Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 1 of 12 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES OF AMERICA v. DAVID SIDOO, et al., Defendants. ) ) ) ) ) ) ) Criminal No.: 19-10080-NMG GOVERNMENT’S CONSOLIDATED SUR-REPLY IN OPPOSITION TO DEFENDANTS’ MOTIONS TO COMPEL The defendants’ reply briefs make three principal assertions: first, that the government’s recent disclosures were late; second, that the government is withholding exculpatory evidence; and third, that the government should be ordered to disclose the complete FBI-302 reports of its witness interviews. These claims are without merit. First, the defendants complain that the government’s January 28 disclosures should have been made earlier – McGlashan, for example, contends the information should have been disclosed within 28 days of his arraignment last spring, Dkt. 806 at 2 (“McGlashan Br.”), and Loughlin and Giannulli assert that it was disclosed at “the eleventh hour,” Dkt 807 at 3 (“Giannulli Br.”) – are baseless because the interviews were not conducted until recently. 1 The government’s disclosures of statements by Rick Singer, for example, were largely based on an interview conducted in December. That is why, in its response brief, the government alerted the Court and the parties that it anticipated “making supplemental disclosures to the defendants in the next few days after this 1 It is, of course, not the “eleventh hour.” No trial date has been set in this case. But if Loughlin and Giannulli believe their contention, it begs the question why they have not made any Rule 16 disclosures, and why they should not therefore be precluded from introducing any items as part of their case-in-chief that they have not disclosed. Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 2 of 12 brief is filed concerning the most recent interview reports.” Dkt. 736 at 2 (“Gov’t Br.”). The government has broad powers, but they do not include mental telepathy or time travel. The government cannot disclose witness statements before the witnesses make them. Second, the defendants demand that the government “cease withholding critical evidence” (Giannulli Br. at 4), and contend that the government “still [has] not made any clear statement regarding what they might have beyond the 302s that has [sic] not been produced” (McGlashan Br. at 10). Putting aside for the moment that the government is under no obligation to itemize what it has not produced, the government has, in fact, made precisely such a disclosure. As set forth in its response brief, the government “has produced e-mails, financial records, audio recordings, and other documentary evidence in its possession, custody or control pertaining to each of the categories of information the defendants seek. The government has not withheld any such evidence based on its disagreement about the merits of the defendants’ requests.” (Gov’t Br. at 3-4). In addition, the government has, in a demonstration of its good faith, provided FBI-302 reports of witness interviews to the Court, together with the related disclosures, for in camera review. These disclosures make clear that the government is not withholding exculpatory evidence. While the defendants may, understandably, be upset about the lack of exculpatory evidence, the absence of such evidence is a result of their criminal conduct, not any government disclosure violations. 2 Third, as the government has noted, the instant dispute boils down to the defendants’ demand for the FBI-302 reports in their entirety. But the defendants are simply not entitled to those 2 The defendants complain that “the Government’s view of the evidence determines what is Brady.” (McGlashan Br. at 5). Their gripe is with the law, not the government. As the Supreme Court has made clear, “[t]he government is primarily responsible for deciding what evidence it must disclose to the defendant under Brady.” United States v. Prochilo, 629 F3d 264, 268 (1st Cir. 2011) (citing Pennsylvania v. Ritchie, 480 U.S. 39, 59–60 (1987)). 2 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 3 of 12 reports at this time. The rules concerning the disclosure of impeachment information and Jencks material are clear. Calling such material “Brady” does not make it so. This case presents no basis to depart from the well-established procedures that govern every criminal case, notwithstanding the defense’s histrionic briefs that appear to be written for an audience other than the Court. While the government may, in the interests of efficiency, disclose impeachment materials earlier than is required under the Local Rules, the defendants’ request for Court intervention is without merit and should be denied. The government briefly addresses the defendants’ specific requests in turn. Lori Loughlin and Mossimo Giannulli 1. Singer’s “Full Statements” About Loughlin’s and Giannulli’s Payments Loughlin and Giannulli demand that the government disclose Singer’s “full statements” about “the nature of their payments.” (Giannulli Br. at 9-10, 17). As previously noted, the government has disclosed all communications in its possession, custody and control between or among Singer, Loughlin and Giannulli, as well as summaries of what Singer told government investigators about what he recalled about his communications with Loughlin and Giannulli concerning their payments. Counsel for Giannulli and Loughlin complain that “the Government has offered no justification for providing a prosecutor’s sanitized characterization of the 302 Reports rather than the actual Reports and accompanying notes from the interviewers themselves.” (Id. at 12). But the defendants’ characterization of the government’s disclosure as “sanitized” is baseless and untrue, and “the Government is under no legal obligation to explain why it chose to summarize the statements at issue rather than produce the notes and FBI 302s.” United States v. Collins, 409 F. Supp. 3d 228, 244–45 (S.D.N.Y. 2019) (“Defendants do not cite case law that supports their argument that the Government is required to produce primary 3 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 4 of 12 materials containing exculpatory statements in order to meet its Brady obligation. This is not surprising because such disclosure is not legally required. . . .”). 3 To the extent the defendants seek Singer’s statements to other, uncharged parents concerning “their admissions-related donations” (Giannulli Br. at 7), the government has, as noted, provided the actual communications in its possession, custody or control. That said, the defendants correctly note that the government has not disclosed the substance of Singer’s statements to investigators about what he told other, uncharged parents. That is because those statements are not exculpatory as to these defendants. 4 The defendants’ contention that, if “Singer did in fact tell some clients that their admissions-related donations were legitimate,” that would “corroborate[] Defendants’ lack of fraudulent intent” is farcical. (Id.). Communications the defendants did not know about cannot be “quintessential Brady,” as they contend, because those communications are not evidence of the defendants’ state of mind and could not have shaped their intent. Indeed, unlike co-conspirator statements, they are not even admissible. 5 (Id.). 2. USC’s Knowledge of Admissions-Related Donations Loughlin and Giannulli also seek all information concerning “USC’s knowledge about Singer and his operation.” As the government has noted, it has disclosed all documents and communications relevant to its investigation that it obtained from USC, including all documents 3 See also, e.g., United States v. Mavashev, 2010 WL 670083, at *1-*3 (E.D.N.Y. Feb. 23, 2010) (rejecting defense request for witness statements where government produced summaries of favorable information witnesses provided); United States v. Henderson, 250 Fed. Appx. 34, 38-39 (5th Cir. 2007) (approving government’s disclosure of information by letter). 4 To the extent such evidence constitutes Jencks or impeachment material, the government will disclose it as such in accordance with the Local Rules. 5 Moreover, to the extent Singer described his scheme to an uncharged parent as “not improper,” such communications simply highlight the inculpatory nature of his communications with Giannulli and Loughlin. 4 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 5 of 12 related to Loughlin, Giannulli or Singer. The government has also reviewed FBI 302 reports of its witness interviews, but – with the notable exception of cooperating witnesses who were members of the charged conspiracy – has not interviewed any USC witness who was aware of Singer’s scheme to facilitate the admission of his clients’ children as purported athletic recruits, in exchange for money. No witness has suggested that USC condoned this scheme, tacitly or otherwise. Nor is the government in possession of any evidence suggesting that anyone at USC, save Heinel, was aware the Giannulli children were admitted in exchange for money, or that they were not the athletes they purported to be. 6 Moreover, the evidence the government has already disclosed explains the absence of such information. For example, Heinel took steps to make sure that payments from Singer could not be traced to the admission of any student. See Ex. A at 3 (Oct. 5, 2018 call in which Heinel instructed Singer to delay having side door families send her the $50,000 checks because she did not want the money “so close” to the time of the applicant’s admission). Likewise, to the extent that Heinel apprised the Dean of Admissions about legitimate donations by the families of applicants, she specifically did not do so with respect to the payments by Loughlin and Giannulli. See Ex. B (presentation of Giannullis’ younger daughter to athletics subcommittee with no reference to “donations”). Similarly, to the extent that Singer, through his purported charity, made payments to Heinel’s accounts at USC, he typically did so through cashier’s checks. See Ex. C (examples of cashiers checks). 6 Singer himself has advised the government that he hid the scheme from USC’s athletic director, and that he was not aware of anyone at the university, besides Heinel and the other coconspirators, who knew about it. 5 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 6 of 12 William McGlashan Jr. 1. Evidence of McGlashan’s Knowledge McGlashan seeks evidence “reflecting what and how much he knew” about the standardized test cheating and the USC “side door” recruitment, including whether his coconspirators deceived or were forthcoming with him. 7 (McGlashan Br. at 8). Evidence that he was deceived, McGlashan contends, should be produced as exculpatory, while evidence that he was not deceived should be produced as pursuant to Rule 16(a)(1)(E)(i) as “material to the preparation of the defense.” Like Loughlin and Giannulli, what McGlashan really seeks are witness statements, inasmuch as the government has already produced all of his all recorded telephone calls, e-mails and text messages with Singer. The government has also reviewed the FBI 302 reports of interviews with Singer and Mark Riddell and produced any statements in those reports reflecting McGlashan’s lack of knowledge of the scheme, as well as any statements Singer and Riddell have made concerning whether his son had a legitimate learning disability. 8 While McGlashan may, understandably, be disappointed that this disclosure was limited, that fact is attributable to the absence of exculpatory evidence, not any failure to disclosure it. To the extent that McGlashan seeks inculpatory witness statements, he is not now entitled to them. McGlashan continues to insist that he is entitled to such statements under Rule 16 as evidence “material” to his defense, citing a 2007 decision by then-Magistrate Judge Sorokin. In a 7 McGlashan refers to two “schemes” but he is, in fact, charged with a single scheme, albeit one that was committed in multiple ways and had multiple victims. 8 The government has also produced evidence obtained from McGlashan’s school and a doctor regarding his son’s learning disability. Further, although not exculpatory, Riddell has told the government that he did not believe that McGlashan’s son had a learning disability. 6 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 7 of 12 later case, however, Judge Sorokin acknowledged that his earlier conclusion does not apply to Jencks Act material, because FED. R. CRIM. P. 16(a)(2), specifically “exclude[s] Jencks Act Information from its reach.” United States v. O’Brien, 2013 WL 1057929, at *9 (D. Mass. Mar. 13, 2013); see also FED. R. CRIM. P. 16(a)(2) (rule does not authorize the “discovery or inspection of statements made by prospective government witnesses except as provided by” the Jencks Act, and does not authorize the inspection of government reports or memoranda except as permitted by subsections concerning statements of the defendant and expert witnesses); see also United States v. Nelson-Rodriguez, 319 F.3d 12, 37 (1st Cir. 2003) (holding that the Jencks Act does not require government to disclose FBI 302 reports until after witness’s testimony on direct examination). Tellingly absent from the “exceptions” set forth in Rule 16(a)(2) is Rule 16(a)(1)(E)(i)—the provision concerning items “material to preparing the defense.” McGlashan’s effort to render the Jencks Act meaningless is at odds with the plain language of Rule 16 and should be rejected. 2. Evidence that McGlashan Did Not Participate in the “Side Door” McGlashan next seeks evidence “reflecting the fact that he did not participate in the side door scheme for which he is charged.” (McGlashan Br. at 11). The government has already disclosed the substance of Singer’s statements to investigators concerning McGlashan’s intent to participate in the side door. There is nothing additional to disclose at this time. 3. Evidence Relevant to an Entrapment Defense McGlashan complains that the government’s disclosures concerning when Singer began cooperating and when “Singer first suspected that he was being investigated” are insufficient. (McGlashan Br. at 13). Once again, however, there is nothing more to disclose. As the government has noted, Singer was first approached by investigators on September 21, 2018, and the 7 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 8 of 12 government has no information suggesting that he was aware of the government’s investigation prior to that date. 4. Evidence that USC Was Not the Victim of Fraud Like Loughlin and Giannulli, McGlashan seeks evidence “showing that USC was familiar with Singer and his method of getting students admitted to USC (or that McGlashan believed as much).” (McGlashan Br. at 13). As set forth above, the government has no evidence that USC was aware of or condoned Singer’s scheme, or of McGlashan’s effort to secure his son’s admission to the university as a purported football recruit in exchange for money. 5. Grand Jury Transcripts McGlashan, in his reply, appears to abandon his request for grand jury transcripts, and instead now seeks in camera review of those transcripts on the grounds that the evidence presented to the grand jury was somehow “inaccurate.” McGlashan offers nothing new in support of this request, and he does not identify a single inaccuracy in the Fourth Superseding Indictment. 9 Accordingly, McGlashan falls far short of meeting his heavy burden of showing a “particularized need” or “compelling necessity” warranting such review. See United States v. Capozzi, 486 F.3d 711, 727 (1st Cir. 2007) (“[T]he indispensable secrecy of grand jury proceedings must not be broken except where there is compelling necessity” and “[t]he burden of showing particularized need rests squarely on the defendant.”). 9 Contrary to McGlashan’s contention, the Fourth Superseding Indictment correctly sets forth the date on which the ACT sent the fraudulently obtained score to Northeastern University. See FSI ¶¶ 200 and 376. While the Northeastern application itself, which contained the ACT score, was sent on October 22, 2018 – the date McGlashan cites – the ACT released the score directly to Northeastern via wire on October 24, 2018. See Ex. D (ACT Internet reporting date for Northeastern (school 1880) was in cycle 81330 for McGlashan, which was Oct. 24, 2018). 8 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 9 of 12 John Wilson 1. Singer’s Description of His Practices to Parents Like Loughlin and Giannulli, Wilson seeks “evidence that Singer assured his clients that their donations were lawful and were welcomed by the recipient institutions,” which Wilson contends “directly negates the existence of the required element of bad intent.” (Wilson Br. at 4). Once again, Wilson’s demand is for a witness statement, because the government has already produced every communication in its possession, custody, or control between Singer and a parent or client regarding his scheme. But Wilson is not entitled to such witness statements because they are not exculpatory. While Singer’s statements assuring clients that their donations were lawful might arguably be exculpatory as to the parents to whom Singer provided such assurances, they are assuredly not exculpatory as to Wilson, who received no such assurances (and who falsely deducted his payments from his taxes as purported business consulting expenses, supported by falsified invoices). Nor is the fact that the government has charged a “nationwide conspiracy” relevant to this analysis. (Id. at 5). The government has not alleged that all of Singer’s clients were members of that conspiracy. And even exculpatory statements to other alleged co-conspirators would not “undermine the overall conspiracy,” as Wilson contends, unless they were made (or known) to every alleged member of the conspiracy, thereby negating its existence. That is not the case. 2. Singer’s Referral Sources As Wilson acknowledges, the government has disclosed to Wilson that it was his long-time accountant who introduced him to Singer. Wilson complains that the disclosure should have been 9 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 10 of 12 made “many months ago.” In contrast to Wilson, however, the government was not in possession of the information many months ago. 3. Colleges’ Attitudes Towards Fundraising from Applicants Wilson’s contention that evidence concerning USC’s “ordinary” fundraising practices “contradicts the government’s theory that USC was defrauded into admitting Wilson’s son” is untrue. (Id. at 6). To the contrary, information about the legitimate fundraising practices of USC and other schools is inculpatory as to Wilson and the other defendants because it highlights the illegality of their end-run around the legitimate development and admissions process. Likewise, Wilson’s contention that his “payment was a donation by all commonsensical and precedent-based definitions of that word,” is perplexing, since Wilson went to great lengths to deduct that payment from his taxes as a business expense, a scheme Wilson himself described as “Awesome.” 10 (Id.) See Dkt. 736-1 at 219 and 221. Notwithstanding its disagreement that this information has any exculpatory value, however, the government will disclose to the defendants the substance of witness statements concerning the role of donations in the admissions process. 4. Singer’s Concealment of Misrepresentations to Colleges Wilson inaccurately describes the government’s disclosure concerning his knowledge of the falsehoods on his son’s USC application. What the government disclosed is that Singer, in a recent interview, did not initially recall whether, six years ago, Wilson was aware of falsehoods in his son’s application, but later did recall, after refreshing his recollection by reviewing his e-mail correspondence, that Wilson was aware of those falsehoods. The government has no other 10 Ultimately, $120,000 was deducted as a business consulting expense and the remaining $100,000 was deducted as a charitable payment to Singer’s KWF. See Dkt. 736-1 at 223-26. 10 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 11 of 12 evidence suggesting that Wilson was unaware of the falsehoods in his son’s application. To the contrary, the evidence is that Singer sent Wilson the water polo profile, which contained falsities. Wilson still presents no argument for why evidence of what Singer did for other individuals is material or exculpatory as to Wilson. It is not, and Wilson is not entitled to additional disclosures on this subject. 5. Singer’s Embezzlement from His Clients The government has produced all bank records in its possession, custody or control showing how the money Singer received was disbursed, as well as charts tracking the money flow. To the extent that Singer (or anyone else) has suggested in interviews that Singer stole money from his clients, that information will be disclosed as impeachment material pursuant to the Local Rules. 6. Singer’s Obstruction and Government Instructions Wilson presents no argument as to why instructions to a cooperating witness are exculpatory, or why scripting a cooperator’s conversations is relevant to a defendant’s state of mind when the defendant does not know that the conversation has been scripted. To the extent that Singer failed to follow the government’s instructions, however, the government will disclose the relevant evidence pursuant to Giglio and the Local Rules. 11 11 Wilson is, in any event, already in possession of the information about Singer’s obstruction. During Singer’s plea colloquy, he explained to Judge Zobel that he received instructions from investigators “that I could not tip anybody or couldn’t talk to anybody about things,” but that he did not follow those instructions and instead alerted certain clients to the government’s investigation. See Singer’s March 12, 2019 Rule 11 colloquy at 28-29. 11 Case 1:19-cr-10080-NMG Document 834 Filed 02/07/20 Page 12 of 12 CONCLUSION For the foregoing reasons, the defendants’ motions should be denied. Respectfully submitted, ANDREW E. LELLING United States Attorney By: Date: February 7, 2020 /s/ Eric S. Rosen ERIC S. ROSEN JUSTIN D. O’CONNELL LESLIE A. WRIGHT KRISTEN A. KEARNEY Assistant United States Attorneys CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) on February 7, 2020. By: 12 /s/ Eric S. Rosen ERIC S. ROSEN Assistant United States Attorney Case 1:19-cr-10080-NMG Document 834-1 Filed 02/07/20 Page 1 of 4 2018-10-05 14-54-46 09593-001 1 Call Date: 2018-10-05 2 Call Duration: 2:21 3 Call Begin [ ] Call End [ ] 4 Call Participants: 5 Rick Singer 6 Donna Heinel 7 File Name: 8 Bates No.: Page 1 2018-10-05 14-54-46 09593-001 9 10 HEINEL: [00:00] USC, this is Donna. 11 SINGER: Donna, it’s Rick Singer, how are you? 12 HEINEL: Good, how are you doing, Rick? 13 SINGER: Good, I was just calling -- 14 HEINEL: Excellent. 15 SINGER: Calling back about, uh, I’m in Boston today so I 16 just, uh, I wanted to catch you before I jump on a plane 17 coming back west. 18 HEINEL: No problem, uh. 19 SINGER: How did subco go? 20 HEINEL: Good, very good, uh, 21 (sp?). 22 SINGER: Wow, both of them, OK. 23 HEINEL: Yeah (inaudible). (sp?) was fine and so is Case 1:19-cr-10080-NMG Document 834-1 Filed 02/07/20 Page 2 of 4 2018-10-05 14-54-46 09593-001 1 2 SINGER: That’s awesome. Page 2 By your message I was like, “Whoa.” OK. 3 HEINEL: Yeah. Uh, was a little harder. 4 SINGER: OK. 5 HEINEL: You know, you know, we, uh (inaudible) 9 was tough 6 but, uh, her test scores, I -- we really did the thing 7 about the LD, uh. 8 SINGER: OK. 9 HEINEL: And the fact that [01:00] she, you know, had that 10 with the -- with the test scores. 11 SINGER: Right. 12 HEINEL: Uh, you know, she still needs to -- to finish 13 (inaudible). 14 SINGER: Her (inaudible). 15 HEINEL: She needs, uh, you know, basically Bs, nothing lower 16 than a 3 point, try to get Bs as (inaudible). 17 SINGER: Got it, no problem. 18 HEINEL: Now I just don’t want to -- are you going to tell 19 the family? Or, uh, I just want to make sure -- 20 SINGER: I can hold. 21 HEINEL: Yeah, I just want to make sure that, uh, you know, 22 23 that doesn’t get out (inaudible). SINGER: Got it. Case 1:19-cr-10080-NMG Document 834-1 Filed 02/07/20 Page 3 of 4 2018-10-05 14-54-46 09593-001 1 2 3 4 HEINEL: Page 3 Uh, I’m always worried about those counselor, you know, the (inaudible). SINGER: Uh, no, absolutely. Totally (inaudible) we already -- we already dealt with that, absolutely. 5 HEINEL: Yeah, but, you know. 6 SINGER: Absolutely. 7 HEINEL: (inaudible) they’re -- they’re both recognized, 8 right, as indoor (inaudible). 9 SINGER: Uh, uh, absolutely. 10 HEINEL: Yeah. 11 SINGER: And 12 Yes. is -- is -- wants to be on the team and she’s good enough -- 13 HEINEL: (inaudible). 14 SINGER: Uh, she could pl-- she -- she’d be a good practice 15 player for the team no doubt about it. 16 HEINEL: OK, uh, like I said I can’t guarantee that. 17 SINGER: No, I got it. 18 HEINEL: (inaudible) so OK, cool (inaudible). 19 SINGER: And what do you want w-- do you want -- are you 20 going to send me the letter and do you want me to then -- 21 then I’ll [02:00] get them to forward the 50K? 22 -- tell me what you want me -- 23 24 HEINEL: now. Or do you (inaudible) yeah, just -- let’s hold on that right I don’t like to do it like so close. Case 1:19-cr-10080-NMG Document 834-1 Filed 02/07/20 Page 4 of 4 2018-10-05 14-54-46 09593-001 Page 4 1 SINGER: Got it. 2 HEINEL: You know. 3 SINGER: No, no, I get it, I get you. 4 HEINEL: So we can -- we can wait a little while on that but 5 I -- I’ll (inaudible). 6 SINGER: OK, uh, just let me know. 7 HEINEL: All right, I appreciate it, thanks. 8 SINGER: You’re the best. 9 HEINEL: (inaudible). 10 SINGER: OK. 11 HEINEL: (inaudible). Have a great weekend. [02:21] 12 13 END OF AUDIO FILE Thanks. Case Document 834-2 Filed 02/07/20 Page 1 of 2 STUDENT PROFILE Date: ?1241"! Major: Name- (a t. (Uranuv; g} 583: Bir?adate: Fresh: Trans (Units) (Semesters) Sport: Slow %Schoiarship Hin- Wm Junior Coiicgc: University: Course Curriculum Factor: - Factor: I High Schooi Cor: GPA: SAY: CR2 ACT Composite Written NCAA Ckm?inghousc Approved Courses: Engiish Math Science FLang Sociak Science SUBCO Comment/interview Aiklc?c Acco meat R?b Xlw??x? "Vb/,7 Other Factors [a3 1024? USC-00003693 Case Document 834-2 Filed 02/07/20 Page 2 of 2 COXSWAIN Los Angeles, CA PERSONAL Graduation: 2018 _High School ROWING MAC ROWING Coxswain SkliISet Awareness, wrganization, direction 21ml Steering COMPETITION 2016,3201? Head of the Chariey?oswn 14*? place-2017 l. piarezm? . 2015-2017 Head ofthe American- Lake N?atnma 0 place 2016,2017 '0 8?1" place 2015 2015-2017 Head of the Lagocxn-Fogter City 0 201? place 0 2016/2015 5 2016;201? Womea?s Varsity 8 beat, Men?s 3V 4 beat - 2016 Fault Line Faceol?f. Bronze medal 2015-2017 Christmas Regatta. Silver zrwdal USRowing Regional In nior (Ilwmpionships, r) Bronze-203.6 o. Silver~ 2013 Marin Crew Festival 0 "l?op 3 ?nish ever the past 4 years San Diego Crew Classic 0 Gold (3 Silver Med3l~2015 (2) Gold Medal- 2014 Sparks Rowing programs: University of Washington, University 9f Florida, University of Califemia. Les Angcles USC has four beats which require 4 coxswains along with 2 back?ups, .wuld be fill the position ol?our 8-3-3 boat. Her sister is currently on our roster and ?ils the positxon of our #4 boat. Division '1 rowin programs use scholarships for the oarsmen but rarely with scholarship a coxswain. Although non~scrholarslzip she is highly talented and has been successful in. both men's and women?s boats, use-00003694 . m! M?u- t! - are 1: 19- c?r- 10080- NM-JDocument 834 3 ?Eban CASHIER 3 CHECK N9.- . 2' 1222 THOUSAND DOLLARS AND 00 CENTS . . .- . - Sax 1 - Security Featura?s Included. -- - 50,000.00 THE .. . . USC WOMENS ATHLETICS .1 :13, ., ?f . THE KEY WORLDWIDE FOUNDATION 5547/1/14 676*! MM "Location: _31935 Irvine i. .. MWH MN 55430 -- . -.- . a-r AUTHORIZED SIGNATURE aci. n. 16080 NMG Document 834 3 Filed? 02/07/21" 3 CHECK . 13D 'Deia-ilan-B . {Wm Location. II3SOIO Campus ICorInmorIlIsII . :?El 55?. a .1'5 -m h. 3 "a .ldl .H . :1 Bank National Associauon Minneapolis. MN 55480 - I Fm:- mam-41m Case Document 834-4 Filed 02/07/20 Page 1 of 4 1/10/18 2968,1614,3800,2838 DOB: 0470,0210,0532,1880 053212 Case Document 834-4 Filed 02/07/20 Page 2 of 4 Reporting Option The ACT Internet Reporting Option (AIRO) Schedule of 2018-2019 Cycles UPDATED 08-10-18 All reporting cycles may include Additional Score Reports (ASRs) and reports from Universal testing residual testing at your institution, and from other test locations, such as State and DANTES). The first reports from each of the seven ACT national test dates will be available in large volume in the reporting cycle noted in the comments section below. Test date score reporting continues as: additional answer documents are submitted for scoring, writing test results become available, and scores are released from ?hold? status. Scores held for nonpayment of required fees are included in the next scheduled cycle after payment is received. All reporting cycles may include reports from previous national test dates. ACT records will be available by 8:00 AM Central Time the day after each cycle runs. it you have questions, please contact ACT institutional Services at 319.337.1360 or CYCLE DATE DAY COMMENTS 81110 09-05?18 WED Sept. 3 Labor Day 81120 09-07-13 FRI Sept. 8 National Test Date 81130 09?10?18 MON 81140 09?12?18 WED 81150 09?14?18 FRI 81160 09?15?18 SAT 3531 NATIONAL 81170 09?17?18 MON 81180 09?19?18 WED 81190 09?21?18 FRI 81200 09-24?18 MON 81210 09?28?18 WED 81220 09?28?18 FRI 81230 10?01?18 MON 81240 10?03?1 8 WED 81250 10?05-18 FRI 81260 10-08?18 MON 81270 10?10?18 WED 81280 10-12?18 FRI 81290 10-15?18 MON 81300 10-17?18 WED 81310 10?19?18 FRI 81320 10-22-18 MON Case Document 834-4 Filed 02/07/20 Page 3 of 4 CYCLE DATE DAY COMMENTS 81330 10?24-18 WED 81340 10-26-18 FRI Oct. 27 National Test Date 81350 10?29?18 MON 81360 10-31?18 WED 81370 11?02~18 FRI 81380 11?05~18 MON 81390 11?07?18 WED 81400 11?09?18 FRI 81410 11?10?18 SAT OCT. NATIONAL 81420 11?12?18 MON 81430 11?14?18 WED 81440 11?16?18 FRI 81450 11?19?18 MON 81460 11?21-18 WED Nov. 22?23 - Thanksgiving 81470 11?26?18 MON 81480 11?28?1 8 WED 81490 11-30?18 FRI 81500 12-03?18 MON 81510 12?05-18 WED 81520 12-07-18 FRI Dec. 8 National Test Date 81530 12?10?18 MON 81540 12?12?18 WED 81550 12-14?18 FRI 81560 12?15-18 SAT 81570 12?17?18 MON 81580 12?19-18 WED 81590 12?21?18 FRI Dec. 24?25 Christmas 81600 12?26?18 WED 81610 12-28-18 FRI Jan. 1 New Year?s Day 81620 12?31-18 MON 81630 01?02?19 WED 81640 01?04?19 FRI 81650 01?07?19 MON 81660 01?09?19 WED 81670 01?11?19 FRI 81680 01?14?19 MON 81690 01-16?19 WED 81700 01?18?19 FRI Jan_21_ MLK Jr_ Day 81710 01?23?19 WED 81720 01?25?19 FRI Case Document 834-4 Filed 02/07/20 Page 4 Of 4 CYCLE DATE DAY COMMENTS 81730 01?28?19 MON 81740 01 ?30?1 9 WED 81750 02-01?19 FRI 81760 02?04?19 MON 81770 02?08?19 WED 81780 02?08?19 FRI Feb. 9 National Test Date 81790 02?11?19 MON 81800 02?13?19 WED 81810 02-15?19 FRI 81820 02?16?19 SAT FEB. NATIONAL 81830 0248?19 MON 81840 02?20?19 WED 81850 02?22?19 FRI 81860 02?25?19 MON 81870 02?27?19 WED 81880 03?01?19 FRI 81890 03044 9 MON 81900 03?06?1 9 WED 81910 03?08?19 FRI 81920 03?11?19 MON 81930 03?13?19 WED 81940 03?15?19 FRI 81950 03?18?19 MON 81960 03-20-19 WED 81970 03?22?19 FRI 81980 03?25?19 MON 81990 03?27?19 WED 82000 03?29?19 FRI 82010 04-01?19 MON 82020 04-03?19 WED 82030 04?05?19 FRI 82040 04?08?19 MON 82050 04?10?19 WED 82060 04?12?1 9 Apr. 13 NationaI Test Date 82070 04454 9 MON 82080 04?17?19 WED 82090 04?19?19 FRI 82100 04?20-19 SAT APRIL NATIONAL 82110 04?224 9 MON 82120 04?24?19 WED