Craig H. Missakian, United States Attorney — Case 5:24-cr-00292-PCP, Document 79

Summary

Declaration of Special Agent Huling, Document 79 in United States v. Cassie Will-Darnall, Case No. 5:24-cr-00292-PCP, in the U.S. District Court for the Northern District of California, filed July 25, 2025. The declarant, a Special Agent with the Office of Inspector General, states that the declaration is made for the limited purpose of supporting the motion to dismiss or for summary judgment of the United States. It identifies attached exhibits, including Exhibit PP, a Form 1099-K listing Cassie Will-Darnall as payee for tax year 2021, Exhibit QQ, an email, and Exhibits UU, VV and WW, quitclaim deeds dated in 2004. It also lists Exhibit RR, a document provided in response to a grand jury subpoena served on Slade and Company.

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

             Case 5:24-cr-00292-PCP          Document 79   Filed 07/25/25   Page 1 of 3




 1 CRAIG H. MISSAKIAN (CABN 125202)
   United States Attorney
 2
   MARTHA BOERSCH (CABN 126569)
 3 Chief, Criminal Division

 4 GALEN A. PHILLIPS (CABN 307644)
   Assistant United States Attorney
 5
          450 Golden Gate Avenue, Box 36055
 6        San Francisco, California 94102-3495
          Telephone: (415) 436-7110
 7        Email: Galen.Phillips@usdoj.gov

 8 Attorneys for United States of America

 9                                      UNITED STATES DISTRICT COURT

10                                     NORTHERN DISTRICT OF CALIFORNIA

11                                            SAN JOSE DIVISION

12
     UNITED STATES OF AMERICA,                     ) CASE NO. CR-24-00292-PCP
13                                                 )
             Plaintiff,                            ) DECLARATION OF
14                                                 ) SPECIAL AGENT HULING
        v.                                         )
15                                                 )
     CASSIE WILL-DARNALL,                          )
16                                                 )
             Defendant.                            )
17                                                 )
     SANDRA WILL,                                  )
18                                                 )
                                                   )
19           Third Party Petitioner.               )
                                                   )
20

21

22

23

24

25

26

27

28

     HULING DECLARATION
     CR-24-00292-PCP
            Case 5:24-cr-00292-PCP          Document 79         Filed 07/25/25     Page 2 of 3




 1          I, Angel D. Huling, declare and state as follows:

 2          1.      I am a Special Agent with the Office of Inspector General, a position I have held since

 3 September 2021.

 4          2.      The facts set forth in this declaration are based on my personal knowledge and

 5 information I received from other law enforcement personnel, or my review of documents and business

 6 records related to this investigation. I make this declaration for the limited purpose of supporting the

 7 motion to dismiss or for summary judgment of the United States. This declaration does not include

 8 everything I know about the investigation.

 9          3.      Attached hereto as Exhibit PP is a true and correct copy, excluding redactions, of a Form

10 1099-K listing Cassie Will-Darnall as the payee for tax year 2021.

11          4.      Attached hereto as Exhibit QQ is a true and correct copy of an email dated February 21,

12 2022.

13          5.      Attached hereto as Exhibit RR is a true and correct copy of a document provided in

14 response to a grand jury subpoena served on Slade and Company, which provided tax services to Cassie

15 Will-Darnall.

16          6.      Attached hereto as Exhibit UU is a true and correct copy of a quitclaim deed dated

17 January 13, 2004.

18          7.      Attached hereto as Exhibit VV is a true and correct copy of a quitclaim deed dated May

19 13, 2004.

20          8.      Attached hereto as Exhibit WW is a true and correct copy of a quitclaim deed dated July

21 28, 2004.

22          9.      Attached hereto as Exhibit ZZ is a true and correct copy of an entity registration

23 statement retrieved from Nevada’s Business Portal.

24          10.     Attached hereto as Exhibit AAA is a true and correct copy of an entity registration

25 statement retrieved from Nevada’s Business Portal.

26          11.     Attached hereto as Exhibit BBB is a true and correct copy of a subpoena return provided

27 by First American Title Company.

28          ///

     HULING DECLARATION
     CR-24-00292-PCP                                  1
            Case 5:24-cr-00292-PCP          Document 79        Filed 07/25/25      Page 3 of 3




 1          12.    Attached hereto as Exhibit CCC is a true and correct copy of an email dated January 10,

 2 2024.

 3

 4          I swear under penalty of perjury that the foregoing is true and correct.

 5
      Executed on: July 25, 2025                                           /s/
 6                                                                         ANGEL D. HULING
                                                                           Special Agent
 7                                                                         Office of Inspector General
 8

 9

10

11

12

13

14

15

16

17

18
19

20

21

22

23

24

25

26

27

28

     HULING DECLARATION
     CR-24-00292-PCP                                  2


File and source

File

gov.uscourts.cand.430212.79.0.pdf

Size

134,944 bytes

SHA-256

fc993ed4cb39c7de1cd72b0b8563434f32187cd1263c39b3e2286e961a36a4d4

Our copy

gov.uscourts.cand.430212.79.0.pdf

Original

No public link identified.