Preview
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
EXHIBIT M
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
From: Scott Parker
Sent: Wednesday, November 30, 2022 12:28 PM
To: Jasmin Tekiner
Cc: Younger, Stephen P.; Sanjay Ibrahim; Fred Hoensch; McDonough, Joanna; Cato,
Shayonna
Subject: RE: [EXTERNAL] Re: Tekiner - Santander subpoena - ATTORNEY-CLIENT PRIVILEGED /
ATTORNEY WORK PRODUCT [PIB-LEGAL_DMS.FID449713]
**EXTERNAL**
Of course! Joanna and Shayonna will send the follow-up to Santander.
Also, just an FYI that we reached out to Goldberg Weprin this morning, got referred to the individual who purportedly
handles subpoena responses, and left him a message to ask him to tell us when we can expect the subpoenaed
documents. We’ll let you know as soon as we hear back.
Best,
Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Jasmin Tekiner
Sent: Wednesday, November 30, 2022 12:14 PM
To: Scott Parker
Cc: Younger, Stephen P. ; Sanjay Ibrahim ; Fred Hoensch
; McDonough, Joanna ; Cato, Shayonna
Subject: [EXTERNAL] Re: Tekiner - Santander subpoena - ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT
[PIB-LEGAL_DMS.FID449713]
Thank you so much for this update and breakdown, Scott! Will look this over.
1
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
Best,
Jasmin
On Nov 30, 2022, at 8:33 AM, Scott Parker wrote:
Jasmin and Steve, we analyzed Santander’s subpoena responses and document production, and we
compared our requests to what they actually produced (and we also sent all the documents to Citrin
Cooperman). Below is a request-by-request analysis of the deficiencies in their production. In sum:
1. Santander fully complied with Request Nos. 1 and 3.
2. Whether Santander fully complied with Request Nos. 9 and 16 depends on whether the
document cutoff date is the date of the subpoena or the date they served their production (see
below).
3. Request No. 17 is duplicative of Request No. 15 (they both refer to Account -5142).
4. We withdrew Request Nos. 18, 19 and 20.
While we should follow up with Santander on all of the deficiencies set forth below, I think we need to
particularly push on: (1) requesting the October and November 2022 statements from the account
ending in -3639 (i.e., the account that contained the statements that reflected Berrin’s two $1 million
transfers in June and October 2022); and (2) the documents requested in #7 (-0897), because this is
Bremen’s payroll account.
Joanna/Shayonna, would you please let us know if you can reach out to Santander on these identified
deficiencies?
Last question – is there any indication as to whether Santander also provided these documents to Pryor
Cashman? If not, we should plan to do that.
Thanks!!
Request No. 2:
1. Instead of account statements for -2579 and -3922 from 12/22/14 to 1/21/15, Santander
produced check images and Transaction Inquiry screenshots (maybe they no longer have
the statements since they were more than 7 years ago – we should ask Santander to
confirm). The contents of the Posted Transactions field in the Transaction Inquiry
screenshots is incomplete, because the scroll bars appear to not have been moved left to
right and up and down. Also, it appears that only content from the Posted Transactions
Tab was provided, but not from the Memo Transactions Tab (assuming there is content
within that tab).
Request No. 4:
2. For Account -9285, Santander produced:
1. Statements for 2018
2. Copies of checks written from 1/1/18 to 5/31/18
3. Copies of deposits from 1/4/18 to 8/3/22
4. One wire record from 4/12/18
5. Statement for March 2020
6. Copies of checks written in March 2020
7. Copies of deposits in March 2020
2
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
3. The following documents are missing for Account -9285:
1. Complete statements for 2015, 2016, 2017, 2019, 2020 (except for March), 2021,
and 2022
2. Copies of all checks written in 2015, 2016, 2017, June 2018 through December
2018, 2019, 2020 (except for March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2019, 2020 (except for March), 2021,
and 2022
4. All wire records for 2015, 2016, 2017, 2019, 2020, 2021, and 2022
Request No. 5:
4. For Account -4194, Santander produced:
1. Statements from 12/28/17-4/30/18
2. Statement for March 2020
3. Copies of checks written in March 2020
4. Copies of deposits in March 2020
5. Wire record for March 2020
5. The following documents are missing for Account -4194:
1. Complete statements for 2015, 2016, 2017 (except for 12/28/17-12/30/17), 2018
(except for January through April 2018), 2019, 2020 (except for March), 2021,
and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for
March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
Request No. 6:
6. For Account -4003, Santander produced:
1. May 2018 Statement, copies of checks written, and copies of deposits
2. March 2020 Statement, copies of checks written, and copies of deposits
7. The following documents are missing for Account -4003:
1. Complete statements for 2015, 2016, 2017, 2018 (except for May), 2019, 2020
(except for March), 2021, and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018 (except for May), 2019,
2020 (except for March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2018 (except for May), 2019, 2020
(except for March), 2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 7:
8. For Account -0897, Santander produced:
1. March 2020 Statement, copies of checks written, copies of deposits, and wire
record
9. The following documents are missing for Account -0897:
1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
3
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for
March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
Request No. 8:
10. For Account -0900, Santander produced:
1. Statements, copies of checks written, copies of deposits and wire transfer records
from 12/1/15 to 1/18/19
11. The following documents are missing for Account -0900:
1. Statements, copies of checks written, copies of deposits and wire transfer records
from 1/1/15 through 11/30/15, and from 1/19/19 through the present (if the
account was open during these time periods)
Request No. 9:
12. For Account -3639, Santander produced:
1. Statements, copies of checks written, copies of deposits and wire transfer records
from 10/30/18 (account opening) to 8/9/22 (date of the subpoena)
13. If the cutoff date for production is the date of the subpoena, then there are no deficiencies
in the response to this request. If the cutoff date is the date Santander actually responded
to the subpoena, then the following documents should also be produced for Account -
3639:
1. Statements, copies of checks written, copies of all deposits and wire transfer
records from 8/10/22 through 11/8/22 (i.e., the date Santander initially emailed
the production link to Joanna).
Request No. 10:
14. For Account -0889, Santander produced:
1. March 2020 Statement, copies of checks written, and copies of deposits
15. The following documents are missing for Account -0889:
1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for
March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 11:
16. For Account -7909, Santander produced:
1. April 2018 Statement
2. March 2020 Statement
17. The following documents are missing for Account -7909:
1. Complete statements for 2015, 2016, 2017, 2018 (except April), 2019, 2020
(except for March), 2021, and 2022
4
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and
2022 (there may not be any since this is a money market account)
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 12:
18. For Account -0978, Santander produced:
1. March 2020 Statement, copies of checks written, and copies of deposits
19. The following documents are missing for Account -0978:
1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for
March), 2021, and 2022
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 13:
20. For Account -5360, Santander produced:
1. March 2020 Statement
21. The following documents are missing for Account -5360:
1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and
2022 (there may not be any since this is a money market account)
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 14:
22. For Account -3589, Santander produced:
1. March 2020 Statement
23. The following documents are missing for Account -3589:
1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March),
2021, and 2022
2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and
2022 (there may not be any since this is a money market account)
3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022
Request No. 15:
24. For Account -5142, Santander produced:
1. Statements, copies of checks written, and copies of deposits from 7/30/20
(account opening) to 4/22/21 (account closing)
25. The following documents are missing for Account -5142:
1. Wire transfer records from 7/30/20 to 4/22/21
Request No. 16:
5
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023
26. For Account -5088, Santander produced:
1. Statements from 7/29/20 (account opening) to 8/31/22 (month in which subpoena
was served)
2. Copy of sole deposit to account on 7/29/20
27. The following documents are missing for Account -5088:
1. Account statements from 9/1/22 to 11/8/22 (depending on the operative cutoff
date; see No. 9 above)
2. Wire transfer records from 7/29/20 to the present
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any
unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the
sender via reply email and destroy all copies of the original message.
6
Preview
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 EXHIBIT M FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 From: Scott Parker Sent: Wednesday, November 30, 2022 12:28 PM To: Jasmin Tekiner Cc: Younger, Stephen P.; Sanjay Ibrahim; Fred Hoensch; McDonough, Joanna; Cato, Shayonna Subject: RE: [EXTERNAL] Re: Tekiner - Santander subpoena - ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT [PIB-LEGAL_DMS.FID449713] **EXTERNAL** Of course! Joanna and Shayonna will send the follow-up to Santander. Also, just an FYI that we reached out to Goldberg Weprin this morning, got referred to the individual who purportedly handles subpoena responses, and left him a message to ask him to tell us when we can expect the subpoenaed documents. We’ll let you know as soon as we hear back. Best, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Jasmin Tekiner Sent: Wednesday, November 30, 2022 12:14 PM To: Scott Parker Cc: Younger, Stephen P. ; Sanjay Ibrahim ; Fred Hoensch ; McDonough, Joanna ; Cato, Shayonna Subject: [EXTERNAL] Re: Tekiner - Santander subpoena - ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT [PIB-LEGAL_DMS.FID449713] Thank you so much for this update and breakdown, Scott! Will look this over. 1 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 Best, Jasmin On Nov 30, 2022, at 8:33 AM, Scott Parker wrote: Jasmin and Steve, we analyzed Santander’s subpoena responses and document production, and we compared our requests to what they actually produced (and we also sent all the documents to Citrin Cooperman). Below is a request-by-request analysis of the deficiencies in their production. In sum: 1. Santander fully complied with Request Nos. 1 and 3. 2. Whether Santander fully complied with Request Nos. 9 and 16 depends on whether the document cutoff date is the date of the subpoena or the date they served their production (see below). 3. Request No. 17 is duplicative of Request No. 15 (they both refer to Account -5142). 4. We withdrew Request Nos. 18, 19 and 20. While we should follow up with Santander on all of the deficiencies set forth below, I think we need to particularly push on: (1) requesting the October and November 2022 statements from the account ending in -3639 (i.e., the account that contained the statements that reflected Berrin’s two $1 million transfers in June and October 2022); and (2) the documents requested in #7 (-0897), because this is Bremen’s payroll account. Joanna/Shayonna, would you please let us know if you can reach out to Santander on these identified deficiencies? Last question – is there any indication as to whether Santander also provided these documents to Pryor Cashman? If not, we should plan to do that. Thanks!! Request No. 2: 1. Instead of account statements for -2579 and -3922 from 12/22/14 to 1/21/15, Santander produced check images and Transaction Inquiry screenshots (maybe they no longer have the statements since they were more than 7 years ago – we should ask Santander to confirm). The contents of the Posted Transactions field in the Transaction Inquiry screenshots is incomplete, because the scroll bars appear to not have been moved left to right and up and down. Also, it appears that only content from the Posted Transactions Tab was provided, but not from the Memo Transactions Tab (assuming there is content within that tab). Request No. 4: 2. For Account -9285, Santander produced: 1. Statements for 2018 2. Copies of checks written from 1/1/18 to 5/31/18 3. Copies of deposits from 1/4/18 to 8/3/22 4. One wire record from 4/12/18 5. Statement for March 2020 6. Copies of checks written in March 2020 7. Copies of deposits in March 2020 2 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 3. The following documents are missing for Account -9285: 1. Complete statements for 2015, 2016, 2017, 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, June 2018 through December 2018, 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2019, 2020, 2021, and 2022 Request No. 5: 4. For Account -4194, Santander produced: 1. Statements from 12/28/17-4/30/18 2. Statement for March 2020 3. Copies of checks written in March 2020 4. Copies of deposits in March 2020 5. Wire record for March 2020 5. The following documents are missing for Account -4194: 1. Complete statements for 2015, 2016, 2017 (except for 12/28/17-12/30/17), 2018 (except for January through April 2018), 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 Request No. 6: 6. For Account -4003, Santander produced: 1. May 2018 Statement, copies of checks written, and copies of deposits 2. March 2020 Statement, copies of checks written, and copies of deposits 7. The following documents are missing for Account -4003: 1. Complete statements for 2015, 2016, 2017, 2018 (except for May), 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018 (except for May), 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2018 (except for May), 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 7: 8. For Account -0897, Santander produced: 1. March 2020 Statement, copies of checks written, copies of deposits, and wire record 9. The following documents are missing for Account -0897: 1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 3 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 Request No. 8: 10. For Account -0900, Santander produced: 1. Statements, copies of checks written, copies of deposits and wire transfer records from 12/1/15 to 1/18/19 11. The following documents are missing for Account -0900: 1. Statements, copies of checks written, copies of deposits and wire transfer records from 1/1/15 through 11/30/15, and from 1/19/19 through the present (if the account was open during these time periods) Request No. 9: 12. For Account -3639, Santander produced: 1. Statements, copies of checks written, copies of deposits and wire transfer records from 10/30/18 (account opening) to 8/9/22 (date of the subpoena) 13. If the cutoff date for production is the date of the subpoena, then there are no deficiencies in the response to this request. If the cutoff date is the date Santander actually responded to the subpoena, then the following documents should also be produced for Account - 3639: 1. Statements, copies of checks written, copies of all deposits and wire transfer records from 8/10/22 through 11/8/22 (i.e., the date Santander initially emailed the production link to Joanna). Request No. 10: 14. For Account -0889, Santander produced: 1. March 2020 Statement, copies of checks written, and copies of deposits 15. The following documents are missing for Account -0889: 1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 11: 16. For Account -7909, Santander produced: 1. April 2018 Statement 2. March 2020 Statement 17. The following documents are missing for Account -7909: 1. Complete statements for 2015, 2016, 2017, 2018 (except April), 2019, 2020 (except for March), 2021, and 2022 4 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 (there may not be any since this is a money market account) 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 12: 18. For Account -0978, Santander produced: 1. March 2020 Statement, copies of checks written, and copies of deposits 19. The following documents are missing for Account -0978: 1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 13: 20. For Account -5360, Santander produced: 1. March 2020 Statement 21. The following documents are missing for Account -5360: 1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 (there may not be any since this is a money market account) 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 14: 22. For Account -3589, Santander produced: 1. March 2020 Statement 23. The following documents are missing for Account -3589: 1. Complete statements for 2015, 2016, 2017, 2018, 2019, 2020 (except for March), 2021, and 2022 2. Copies of all checks written in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 (there may not be any since this is a money market account) 3. Copies of all deposits in 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 4. All wire records for 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022 Request No. 15: 24. For Account -5142, Santander produced: 1. Statements, copies of checks written, and copies of deposits from 7/30/20 (account opening) to 4/22/21 (account closing) 25. The following documents are missing for Account -5142: 1. Wire transfer records from 7/30/20 to 4/22/21 Request No. 16: 5 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1255 RECEIVED NYSCEF: 02/14/2023 26. For Account -5088, Santander produced: 1. Statements from 7/29/20 (account opening) to 8/31/22 (month in which subpoena was served) 2. Copy of sole deposit to account on 7/29/20 27. The following documents are missing for Account -5088: 1. Account statements from 9/1/22 to 11/8/22 (depending on the operative cutoff date; see No. 9 above) 2. Wire transfer records from 7/29/20 to the present Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. 6