NOTICE OF INTENT TO OFFER CERTIFIED BUSINESS RECORDS PURSUANT TO F.R.E. 902(11) by USA — USA v. Harun (Dkt. 81)

Record facts

U.S. District Court for the Southern District of Georgia · No. 3:22-cr-00009-DHB-BKE · Doc. 81 · 2023-02-03 · Docket on CourtListener

Summary

The United States' Notice of Intent to Offer Certified Business Records Pursuant to F.R.E. 902(11) in United States v. Gladys Harun, No. 3:22-cr-00009-DHB-BKE, in the U.S. District Court for the Southern District of Georgia, filed February 3, 2023 as Doc. 81. The government states it intends to offer at trial self-authenticating records, each with a custodian certification under Rules 902(11) and 803(6)(A)–(C), cited as Exs. A–J. The records come from Truist Financial, Wells Fargo Bank, N.A., Green Dot Bank, Yahoo, Inc., DocuSign, Inc., Lendio, Block, Inc., Google LLC and Charter Communications, Inc. They include bank statements, the defendant's PPP application and promissory note, DocuSign audit histories, subscriber and IP records, and a PPP borrower application dated March 16, 2021. The notice is signed by Assistant United States Attorney L. Alexander Hamner.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
 
GLADYS HARUN 
 
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CASE NO. CR 3:22-CR-009 
 
UNITED STATES’ NOTICE OF INTENT TO OFFER  
CERTIFIED BUSINESS RECORDS PURSUANT TO F.R.E. 902(11) 
 
The United States notifies the Court and counsel of its intent to offer at trial 
self-authenticating records pursuant to Federal Rule of Evidence 902(11).  Said 
records were created and maintained by Truist Financial (“Truist), formerly 
SunTrust Bank, Wells Fargo Bank, N.A. (“Wells Fargo”), Green Dot Bank, a wholly 
owned subsidiary of Green Dot Corporation (“Green Dot”), Yahoo, Inc. (“Yahoo”), 
DocuSign, Inc. (“DocuSign”), and Block, Inc. (“Block”), formerly known as Square, 
Inc., Google LLC (“Google”), and Charter Communications, Inc. (“Charter”). 
 Each record referred to herein is accompanied by a certification of a qualified 
custodian that meets the requirements of Rules 902(11) and 803(6)(A)–(C).  See Exs. 
A–J. 
The Truist records contain signature cards, statements, deposits, checks, and 
debits for Defendant’s personal and business accounts ending in 2876, 6416, 6440, 
and 7890.  See Ex. A.  The Wells Fargo records Bates numbered WF000001 to 
WF000127 and referenced in Exhibit B’s certification include documents, Defendant’s 
PPP application, promissory note and agreement, and records for Defendant’s 
account ending in 6523.  See Ex. B.  The Wells Fargo records referenced in Exhibit 
Case 3:22-cr-00009-DHB-BKE     Document 81     Filed 02/03/23     Page 1 of 3

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C’s certification contain signature cards, statements, deposits, checks, and debits for 
the accounts listed in the certification.  See Ex. C.  The Green Dot records concern 
card reference number ending in 4854 and consist of cardholder information, 
transaction records and history, direct deposit, and IP address information.  See Ex. 
D.  The Yahoo records pertain to the email account embraceafrica@yahoo.com and 
consist of subscriber details, IP login events, and email content.  See Ex. E. 
The DocuSign records consist of Certificates of Completion and audit histories 
concerning Defendant’s PPP loan submissions.  See Ex. F.  The Lendio records, Bates 
numbered BJ0001-BJ0069, contain Defendant’s PPP borrower application dated 
March 16, 2021, and documents submitted in support of her application.  See Ex. G.  
The Block records consist of account transactions, payment history, and subscriber 
information for Defendant’s Square account.  See Ex. H.  The Google records consist 
of subscriber, customer, and billing information, along with IP records, associated 
with the email account embraceafrica20@gmail.com.  See Ex. I.  The Charter records 
consist of subscriber accounts for IP addresses 96.32.198.181, 96.32.198.181, 
96.32.198.181.  See Ex. J.         
The records and certifications have been produced in discovery and made 
available to defense counsel for inspection.      
 
 
 
 
Case 3:22-cr-00009-DHB-BKE     Document 81     Filed 02/03/23     Page 2 of 3

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RESPECTFULLY SUBMITTED this __ day of February 2023. 
DAVID H. ESTES 
UNITED STATES ATTORNEY 
 
______________________ 
s/L. Alexander Hamner 
 
s/L. Alexander Hamner 
Assistant United States Attorney 
  
 
Post Office Box 8970 
Savannah, Georgia 31412 
Telephone Number:  912-652-4422 
E-mail:  ahamner@usa.doj.gov 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 3:22-cr-00009-DHB-BKE     Document 81     Filed 02/03/23     Page 3 of 3

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