united states district court· - wordpress.com...... (sdny rev. 05/10) search and seizure warrant...

AO 93 (SDNY Rev. 05/10) Search and Seizure Warrant

UNITED STATES DISTRICT COURT· for the

Southembistrict of New York·

In the Matter of the Search of (Briefly describe the property to be searched or identifY the person by name and address)

THE PREMISES KNOWN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE,

27TH FLOOR, NEW YORK, NY (AS ATTACHED)

) ) ) ) ) )

SEARCH AND SEIZURE WARRANT

To: Any authorized law enforcement officer

G2587

An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the SOUTHERN District of NEW YORK

· (identifY the person or describe the property to be searched and give its location): THE PREMISES KNOWN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NY (AS ATTACHED) (AND ANY LOCKED OR CLOSED CLOSETS, SAFES, CABINETS AND CONTAINERS THEREIN)

The person or property to be searched, described above, is believed to conceal (identifY the person or describe the

property to be seized);

SEE ATTACHED AFFIDAVIT, INCLUDING ALL ATTACHMENTS

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property.

YOU ARE COMMANDED to execute this warrant on or before

li?f in the daytime 6:00a.m. to 10 p.m. (not to extfeed 14 dayo)

0 at any time in the day or night as I find reasonable cause has been established.

Unless delayed notice is authorized below, you must give a copy of the wan·ant and a receipt for the property takeri to the person from whom, or from whose premises, the property was taken, or leave th~ copy ·and receipt at the place where the property was taken.

The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventod' as required by law and promptly return this warrant and inventory to the Clerk of the Court. ·f~

&i'Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. _LJ_+-"-.. -'-( -'::._'---__ USMJ Initials

0 I find that immediate notification may have an adverse result listed in 18 U.S. C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor days (not to exceed 30).

Ountil, the facts justifying, the later specific date of ((' /)// ~CT"1 .v' ) ,; /}/ ~

Date and time issued: /1/t-vi::Vf/'.)~! /o/U ___ _.S'--/--~'--k-~----o---:-'/-:-f'--1_{_ "-----~-~-( Judge's signature

City and state: NEW YORK NEW YORK HONORABLE THEODORE H. KATZ, U.S.M.J. Pr(nted name and title

AO 93 (Rev 01/09) Search and Seizure Warrant ()

Return

Case No.: l Date and time warrant executed: I Copy of warrant and inventory left with:

Inventory made in the presence of :

·Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court.

Date: Executing officer's signature

Printed name and title

ATTACHMENT A (page 1 of 2)

THE PREMISES KNOWN AND DESCRIBED AS (A) THE OFFICES OF DAVID GANEK.t ANTHONY CHIASSON, AND INCLUDING ALL

COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR

IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN

ATTACHMENT B 1 •. ALL LOCATED AT LEVEL GLOBAL INVEST<?RS, 888 7TH AVENUEr 27TH FLOORr NEW YORKr NEW YORK

(A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND

111111111111, INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND

CELLULAR.TELEPHONES: All financial records, handwritten documents

and/or notebooks, letters and correspondence, photographs,

telephone and address books, identification documents, travel

documents, telephone records, computers and other electronic

devices, cellular telephones, and other records and documents

that constitute evidence of the commission of securities fraud,

wire fraud, money laundering, commercial bribery, conspiracy to

commit and aiding and abetting the commission of such ,crimes, or

are contraband and/or the fruits of violations of the federal

securities fraud, wire fraud, money laundering, and commercial

bribery laws, and/or are designed or intended as a m~ans of

violating the federal securities fraud, wire fraud, money

laundering, and commercial bribery laws, including any of the

above items that are maintained within other closed or locked

containers, including those that may be further secured by key

locks (or combination locks) of various kinds. These items will

be searched pursuant to the procedure set forth in Attachment B.

AND


(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS,

(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS

WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND

PROCEDURE SET FORTH IN ATTACHMENT B.

ATTACHMENT B (page 1 of 2)

1. The Federal Bureau of Investigation ("FBI") will follow the following procedure with respect to the search of the servers listed in Attachment A at Level Global Investors.

First, personnel at the FBI will make a mirror image of all, or as much as feasible and necessary, of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event, once the servers have been imaged, they will be returned.

Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all, or as much as feasible and necessary, of the servers at Level Global Investors will be imaged.

Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches. of the imaged material from the servers:

(1) Search for all emails and documents authored by, sent to, and/or received from David Ganek, Anthony Chiasson, 111111111111111, and Sam Adondakis.

(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s)

(a) (b) (c) "my check" (d) consultant (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell (j) (k)


2. For all other items listed in Attachment A (other than the servers which is covered by procedure #1 above}, the FBI will search the content in Attachment A for the following information:

1. Ganek, consultants,

Any and all Chiasson,

Broadband Research, and any

communications between and , Sam Adondakis 1

1 1 John Kinnuc thi~d-party consultant.

2. Any and all documents relating to, reflecting, and/or concerning information about public companies.

3. Any and all evidence reflecting communications about trading based on information about public companies.

avid

4. Any and all other evidence that will.assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidentiality and/or involved in trading based on material, nonpublic information.

5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United Stat~s Code, Sections 371, 1343, 1348, 1349, 1952 1 1956, Title 15. United States Code, Sections 78j (b) and 78ff, and Title 18, United States Code, Section 2 in connection with those offenses.

AO J06 (Rev. 06/09) Application for a Search Warrant

UNITED STATES DISTRICT COURT for the

Southern District of New York

In the Matter of the Search of (Briefly describe the property to be searched or identifY the person by name and address)

LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK

)

~ ) ) )

APPLICATION FOR A SEARCH WARRANT

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (identifY the person or describe the

prf~g>'r:f~~Tg~'kf.J(SV()'f~/~fs6affEfuCRIBED AS 888 SEVENTH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK (AS ATTACHED) .

located in the _.......=S...--0...--U...--T...--H..:...E..:...:...:.R.-N __ District of ___ ..:...:...:.N...--E--W.---Y..:...O...--R..:...K--=--- , there is now concealed (identifY the

person or describe the property to be seized):

PLEASE SEE ATTACHED AFFIDAVIT AND ALL ATTACHMENTS.

The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):

~evidence of a crime;

~contraband, fruits of crime, or other items illegally possessed;

ri property designed for use, intended for use, or used in committing a crime;

0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:

Code Section 18 U.S.C, §§ 2, 3711 1343, 1348, 1349; 15 u.s.c. §§ 78j

Offinse Description Including but not limited to wire fraud , fraud 1n connection with securities, and money laundering, and conspiracy to commit the same.·

(b), 78ff

The application is based on these facts:

PLEASE SEE ATTACHED AFFIDAVIT AND RIDER.

~ Continued on the attached sheet.

0 Delayed notice of __ days (give exact ending date if more than 30 days: _____ )is requested under 18 U.S.C. § 31 03a, the basis of which is set forth on the attached sheet.

p/i nt 's srgnature

HOLLY J. TRASK, SPECIAL AGENT, FBI Printed name and title

Sworn to before me and signed in my presence.

Date: 11/21/2010 ( Judge's signature

j / 11! c_;....---? City and state: __ ,.&;""-""?iH_,· <...:.:.'1_d_i1-r..A/ __ ,_,?./_/_ v ,,__._ .. -'=C.L---' THEODORE H. KATZ

Printed name and title

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

IN THE MATTER OF THE APPLICATION OF THE UNITED STATES OF AMERICA

- - X

FOR A SEARCH WARRANT FOR THE PREMISES KNOWN AND DESCRIBED AS (A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND 111111111111, INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING A SPECIFIC PROCEDURE, ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK

- - - - X

FILED UNDER SEAL

AFFIDAVIT IN SUPPORT OF A SEARCH WARRANT

HOLLY J. TRASK, being duly sworn, deposes and says:

1. I am a Special Agent with the Federal Bureau of

Investigation ("FBI"). I make this Affidavit pursuant to Rule 41

of the Federal Rules of Criminal Procedure for the issuance of a

warrant to search THE PREMISES KNOWN AND DESCRIBED AS (A) THE

OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND

INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND CELLULAR

TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM

ADONDAKIS, AND (C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS'

SERVERS WHICH WILL THEN BE SEARCHED USING A SPECIFIC PROCEDURE,

(as set forth in this affidavit and its attachments) , ALL LOCATED

. AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK,

NEW YORK (the "PREMISES"). The grounds for my belief are as

follows.

2. I have been a Special Agent with the FBI for over

7 years. I have participated in numerous investigations of

fraudulent schemes, including wire fraud/ mail fraud, money

laundering, and securities fraud. Among other things, during

these investigations, I have participated in the execution of

search warrants. Through my training, education, and experience/

I have become familiar with the manner in which fraudulent

schemes, including illegal insider trading and wire fraud

schemes, are operated/ and the types of electronic records kept

in and maintained in connection with these fraudulent schemes.

3. This application is submitted in connection with

an investigation of wire fraud and illegal insider trading

schemes in which individuals have been receiving and then

transmitting to others material, nonpublic information .regarding

certain public companies' quarterly earnings releases and other

market moving events (the "Inside Information11) for the purpose

of executing profitable securities transactions, and in which the

Inside Information has been misappropriated by individuals in

violation of their fiduciary and other duties of trust and

confidence to their employers. For the reasons detailed below,

there is probable cause to believe that, in the PREMISES 1 there

exists evidence/ fruits, and instrumentalities of violations of

the following statutes: (a) wire fraud 1 in violation of Title 18 1

United States Code, Section 1343; (b) money laundering, in

2

violation of Title 18, United States Code, 1956; (c) travel act,

commercial bribery, in violation of Title 18, United States Code,

Section 1952; (d) conspiracy to commit wire fraud, in violation

of Title 18, United States Code, Section 371; (e) conspiracy to

commit commercial bribery, in violation of Title ·18, United

States Code, Section 371; (f) conspiracy to commit money

laundering, in violation of Title 18, United States Code, 371;

(g) securities fraud, in violation of Title 18, United States

Code, Section 1348, and Title 15, United States Code, Sections

78j (b) and 78ff, and Title 17, Code of Federal Regulations,

Sections 240.10b-5 and 240.10b5-2; (h) conspiracy to commit

securities fraud, in violation of Title 18, United States Code,

Section 371, and Title 18, United States Code, Section 1349; and

(i) aiding and abetting the substantive offenses of wire fraud,

money laundering, travel act/commercial bribery, and securities

fraud, in violation of Title 18, United States Code, Sect}on 2

(hereinafter collectively referred to as "TARGET OFFENSES"), as

described below and in Attachments A and B to this A~fidavit.

4. Because this Affidavit is being submitted for the

limited purpose of establishing probable cause for a warrant to

search the PREMISES, I have not included every detail of every

aspect of the investigation. Rather, I have set forth only those

facts that I believe are necessary to establish probable cause.

The information contained in this Affidavit is based upon

3

conversations with other law enforcement officers, cooperating

witnesses (as reflected below), my review of various documents

and records, my review of interceptions of wire communications as

a result of court-authorized wiretaps pursuant to Title 1&,

United States Code, Section 2518 and, where specified, my

personal observations and knowledge. Unless specific~lly

indicated, all conversations and statements described in this

Affidavit are related in substance and in part only.

THE INVESTIGATION

5. Since at least in or about 2009, I and ocher FBI

agents have been investigating the TARGET OFFENSES in(connection

with the use of third-party consultants hired by money managers,

including hedge funds, to provide Inside Information relating to

public companies. In certain circumstances, the investigation

has focused on third-party consultants like JOHN KINNUCAN who

operated his own firm called Broadband Research. Consultants

like KINNUCAN received money from money managers, including hedge

funds, for information that they obtained from, among other

sources, insiders at public companies. In other· circumstances,

the investigation has focused on third-party consultant firms

like who pay, among other

people, insiders at public companies to speak with and provide

information to their clients, including hedge funds.

4

6. Since at least in or about 2009, I and other FBI

agents have determined that there is probable cause to believe

that certain third-party consultants, certain third-party

consultant firms, certain insiders at public companies, and

certain money managers, among others, have violated the TARGET

OFFENSES. During the course of the investigation, I an¢ other

FBI agents have obtained the cooperation of multiple participants

in these TARGET OFFENSES. In addition, under the direction of

the FBI, several of these cooperating witnesses have recorded

conversations with participants in these TARGET OFFENSES.

Moreover, I and other FBI agents have obtained court

authorization to intercept wire communications over the I

telephones used by multiple individuals.

7. From on or about October 7, 2009 through on or

about May 27, 2010, I and other FBI agents obtained court

authorization to intercept wire communications over two

conference lines used by to connect, among other things,

consultants who included insiders at public companies with

clients who included hedge funds. (In this affidavit I refer to

these telephone lines as Conference Line 1," Conference

Line 2," and collectively, the Conference Lines") Based on

these wire interceptions, I and other FBI agents learned that

numerous insiders at public companies were violating their

5

fiduciary and other duties of trust and confidence to their

employers by disclosing Inside Information to 's clients.

8. Based on my review of summary line sheets and my

conversations with other FBI agents, I have learned that certain

wire interceptions over the conference lines included

conversations between SAM ADONDAKIS, an employee at the time with

a hedge fund called LEVEL GLOBAL INVESTORS, and consultants

who were insiders at public companies. I have further learned

that, during these conversations, ADONDAKIS knowingly received

Inside Information from these consultants who were violating

their fiduciary and other duties of trust and confidence to their

employers. The following are some examples of those

interceptions: 1

a. On or about November 6, 2009, at approximately

11:32 a.m., an incoming call was intercepted

Conference Lines, between SAM ADONDAKIS and

During the conversation, ADONDAKIS stated that he

In certain instances throughout this affidavit, I have included in parentheses my interpretation of certain abbreviations, words, and phrases used in the recorded communications quoted herein, and I have used ellipses (". .") to denote where I have omitted other recorded words, phrases, or other statements made within the passages quoted herein, These interpretations are based on my training, experience, my conversations with cooperating witnesses, my review of intercepted conversations, and my review of publicly available information.

learned conversations with

has been identified as

6

worked for Level Global Investors, that Level Global Investors

has $4 billion in assets and is based in New York, and that

ADONDAKIS covers computer hardware and semiconductors. During

the conversation, tated that he worked for which

is a business unit within llllllliiiJI

was involved with all of

and that his group

(Based on my review

of the wiretap application submitted by the FBI to intercept wire

communications over the Conference Lines (hereinafter "

Wiretap Application"), I have learned that

public company whose shares are traded on NASDAQ.)

further stated that he has "good visibility" into the

is a

semiconductor side of (Based on my review of

the Wiretap Application, I have learned that the

semiconductor side of accounts for

approximately 50~ of the company's overall revenue.)

stated that "from the semico~ductor side 1 I think I have a pretty

good idea of what is going on in terms of capital expenditure

from the outside world as we see it." ADONDAKIS responded:

"Great." urther stated that " ... technically my role

here is 1 I am a materials project manager/ but in order to do

what we do for projects that are wide (in) scope across the

company/ it requires us to have that vision of what is happening

in a more global sense." ADONDAKIS responded: "Sure, ok,

perfect." ADONDAKIS later stated that he thought that most

7

companies who had reported (earnings) recently think thir).gs are

going well and that the order guidance was strong for the fourth

quarter. ADONDAKIS stated that recently there had been a couple

of reports that there was a chance that things could slow and he

would be curious to

continued," and how

quarters."

s take "if momentum has

the slope of the next few

responded: "Yeah, so hopefully you are hearing

that news from our competitors, because I am not seeing it the

same way. You know really what I am look at the fourth quarter,

of course, our earnings call will be next week, but, urn, the

fourth quarter from my viewpoint finished up what was a pretty

dismal year at least on a positive note, you know. I am looking

at about a 75% uptick from the previous quarter, although it was

down from the previous year, it was single digits down, right, so

7% below the previous year . and let me preface what I am

about to say with, urn, the information, what I look (at)

basically are, is, in a sense, kind of a build plan, so it gives

me a tick on what we are seeing coming in from our customer base.

Urn, typically, because it is more manufacturing oriented, the

future outlook is somewhat sketchy, I guess would be the best way

to put it. Urn, so it is not a real, there is not a real

scientific forecast that we have. Urn, so really what we see

comes down to the nuts and bolts of hard orders, urn, as we get

into real time. So you know, a month awayr two months way,

8

pretty good information, pretty much speculative as we go further

than that." A short time later, dded that "I am

expecting a first quarter uptick of at least 50~ on top of the

fourth quarter, and then right now the second quarter and the

third quarter are somewhat leveling out, and the reason I think

that is good news is because, right now, if we can say in the

first quarter 1 in early first quarter 1 that the second quarter

and the third quarter are leveling out, more than likely/ what we

have seen is a lot of that drop in demand come in clos~r to the

time, and we see the numbers increase. 11 ADONDAKIS responded: "I

see. 11 then stated: "So do I think we are leveling out? I

don 1 t think so. I think the numbers right now mathematically

would say that it is leveling 1 but I believe the way.'the momentum

is going right now is that we will see a continual rise/ at least

probably through the mid-part of 2010." (Based on my training,

experience/ and conversations with other agents, I believe that

the information that. rovided to ADONDAKIS would be

important to an investor in determining whether to buy and/or

sell securities, and that the information

regarding the growth of the semiconductor part of the business in

the fourth quarter of this year and the first 1 second 1 and third

quarters of next year, was nonpublic at the time.) Later in the

conversation/ ADONDAKIS asked: "When do you start to get, um, you

know/ very good confidence injthe next quarter? At what point? 11

9

sponded: "Oh, I would say 1 you know, I mean obviously

the closer the better, but as we get within a month or S0 1 I

think we have a pretty good idea. We will see some ebbing and

flowing going on for a little while yet 1 but, like I say, because

we are where we are at, and the numbers that I am seeing for the

second quarter 1 even the third quarter 1 is what really makes me

feel a little bit more comfortable in saying that those are going

to be some pretty solid quarters for us. No obviously not going

to be at levels we were used to a couple of years ago( but

certainly( you know, reaching levels we were at in mid-2006.

Hold on a sec, I will tell you exactly where that falls in, yeah,

so 2005, mid-to-late 2005, was a bit of a lull 1 but we are

approaching those levels right now." ADONDAKIS asked: "OK, so

you are approaching levels of 2006 or 2005?" sponded:

"2005 1 yeah, 2006 really started to shoot up in the second

quarter 1 um 1 you know( way up there. We are not there yet. 11

(Based on my training( experience 1 and conversations with other

agents( I believe that the information that rovided to

ADONDAKIS about how the "numbers" looked·in the fourth quarter as

compared with the numbers in 2005 and 2006 would be important to

an investor in determining whether to buy and/or sell

ecurities.) Toward the end of the conversation 1

"As we near the end of the quarter is probably a

good time to get a little bit f·irmer numbers and see where things

10

are going, but you know, I leave that up to you, what makes sense

to you, so you just let me know and I can make it happen."

ADONDAKIS responded: "OK, perfect. Well, you know what; maybe I

will check in with you following, well I guess the e~rnings call

is next week, so maybe it makes sense for us to talk, uh, kind of

late November, later in the month, like uh, the last week of

November, the first week of December timeframe."

responded: "Sure."

b. On or about December 1, 2009, at approximately

12:04 p.m., an incoming call was intercepted over the

Conference Lines during which BOB NGUYEN, a employee, spoke

who stated that he previously worked at

and now worked at (Based on my review of the

Application, I have learned tha is

a public company whose shares trade on the New York Stock

During the conversation, NGUYEN stated that he was

~nstructed to speak with by "JESSE" [LNU] (who appears to be

client named JESSE TORTORA) and that he was interested in

learning about and NGUYEN mentioned

that he spoken with JESSE TORTORA and "SAM"

(whom I believe to be SAM ADONDAKIS) in the past, and that NGUYEN

was directed to speak with NGUYEN stated that JESSE

11

TORTORA was at·a firm whose compliance has grown stronger, so

there might have been recent hesitation with JESSE TORTORA

reaching out to (Based on my training, experience, and

conversations with other agents, I believe that NGUYEN was

stating that JESSE TORTORA's compliance department did not want

JESSE TORTORA speaking directly with employees at public

companies and, as a result, JESSE TORTORA directed NGUYEN to

speak with and then provide the information to JESSE

TORTORA, as a means by which JESSE TORTORA would be able to get

around the compliance department's policies.) stated that

~he information he had provided was his read on the industry but

nothing confidential and now that s working at a private

company, there should be no conflict of interest. NGUYEN stated

that JESSE TORTORA told NGUYEN that

past was a good market indicator even

information in the

was not working at

the executive level. stated that he left

because it was a massive company, but was growing and

focusing on cellular wireless technology solutions. NGUYEN asked

interaction with and whether

was trying to sell its baseband group. said

yes, that was trying to sell. it, but that no

one was willing to pay for it right now so that they pulled it

back in-house. further stated that and

a supply agreement for the next ten years. said

12

that was not buying any big companies. NGUYEN

still followed what was going on at

interacts with some of

that he hoped to continue that

relationship. stated that his wife worked for

as well. (Based on my training, experience, and

conversations with other agents, I believe that NGUYEN was asking

whether had access to Inside Information at

though no longer worked for that company,

and that stated in his response that he had access to

information as a result of his company's business relationship

with his continued access to executives at

and his wife's employment at

NGUYEN asked about the next couple of months and

quarters in the semiconductor industry, and responded that,

among other things, it would be until February before

could improve its lead times and that there were supply system

issues with that demand was still strong

into the end of the first quarter but who knew afterwards and

that, as far as double-booking, it was not a large concern right

now. (Based on my training, experience, and conversations with

other agents, I believe that the information that provided

NGUYEN relating to would be important to an

investor in determining whether to buy and/or sell

13

securities, and that the information was not public.)

NGUYEN wondered whether was on a two-to-three

year downturn, and stated that inside management at

was short-sighted, that there was a lot of in-house

arguing, and that had lost share over the last

few quarters (according to an individual named

believe to be

based on my review of publicly available

information) . NGUYEN asked if will have

oversupply in the next year, and that he thought

s was still conservative at least for the next

few quarters. NGUYEN stated that he wanted to speak with

another month or two, and will ask about whether or not

"double-booking" will become an issue. NGUYEN asked if

in

needed help with anything, and tated that he was interested

in certain areas and if NGUYEN heard about any upcoming mergers

and acquisitions. (Based on my training, experience, and

conversations with other agents, I believe that NGUYEN was

offering to provide information to about other companies as

a way to obtain further information from about

in the future.) stated that some "M&A"

(referring to mergers and acquisitions) should happen but he did

not know of any right now. NGUYEN stated that he will send any

interesting notes that he has from a contact at AT&T and email

14

them

that

NGUY~N stated that he will let JESSE TORTORA know

at a private company now.

c. On or about December 2, 2009, at approximately

3:05p.m., an incoming call was intercepted over the

Conference Lines in which SAM ADONDAKIS spoke with of

During the conversation, stated that they talked in

late October and that bookings was making a decent first quarter.

ADONDAKIS asked whe~her bookings were going to go up in the first

quarter, and stated that executives were

expecting things to slow down but it had not, and that this was

overall, not just analog or wireless. ADONDAKIS asked if

knew what the bookings were in the fourth quarter as compared to

the third quarter, and sponded "the bookings in Q4 (fourth

quarter) were, let's see, versus Q3 (third quarter) slightly up,

just slightly greater than one book-to-bill, but not drastically

better." ADONDAKIS asked about double-ordering, and tated

that there was not much of a concern, just a week and a half ago

when he talked to the guys, over double-ordering, and that it

looked like the first quarter was going to come in flat.

ADONDAKIS asked if there was anything else important, and

stated that lead times at had been pretty

consistent across the industry. (Based on my training,

experience, and conversations with other agents, I believe that

the information that ided to ADONDAKIS relating to

15

bookings and double-ordering would be important to an investor in

determining whether to buy and/or sell Texas Instruments

securities and that this information was not public at the time.)

ADONDAKIS thanked for the rundown, and stated that he will

check in with him on the December timeframe. stated that he

"will check in with some of the guys and try to get a read on how

things are, um, looking, rolling up, coming into mid-December,

they should have a good feel for how December is going to roll,

um, I'l-l see if I can get another datapoint for you." ADONDAKIS

responded: "Sounds good." They agreed to speak again in a couple

of weeks.

d. On or about January 15, 2010, at approximately

11:36 a.m., an incoming call was intercepted on the

Conference Lines, during which SAM ADONDAKIS spoke with

(Based on my conversations with other FBI agents, I have

learned that was one of several global supply managers for

Dell, Inc., during the relevant period.) During the

conversation, ADONDAKIS stated that he had spoken with "some

foH:s at distributors" who told him that they just had a really

hard time getting parts, that "they couldn't get anything and

they are all freaked out about it," and that in the last.two

weeks there was a sudden magical supply. ADONDAKIS asked whether

"heard anything like this or does this make ~ense on what

you are seeing?" esponded: "It does make sense because

16

my supply position right now and outlook is much better than it

was two months ago. Where I have been living on 1 to 3 days of

inventory to my to my forecast, I am now probably sitting on

almost 5 to 6 days, so things have drastically improved. I think

a lot of it is due to that both WD (Western Digital) and seagate

added some capacity and we are starting to see the fruitions of

that. Now on the demand side, demand continues to be relatively

healthy and strong. My forecast for December was what I think I

told you like maybe 2.2 or 2.3 (million notebooks) .'and I finished

at 2.1 (million), so you know we take that as a positive."

ADONDAKIS replied: "OK." continued: "Now January, my

forecast is sitting, I wanted to tell you, I probably told you,

like another 2.3 (million). And I am going to land anywhere

between 1.9 (million) and 2 (million), that might be down a

little bit but week one of January got off to a slow start. But

at the same time, there is a lot of people off during that time

period. So we are starting to see the hockey stick effect, as

far as we get towards our end of the quarter in January that we

are starting to see a good pickup. So we will probably land in

the 1.9 (million) to 2.0 (million) range. That is off a little

bit of the forecast of 2.3 (million), but we always put in a

little bit of hedge in there to kind of drive more ~upply, If

Toward the end of the conversation, stated: "Going forward

for notebooks, February is at 1.93 (million); March is at 1.97

17

(million); April is at 2.19 (million); and May is at 1.65

(million) . " ADONDAKIS replied: "OK." then stated: "With

my 2.1 (million) that I did in December, my Q4 ended at 6.1

(million). And if you were to compare that to what Q3 was/ my Q3

was at 5.4 (million). And so you know there was some' growth

there but at the same time, my company continues to l.ose market

share. And I think the IDC 1 or the data just came out/ I guess/

yesterday that we showed that we lost market share. Of course/

we have always been margin focused over the last nine months and

I think that is going to change a little bit, and I think we are

going to be going more for revenue and trying to get back some of

this market share. So I think that is the strategy from our

executives coming out here relatively soon." ADONDAKIS asked:

"OK. Do you think that means/ you know, taking action on

pricing?" I responded: "I would say yes. 11 later

explained that companies like Dell, HP, Acer, and especially

Apple are moving away from using the "5400" RPM (revolutions per

minute) and move toward the "7200" RPM, and that "it's higher

margin for us of sales and then also for the hard drive suppliers

themselves." ADONDAKIS replied: "Gotcha. Yeah. That definitely

is something that should benefit them. I would that both

companies will report earnings next week 1 and I would think that

these will be kind of blowout numbers. 11 stated, "right 1

yeah, and it will be interesting to see what they say is their

18

outlook." (Based on my training, experience, and conversations

with other agents, I believe that the information that

provided to ADONDAKIS relating to actual and projected Dell

notebook sales would be important to an investor in determining

whether to buy and/or sell Dellr Western Digitalr and Seagate

securities 1 and that the information was not public at the time.)

9. From on or about May 5 1 2010 1 through on or about

August 10 1 2010, I and other FBI agents obtained court

authorization to intercept wire communications over the cellular

telephone of JOHN KINNUCAN, an independent third-party consultant

who operated his own firm called Broadband Research. Based on

these wire interceptions, I and other FBI agents learned that

KINNUCAN obtained Inside Information from numerous insiders at

public companies who were violating their fiduciary and other.

duties of trust and confidence to their employers by disclosing

Inside Information to KINNUCAN. I and other FBI agents further

learned that KINNUCAN then provided the Inside Information that

he obtained from insiders at public companies to his hedge fund

clients.

10. Based on my review of summary line sheets and my

conversations with other FBI agents 1 I have learned that certain

wire interceptions over the cellular telephone of JOHN KINNUCAN

were between KINNUCAN and both ANTHONY CHIASSON and

of Level Global Investors. Based on my conversations with other

19

FBI agents, I know that CHIASSON is a co-founding partner and the

director of research for Level Global Investors and that

is an employee of Level Global Investors. Based on my

conversations with other FBI agents, I have further learned that 1

during the conversations intercepted between KINNUCAN and

CHIASSON and KINNUCAN provided Inside Information to

CHIASSON and and that KINNUCAN 1 S sources of Inside

Information violated their fiduciary and other duties of trust

and confidence to their employers by providing that information

to KINNUCAN. The following are some examples of those

interceptions:

a. On or about July 26, 2010, at approximately 10:29

a.m., an outgoing call was intercepted from the cellular

telephone of JOHN KINNUCAN to ANTHONY CHIASSON and

of Level Global Investors. At some point during the

conversation/ KINNUCAN stated that Apple was lining up Sony as a

second source on the camera sensor due to execution miscues by

Omnivision 1 and that Apple was getting pretty frustrated with

Omnivision 1 S execution. CHIASSON then asked whether KINNUCAN did

"primary research" or whether the information was from a "rumoru

that KINNUCAN was picking up. KINNUCAN told CHIASSON and

that he wanted to be very clear that he did not traffic in

"second hand and rumors 1 u that he does not repeat stuff that he

heard/ and that he only traffics in stuff that he has heard from

20

"my primary contacts. 11 CHIASSON then said okay/ and asked

whether this. would be somebody in Taiwan or someone speaking to

somebody over there. KINNUCAN then stated that/ "frankly/ his

source was the chief contract manufacturer building the stuff for

Apple. 11 (Based on my conversations with other FBI agents/ I have

learned that KINNUCAN 1S source of information about Apple was

who was working for the chief cont~act

manufacturer at a public company called

of putting cameras into certain Apple products.

in charge

I have further

learned that s violating his fiduciary and other duties

of trust and confidence to and 1 in turn 1 Apple by

disclosing Inside Information to KINNUCAN1 among others, in

exchange for money.) CHIASSON then asked KINNUCAN about the

impact on the near term and whether this was something to worry

about simply because it was going to be something that was a

product cycle down in the future. KINNUCAN responded that that

was absolutely true and that they were talking six months. Later

in the conversation, KINNUCAN provided information about

Broadcom. KINNUCAN stated that Broadcom was seeing very nice

upside over the course of the enterprise networking business

which had been a major source of concern. KINNUCAN further

stated that they may temper their guidance, and that all the high

profile names like Broadcom, Netlogic, cavium 1 and Acme Packet

will all be quite positive. KINNUCAN also stated that he will

21

get some more updates on Netlogic later that day and that

Netlogic is a favorite short of some funds. CHIASSON asked about

Sandisk, and KINNUCAN stated that he thought the market would

tighten in the next few weeks and that he is happy with his call

on sandisk.

b. On or about July 27, 2010, at approximately 11:33

a.m. , an outgoing call from JOHN KINNUCAN' s cellular t-elephone to

ANTHONY CHIASSON was intercepted. During the conversation,

KINNUCAN said that he was calling on Sandisk. CHIASSON said that

he had just stepped into a meeting. KINNUCAN then stated that

the long awaited tightening in the market finally appeared to be

happening.

c. On or about July 27, 2010, at approximately 2:13

p.m., an outgoing call from JOHN KINNUCAN to ANTHONY CHIASSON was

intercepted. During the conversation, KINNUCAN stated that flash

market was starting to_tighten up, that Apple was back in the

market asking for parts again after about a month off, and that

Cisco was cutting orders, the vast majority of which were never

being filled.

11. Based on my conversations with other FBI agents, I

have learned the following regarding SAM ADONDAKIS: During the

course of this investigation, in October 2010, two FBI agents

approached SAM ADONDAKIS _regarding his involvement in

participating in trades based on material nonpublic information

22

at Level Global Investors, and asked for his cooperation. By on

or about November 2, 2010, ADONDAKIS agreed to cooperate with law

enforcement in this investigation. Among other things, ADONDAKIS

has gdmitted his participation in obtaining Inside Information,

knowing that the Inside Information came directly and/or

indirectly from public employees who were violating a duty of

confidentiality that prohibited them from disclosing the

information, providing the Inside Information to DAVID GANEK,

ANTHONY CHIASSON, among others, at Level Global

Investors who then executed and caused others to execute

securities transactions based in part on the Inside Information,

and exchanging that Inside Information with other individuals. I

know from my conversations with other FBI agents that GANEK is

of Level Global Investors.

12. SAM ADONDAKIS, who has not yet been charged with

any crimes, is cooperating with the Government in the hope that

he will be able to provide substantial assistance to the

Government, enter into a cooperation agreement with the

Government, and receive a reduced sentence for his crimes.

Certain information provided by ADONDAKIS has proven to be

reliable and accurate through telephone records, recorded

conversations, and other information.

23

13. Based on my conversations with other FBI agents

who have spoken with SAM ADONDAKIS, I have learned, among other

things, the following:

a. ADONDAKIS was an analyst at Level Global Investors

and was asked to leave the hedge fund in or about March 2010.

b. ADONDAKIS worked analyzing and researching public

companies in the technology sector.

c. During his work as an analyst at Level Glqbal

Investors, ADONDAKIS obtained Inside Information from insiders at

public companies through third-party consultants, including

and from colleagues at other money managers,

including hedge funds. On certain occasions, ADONDAKIS provided

this Inside Information to DAVID GANEK, ANTHONY CHIASSON, and

, and GANEK, CHIASSON, and executed and

caused others to execute certain securities transactions based,

in part/ on the Inside Information, and that ADONDAKIS informed

GANEK, CHIASSON, and of the sources of the Inside

Information. Among other things, ADONDAKIS typed notes of his

conversations with insiders at public companies regar~ing the

Inside Information that he received from them. ADONDAKIS saved

these notes to the shared network drive at Level Global

Investors. These notes on the shared network drive wouid and

should be maintained and kept on the servers of Level Global

Investors.

24

d. During his work as an analyst at Level Global

Investors, ADONDAKIS exchanged Inside Information with several

colleagues at other money managers, including hedge fu~ds.

ADONDAKIS exchanged the Inside Information with these colleagues

by and through, among other means, email communications. Prior

to the arrests of Raj Rajaratnam, the founder of Galleon Group

hedge fund, and other individuals on insider trading charges on

or about October 16, 2009, ADONDAKIS used his email address at

Level Global Investors to exchange Inside Information with these

colleagues. At times, ADONDAKIS also forwarded certain emails

that he received from colleagues at other money managers

containing Inside Information to, among other people,. CHIASSON.

These email communications would and should be maintained and

kept on the servers at Level Global Investors. Following the

arrests on or about October 16, 2009, ADONDAKIS and certain

colleagues with whom he exchanged Inside Information at other

money managers stopped using their work email addresses and

started to use personal email addresses to communicate with each

other.

e. During his work as an analyst at Level Global

Investors, ADONDAKIS spoke with and provided Inside Information

to GANEK, CHIASSON, and and informed GA-NEK, CHIASSON,

and regarding the sources of the Inside Information.

25

These conversations would take place in, among other locations,

the offices of GANEK, CHIASSON, and

f. Level Global Investors is currehtly located on the

27th floor of the building at 888 7th Avenue in New York, New

York. Level Global Investors occupies the entire 27th floor of

the building. On the 27th floor, one enters Level Global

Investors by walking through big wooden double doors. Upon

walking through those doors, the receptionist desk is on the

right.

g. GANEK has an office on the 27th floor at 888 7th

Avenue in New York, New York. GANEK's office can be located by

passing the receptionist desk, making a right turn, and then

making an immediate left turn to GANEK's office. The door to

GANEK's office is a frosted glass door, GANEK has multiple

computer screens in his office connected to a computer tower.

GANEK also has a laptop computer.

h. CHIASSON has an office on the 27th floor at 888

7th Avenue in New York, New York. CHIASSON's office can be

located by passing the receptionist desk, making a right turn,

then making another right turn, and then walking down to the end

of the hallway to CHIASSON's office. The door to CHIASSON's

office is a clear sliding glass door. CHIASSON has multiple

computer screens in his office connected to a computer tower.

CHIASSON also has a laptop computer.

26

i. has an

Avenue in New York/

a laptop

computer.

j. ADONDAKIS still has possession/ custody/ and

control over his laptop computer from Level Global Investors.

While working at Level Global Investors on the 27th floor at 888

7th Avenue in New York 1 New York 1 ADONDAKIS also used a desktop

computer.

k. Level Global Investors maintains servers on the

27th floor at 888 7th Avenue in New York, New York. ADONDAKIS

does not know where the servers are located on the 27th floor.

All of the notes that ADONDAKIS took during his conversations

with third-party consultants, including those conversations with

inside~s at public companies who provided ADONDAKIS with Inside

Information/ would and should be stored on the servers of Level

Global Investors. Moreover/ all of ADONDAKI8 1 S emails from and

to his address at Level Global Investors/ and his emails from and

27

to GANEK, CHIASSON, and would and should be maintained

and kept on the servers of Level Global Investors. Following the

arrests of Raj Rajaratnam several individuals on October 16,

2009, ADONDAKIS was asked about several of these emails.


have learned the following:

a. In or about October 2010, the FBI approached BOB

NGUYEN and asked him to cooperate with law enforcement in this

investigation. NGUYEN agreed to cooperate with law enforcement.

Among other things, NGUYEN admitted that he participated with

others at in obtaining Inside Information from

including insiders at public companies, and that

NGUYEN participated in helping clients obtain Inside

Information from NGUYEN, who has not yet been

charged with any crimes yet, is cooperating with the Government

in the hope that he will be able to provide substantial

assistance to the Government, enter into a cooperation agreement

with the Government, and receive a reduced sentence for his

crimes. Certain information provided by NGUYEN has proven to be

reliable and acdurate through telephone records, recorded

conversations, and other information.

b. In or about October 2010 and November 2010, the

FBI has approached certain (and others) who

worked as insiders at public companies. Certain

28

admitted that they had violated their fiduciary and other duties

of trust and confidence to their employers by providing Inside

Information to clients, including hedge funds, in exchange

for money. For example, admitted that he had violated

his fiduciary and other duties of trust and confidence to his

employer Dell by providing Inside Information to clients,

including Level Global Investors, in exchange for money.

who has not yet been charged with any crimes yet, is cooperating

with the Government in the hope that he will be able to provide

substantial assistance to the Government, enter into a

cooperation agre~ment with the Government, and receive a reduced

sentence for his crimes. Certain information provided by

to has proven to be reliable and accurate through telephone

records, recorded conversations, and other information.

15. Based on my review of the Wall Street Journal

("WSJ"), and other media, I have learned that, during the evening

hours of November 19, 2010, the WSJ published online an article

which appeared the next day on the front page of the print

edition, entitled "U.S. in Vast Insider Trading Probe." Among

other things, the article stated: •Federal authorities, capping a

three-year investigation, are preparing insider-trading charges

that could ensnare consultants, investment bankers, hedge-fund

and mutual-fund traders and analysts across the nation, according

to people familiar with the matter." The article further stated:

29

"One focus of the criminal investigation is examining whether

nonpublic information was passed along by independent analysts

and consultants who work for companies that provide 'expert

network' services to hedge funds and mutual funds. These

companies set up meetings and calls with current and former

managers from hundreds of companies for traders seeking an

investing edge. Among the expert networks whose consultants are

being examined, the people say, is Primary Global Research LLC, a

Mountain View, Calif., firm that connects experts with investors

seeking information in the technology, health-care and other

industries."

16. The November 20, 2010, WSJ article further

reported: "John Kinnucan, a principal at Broadband Research LLC

in Portland, Ore., sent an email on Oct. 26 to roughly 20

hedge-fund and mutual-fund clients telling of a visit by the

Federal Bureau of Investigation: 'Today two fresh faced· eager

beavers from the FBI showed up unannounced (obviously) on my

doorstep thoroughly convinced that my clients have ~een trading

on copious inside information,' the email said. '(They obviously

have been recording my cell phone conversations for quite some

time, with what motivation I have no idea.) We obviously beg to

differ, so have therefore declined the young gentleman's gracious

offer to wear a wire and therefore ensnare you in their devious

web.'"

30


have learned that, following publication of the WSJ article on

the evening of November 19, 2010, a confidential source ("CS-1"),

who works at a hedge fund which used consultants, among other

people, to obtain Inside Information, informed the FBI that CS-

1's supervisor directed him to delete and discard evidence of

their participation in illegal insider trading and wire fraud

schemes. 3

18. Based on my training, experience, conversations

with other FBI agents, and knowledge of the actions taken by CW-

1's supervisor to discard and destroy evidence for purposes of

obstructing the Government's investigation, as well as the

actions that appear to be taken by JOHN KINNUCAN to obstruct the

Government's investigation through his email to his clients,

there is probable cause to believe that because, among other

things, GANEK, CHIASSON, and ceived and executed trades

based in part on Inside Information provided by ADONDAKIS (who

obtained the Inside Information from consultants and

ADONDAKIS's colleagues at other funds), and CHIASSON and

received Inside Information from KINNUCAN, this search warrant of

CS-1, who has not yet been charged with any crimes yet, is cooperating with the Government in the hope that CS-l will be able to provide substantial assistance to the Government, enter into a cooperation agreement with the Government, and receive a reduced sentence for CS-1's crimes. Certain information provided by CS-1 has proven to be reliable and accurate through telephone records, recorded conversations, and other information.

31

the PREMISES is not only necessary to obtain evidence, fruits,

and instrumentalities of the TARGET OFFENSES, but to preserve

such evidence.

32

ITEMS LIKELY TO BE FOUND AT THE PREMISES

19. Based upon my training, experience and

participation in investigations of fraudulent schemes,

particularly schemes relating to illegal insider trading and wire

fraud, as well as my conversations with other FBI agents, I know

the following:

a. Participants in fraudulent schemes, including

insider trading and wire fraud schemes, frequently maintain

documents in paper and electronic form that reflect their

communications relating to Inside Information, their

communications relating to trades executed based in part on

Inside Information, notes reflecting the receipt of Inside

Information, the location of fraudulent proceeds, the transfers

of money and other proceeds of the schemes, and other evidence of .. . the fraudulent schemes. Iri particular, based on the information

provided above, I believe that PREMISES will contain emails,

notes, and financial records that would constitute evidence,

fruits, and/or instrumentalities of the TARGET OFFENSES.

b. Participants in fraudulent schemes, including

insider trading and wire fraud schemes, also commonly maintain

addresses and telephone numbers in books and papers in both

electronic and paper form which reflect names, addresses 1

telephone numbers and/or paging numbers for their associates in

the schemes. Based on the information· provided above 1 I believe

33

that the PREMISES will contain telephone and address books and

other documents reflecting names and numbers in both paper and

electronic form and that such items would constitute evidence,

fruits, and/or instrumentalities of the TARGET OFFENSES.

c. Participants in fraudulent schemes, including

insider trading and wire fraud schemes, often use computers and

other electronic devices, including hand-held devices, for the

storage of documents and to send and/or receive email

communications. Based on the information above, I believe that

the computers and other electronic devices, including hand-held

devices, on the PREMISES are items that would constitute

evidence, fruits, and/or instrumentalities of the TARGET

OFFENSES. I further believe that the servers on the PREMISES

would contain evidence 1 fruits, and/or instrumentalities of the

TARGET OFFENSES.

d. Participants in fraudulent schemes, including

insider trading and wire fraud schemes, often use cellular

telephones to store contact information of other participants and

to send and receive text messages in furtherance of the schemes.

Based on the information above, I believe that cellular

telephones on the PREMISES are items that would constitute

evidence, fruits, and/or instrumentalities of the TARGET

OFFENSES.

34

e. Based on my training, experience and knowledge, as

well as conversations with other law enforcement agents and other

individuals, I have learned the following: Email is a popular

form of transmitting messages and/or files in an electronic

environment between computer users. When an individual computer

user sends email, it is initiated at the user 1 s computer,

transmitted to the subscriber's mail server, then transmitted to

its final destination. Typewritten documents on a computer can

be saved to the computer's hard drive and dedicated network which

is shared by many users. A "server" is a computer that is

attached to a dedicated network and serves many users. Emails

and other electronic data deleted on computers will often remain

stored on the server. In other words, if individuals

intentionally deleted certain emails and electronic.d~ta from

their own computers, the emails and electronic data will likely

remain on the server unless and until further actions are taken

to destroy the emails and data on the server.

20. Based on my training, experienc·e, conversations

with other FBI agents, review of wire interceptions, and

conversations with cooperating witnesses who have participated in

illegal insider trading and wire fraud schemes, I am familiar

with the practices and methods of persons committing the TARGET

OFFENSES, and the means by which such persons communicate with

each other and maintain documents and records in paper and

35

electronic form. In addition, based on my conversations with

other FBI agents who have spoken to SAM ADONDAKis; I know that

there is probable cause to believe that the PREMISES contains

certain electronic data relating to the TARGET OFFENSES.

21. Finally, based upon the facts set forth herein, I

request authorization to search and seize any of the above items

constituting the PROPERTY that are maintained within safes

(including but not limited to those referenced in this

affidavit), suitcases, containers, safe deposit boxes, and other

closed or locJ~ed containers, including those that may be further

secured by combination and/or key locks of various kinds.

22. Based on the foregoing, I believe that there is

probable cause to believe that the documents, records, computers,

hand-held devices, servers, and cellular telephones on the

PREMISES constitute evidence, fruits, and instrumentalities of

the commission of violations of federal laws, including the

TARGET OFFENSES.

SEARCH PROCEDURE

23. In order to ensure that agents search only the

PREMISES, the search warrant will direct Level Global Investors

to produce the items on the PREMISES as described in Attachment

A, and the FBI will conduct a search of the servers on the

PREMISES and the other items on the PREMISES in accordance with

the procedure and use of search terms set forth in Attachment B.

36

CONCLUSION

WHEREFORE, I respectfully request that a search warrant

issue, pursuant to Rule 41 of the Federal Rules of Criminal

Procedure, to search the PREMISES for the items and information

set forth in Attachment A, and following the procedure described

in Attachment B, all of which constitute evidence, fruits, and

instrumentalities of violations of the TARGET OFFENSES.

Dated: November 21, 2010 New York, New York

SO ORDERED:

HON 1 RABLE THEODORE H. KATZ UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK

HOLL~l/~ Special Agent Federal Bureau of Investigation

37

Request for Sealing

Since this criminal investigation is non-public and

ongoing, disclosure of the search warrant, this affidavit, and/or

this application and the attachments thereto will seriously

jeopardize the progress of the investigation. Accordingly, I

request that the Court issue an order that the search warrant,

this affidavit in support of application for the search warrant,

the application for the search warrant, and any attachment

thereto be filed under seal until further order of this Court.

Dated: November 21, 2010 New York, New York

SO ORDERED:

HON6RABLE THEODORE H. KATZ UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK

HOLLY J. T S Special Agent Federal Bureau of Investigation

38

THE PREMISES KNOWN AND

ATTACHMENT A (page 1 of ;2)

OFFICES OF DAVID GANEK, ANTHONY CHIASSON, INCLUDING ALL

COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES,. (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR

IMAGE OF LEVEL GLOBAL INVESTORS 1 SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN

ATTACHMENT B ,_ ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AvENUE, 27TH FLOOR, NEW YORK, NEW YORK

{A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND

INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND

CELLULAR TELEPHONES: All financial records, handwritten documents







commit and aiding and abetting the commission of such crimes, or


securities fraud, wire fraud, money laundering, and commercial

bribery laws, and/or are designed or intended as a means of

violating the fe~eral securities fraud, wire fraud, money






AND


(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS,

(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS




1. The Federal Bureau of Investigation ("FBI") will follow the following procedure with respect to the search of.the servers listed in Attachment A at Level Global Investors.

First 1 personnel at the FBI will make a mirror image of all 1 or as much as feasible and necessary/ of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event 1 once the servers have been ~maged 1 they will be returned.

Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all 1 or as much as feasible and necessary/ of the servers at Level Global Investors will be imaged.

Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches of the imaged material from the servers:

(1) Search for all emails and documents authored and/or received from David Ganek, Anthony Chiasson/

and Sam Adondakis.

(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s)

(a) (b) (c) "my check" (d) consultant (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell ( j ) (k)


2. For all other items listed in Attachment A (other than the servers which is covered by procedure #1 above), the FBI will search the content in Attachment A for the following information:

1. Ganek, consultants, Broadband

and all communications between and Sam Adondakis,

John Kinnucan,

David

2. Any·and all documents relating to, reflecting, and/or concerning information about public companies.


4. Any and all other evidence that will assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidential·ity and/or involved in trading based on material, nonpublic information.

5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United States Code, Sections 371, 1343, 1348 1 1349, 1952, 1956, Title 15, United States Code, Sections 78j(b) and 78ff, and Title 18, Uriited States Code, Section 2 in connection with those offenses.

.'

t\0 93 (SDNY Rev. 05/10) Scnrch nnd Seizure Wr.m111t

UNITED.STATES DISTRICT COURT for the

Southern District of New York

In the Maller of the Search of (Briefly describe the property to be searched or irhnt!!Y the person by name. and address)

THE I)I~EMISES I<NOVVN AND DESCRIBED /\S LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE,

27TH FLOOr::\, NEW YORI<, NY (AS ATTACHED)

) ) ) ) ) )

Case No. 1 D /Ja.g .2 587/

0 (2;:/c;;-J-;J Ill-/ SEARCH AND SEJZUHE WARRANT

To: Any authorized law enforcement officer

An application by n federal law enforcement officer or an anorney for the government requests the search of the following person or properly located in the ·soUTHERN -· District of --·---~_Y._Q_RJ\ -··· (idanll}j,tlw person or describr. tire prnpl!rty to he searched and give its /om/ion): THE. PREMISES l<NOVVN AND DESCRIBED AS LEVEL GLOBAL INVESTORS, 888 SEVENTH AVENUE, 2TrH FLOOR, NEW YORI\, NY (AS ATTACHED) (AND ANY LOCI<ED OR CLOSED CLOSETS, SAFES, CAl31NETS AND CONTAINERS THEREIN) .

The person or properly to be searched, deseri bed above, is believed to coi1ccal (identify the person or dexr:rilw the

properly to be seir.ed):

SEE ATTACHED AFFIDAVIT, INCLUDING ALL ATTACHMENTS

J find that the afficlavit(s), or any recorded testimony, est8blish probable cause to scRrch and seize the person or property.

YOU ARE COlviiVIANDEb.to execute this warrant on or before l\J..D1L£a:f'lk:W\, cl i} \~0.\.J) _________ _ (11ol Ia exceed 14 days)

&1 in the claytinie .6:00a.m. to 10 p.m. IJ at any time in the clay or night as I find reasonable cause lws been established.

Unless clelayec(notice is authorized below, you must give a copy of the warrant and a receipt for the property takCii to the ·person from whom, or fi·om whose premises, t)lc properly was taken, or leave the copy and receipt at the

·· ··-plnce·whcre·the-property was·taken-.-·· · ·· --···· · ····-··-·-· ---·· : ........ ---····- -----· ··-·-···· ·-·--······ -·- · ··- ··· ······ ····-··

The oftlcer executing this wanant, or an ofiicer present clt1ring the execution of the warmnt, must prep~'"J )P invcntovf as required by law and promptly return this warrant and inventory to the Clerk of the Court. -7.- ~--

15ifUpon its reLurn, this wnrrnnt and inventory shol!ld be filed under seal by the Clerk of the Court.=~-~---~~ 1

USA·f.! Initials

0 I find that immediate notification may have an adverse result listed in 18 U.8.C. § 2705 (except for delay oftrinl), nnd authorize the offi~cr executing this warrant to delay notice to the person who, or·whose property, will be searched or seized (check the appropriate box) Ofor ___ days (not to exceed 30). ~

. )j}'!]'til, the ""' jt•tifyhtg, the J.t"· 'peoific bYf ~ . I)' o~o lr'/7 - /3/J- ·-. Date and time issued: L.lJ: ,;.eri« ;;Lf;. ~:!'../0 ~.;:;;t;!fo<.e.. ___ '_ "'~~-=--------

, J11dge 's signature •

·-------··_l::l.P_hlQRABl E THEODOI~E H. I<ATZ lJS.M.J ·--!'rinted name and title

AO 93 (RI'v. 0 1109) Search nnd Seizure Wnnrmt (Pnge 2) ·------------------Return

. ·: .. \.'

Certification

1 declare under pcnnlty of-perjury that this inventory is correct and was returned along with the original warrant to the Court.

·~~ftdl~ • 1 .

·------·--- '/-· -:- ((_ ·-· ~-----~-------~ r3t ling officers signlrfrrr~< J}_0 tl , .. -~ ·r , )/,~ , !) 11&1,

__ _ __ ( .. (LL{Jdf_;,.}__;_ __ _L_(vJ}c. '(f'C'f/ULJTf?&.Lt () 'i'rintud nama anr til/r- t-B I rr ..

<-----------------------


THE PREMISES KNOWN AND DESCRI ICES OF DAVID GANEK, ANTHONY CHIASSON, AND INCLUDING ALL

COMPUTERS, HAND-HELD DEVICES, AND CELLULAR TELEPHONES, (B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKIS, AND (C) A MIRROR

IMAGE OF LEVEL GLOBAL INVESTORS' SERVERS WHICH WILL THEN BE SEARCHED USING SPECIFIC SEARCH TERMS AND PROCEDURE SET FORTH IN

ATTACHMENT B ,. ALL LOCATED AT LEVEL GLOBAL INVESTORS, 888 7TH AVENUE, 27TH FLOOR, NEW YORK, NEW YORK

(A) THE OFFICES OF DAVID GANEK, ANTHONY CHIASSON, AND

INCLUDING ALL COMPUTERS, HAND-HELD DEVICES, AND

CELLULAR TELEPHONES; All financial records, handwritten documents







commit and aiding and abetting the commission of such crimes, or


securities fraud, wire fraud, money laundering, and commer·cial

bribery laws, and/or are designed or intended as a means of

violating the federal securities fraud, wire fraud, money






AND


(B) THE DESKTOP AND LAPTOP COMPUTERS OF SAM ADONDAKISr

(C) A MIRROR IMAGE OF LEVEL GLOBAL INVESTORS~ SERVERS




1. The Federal Bureau of Investigation ( "FBI'1 ) will follow the following procedure with respect to the search of the servers listed in Attachment A at Level Global Investors.

First, personnel at the FBI will make a mirror image of all, or as much as feasible and necessary/ of the servers at Level Global Investors. In the event that the FBI cannot make a mirror image of a server or servers on site, the FBI will remove the servers and mirror the servers off site as soon as reasonably possible. In that event, once the servers have been imaged, they will be returned.

Second, if Level Global Investors volunteers to make a mirror image of the servers and (if and only if) the FBI determines that their assistance is necessary and proper, the FBI will supervise the process by which all, or as much as feasible and necessary, of the servers at Level Global Investors will be imaged.

Third, following completion of the imaging process, the FBI will designate one or more personnel who will be walled off from the investigation to conduct the following searches of the imaged material from the servers:

(1) Search for all emails and documents authored by, sent to/ and/or received from David Ganek, Anthony Chiasson,

and Sam Adondakis.

(2) Search for all emails and documents containing the following search terms in the file name or anywhere in the electronic data of the file(s):

(a) (b) (c) (d) (e) (f) (g) Kinnucan (h) "Broadband Research" (i) Dell ( j ) (k)


2. For all other items listed in Attachment A (.other than the servers which is covered by procedure #1 above), the FBI will search the content in Attachment A for the following information:

1. Ganek, An consultants, Broadband Rese

and all communications between and Sam Adondakis,

John Kinnucan, y consultant.

David

2. Any·and all documents relating to, reflecting, and/or concerning information about public companies.


4. Any and all other evidence that will assist the FBI in identifying and/or determining whether other individuals were involved in providing material, nonpublic information in violation of fiduciary and other duties of confidentiality and/or involved in trading based on material, nonpublic information.

5. Any and all other information reflecting and/or showing and/or leading to evidence, fruits, and/or instrumentalities of violations of Title 18, United States Code, Sections 371, 1343, 1348, 1349, 1952, 1956, Title 15, United States Code, Sections 78j (b) and 78ff, and Title 18, United States Code, Section 2 in connection with those offenses.

F'D-507 (Rev 8··11-'J4) P:>ge ____ J__of ___ .L __

UNlTED STATES DEPARTl'vfENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION

Receipt for Property Received/Returned/Released/Seized

File # 3 ~ )?\:>- \.J'-'1 - 3c.Y2.. 'j )-\ \,.

On (date) ---~----==-U::=.__....J.O-~~'-''--"''(__j):::.___l,_'O=----------

(Name) Uf:u£r_. (51-A f>G\!(......

item(s) listed below \Vere: 0 Received From 0 Returned To 0 R)X'eased To ~eized ~

~~ ? Ttrft'. . t>r I • L....-. . 1 (.1 () .tJ V (Street Address), __ ~~...l::)._---.-7-f---..-LJ~c....=::::......._+-_f'J~I;:;-/'-'V~--ff---"'=!-~>F-t'--...!......... _________ _

(City) _______________________________ _

Description of Item(s): ON"el0 .:56ft(Dth"J1 t-lDj) S(r-.J G, Vr!'/ 9rH 49 ~ {Lqcv.. Pc ( sq) ~~ ,) 5cfk b'rqj r-ron sj,-J C..,vtJ19 -rr~ t-+ ~~A ( sc..lb) ct'IBCt) 5~ t~p W C.v',V'iVXr-1 I+ ~ ~ u ( s:c::s) __ _ o~{,) ~ 1-FJ)J) j.!;J ~VM91J(.6:<; ~-~j) Lsc.-\.{~-~l') ~~ J)tCn~ rrDD S/;J WMPr<./~-2fdCt~S'9! ~

I~ ccei v,·,d I· rn1ll"

Page -------4/'---of __J_ UNITED STATES DEP AR Tl\1ENT OF JUSTICE

FEDERAL BUREAU OF INVESTIGATION Receipt for Property Received/Returned/Released/Seized

File # -~ \.. \{,1;) - t-)'i - ~0 ::::{:t, ~\

~ --------------------------------------------------------------------------~·L/'_· Dr;lscription of Item(s): Q<;\£..-1 \~DO±i1\I·D.C\ \''1\\':l's:;.\.v. ·:\>\$),\·!) (S-~1,.),('-J, ;>'J ()J ftt\- I\

?·<ols)~\ \- oH) ; Qo~ s=n, .. ;j'o~;o\n l''nn'£,\\.o v\~,Q,~')-(; (3,ub,.:;>722.) ~~ ~n;:/' . \ \ ~ \l.o )'=\ \\ - :.L.$ ) \"}l'I.Q ~'''~Ytl.)'\ ~$},. N-,0\i\-<L •;--,\-'.,)C)-¥ ( -::,. \() q '2i:.X) don F ._

\ \ ~ '

(1 \ ~ )$:2\0 f'r ~ \ SS \'J - O'S\. ,J IV~ 1..\ 0 .Q. L Cq C \ :IS d,\ 0, , , .:_ "{ \\-'( . \"1\l':N'J.,'\ .Q ,

I .

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\~ (::\c. n ')).t··\- S \';): ~\? :h;.v,n•,\;J 9\ \") \J ) SJ\"\-.0 'S'>v 'S) \aS:':l~·:\·~d '' Ei~-1

..... ·:o~\-\\~-AL·~b :±;\·,~ (;:z.\-r ., \ \>•;\·R. Uc Cq\b ~,~\ •,c<,n), />Jy·"t~A-'?\.i4~t')S,S~

:'i.!:'"',.

,. -------------~~----~--------------------~------~ I· •

\ .( _j

Received By: Received From: (Signature) (Signature)

FD'-597 '(R'~v 8-11-94) Page --'---of _ _!.__

UNITED STATES DEP"ARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION


File # ?· I '? I)- N f - _s 0 2 <( 2 I

,-/"

item(s) listed below were: ~Received From O ~eturned To 0 · Released To 0 Seized

"/

( ,. ;:'V\ 0 ' (Name) ______ '--~=·-·~\_,_r_.~5----~~~~~-~~·:~,:~-v~~~~·~~-~----------------------------------

(Street Address), ____ ;;:;"-~-..c-'~'""-~·~'Y~---·'-z_-r_· _'· _:_1_\~v...:.<"___,J~~:...:· c...::.-,,----=2'---L.7_'_'_· _(!...._. _··.:....1 ::.:'··a::_;· ,....=---------------

(City) f\.J r -v "-.

1.::: /\ .5 ,,..-

... :) (:' ~· v ( ,.. ' i)L .J(, 0 ( l( ..

L c" r ??: rv .-, CT

<%>". J 1'-../ :, .. / '' X t '·, <r (c~ ·· v" c . ..- ' V f'.'\ VV t::• v---= bv ..- ' t "'-- // P j.V / .· f ~ - - J' - ) '- ...> t- = r /co r "· ·" .

LG IS(~ 1 .1 c. T

FD-597 (Rev 8-11-94) Page _ _!__ __ of _ _,_____

UNITED STATES DEPARTMENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION


File # 316f) -IVY- . ;:.('j!

CJ -7-\k /, (Street Address) ( 18\?J 7_ AIJ!!"' V:<:.

(City) N <?\JI y.A. . /\/)' ~QOI"t\ 0

Received By: Received From: (Signature)

item(s) listed below were: 0 Received From D Returned To Q Released To

? Seized

t::: 1'~--11 ( ~

'\

(Signature)

FD-597 (Rev 8-11-94) Page _·..-~/ __ of __ _

File#



5 I 8 I) - (\) IJ - 3u2 0 2 I 0 ( {' Oz b I

on (date) __ ___:_/_r_J_/ _2_2-----+/_,::---=7'-u_..;_/_u _________ _ I

item(s) listed below were: 0 Received From D Returned To 0 Released To

. /1 .~ Seized

(Name)_L_P~_e_!~G~/~u b~o"'--: _1----~.o"--'-f-L6..:..::c.--e~--"-c.>.!..-/~l).J::::...?/..::._V'_·/_. ~(j~tl.:.....:../l<?:::.___;t=/----(Street Address) tJ /:3 8 5 f>V17/lf1,_, At>...-?UQ r:/ 7 ~ F /-.Jur-

(City) ______ /~l!!.-/f=---w_7t/=---o=--r--'-/::...,--'. --,~...M~f vv'::.:.__-Tf6....l::():_:_r_:_k=-..· _:___ ________ _ / 17

Description of fiem0~ ~~~~~~~~~L~~P~f~J~~~~~~~~~~~~~~~~-~~~~~P~~~~)~~~~~.~~~~~~ 1/~ I f//JVPI.J.,.,'I?J

v e --!.."' . .) ,. I c r

Received By: (Signature)

-~--.· Received From:. _ __,..__..:.::...-.:.·_.•r-7, .. ·..---:-";:.....,.----

(Signature) •,. : ;·

FD-5\)7 (Rr.v 8-ll-(H)

File#


Receipt for Property Recei vcd/Retu rned/Released/Se ized

-~:L __ _

On (date) ,~-%re-M @.C7'S 7 '2- > ·2-- o I V item(s) listed below were: 0 Received From 0 Returned To g Relef)sed To i::fd- Seized

(Nnme) Le.,l S? ~ C?z\vm\ \6-.Jg,S)±bs.s;

(Street Acldress) ~B. 8f<,;J 'S c0;:.\c 1\\J Q\\u.Q. 1 dJ4.1r, 5j\oo\

(Ciry).~s:-·~~------------------------------

Description of Ttem(sJ:.-~~----------------------------~ _ ·pve_,.v~~·'I'~-C ~ )_C::CJ_~ Ye-r w ~c..J WJ<rn rJ c, f?A-J.>,S )

_u)_t21Ve f14rvu . .LA hJL7>E& ~ez.E!> 11,Aeo.-rer:c-:r OHo:P' '> CtJilirAt.JYtAJC) .JkfRta LLJ

____ l~AJClC!~ .. j-------------------------

_ ___{j__Lc2&I£..A_Tffcts _ _aE___f./L(gtotJ,(' ~ INtLU});rJt) ·GJJ'd&r L' CJilfb___S~

'I

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___ El:fJI~_s..tLt__(N i/i$.Zki.-~tr S"t&4Tai y ., 'I

/)cTP 6eR 2o() ~ i..E:JL/Ib ___ _ h

----~~~~&£ td~~roe.~1e-~~~·o~,s~-~)-----------------

- D .. ) ..... 111/F' -~BU..C}i;_L.p.L'-1./?i25..f..:L!L~ .. ~J2Q/:; __ ~E'J)_ 1! .,. ____ ZQQ./;__,__._... _________________________________ ,

__ f!l_CN& "l>.ftBt:.. 75Ld[ Ct'/VfPo)lftoN IV<.._ceJ3""'p""'o~l<...."""-?-> __________ _

,.._ c.r_)__(h.!£__l.~£fiJd~....iliL\)_(,_\-f!?.!ff5JD { JS ,/)qPfi7?.1d 1<1 &!;.. iNC. L !/ .l) t 6..}_wc.:l-, __

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___ (1) !)_~y~~ {iJg_t;;J;?.:L.EP_~..::ld.f.-:zi_LA::BS:-..TLk"D_f_!_}?_E..J?_T!:.rL L..QP._t:;~z.:_'_aN::f.Llr.AJLc:..J£r-t-A±WJ u I

. P/ffl..Sf?-c.r)f.'PJ~-'-

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(~) -€7f,t+T ?L/r.s.·-rrer i3ovrvn )>,lc .... i/"(ti'Nri Cr!NI.:'t"'-~'A.JC:, V.!f~1QLJ.~~~~u.:'/~c 71:1

!IUCL.ut'>e-:-11 {fltAS.'i;.t~,.\) Q3 Zc:o8 J(t;Vtct.J - IJtlV 2-1, 2;_Q.{>6 1')

,..-;/; l·~(·•:t•i•,;:·d I 'ro111: /,.;.··,/ · "7--

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l/

P:>ge _ _o:]_ __ of -~-

UN1TED STATES DEPARTJ\.•IENT OF JUSTICE FEDERAL BUREAU OF INVESTIGATION


File # :Si '3J) -A! Y - . .So :2.9 :z_.j

(Name) 6v£ZL c}L...i-1 8.41....- /rJ /t~TDR· (Street Address)~-p::j___A}~trb/ :.)€

item(s) listed below were: 0 Received From 0 Returned To Q Released To if Seized

rcir~') /J./€1... 1 Yd"R 1< 2 Nkb,L.~o~~'--------------------

Description of Item(s):

(f) Qll/e,- ,..£L4c.<. (Jl::' J?i1.rl\r'd:;'"'JJ t74A£L.S: 7o 11\iC'-•rDrS: {fl.14U 7o ~,;,i) G':.d!'i&k

(' t) () II / · II -"----_...."-Ld~e_13..l.A£_K:.-i-t2~'l E l EAF ~~ ~ .. c~-J:'..,._, _.L.L.4B_g;;;;lJf5...._~J..l(..El)~.J---.-,'4A-'-c~7 '---'-"'7>=<1T---"-.I-"-'Vo.,.. .. r._.:ef3~"""o....,[J..p.&-+1 ___ _

_ { r) 0 11f0:: tuf{j_'IE.J...f11M.E t.E;4£ 8uJ O@ LAB e-LfT'l) rr 2o i o RaatRc B r1it.4--S 1/

(r) Q,tVe:f .,~t: oF i#t-fZtaUc.S /?tif<Zf2t<.,;agf: To u.)""£ uDC 7:>,)c tJM('S'Z\~T '' PrRT'@J...J_o...--1(

.S--mA+E4Y oun..o~-'R. 4£~ o9 $11:> St:~ND ( ( ) ONE c Lf'/3-~ ?Uh~ c.. DUJ ])'C']?_, t.AB.i::!LE"b (I ( tc'' ... LF EJ(A {_ \) +Tt:t2 aJ 2 0 0 7 11

{l ) ONe 'Bi.Ab'.t:: -l5 .. LbL'!H:7Z i ABEL@ r'.gLA(.J;.s.::.[QNF {ot\l'R:7?£0';,cr. C.'-4.~~-~~--~

Cr) (Jr.l[;"pACI( 81AJ'P~ Cl!tJ'Ot!AIINc{ V:AR!titl-:S: DocvNEZ0TS ·n /N,.,t.v.f:l£~'7-oo_J____ CO t'-1 f'f?.J,S$:.L£l n.J 8Bi; ~:.;~ · !I _____ _

.LLl. ().t£E S'L'H&....d£.1UJ£w_~):S,_22.52.r.v~?Jt..£: 7D IN c.Lu ;_,.,.£' Bo 1 ! N G :;,1 c ; 1 euscJ r ·f:N'J:LT..L.£!])

(( Cl! rD· \/1"'7'- Ll r-dr 1 I •• _,_-,.. 7\j- 1"""::: • A I/ ..... ---·-- ...... 0.':lL L(._u::::s::;_ __ ..Ln.,J,'-> .. ~.'6J~~t- { c:::O.R_.._.,_cq~----------

_{j_)_i2t!e-SI~F V6-R,l.QJ..2~S 7a ;tJC.L.~,.Jl)(s: liltt{tH-' . .'RI 7l~7\.i Prtcfl.--

-----~.Tl.TL~J:>-~SL.-E_.C_T...._.__t D"""--'•'-.1.,...' -4.-\-,'-' ------------------------

(!)_0,-"IE .. /)LA;:~I'/.iX.'R_ L4B FL G' 1:::.>-.!!___!.R.f&L2t2LC2 11

Cr_)_ C.~Y..t:;n tlO.k~ND .. l;_a.r:...u.M~ .. E'Y.I.l .. rv£'])_!_~_Ca.!'dP-t...&&Y..~P-k.LC'I t.{S -~J..ki.c.tl:•i.'.-((f:'

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(/) .r).-'e;·:; ·u,_~,- f) ''b ·~o /:·"··r 1 ..,-~_..,..,..... t,"7"'l\..,T A .... oc--N ~ v v rv [)v-n.:: K. ol 'V t r, ..: •v · t ' 1:-.v. 1 tv I. .. r-LI;:'. -. {I . <>.1 . , ...

(,) 0/"~E Autc.c.. ·'J2,,;v,)E12.. t5rvTiru::.-D rc Zao'-7 Tt+£'HE'3. ;; ~> . ./;;.-.:.-_ .

.... .. ~... •' ... , __ -- . ...--- -- - - ; >; i ~ 1, t \'\! t II •.' J

F·h< ill 1c: c L ...



On (date) --1-;1:_j.L.\!o.uV:uetvfd· ..:.u../3~(,J.-:,'"R.:;,.--.___to2~2'-}J-'2-=o....!.t-=O---------

(Name) Leven_ G~o SAL /1\JI/f::S:TORJ.'

(Street Address) BB B SeY-t7'-J'7t± Av£N!..H.: J 27·r.f± FLoot<)

item(s) listed below were: 0 Received From 0 Returned To g Released To p4 Seized

(City) /l[e;w 'CoR{:?.) Nf?N___'Lnp>.;._' ..~.-K~---- -----------


-/·, ) AN:c lSTII('-L _ u,_,.._ --.J:CP-~ t~'E 1//U?.tOtJ~ i>oc.uMeNT$· TO !A.J(.,'"'Ji)£ ?:::oc~?:::i.~-

11 TR.V~ S'RrN6; fd4RH_(.(N'DoMrNtll'.vf LU,)J'T ?RoE; ~-Y _________ _

(r) 0Nv '1>e:s:,K ~~E B>~-e 1\[a-V&?vff;t:~fi 2o 1 D.

(r) (~N£' ~t.A;C&. 2.trJDt=}7e LABELED'' C~Hf?J..IANt£ fbLtCo:.SS. ~1-ND '?8.~

<To~..- --·-(t~ O~w; '$"iD~IA-STcc. FOLDER LitR<;.;:u::--:.'b r~J>tttL...Y P'<'Sl'D'DN~_L1bvt=1v1Bt.:,R

fti.,~ 2-or o 1r CaN~~_I(df?cc!JS 'Zi.....,u ..... c_,_;.,...tM=·i!N""""·..._r-::8-s-1-r------·--------

( r) y{:L.Lo c:J Alo:z1s- '?, '

D () (' 0 ME"Nf> )

VMwu-:;, 'Oo<· klt'1EJS.[I"S. ___________ _

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