Government’s Notice of Intent to Offer Certified Records into Evidence Pursuant to Federal Rule of Evidence 902 — United States v. Joselin (Dkt. 32, S.D. Fla.)

Summary

The government's notice of intent to offer certified records into evidence under Federal Rule of Evidence 902, filed July 25, 2022 in United States v. Luke Joselin, Case No. 22-60028-CR-DIMITROULEAS/SNOW, in the U.S. District Court for the Southern District of Florida. Under Federal Rules of Evidence 902(1), (2), (4) and (11), the government gives notice that it will offer certified records without calling a records custodian. Listed items include DAVID driver and vehicle records for Joselin, Florida Division of Corporations records for 24Hour Printing Inc, Hug a Print LLC, Skicas LLC and Pricerite LLC, Paycheck Protection Program loan records from BlueVine Capital Inc. and KServicing Corporation, mortgage and bank records, and internet service provider subscriber records. It is signed by Assistant United States Attorney Kiran N. Bhat.

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Case 0:22-cr-60028-WPD Document 32 Entered on FLSD Docket 07/25/2022 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA

                        CASE NO. 22-60028-CR-DIMITROULEAS/SNOW

  UNITED STATES OF AMERICA

  v.

  LUKE JOSELIN,

        Defendant.
  __________________________________/

       GOVERNMENT=S NOTICE OF INTENT TO OFFER CERTIFIED RECORDS INTO
            EVIDENCE PURSUANT TO FEDERAL RULE OF EVIDENCE 902

           The government submits this notice, pursuant to Federal Rules of Evidence 902(1), (2), (4)

  and (11), to offer into evidence the following certified records without calling a records custodian.

  These records and the accompanying certifications have been or will be provided to the defense:

           1. Certified Driver and Vehicle Information Database (“DAVID”) records for Luke
              Joselin;

           2. Florida Department of State, Division of Corporations records for (1) 24Hour Printing
              Inc; (2) Hug a Print LLC; (3) Skicas LLC; and (4) Pricerite LLC;

           3. Paycheck Protection Program (“PPP”) loan records from BlueVine Capital Inc.;

           4. PPP loan records from KServicing Corporation, f/k/a Kabbage, Inc.;

           5. Mortgage loan records from First Savings Bank;

           6. Bank records from (1) Pentagon Federal Credit Union; (2) BBVA USA; (3) Tropical
              Financial Credit Union; (4) Discover Products, Inc.; (5) JPMorgan Chase Bank, N.A.;
              and (6) Wells Fargo Bank, N.A.;

           7. Internet service provider subscriber records from (1) AT&T; (2) Blue Stream
              Communications, LLC; and (3) Comcast Cable Communications, LLC; 1

           8. Email account subscriber records from Google LLC;



  1
      A records certification from Blue Stream Communications, LLC, remains pending.

Case 0:22-cr-60028-WPD Document 32 Entered on FLSD Docket 07/25/2022 Page 2 of 3




         9. Cellular telephone subscriber records from: (1) Verizon; and (2) T-Mobile;

         10. United States Small Business Administration (“SBA”) Economic Injury Disaster Loan
             (“EIDL”) records for (1) 24Hour Printing, Inc.; (2) Hug a Print LLC; (3) Skicas LLC;
             and (4) Pricerite LLC. 2

                                                    Respectfully submitted,

                                                    JUAN ANTONIO GONZALEZ
                                                    UNITED STATES ATTORNEY


                                             By:
                                                    Kiran N. Bhat
                                                    Assistant United States Attorney
                                                    Florida Bar No. 1008370
                                                    99 NE 4th Street
                                                    Miami, Florida 33132-2111
                                                    Phone: (305) 961-9103
                                                    Email: Kiran.Bhat@usdoj.gov

                                                    Michael B. Homer
                                                    Assistant United States Attorney
                                                    Court ID No. A5502497
                                                    99 Northeast 4th Street
                                                    Miami, Florida 33132-2111
                                                    Tel: (305) 961-9289
                                                    Email: Michael.Homer@usdoj.gov




  2
    These SBA EIDL records are the subject, in part, of the separately filed Notice of Intent to
  Introduce Evidence Pursuant to the Inextricably Intertwined Doctrine and Rule 404(b).

Case 0:22-cr-60028-WPD Document 32 Entered on FLSD Docket 07/25/2022 Page 3 of 3




                                CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that on July 25, 2022, I electronically filed the foregoing document

  with the Clerk of the Court using CM/ECF.


                                              s/ Kiran N. Bhat
                                              Kiran N. Bhat
                                              Assistant United States Attorney

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