to discuss specifics of Ford’s business
arrangements with partners.
“With any API model, there are a variety of ways in which you can do
different revenue share opportunities,” said Kennedy. “The access to
the portal is 100%, free and we're encouraging people to come and
use the API's and work with us on ways in which we can, we can
build a great solution for customers. Then today for what we're what
we're doing with the API set, we're looking at the partnership and
the type of service we provide and we work out an individual deal
with each third party.”
We'll know doubt be seeing a lot more of this from almost every
automaker in the months and years to come.
Follow me on Twitter or LinkedIn. Check out my website.
Sam Abuelsamid
I’ve spent my adult life working in and around the automotive industry. After
earning a mechanical engineering degree from GMI I spent the next 17 years
Follow
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1
Provided Services AGREEMENT
This Provided Services Agreement (this “Agreement”), made effective as of the date both parties have signed
the Agreement, 2018 (the “Effective Date”), is by and between FordSmart Mobility, LLC, a Delaware corporation,
whose principal place of business is at One American Road, Dearborn, Michigan 48126 (“Ford”) and RUB A DUB
Holdings, Inc. , a Delaware corporation whose principal place of business is at 1676 International Drive, McLean, VA
22031 (“RUB A DUB” or “Service Provider”); each a “Party” and together the “Parties”.
RECITALS
WHEREAS, RUB A DUB intends to offer customers of RUB A DUB the option to have car wash services
performed at eligible customer vehicles (rather than customers coming to a stationary car wash/service center) by
RUB A DUB Personnel; and
WHEREAS, Ford and its Affiliates manufacture vehicles outfitted with communication and other
technologies (“Ford Connected Vehicles”) that enable Ford to receive data from, and issue commands to, the Ford
Connected Vehicles; and
WHEREAS, the Parties wish to enter into this Agreement to set forth the terms by which Service Provider
will make Provider Services available to Service Provider’s Customers who own the types of Ford Connected Vehicles
identified on Exhibit A, and Service Provider and Ford will make available certain communication and other
technologies to support the Provider Services.
NOW, THEREFORE, in consideration of the mutual covenants and obligations set forth herein, the receipt
and sufficiency of which are hereby acknowledged, Service Provider and Ford agree as follows:
1.
DEFINITIONS
As used in this Agreement, the following terms shall have the following meanings:
1.1.
“Acceptance Testing” shall have the meaning set forth in Section 3.2.
1.2.
“Acceptance Date” shall have the meaning set forth in Section 3.2.
1.3.
“Affiliate” means any Person that directly or indirectly controls, is controlled by, or is under
common control with, another Person. For the purposes of this definition, the term “control” (including,
with correlative meanings, the terms “controlling”, “controlled by”, and “under common control with”), as
used with respect to any Person, means having the right to elect a majority of the board of directors or other
comparable body responsible for management and direction of a Person, or otherwise having, direct or
indirect power to direct or cause the direction of the management and policies of such Person, by contract,
ownership of voting securities, law or otherwise (e.g., by being the manager of a manager-managed limited
liability company).
1.4.
“API” means a hosted application program interface.
1.5.
“API Parameters” means specifications for one or more APIs as necessary to deliver and exchange
information between the Ford Systems and Service Provider Systems.
1.6.
“Applicable Laws” means all laws, rules, and regulations applicable to the specified entity and to
the business conducted by that entity.
1.7.
“Change of Control” means a sale or other disposition (including through a merger, stock sale or
otherwise) of 50% or more of the economic interest in or voting power of a Party in a transaction or series of
related transactions, or the sale of all or substantially all of the assets of such Party.
1.8.
“Confidential Information” means any information in any form, including oral, written, graphic,
or electromagnetic, which the Disclosing Party desires to protect against unrestricted disclosure, and is
designated as proprietary or confidential in the following manner: (a) if in writing or other tangible form,
shall be conspicuously labeled as “confidential” or “proprietary” at the time of delivery or (b) if oral, shall
be identified as “confidential” or “proprietary” prior to disclosure. Notwithstanding the foregoing, (x) the
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Confidential Information of Ford shall include all Customer Information (including Personal Data) collected
by Ford (including any Customer Information provided by Ford to Service Provider), technical know-how
and other information (including plans and strategies) related to the Ford Systems, all information regarding
Ford’s marketing strategies and prospective marketing campaigns, and all proprietary or confidential
information of Ford Affiliates; (y) the Confidential Information of Service Provider shall include all
Customer Information (including Personal Data) collected by Service Provider (including any Customer
Information provided by Service Provider to Ford), technical know-how and other information (including
plans and strategies) related to the Service Provider Systems, and all information regarding Service Provider’s
marketing strategies and prospective marketing campaigns; and (z) the terms of this Agreement shall be
deemed Confidential Information of both Parties. Confidential Information shall not include information
that (i) other than with respect to Personal Data, is or becomes generally known to the public through no act
or omission of the Receiving Party, (ii) was in the Receiving Party’s possession prior to the disclosure
hereunder without an obligation of confidentiality, (iii) is disclosed to the Receiving Party by a third party
not under an obligation of confidentiality, or (iv) was independently developed by the Receiving Party
without use or reference to the Confidential Information of the other Party.
1.9.
“Customer” means any person who registers a Ford Connected Vehicle with Service Provider for
Provided Services.
1.10.
“Customer Information” means the names, screen names, addresses, or other Personal Data or
information that identifies or pertains to Customer, including any navigational information obtained through
a tracking system, technical information retrieved from the vehicle, or payment or financial information
(including credit card, debit card, or bank account information).
1.11.
“Disclosing Party” means the Party disclosing its Confidential Information.
1.12.
“Ford Marks” means the trademarks, trade names, service marks, designs, characters, logos, and
other indicia of origin of Ford as set forth on Exhibit A.
1.13.
“Ford Systems” means the Ford controlled or provided systems or networks providing information
or functionality including any APIs used to connect to one or more systems.
1.14.
“Governmental Authorization” means all permits, consents, decisions, licenses, approvals,
certificates, confirmations or exemptions from, and all applications and notices filed with or required by, any
Governmental Entity that are required for the performance of a Party’s obligations pursuant to this
Agreement.
1.15.
“Governmental Entity” means a court, administrative agency or commission or other federal, state,
county, local or other foreign governmental authority, instrumentality, agency or commission.
1.16.
“Indemnified Party” shall have the meaning set forth in Section 9.1.
1.17.
“Indemnifying Party” shall have the meaning set forth in Section 9.1.
1.18.
“Intellectual Property Rights” means all patent, copyright, trademark, trade secret and other
intellectual property or proprietary rights of any kind.
1.19.
“Losses” shall have the meaning set forth in Section 9.1.
1.20.
“Person” means an individual, corporation, partnership, limited liability company, association,
trust or other entity or organization, including a government or political subdivision or an agency or
instrumentality thereof.
1.21.
“Personal Data” means (a) any information that can identify or locate a unique individual or be
identified to that individual, such as: name, address, telephone number, and similar items, and includes
vehicle identification number (VIN), device ID and geo-location information if the data can be associated
with a specific person; and (b) if any data is of residents of the European Union, Personal Data has the
meaning given to this term by the Data Protection Act 1998.
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1.22.
“Provided Services” means the on-location washing and other agreed maintenance services for End
Users as further defined in Exhibit A.
1.23.
“Receiving Party” means the Party receiving the other Party’s Confidential Information.
1.24.
“Service Provider Personnel” means employees, contractors, subcontractors or other
representatives or agents who perform delivery and/or returns services on behalf of Service Provider.
1.25.
“Service Provider Marks” means the trademarks, trade names, service marks, designs, characters,
logos, and other indicia of origin of Service Provider as set forth on Exhibit A.
1.26.
“Service Provider Systems” means the Service Provider Cloud, Service Provider Customer Mobile
Application, and the Service Provider Delivery Associate Mobile Application, as further set forth in Exhibit
A.
“Term” has the meaning set forth in Section 11.1.
1.27.
“Territory” means the United States, and any additional territories as mutually agreed in writing by the
Parties.
2.
OVERVIEW.
2.1.
Service Provider intends to roll-out Provided Services on a city-by-city basis within the United
States and in additional territories around the world. Ford has the capability to communicate with Ford
Connected Vehicles on a remote basis, which allows for remote control of certain vehicle functions including
lock, unlock, and flash lights.
2.2.
The Parties agree that Ford will be Service Provider’s first vehicle manufacturer participant in
Provided Services within the United States, and that Ford shall be provided, on a country by country basis,
the first right of refusal to be Service Provider’s first vehicle manufacturer participant in Provided Services
in any additional countries where Service Provider rolls-out Provided Services. As the first vehicle
manufacturer participant in a particular country, Ford will receive special marketing and advertising
treatment. Ford agrees that Service Provider will be the first Provided Services participant in the following
markets, and as the first participant Ford shall not announce or promote any other participants to the service
in these markets for ninety (90) days following the initial signing of this Agreement: Washington DC;
Northern Virginia; Philadelphia, Pennsylvania; Pittsburg, Pennsylvania; Austin, Texas; and Southern
Florida.
2.3.
Service Provider and Ford agree that the Customer interface for selecting Provided Services will be
through Service Provider, however there may be some level of integration which is visible to the Customer
between Service Provider’s Customer-facing platforms and applications and Ford’s Customer-facing
platforms and applications (e.g. FordPass); and there may be additional back-end integration between the
Party’s Customer-facing platforms and applications.
3.
DEVELOPMENT, PROVISION AND TESTING OF PROVIDED SERVICES
3.1.
API Development. Ford will make available, at its own cost, directly or via a third party of Ford’s
choice, APIs to connect the Ford Systems and Service Provider Systems for Provided Services. As between
Ford and Service Provider, Ford shall own the results of such development. Service Provider will make
available, at its own cost, directly or via a third party of Service Provider’s choice, APIs to connect Ford
Systems and Service Provider Systems for Provided Services. The Service Provider agrees to cooperate with
Ford regarding any Service Provider API Parameters. As between Ford and Service Provider, Service
Provider shall own the results of such development.
3.2.
API Acceptance Testing. Prior to making Provided Services commercially available with respect
to Ford Connected Vehicles, the Parties shall cooperate to test the connectivity and security of the Ford
Systems and Service Provider Systems for Provided Services, including whether the APIs conform to the
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API Parameters. No such commercial launch shall occur until each Party agrees (which agreement shall not
be unreasonably withheld, conditioned or delayed) in writing that such connectivity is working properly.
3.3.
Service Levels. Service Provider and Ford shall comply with the service level terms set forth in
Exhibit C hereto.
3.4.
Information Security. At all times during the Term, Service Provider and Ford shall (a) maintain
Service Provider System, Ford System, APIs, and API Parameters, as applicable, in accordance with industry
security standards; (b) implement ISO 27002 security standards relevant to the respective Ford Systems and
Service Provider Systems; (c) encrypt API Parameters (input and responses) while in transit and while at rest,
including on and between computers or contracted facilities/processors; (d) cooperate with the other Party to
verify (including by providing evidence of controls) and test (including through penetration testing) the end-
to-end security controls of the Ford Systems and Service Provider Systems as applied to Provided Services;
(e) engage subcontractors under terms at least as stringent as those agreed between Ford and Service Provider,
and be responsible for the acts of such Party’s subcontractors; (f) monitor for security incidents; (g) provide
timely notification to the other Party of security incidents in order to enable appropriate and required
remediation to be taken; and (h) treat security related information as Confidential Information.
4.
LICENSES
4.1.
Service Provider License. Service Provider hereby grants to Ford a fully paid-up, royalty-free, irrevocable,
worldwide, non-exclusive license (a) during the Term, to use Service Provider’s APIs and associated API
Parameters for the limited purpose of carrying out this Agreement; and (b) during and after the Term, to use
for any purpose information (which is not PII or Service Provider Confidential Information) derived from
shared data/parameters.
4.2.
Ford License. Ford hereby grants to Service Provider a fully paid-up, royalty-free, irrevocable, worldwide,
non-exclusive license (a) during the Term, to use Ford’s APIs and associated API Parameters listed in Exhibit
A for the limited purpose of carrying out this Agreement; and (b) during the Term, to use to use for any
purpose information (which is not PII or Ford Confidential Information) derived from shared data/parameters
(other than VINs).
4.3.
Marks. Service Provider hereby grants to Ford a fully paid-up, royalty-free, worldwide, non-
exclusive license to use Service Provider Marks, during the Term, in accordance with Service Provider’s
reasonable usage guidelines provided to Ford in writing, in connection with the advertising, marketing and
promotion (online and otherwise), of Provided Services. Service Provider will retain all goodwill and all
other rights thereto, and Ford will obtain no goodwill or any other rights thereto as a result of the use of
Service Provider Marks. Ford hereby grants to Service Provider a fully paid-up, royalty-free, worldwide,
non-exclusive license to use Ford Marks, during the Term, in accordance with Ford’s reasonable usage
guidelines provided to Service Provider in writing, in connection with the advertising, marketing and
promotion (online and otherwise), of Provided Services. Ford will retain all goodwill and all other rights
thereto, and Service Provider will obtain no goodwill or any other rights thereto as a result of the use of Ford
Marks.
4.4.
Restrictions on use. Neither Party will:
4.4.1.
use the systems of the other party to violate any laws or regulations;
4.4.2.
use or reproduce the systems of the other party in source code format;
4.4.3.
decompile, disassemble, or otherwise reverse engineer or attempt to reconstruct or
discover any source code or underlying ideas or algorithms of any of the systems of the other party by
any means whatsoever;
4.4.4.
modify or alter the systems of the other party or Documentation in any manner;
4.4.5.
knowingly introduce into or transmit through the systems of the other party any data,
content or other computer technology that may damage, interfere with, surreptitiously intercept, or
expropriate any system, program, or data, including viruses, Trojan horses, worms, or time bombs,
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irrespective of whether any such program or routine results in detrimental harm to the systems of the other
party or any data contained therein; or
4.4.6.
use the systems of the other party to (A) engage in spamming, mailbombing, spoofing
or any other fraudulent, illegal or unauthorized use of the systems of the other party; (B) transmit, store,
display, distribute or otherwise make available data or content that is fraudulent, illegal or infringing; (C)
violate the security or integrity of any network, computer or communications system, software
application, or network or computing device (each, a “System”), including without limitation by (x)
accessing or using any System without permission, (y) attempting to probe, scan, or test the vulnerability
of a System or to breach any security or authentication measures used by a System, or (z) monitoring data
or traffic on a System without permission; or (D) make network connections to any System without
permission to communicate with such System.
4.4.7.
monitor or crawl the systems of the other party in a way that impairs or disrupts any
part of the Ford Systems;
4.4.8.
inundate the systems of the other party with communication requests with the intent
that systems of the other party or any part thereof cannot respond to legitimate traffic or responds so
slowly that it becomes ineffective; or
4.4.9.
intentionally interfere with the proper functioning of any part of the systems of the other
party, including any deliberate attack to overload the systems of the other party.
5.
OWNERSHIP
Service Provider shall own all right, title, and interest in and to the Service Provider Systems, Service
Provider’s APIs and associated API Parameters, Service Provider’s Customer Information, Service Provider’s
Confidential Information, usage/operational data collected by Service Provider and other Service Provider technology,
and all Intellectual Property Rights in and to the foregoing. Ford shall own all right, title, and interest in and to the
Ford Systems, Ford’s APIs and associated API Parameters, Ford’s Customer Information, Ford’s Confidential
Information, usage or operational data collected by Ford and other Ford technology, and all Intellectual Property
Rights in and to the foregoing. In addition, each Party shall own any feedback that such Party provides regarding the
other Party’s systems, technology, information or methodologies, and such providing Party hereby grants the other
Party a fully paid-up, royalty-free, irrevocable, worldwide, non-exclusive license to use such feedback for purposes
of improving the receiving Party’s systems, technology, information and/or methodologies.
6.
ADDITIONAL RIGHTS, OBLIGATIONS, AND COVENANTS
6.1.
Marketing. Service Provider will have primary responsibility for marketing the availability of Provided
Services to its customers. Such marketing shall include appropriate references to Ford and the Ford
technology being used in connection with Provided Services, as mutually agreed by the Parties. Service
Provider represents and warrants that all communications between Service Provider and its customers will
comply with Applicable Laws, including the Telephone Consumer Protection Act, the Telemarketing and
Consumer Fraud and Abuse Prevention Act, the Telemarketing Sales Rule, the Do-Not Call Implementation
Act, and the Controlling the Assault on Non-Solicited Pornography and Marketing Act, and the respective
federal implementing regulations, and applicable state law and regulations. The parties may agree to
additional marketing responsibilities in Exhibit D.
6.2.
Non-Exclusive. While this Agreement is non-exclusive (meaning that Service Provider can offer Provided
Services in connection with other vehicle manufacturers, and Ford can use Ford’s technology to make
available Provided Services as part of other delivery and return solutions), Service Provider agrees that Ford
will be Service Provider’s first vehicle manufacturer Provided Services partner and that Ford will be
promoted and advertised as such in a meaningful manner prior to Service Provider announcing or
implementing Provided Services with any other vehicle manufacturer. Ford agrees to the marketing
conditions contained in Section 2.2.
6.3.
Support Services. Each Party shall identify one or more technical contacts for the provision of technical
support to the other Party related to Provided Services in connection with Ford Connected Vehicles
(“Support Services”). In addition, each Party shall provide relevant customer support for that Party’s
offerings, including: (a) Service Provider will provide (i) customer support for the Provided Services service,
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including in connection with the use of Service Provider web site/apps, registering vehicles, handling issues
with the delivery and changing delivery preferences and (ii) support to Service Provider Delivery Personnel;
and (b) Ford will provide customer support for Ford Connected Vehicle modem activation.
6.4.
Reports.
6.4.1.
Payment Reports. Service Provider shall provide quarterly reports to Ford to validate
the payments provided by Service Provider hereunder. Such reports shall include the date of customer
registration of a Ford Connected Vehicle for Provided Services and, if applicable, the date that such Ford
Connected Vehicle was removed from registration for Service Provider’s Provided Services option.
6.4.2.
Technology Reports. Service Provider shall provide quarterly reports to Ford to assist
in understanding problems with the Provided Services, including failed delivery issues due to technology
and vehicle issues.
6.4.3.
Additional Reports. The parties agree to provide any additional reports that are
specifically detailed in Exhibit A.
7.
FINANCIAL SHARING AND PAYMENT TERMS
The Parties shall comply with the financial sharing and related payment terms set forth in Exhibit B.
8.
REPRESENTATIONS AND WARRANTIES
8.1.
Mutual Warranties. Each Party represents and warrants to the other that:
8.1.1.
Corporate Standing. Such Party is a corporation duly incorporated, validly existing and
in good standing under the laws of the state of its incorporation. Such Party is duly qualified to do business
as a foreign corporation and is in good standing under the laws of each jurisdiction that its business, as
currently being conducted, will require it to be so qualified.
8.1.2.
Due Authorization; Enforceability. Such Party possesses all requisite power and
authority to enter into and perform this Agreement. Such Party’s execution, delivery and performance of
this Agreement have been duly authorized and this Agreement has been duly executed and delivered and
constitutes such Party’s legal, valid and binding obligation, enforceable against such Party in accordance
with its terms, except as enforceability may be limited by bankruptcy, insolvency and other legal
principles pertaining to creditor’s rights.
8.1.3.
Governmental Authorizations; Compliance with Law. Such Party is the holder of and
is in compliance with all Governmental Authorizations required in order for such Party to enter into and
perform its obligations under this Agreement. As of the Effective Date, such Party is not in violation of
any Applicable Law which violation, individually or in the aggregate, would affect its performance of
any obligation under this Agreement, or its ability to grant the rights granted to the other Party under this
Agreement. None of the execution, delivery or performance of this Agreement or compliance with the
terms and provisions hereof will result in the violation by such Party of any Applicable Law.
8.1.4.
Litigation. There is no litigation, nor are there any proceedings by or before any
arbitrators, courts or other Governmental Authorities pending or, to its best knowledge, threatened against
it which, if adversely determined, could reasonably be expected to have a material adverse effect on its
ability to perform all of its obligations under this Agreement.
8.1.5.
No Breach or Consent Required. None of the execution, delivery or performance of this
Agreement, the consummation of the transactions herein contemplated, or compliance with the terms and
provisions hereof: (i) will conflict with or result in a breach of any agreement or instrument to which it is
a party or by which it is bound or to which it or any of its assets are subject, or constitute a default under
any such agreement or instrument; or (ii) require consent or approval of a third party or Governmental
Entity.
8.2.
Warranty Disclaimers. EXCEPT FOR THE REPRESENTATIONS AND WARRANTIES SET FORTH
IN SECTION 8.1 OR AS OTHERWISE EXPRESSLY PROVIDED FOR IN THIS AGREEMENT,
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NEITHER PARTY MAKES ANY REPRESENTATIONS OR WARRANTIES CONCERNING
PROVIDED SERVICES OR SUCH PARTIES DELIVERABLES IN CONNECTION WITH THIS
AGREEMENT, EXPRESS OR IMPLIED. EACH PARTY SPECIFICALLY DISCLAIMS THE IMPLIED
WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, SYSTEM
INTEGRATION, AND NONINFRINGEMENT WITH RESPECT TO ANY AND ALL DELIVERABLES
PROVIDED BY FORD OR SERVICE PROVIDER IN CONNECTION WITH THIS AGREEMENT.
NEITHER PARTY GUARANTEES THAT USE OF SUCH PARTY’S DEVLIERABLES WILL BE
UNINTERRUPTED OR ERROR-FREE.
9.
INDEMNITY
9.1.
Mutual. Each Party (the “Indemnifying Party”) hereby agrees to defend, indemnify, and hold harmless
the other Party, its Affiliates, and its and their respective officers, directors, employees, agents, successors,
and assigns (collectively, “Indemnified Parties”) from and against all claims, costs, liabilities,
judgments, expenses, and damages (including amounts paid in settlement and reasonable attorneys’ fees,
costs and expenses) (collectively, “Losses”) incurred by an Indemnified Party as a result of any claim,
demand, action, or proceeding against such Indemnified Party asserted by a third party arising out of or in
connection with the Indemnifying Party’s breach of any covenants, warranties, or representations made in
this Agreement.
9.2.
By Service Provider. Service Provider hereby agrees to defend, indemnify and hold harmless Ford and the
other Ford Indemnified Parties from and against all Losses incurred by Ford and such other Ford Indemnified
Parties as a result of any claim, demand, action, or proceeding against a Ford Indemnified Party asserted by
a third party relating to or arising out of (a) the provision of Provided Services to a customer, including claims
for any actual or alleged bodily injury (including death); damage to, or theft of, any tangible or real property
(e.g., damage to or theft of a vehicle or property in a vehicle); contraband placed in a vehicle; or act or
omission of Service Provider, its affiliates, or Provided Services delivery personnel or contractors (including,
without limitation, any failure of Service Provider Delivery Personnel to lock a vehicle immediately
following completion of the applicable delivery); (b) any agreement between Service Provider and an Service
Provider customer; or (c) any breach of law by Service Provider or its Affiliates; except in the case of (a) -
(c) to the extent that the claim, loss or liability is due to Ford’s breach of this Agreement, intentional
misconduct, or gross negligence.
9.3.
By Ford. Ford hereby agrees to defend, indemnify and hold harmless Service Provider and the other Service
Provider Indemnified Parties from and against all Losses incurred by Service Provider and such other Service
Provider Indemnified Parties as a result of any claim, demand, action, or proceeding against an Service
Provider Indemnified Party asserted by a third party relating to or arising out of any breach of law by Ford
or its Affiliates; except to the extent that the claim, loss or liability is due to Service Provider’s breach of this
Agreement, intentional misconduct, or gross negligence.
9.4.
Conditions. The Indemnified Party shall give prompt written notice to the Indemnifying Party of any claim,
demand, action, or proceeding for which indemnity is sought. The Indemnifying Party shall lead the defense
or settlement of any such claim, demand, or action, at the expense of the Indemnifying Party, if requested by
the Indemnified Party in writing. If the Indemnified Party does not provide such written request, the
Indemnified Party shall lead the defense or settlement of such claim, demand, or action, at the expense of the
Indemnifying Party. Notwithstanding anything to the contrary, the failure of the Indemnified Party to give
prompt notice or to timely mitigate shall not affect the Indemnified Party’s rights to indemnification, except
(and then only to the extent) that the Indemnifying Party’s ability to provide indemnification is impeded or
frustrated or Losses would have been avoided by prompt notice or mitigation. The Indemnifying Party shall
obtain the written agreement of the Indemnified Party prior to entry into any non-monetary settlement or
proposal of settlement, or admission of any fault on the part of the Indemnified Party, relating to any claim
for which indemnification is due hereunder.
10.
LIMITATION OF LIABILITY
EXCEPT FOR CLAIMS RELATING TO INDEMNIFICATION UNDER SECTION 9, BREACHES OF A
PARTY’S OBLIGATIONS WITH RESPECT TO CONFIDENTIAL INFORMATION, BREACHES OF A
PARTY’S OBLIGATIONS RELATING TO THE OTHER PARTY’S INTELLECTUAL PROPERTY, AND
CLAIMS ARISING FROM FRAUD, WILLFUL MISCONDUCT OR GROSS NEGLIGENCE, UNDER NO
CIRCUMSTANCES SHALL EITHER PARTY (OR ANY OF ITS AFFILIATES) BE LIABLE TO THE OTHER
PARTY (OR ANY OF ITS AFFILIATES), WHETHER IN CONTRACT OR IN TORT, UNDER THIS
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AGREEMENT FOR (A) INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR EXEMPLARY
DAMAGES (EVEN IF THE PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES),
INCLUDING, LOSS OF REVENUE, ANTICIPATED PROFITS, DATA, CONTENT, OR BUSINESS, OR (B)
AMOUNTS IN EXCESS OF $5,000,000.
11.
TERM, SUSPENSION AND TERMINATION
11.1.
Term. The Term of this Agreement shall commence on the Effective Date and, unless terminated earlier in
accordance with this Agreement, shall continue until the third anniversary of the Effective Date (“Term”).
11.2.
Suspension. Either Party may suspend its performance under this Agreement immediately in regard to a
particular customer or vehicle, or category of customers or vehicles (e.g. customers or vehicles located in a
certain geographic area) if provision of Provided Services to those customers or vehicles violates or is
reasonably likely to violate Applicable Law or court order, or be subject to regulation, or exposes or is
reasonably likely to expose the Party’s or its Affiliates’ IT systems or application to risk (e.g. risk of
intrusion/hacking/denial of services attacks). The Parties will discuss in good faith the cause of any such
suspension and the extent to which such cause can be addressed by the Parties in a manner to remove the
violation, regulation or exposure.
11.3.
Termination for Breach. Either Party may terminate this Agreement if the other Party materially breaches
this Agreement and fails to cure such breach within thirty (30) days following receipt of written notice
thereof.
11.4.
Termination for Bankruptcy. Either Party may terminate this Agreement upon written notice if the other
Party (a) terminates or suspends its business (and there is no successor); (b) becomes insolvent or subject to
bankruptcy or insolvency proceedings or direct control by a trustee, receiver or similar authority; or (c) has
wound up or liquidated, voluntarily or otherwise and there is no successor.
11.5.
Termination for Convenience. Either Party may terminate this Agreement at any time for its convenience
by providing the other Party with at least sixty (60) days’ notice in advance of such termination. If Ford
terminates under this Section 11.5 within the first year of operations than Ford shall reimburse Service
Provider for documented expenses up to a maximum of $20,000 directly applicable to Supplier’s IT
development costs to connect to Ford’s systems.
11.6.
Termination for Violation in Applicable Law. Either Party may terminate this Agreement immediately
upon written notice if (a) the provision of Provided Services violates or is reasonably likely to violate
Applicable Law or court order, or (b) Provided Services becomes subject to regulation, in each case, in a
majority of the US cities planned to be covered by Service Provider’s Provided Services offering.
11.7.
Effect of Termination. The exercise of any termination right hereunder shall not limit a Party’s remedies
as otherwise provided under this Agreement and/or at law. Except as set forth in this Section, upon
termination or expiration of this Agreement for any reason, the licenses granted in this Agreement shall
terminate. The provisions of Articles 1, 5, 7, 9, 10, 11.8, and 13 shall survive the expiration or earlier
termination of this Agreement.
12.
CONFIDENTIALITY
Each Party acknowledges that in performing under this Agreement, it may gain access to Confidential
Information belonging to the other Party. Accordingly, when the Receiving Party receives Confidential Information
from the Disclosing Party, the Receiving Party shall, and shall obligate its employees and agents to: (a) maintain the
Confidential Information received from the Disclosing Party in accordance with the Section; and (b) not disclose the
Confidential Information received from the Disclosing Party to a third party without the Disclosing Party’s prior
written approval. Each Party undertakes to ensure that its employees and agents are bound by confidentiality and
nondisclosure obligations with respect to such Confidential Information that are no less strict than the confidentiality
and nondisclosure obligations set forth in this Article 12. Each Party also shall have the right to disclose Confidential
Information to its Affiliates in accordance with the foregoing sentence. Each Party shall take reasonable measures to
protect the Confidential Information of the other Party, which measures shall not be less than the measures taken by
such Party to protect its own confidential and proprietary information. All Confidential Information shall remain the
sole property of the Disclosing Party. The obligations of the Receiving Party under this Article 12 shall continue
during the Term and for a period of two (2) years after expiration or termination thereof; provided, however, that with
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respect to Customer Information (including Personal Data), the obligations of the Receiving Party under this Article 12
shall continue indefinitely. In the event of an actual or reasonably suspected data breach, unauthorized access,
misappropriation, or other compromise of the security, confidentiality, or integrity of the Disclosing Party’s
Confidential Information, that Receiving Party shall (1) immediately take action to prevent any further breach, (2)
immediately notify the Disclosing Party of such breach, (3) cooperate with the Disclosing Party to develop and
implement corrective actions to resolve the data breach, (4) comply with any remedial requirements, including
reporting requirements, of applicable data breach law, and (5) be responsible for all costs associated with remedial
actions. With regard to Ford Personal Data, such notification shall be made to CIRT@ford.com. If no response is
received within sixty minutes, call U.S. (313) 580-6328.
13.
GENERAL
13.1.
Public Announcements. Except as otherwise permitted in this Agreement (including in the licenses granted
to Ford under Section 4.1 and Section 4.2) or as required by Applicable Law or a listing agreement with a
national securities exchange (in which case the issuing party will consult with the other Party prior to making
any a release or statement), neither Party shall use the other Party’s or its Affiliates’ names or logos, or
otherwise issue any publicity releases or make any public statement(s) (including in the form of news
releases, advertising or solicitation materials, or blog or social media postings) relating to this Agreement,
without the prior written approval of the other Party, which approval shall not be unreasonably withheld,
conditioned or delayed.
13.2.
No Agency or Joint Venture. The Parties agree and acknowledge that the relationship of the Parties under
this Agreement is that of independent contracting parties. This Agreement shall not be deemed to create a
partnership or joint venture between the Parties, and neither Party nor its agents, partners, employees, or
contractors is the other Party’s agent, partner, employee, or representative.
13.3.
Severability. Should any provision of this Agreement be held to be void, invalid, or unenforceable, such
provision shall be enforced to the maximum extent permissible, and the remaining provisions of this
Agreement shall remain in full force and effect.
13.4.
No Waiver. The failure of either Party to partially or fully exercise any right or the waiver by either Party
of any breach shall not prevent a subsequent exercise of such right or be deemed a waiver of any subsequent
breach of the same or any other term of this Agreement.
13.5.
No Assignment; Affiliate Rights. Neither Party may assign this Agreement or any of its rights or obligations
under this Agreement, whether by operation of law or otherwise, without the prior written consent of the
other Party, which consent shall not be unreasonably withheld, except that either Party may assign this
Agreement (in whole or in part) to any of its Affiliates without the consent of the other Party. Any attempted
assignment or other transfer in violation of the foregoing shall be void and of no force or effect. Either Party,
at its option, may exercise any of its rights or remedies under this Agreement, or perform any of its duties or
obligations hereunder, by itself or through any of such Party’s Affiliates in conformity with the terms and
conditions of this Agreement.
13.6.
Binding Agreement. This Agreement shall be fully binding upon, inure to the benefit of and be enforceable
by the Parties hereto and their permitted successors and assigns.
13.7.
Notices. Any notice required or permitted to be given under this Agreement shall be in writing and shall be
deemed duly given (a) if delivered personally, when received, (b) if sent by recognized overnight courier
service, on the business day following the date of deposit with such courier service, and (c) if sent by
registered mail, postage prepaid, return receipt requested, on the third business day following the date of
deposit in the United States mail. All such notices shall be addressed to a Party at the following address:
If to Ford:
Ford Smart Mobility, LLC
One American Road
Dearborn, Michigan 48126
Attention: Corporate Secretary
CC: Director, Digital Services
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If to Service Provider:
RUB A DUB Holdings, LLC
1676 International Drive
McLean, VA 22031
Attention: Daniel Tisone, CEO
or to such other address as a Party shall notify the other in accordance with this Section 13.7.
13.8.
Entire Agreement. This Agreement and the exhibits hereto, which are incorporated herein by this reference,
set forth the entire agreement between the Parties regarding the subject matter hereof and supersede in their
entirety all prior written or oral negotiations, understandings and agreements between the Parties concerning
the subject matter hereof. Any amendment or modification of this Agreement must be in a writing signed by
both Parties.
13.9.
Governing Law. The interpretation, validity, and enforcement of this Agreement, and all legal actions
brought under or in connection with the subject matter of this Agreement, shall be governed by the law of
the State of Michigan (except that any conflicts-of-law principles of such state that would result in the
application of the law of another jurisdiction shall be disregarded).
13.10.
Dispute Resolution.
13.10.1.
Negotiation. In the event of a dispute between the Parties relating to this Agreement,
the Party raising the matter in dispute will notify the other Party in a written notice describing in sufficient
detail the nature of the dispute (“Dispute Notice”). The Parties will promptly meet and negotiate in good
faith to reach a fair and equitable settlement. At the end of sixty (60) days, if no settlement has been
reached, either Party may end discussions and declare an impasse.
13.10.2.
Mediation. If an impasse is declared under Section 13.11.1, the Parties will participate
in non-binding mediation by a third-party mediator in good faith. The Parties will promptly agree on the
mediator and the cost of the mediator will be shared equally. The mediator shall have ninety (90) days
from the date of appointment to help resolve the dispute.
13.10.3.
Arbitration. The Parties may request the other to participate in binding arbitration
following the declaration of an impasse under Section 13.11.1 or the conclusion of mediation under
Section 13.11.2. The request will be made in a Dispute Notice provided within thirty (30) days following
the end of the applicable resolution time period, and the other Party must respond within thirty (30) days
after receipt of the Dispute Notice. Neither Party is required to participate in any arbitration proceeding
under this Section 13.11.3.
13.10.4.
Litigation. If the dispute has not been resolved within sixty (60) days after the end of
the mediation period specified in Section 13.11.2, litigation may be initiated, unless the Parties agree to
arbitration under Section 13.11.3. In any litigation, the Parties agree that the litigation will be filed only
in accordance with Section 13.11.6.
13.10.5.
Effect on Parties’ Rights. The dispute resolution processes specified in this Section
13.11 are not preconditions to the exercise by any of the Parties of their respective rights or remedies
under this Agreement or Applicable Law. The exercise by any Party of its rights will not, however, affect
any Party’s obligations to comply with the requirements of this Section 13.11.
13.10.6.
Jurisdiction; Service of Process. Any Proceeding arising out of or relating to this
Agreement shall be brought in the Circuit Court for the County of Oakland, Michigan (6th Circuit –
Pontiac), or, if it has or can acquire jurisdiction, in the United States District Court for the Eastern District
of Michigan, Southern Division in Detroit, and each of the Parties irrevocably submits to the exclusive
jurisdiction of each such court in any such Proceeding, waives any objection it may now or hereafter have
to venue or to convenience of forum, agrees that all claims in respect of such Proceeding shall be heard
and determined only in any such court, and agrees not to bring any Proceeding arising out of or relating
to this Agreement in any other court.
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13.11.
Audit. Ford shall have the right at any reasonable time to send its authorized representatives to examine all
books, records and other materials in the possession or under the control of Service Provider relating to any
of Service Provider's payment obligations under this Agreement. Service Provider shall maintain all such
books, records and other materials relating to this Agreement for a period of two years after the expiration or
termination (whichever first occurs) of this Agreement.
13.12.
Other Definitional and Interpretative Provisions. The words “hereof,” “herein” and “hereunder” and
words of like import used in this Agreement shall refer to this Agreement as a whole and not to any particular
provision of this Agreement. The captions herein are included for convenience of reference only and shall
be ignored in the construction or interpretation hereof. References to Sections and Exhibits are to those in or
to this Agreement, unless otherwise specified. All Exhibits hereto are hereby incorporated in and made a
part of this Agreement as if set forth in full herein. Any capitalized terms used in any Exhibit, but not
otherwise defined therein, shall have the meaning as defined in this Agreement. Any singular term in this
Agreement shall be deemed to include the plural, and any plural term the singular. Whenever the words
“include,” “includes” or “including” are used in this Agreement or any Exhibit, they shall be deemed to be
followed by the words “without limitation,” whether or not they are in fact followed by those words or words
of like import. “Writing,” “written” and comparable terms refer to printing, typing and other means of
reproducing words (including electronic media) in a visible form. References in this Agreement to any
Person include the successors and permitted assigns of that Person.
13.13.
Counterparts. This Agreement may be executed in one or more counterparts, each of which shall be deemed
an original and all of which, when taken together, shall constitute one and the same instrument.
IN WITNESS WHEREOF, the Parties have executed and delivered this Agreement effective as of the Effective
Date.
Ford Smart Mobility, LLC
RUB A DUB Holdings, LLC
By:
______________________________
By:
___________________________
Name: ______________________________
Name: ___________________________
Title:
______________________________
Title:
___________________________
Date:
______________________________
Date:
___________________________
Daniel Tisone
Founder
Aug 9, 2018
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Brett Wheatley
VP, Mobility Marketing & Growth
Oct-03-2018
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Exhibit A
Ford Connected Vehicles
o
Ford Connected Vehicles are those vehicles for which Ford has equipped a method of remote connectivity
(i.e. modem) that is capable of providing the API Parameters to third parties and for which the modem has
been activated by the customer and the customer has consented to Provided Services via a Ford designated
consent process.
o
For the avoidance of doubt, Ford has no obligation to cause modems to be (or remain) activated by
customers or to promote activation.
API Parameters:
Ford shall make available to Service Provider under the terms of the Agreement APIs to enable the following
functions:
1. Vehicle and Account authentication
2. Geolocation of the vehicle including latitude and longitude
3. Remote light blink command
4. Door lock and unlock command
Service Provider Systems
1. Service Provider’s web application and back end database systems running on an Amazon EC2 Cloud
2. Service Provider’s Mobile Applications for iOS / Android
Additional Reports:
Service Provider shall provide Ford with the following additional reports:
1. Service Provider will provide quarterly reporting to Ford which contains, at minimum, the following
information in a manner mutually agreeable by the parties:
2. Customer demographic and usage data to enable Ford to match Customers with the associated Ford account
3. Customer transaction history
4. Service Providers KPIs for the Provided Service including metrics on how Service Provider has delivered
services to customers using Ford Systems
5. Times of orders
6. Times of service
7. Other reports that are agreed between the parties from time to time
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Ford Marks
A. Ford Marks: Ford blue oval and the FordPass “F” logo
B. Guidelines for Using the Ford Marks (“Ford Guidelines”)
Guidelines for Using the Ford Marks (“Ford Guidelines”)
Strict compliance with these Ford Guidelines is required at all times, and any use of an Ford Mark in violation of these
Guidelines will automatically terminate any license related to Service Provider’s use of the Ford Mark.
1.
Service Provider may use the Ford Marks solely for the purpose and in a manner expressly authorized by Ford in
writing and Service Provider’s use must: (i) comply with the most up-to-date version of these Ford Guidelines;
(ii) comply with Ford’s Global Look + Style Guidelines (provided upon request); and (iii) comply with any other
reasonable terms, conditions, or policies that Ford may issue from time to time that apply to the use of the Ford
Marks and of which Ford provides Service Provider with written notice.
2.
Ford will supply approved Ford Marks images for Service Provider to use. Service Provider may not alter the
Ford Marks in any manner, including but not limited to, changing the proportion, color, or font of the Ford Marks,
or adding or removing any element(s) to or from the Ford Marks. Prior to using Ford Marks, Service Provider
shall provide all materials incorporating Ford Marks to Ford for its written approval.
3.
Service Provider shall not at any time do any act or thing which will, in Ford’s sole discretion, in any way impair
the rights of Ford to the Ford Marks or the goodwill of the Ford Marks.
4.
Service Provider acknowledges that all rights to the Ford Marks are the exclusive property of Ford, and all
goodwill generated through Service Provider’s use of the Ford Marks will inure solely to the benefit of Ford.
Service Provider will not take any action that is in conflict with Ford’s rights in, or ownership of, the Ford Marks.
5.
Service Provider agrees that its right to use the Ford Marks shall exist only when and so long as the Agreement
remains in effect and Service Provider shall promptly cease all use of the Ford Marks upon expiration or
termination of the Agreement for any reason.
Ford reserves the right, exercisable at its sole discretion, to reasonably modify these Ford Guidelines
and/or the list of Ford Marks in Appendix A at any time and to take appropriate action against any use without
permission or any use that does not conform to these Ford Guidelines as provided in writing to Service
Provider.
Service Provider Marks
A. Service Provider Marks: RUB A DUB yellow duck with three yellow circles and the RUB A DUB text
logo, slogan “Car Care for Smart Cities” text, RUB A DUB mobile application icon (black square with
yellow duck and three yellow circles)
B. Guidelines for Using the RUB A DUB Marks (“RUB A DUB Guidelines”)
Guidelines for Using the RUB A DUB Marks (“RUB A DUB Guidelines”)
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Strict compliance with these RUB A DUB Guidelines is required at all times, and any use of an RUB A DUB Mark
in violation of these Guidelines will automatically terminate any license related to Ford's use of the RUB A DUB
Mark.
1.
Ford may use the RUB A DUB Marks solely for the purpose and in a manner expressly authorized by RUB A
DUB in writing
2.
RUB A DUB will supply approved RUB A DUB Marks images for Ford to use. Ford may not alter the RUB A
DUB Marks in any manner, including but not limited to, changing the proportion, color, or font of the RUB A
DUB Marks, or adding or removing any element(s) to or from the RUB A DUB Marks. Prior to using RUB A
DUB Marks, Service Provider shall provide all materials incorporating RUB A DUB Marks to Ford for its written
approval.
3.
Ford shall not at any time do any act or thing which will, in RUB A DUB’s sole discretion, in any way impair the
rights of RUB ADUB to the RUB A DUB Marks or the goodwill of the RUB A DUB Marks.
4.
Ford acknowledges that all rights to the RUB A DUB Marks are the exclusive property of RUB A DUB, and all
goodwill generated through Ford’s use of the RUB A DUB Marks will inure solely to the benefit of RUB A DUB.
Ford will not take any action that is in conflict with RUB A DUB’s rights in, or ownership of, the RUB A DUB
Marks.
5.
Ford agrees that its right to use the RUB A DUB Marks shall exist only when and so long as the Agreement
remains in effect and Ford shall promptly cease all use of the RUB A DUB Marks upon expiration or termination
of the Agreement for any reason.
RUB A DUB reserves the right, exercisable at its sole discretion, to reasonably modify these RUB A
DUB Guidelines and/or the list of RUB A DUB Marks in Appendix A at any time and to take appropriate action
against any use without permission or any use that does not conform to these RUB A DUB Guidelines as
provided in writing to Ford.
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EXHIBIT B
FINANCIAL SHARING AND PAYMENT TERMS
1. Payment Amounts. Service Provider shall pay to Ford an amount of 10% if the total cost of service,
rounded down to the nearest dollar for every individual service call ordered on Service Provider’s network by
an account where the End User has enabled Service Provider’s access to Ford Vehicle Services.
Should Ford and Service Provider renew this agreement, Ford agrees to hold the Payment Amounts at the
current amounts for two (2) one-year renewal periods.
2.
Process.
a.
Processing of End User Payments; Payment of Processing Fees.
i. Service Provider shall manage or facilitate payment processing for all End User transactions
ii. Service Provider will pay all third-party charges or fees that it incurs for processing End-User
payments.
b.
Monthly Payment.
Within 7 Business Days from the end of a month, Provider will pay Ford the fees agreed in Exhibit B
Section 1. Such payments will be made by EFT to a bank account specified by Ford (as applicable). A
"Business Day" means a day that is not a Saturday, Sunday or other day on which commercial banks in
Detroit, Michigan are authorized or required by law to close.
3.
Reporting
Provider will report and provide Ford with standard quarterly reports on the activity generated by customers
who have either enrolled in the Provider service who will use the Ford Vehicle Services.
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EXHIBIT C
SERVICE LEVELS
A. Service Levels: Ford
API Parameter Response: The technical specifications would describe the API Parameter responses for
various Provided Services situations. Ford would provide at least the same level of API Parameter response
to Service Provider as Ford provides to Ford vehicle owners.
Overall availability: Ford would provide at least the same level of Ford System availability to Service
Provider as Ford provides to Ford vehicle owners.
Transaction Load: Ford would provide at least the same level of Ford System transaction load capability to
Service Provider as Ford provides to Ford vehicle owners.
B. Service Levels: Service Provider
Service Provider would engage in appropriate API request behavior (e.g., avoid DoS attacks)
Service Provider would support issue resolution by providing data.
DocuSign Envelope ID: F2B9D8F4-B24C-43F2-8225-0B6CC1B746F3
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EXHIBIT D
MARKETING AGREEMENTS
Service Provider will work with Ford specified mobile application teams to optimize and deliver a promotional
strategy to all customers owning or leasing a connected vehicle.
During the Term, Ford will relay to Customers of Ford that have Ford Connected Vehicles and who
have elected to receive applicable marketing messages from Ford reasonable Service Provider
promotions and offers based on a mutually agreed marketing plan between Service Provider and Ford.
These promotions and offers will be limited to users in geographies where Service Provider offers
service.
Ford agrees to reasonably work with Service Provider in the first 60 days to develop a public relations
strategy to announce the launch of the service. Any Service Provider independent statements must
comply with Ford’s Publicity Web-Guide and Advertising Web-Guide.
DocuSign Envelope ID: F2B9D8F4-B24C-43F2-8225-0B6CC1B746F3
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Attachment 29
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Tec Ventures COVID Pandemic Business Support Application and Response April 2020
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OJT Monthly Invoice
Equal Opportunity Employer/Program. Auxiliary aids and services are available upon request to individual with disabilities.
Case Management Team – revised Jan 25, 2011
Northern Virginia Workforce Investment Area
On-The-Job Training Program
Employer Monthly Invoice
This form must be completed by the OJT Employer and mailed directly to the WIOA Case Representative monthly during the OJT contract period.
April 22, 2019- July 05. 2019
$11.00
Per Hour
____________________________________________
$______ 1199.00
____________________________________________
CONTRACT PERIOD:
Logistics Operations Assoicate
$22.00
Per Hour
OJT WAGE RATE:
30 $ 660.00 $ 330.00
$ 880.00 $ 440.00
40
39 $ 858.00 $ 429.00
06/29/19
Total amount due:
Manager Signature:
OJT Trainee Signature:
OJT Pay Wage
Sat
Number of hours worked each day (please indicate date matching the day worked)- week
per line please- Date worked top line hours worked bottom line
Sun
Mon
Tue
Wed
Thu
Fri
Total
9445 Fairfax Blvd. #2019 Fairfax, VA 22031
EMPLOYER NAME:
EMPLOYER CONTACT REPRESENTATIVE:
EMPLOYER BILLING ADDRESS:
OJT TRAINEE NAME:
JOB TITLE:
Daniel Joseph
RUB A DUB
Nathaly Alfaro
07/04/19
07/05/19
06/30/19
07/01/19
07/02/19
07/03/19
8
7
7
06/23/19
06/24/19
06/25/19
06/26/19
06/27/19
06/28/19
8
8
8
8
8
# of Hours
(MAX 40)
Gross Pay
Pay Period
Start Date
Pay Period
End Date
Pay Date
HOURLY WAGE:
06/16/19
06/17/19
06/18/19
06/19/19
06/20/19
06/21/19
06/22/19
8
7
8
8
8
0
8
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OJT Monthly Invoice
Equal Opportunity Employer/Program. Auxiliary aids and services are available upon request to individual with disabilities.
Case Management Team – revised Jan 25, 2011
Northern Virginia Workforce Investment Area
On-The-Job Training Program
Employer Monthly Invoice
This form must be completed by the OJT Employer and mailed directly to the WIOA Case Representative monthly during the OJT contract period.
April 22, 2019- July 05. 2019
$11.00
Per Hour
____________________________________________
$____1,276.00_________________________________________________________
____________________________________________
CONTRACT PERIOD:
Logistics Operations Assoicate
$22.00
Per Hour
OJT WAGE RATE:
$ 660.00 $ 330.00
30
30 $ 660.00 $ 330.00
$ 528.00 $ 264.00
24
32 $ 704.00 $ 352.00
06/01/19
Total amount due:
Manager Signature:
OJT Trainee Signature:
OJT Pay Wage
Sat
Number of hours worked each day (please indicate date matching the day worked)-
week per line please- Date worked top line hours worked bottom line
Sun
Mon
Tue
Wed
Thu
Fri
6
6
6
Total
$ 2,552.00 $ 1,276.00
9445 Fairfax Blvd. #2019 Fairfax, VA 22031
EMPLOYER NAME:
EMPLOYER CONTACT REPRESENTATIVE:
EMPLOYER BILLING ADDRESS:
OJT TRAINEE NAME:
JOB TITLE:
Daniel Joseph
RUB A DUB
Nathaly Alfaro
06/06/19
06/07/19
06/08/19
06/09/19
06/10/19
06/11/19
06/12/19
06/13/19
06/14/19
06/15/19
06/02/19
06/03/19
06/04/19
06/05/19
6
6
6
05/26/19
05/27/19
05/28/19
05/29/19
05/30/19
05/31/19
0
6
6
6
6
# of Hours
(MAX 40)
Gross Pay
Pay Period
Start Date
Pay Period
End Date
Pay Date
HOURLY WAGE:
05/19/19
05/20/19
05/21/19
05/22/19
05/23/19
05/24/19
05/25/19
8
6
6
6
6
6
6
6
6
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Earn your certificate in automotive re-conditioning
through our training program and benefit from
employment placement assistance.
Automotive Detailing Training
GAIN
THE
SKILLS
FOR
EMPLOYMENT
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Welcome
One of the world’s largest and most advanced car detailing
and auto reconditioning training facilities. Auto Detailing
Training is an entrepreneurial-minded training course for
Professional Auto Detailing & Reconditioning. The courses
offered provide attendees with the appropriate
information, knowledge and certification necessary to start
a career in automotive reconditioning or start their own
lucrative auto detailing business.
The Auto Detailing Training program is a hands-on training
curriculum that includes detailed instruction from some of
the most world renowned detailing professionals. From
the first day you set foot in our lecture classrooms and are
handed your detailer training guide, to the days that follow
getting hands-on guidance in the Professional Detailing
Arena. Every step brings you closer to achieving success.
Our job placement services also often lead to employment.
Easy
to learn
Available
Secure
a Career
Mentorship &
Support
Through Success
Automotive Detailing Training is a certificate program that teaches all
aspects of automotive detailing & reconditioning. Our curriculum allows
you to explore all aspects of Auto Detailing and Reconditioning,
matched by in-depth study in many areas of marketing, business
development, communication, and systems for success.
Thank you for your
interest in Automotive Detailing Training!
Auto Detailing Training program overview
Our training program will give you the tools, knowledge and experience
you need to succeed!
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Job Placement Assistance
We have built a strong reputation for providing quality
training which has been validated by the industry with our
students being in high demand.
We are proud of the placement rate for graduating
students. Our HR department takes care of our graduate’s
employment needs. We provide services such as our alumni
recruit database, job postings, and student events further
support our students and have helped thousands of
graduates start successful careers in the Automotive
Industry.
Our advisors look forward to assisting you in finding the
right profession for you. If you’re ready to get started on a
new career path, fill out the application form online or call
us to discuss your career potential.
HOW IT
WORKS
Learn Success through Success!
By bringing together industry leaders and innovators our professors are the most
successful in all areas of detailing. Imagine learning how to succeed from professionals
who actually have and continue to succeed.
Guided Hands-On Training
After class lecture, you will enter a hands-on educational
workshop structured around the basic techniques,
machines, and products used in dual-action polishing.
Discover all the tips and tricks the professionals use to
remove swirls, scratches, and oxidation while also learning
how to utilize the dual-action polisher to apply wax and
sealant to any vehicle.
We can teach you the newest and most advanced buffing
and polishing techniques and take the guesswork away!
Class Room Lecture
We begin in the class room through an interactive course.
You will be educated on everything from advanced
communication skills to modern sales techniques.
You will also learn how to properly use and safely handle all
chemicals, machines and accessories to maximum efficiency.
Our classroom setting is where our instructors take an
informal yet effective approach in showing you ways to
confidently communicate with your customers.
Auto Detailing Training program overview
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875
Apply
Choose the course you and
schedule application
interview with a member of
our program. We will guide
you through the process
and what each program
entails.
Courses
We have many courses
available from 1 day
crash courses to our 5
day "Master Course"
which includes all
aspects of auto detailing
& reconditioning.
Career Placement
Upon completion of
course you will be able to
interview with our partner
companies which include
auto dealerships and auto
body shops should you so
choose.
Continued Support
Our staff is always
available for students
through our Established
mentorship program to
assure that every student
receives the ongoing
support as they grow.
THE
SYSTEM
APPLY
Start
interviews
with partner
companies
5 Day
Master
Course
Basics
of
Detailing
Intro to
Buffing &
Polishing
Windshield
Repair
Training
Mentorship
Re-Train
LEARN
IMPLEMENT
GROW
The Auto Detailing Training program is developed to give students the
framework and systems necessary to become more effective detailers and
find successful careers in automotive industry.
START
Auto Detailing Training program overview
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SERVICES
TouchFree Automatic
2 stations
Carrum Downs
Hall Rd
Evans Rd
Frankston
11
11
4
Turbo Vacuum
3 stations
Dog Wash
1 station
Self-Service
4 stations
Vending
8 items
Start a career with RUB A
DUB after earning a
certificate in auto detailing
and re-conditioning!
With the RUB A DUB Provider
Application you can receive service
requests from area buildings,
dealerships and auto body shops!
Our system allows you to excel!
After completion of the Auto Detailing Training program,
you will be able to gain employment through one of
our partners or through RUB A DUB!
On day 5 of our program, you will meet with an area GM to
interview and find out your career goals and inquire about
job placement assistance.
Should you choose, we will on-board you into our system
and provide you with our software to get started as an area
detailer!
Auto Detailing Training program overview
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Day 1
Determine a vehicle needs
Scratches & micro marring
Determine paint condition
Basic Safety and Legal
Laying Out The Groundwork
Chemicals & Supplies
Detailing Tools Overview
The Course
Curriculum
Our training program is very cost e ective.
Auto Detailing Training is a hands-on training curriculum that includes detailed
instruction from some of the most world renowned detailing professionals. From
the first day you set foot in our lecture classrooms and are handed your detailer
training guide, to the days that follow getting hands-on guidance in the Professional
Detailing Arena. Every step brings you closer to achieving financial success and
gratification as a professional detailer.
Sales & Support
P +703 635 9362
E Info@rubadub.com
Contact
1775 Tysons Blvd
#400
McLean, VA 22102
Connect with us:
Day 2
Day 3
Day 4
Exterior Detailing Training
Buffing, Polish & Sealing
Base/Coat/Clear Paints
Auto Detailing Clay
Vacuuming & Air Purging
Interior Soil Extractor
Dressing, Chrome, Plastic
Interior Final Inspection
Interior Detailing Training
Scrubbing Of Components
Introduction to Detailing
Business Overview
OSHA + EPA Guidelines
Dress & Success
Basic Marketing & Pricing
Types of Business Models
Exterior Final Inspection
Day 5 is reserved for an overview, certificate ceremony and job placement interviews and resume building. We will provide
you with options from various employers and recommendation letters and introductory calls.
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The SkillSource Group, Inc. and
Virginia Career Works - Northern (Area #11)
Northern Virginia Rapid Response COVID-19 Business Support Initiative Application Form
__________________________________________
__________________________________________
_________________________________________
_________________________________________
_________________________________________
____________
Employer Name:
Address:
Telephone:
Email:
Contact Name:
# of Employees Impacted:
Industry Type:
_________________________________________
Detailed Description of Rapid Response Project Request:
Estimate of Number of Jobs Saved and Amount of Annual Wages Saved:
Description of Leveraged Resources (if applicable):
Total Costs per Impacted Worker Funded by Grant Project:
Signature*
_______________________
______________________
___________
Name
Title
Date
*Signed form to be submitted with Rapid Response COVID-19 Budget Spreadsheet.
TEC Ventures LLC
9445 Fairfax Blvd #203
703-635-9362
info@tecventuresllc.com
Daniel Tisone
9
Commercial Cleaning
We had recurring commercial cleaning contracts but with buildings empty due to work from
home orders, we have been "furloughed". However, we were awarded contracts for disinfecting
offices where there have been known outbreaks or prior occupancy by individuals diagnosed
with Covid-19. This is good news for us, however we do not have the proper sanitation /
equipment to deal with a virus such as Covid-19. We need gear to protect our workers and
9 - 378k
Our existing cleaning contracts / commercial clients wish to render our disinfectant services.
2,666.00 per worker (coveralls, masks, gloves, disposable rags, sprayers, proper chemicals)
Owner
April 2, 2020
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