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Exhibit 3 — No. 1:22-cr-00024 (N.D. Fla., Dkt. 35-3, filed 01/30/23)

Summary

Document 35-3, filed January 30, 2023, in Case 1:22-cr-00024 in the N.D. Fla.: an email chain on SBA liens. The top message is from Keen, Justin (USAFLN), sent Friday, November 4, 2022 3:01 PM to David Lazarus and Nicole Waid, subject RE: SBA Liens. It lists steps that include continuing with the sale of the airship, having the escrow agent send the SBA checks for the two liens, and wiring the rest of the sale proceeds to the USMS/DOJ. It asks for documentation so the Court is made aware of the partial prepayment of restitution. The forwarded message from David Lazarus, sent Friday, October 21, 2022 10:32 AM, says the SBA recorded UCC Liens and that a limited release of the two attached liens is needed for the sale to happen.

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Cite this document

“Exhibit 3 — No. 1:22-cr-00024 (N.D. Fla., Dkt. 35-3, filed 01/30/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-n-d-fla-no-1-22-cr-00024-dkt-35-3-n-d-fla-9c3f369f6e/, SHA-256 fdd71bcafca211b53ed6a51fcf5702493efe0124da71f56f229bb30af2ec94c6.

Full text

               Case 1:22-cr-00024-AW-GRJ Document 35-3 Filed 01/30/23 Page 1 of 2
                                                                                  EXHIBIT

David Lazarus
                                                                                        3
From:                         Keen, Justin (USAFLN) <Justin.Keen@usdoj.gov>
Sent:                         Friday, November 4, 2022 3:01 PM
To:                           David Lazarus; Nicole Waid
Cc:                           Brown, Raymond N.; Littwin, Kathleen R.; Byron, David (USAFLN); Milligan, Gary
                              (USAFLN); Bird, Karen (USAFLN) [Contractor]; Kerwin, Katherine (USAFLN)
Subject:                      RE: SBA Liens
Attachments:                  202002512890 - AirSign AirShips Title.pdf; 202002512815 - AirSign Airships America.pdf



Good afternoon, Dave (and Nicole),

As we just discussed, this afternoon I spoke with Kathleen Littwin, one of the attorney advisors for
the SBA’s EIDL department (she is CC’ed on this email). The simplest solution to Mr. Walsh’s
situation regarding the two attached liens (which I’ve been advised are for $73k and $150k) is as
follows:

   1) Continue with the sale of the airship,
   2) Ensure that escrow agent sends the SBA a check for $73k and $150k, with a memo noting
      the loan numbers (the end of box 4 of each lien contains the loan number), and
   3) Ensure that the escrow agent wires the rest of the sale proceeds to the USMS/DOJ per our
      previous correspondence.

The POC at SBA’s EIDL department to resolve this will be Ray Brown, EIDL Risk Management
Supervisor. His email address is Raymond.Brown@sba.gov (he is CC’ed on this email). I defer to
Mr. Brown as to the specific instructions that the escrow agent must follow to ensure prompt
disposition of these two SBA liens. Ms. Littwin advised that the SBA will not release the liens
before payment is received, but it seems that the above steps is pretty routine in their world.

Once the balance of the sale proceeds are sent to USMS/DOJ, please send me documentation of
same so I can be sure that the Court is made aware of Mr. Walsh’s partial prepayment of
restitution.

Please let me know if you have any questions or issues on this.

Justin
                        Justin M. Keen
                        Assistant United States Attorney
                        Northern District of Florida
                          Financial Fraud Coordinator
                          Elder Justice Coordinator
                          Coronavirus Fraud Coordinator
                          NDFL BSA Review Team, Member - Legal Advisor
                        Justin.Keen@usdoj.gov
                        Direct: (850) 216-3802
                        Cell: (850) 694-3178
                                                       1
                Case 1:22-cr-00024-AW-GRJ Document 35-3 Filed 01/30/23 Page 2 of 2
                                 Follow us on Twitter|@NDFLnews

  ***Please be advised that all emails sent to this address are archived and retained by the United States
                                         Department of Justice.***

From: David Lazarus <dlazarus@verrill-law.com>
Sent: Friday, October 21, 2022 10:32 AM
To: Keen, Justin (USAFLN) <JKeen2@usa.doj.gov>
Cc: Nicole Waid <nicole.waid@FisherBroyles.com>
Subject: [EXTERNAL] FW: SBA Liens

Justin –

The SBA recorded UCC Liens against Patrick’s businesses and assets. I think this was routinely done for loans in excess of
certain amounts. The hiccup is that the airship sale we disclosed to the government late last week appears to be held
up by the SBA Lien. Would you be able to let your SBA contact for this case know about the sale and that it is going to
fund restitution back to the SBA? I can contact them myself but experience tells me that they won’t listen to me. For the
sale to happen, Mr. Walsh needs a limited release of the two attached liens from the SBA.

Happy to hop on a call today if that is helpful. Thanks.

Dave



David G. Lazarus PARTNER
Admitted in MA and NY
Verrill Dana LLP
One Federal Street, 20th Floor
Boston, MA 02110
T 617-292-2859

dlazarus@verrill-law.com
https://www.verrill-law.com/david-g-lazarus/




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