Part 4 · § IX

The blockchain, and “not paid”

The motion says the Government put its own narrative in place of the blockchain record, then told the jury the tech contractors were never paid.

Memorandum § IX.A

“The inverted timeline”

“In a pretrial motion in limine, the Government substituted three versions of its blockchain theory in place of what the blockchain records show.”

The Government’s timelines, and the blockchain

ECF 73 · ECF 73-1 · ECF 79 at 20 · Tr. 1055 · PX 850–851 · DX 35

What the court and jury were told

ECF 73 at 4WSA “never completed a digital currency offering, nor did it take any substantial steps towards doing so.”
ECF 73 at 6–7“[I]t was not until 2020 — after the Government executed a search at WSA’s offices and after Saint Clair was arrested — that concrete steps were taken.”
ECF 73 at 11“[N]o concrete GUMMEE developments took place … until after the search.”
Pretrial conference · ECF 79 at 20The coins “were issued by a completely … different entity … that was not involved.”
Closing · Tr. 1055“[T]he GUMMEE transfers, all that activity, that starts the day after the World Sports Alliance’s offices were searched.”

What the record shows

The same filing · ECF 73 at 10 n.3It quotes the white paper: “there is irrefutable proof that GUMMEE was created September 18, 2019 … and finalized on September 23, 2019.” The Government has never disputed those dates.
Sept. 18, 2019 · PX 851The first GUMMEE test transaction on the public Stellar ledger, 18:21:34 UTC.
Sept. 18, 2019 · PX 850The working G2 Digi-Wallet.
Sept. 23, 2019 · DX 35The first live GUMMEE transaction, three days before the search.
Sept. 26, 2019 · PX 199White Paper Version 1.0. The motion says the Government withheld it and attached instead a version re-dated to February 2020. (ECF 73-1)
Mar. 3, 2019 · PX 198The GME Foundation’s incorporation, showing continuity of incorporators, management and beneficiaries. (ECF 191 at 12)

“A motive theory built on a backward timeline is not a theory; it is an invention presented as evidence.” The search was September 26, 2019.

The Stellar blockchain record for GUMMEE: first transaction 2019-09-18 18:21:34 UTC. — Tap an image to see it full size.

The G2 Digi-Wallet dashboard showing a GUMMEE account. — Tap an image to see it full size.

Cover of the GUMMEE Coin Initial Coin Offering Technical Overview marked DRAFT, dated February 14th, 2020, as filed by the Government at ECF 73-1 page 1.

Cover of the GME Coin Initial Coin Offering Technical Overview marked DRAFT, dated September 26th, 2019, in collaboration with VO2 Global, WSA and Commtrade International, filed at ECF 191 page 16.

Exhibit D page 1: what the Government told the court and the jury.

Exhibit D page 2: the blockchain record, every event before the search.

Demonstrative chart filed with the motion. It organizes record evidence; it is not itself evidence. Tap to enlarge.

The exhibit

Arizona Corporation Commission Articles of Incorporation for the Global Monetary Equality Foundation, filed 3/3/2019. Emails and one incorporator’s name blacked out.

Addresses, phone numbers, emails, account numbers and signatures are blacked out. Tap a page to read it full size.

Memorandum § IX.A

Why a later white paper?

The two covers above are the same document. The date on the cover decides which side of the September 26, 2019 search the coin falls on.

Above the line: what the record showsBelow the line: what the Government did, filed and argued

First GUMMEE transaction on the public Stellar ledger.

PX 851

First live GUMMEE transaction.

DX 35

White Paper Version 1.0 is dated this day, “in collaboration with” WSA.

PX 199 · ECF 191 at 16

He gives the prosecutor his cloud-drive password, which opens the GUMMEE blockchain records, and tells her where the crypto files are.

Decl. ¶¶ 3, 5 · ECF 150-1 at 37

Sept. 18, 2019

Sept. 23, 2019

Sept. 26, 2019

Sept. 30, 2019

Oct. 10, 2019

Feb. 14, 2020

Feb. 9, 2022

March 2022

Agents search WSA’s New York office.

Decl. ¶ 2

He is arrested in Los Angeles.

Decl. ¶ 5

The date printed on the cover the Government would later file.

ECF 73-1 at 1

Pretrial filing: “not until 2020 … that concrete steps were taken,” with the 2020 cover attached. Its own footnote quotes the Sept. 18 and 23, 2019 dates.

ECF 73 at 6–7, 10 n.3 · ECF 73-1

Closing: the GUMMEE activity “starts the day after the World Sports Alliance’s offices were searched.”

Tr. 1055

Scroll sideways to see the whole timeline.

The motion says the Government “suppressed PX 199 (the September 26, 2019 GUMMEE Whitepaper 1.0) and injected ECF 73-1, the same document re-dated to February 2020, to support” its timeline, and that it “thus possessed all of the exculpatory evidence to disprove its claims.” (Memorandum at 2–3, § IX.A)

Memorandum § IX.B

“The manufactured void: ‘Not paid’”

“He never paid any of them”

Tr. 1092 · DX 44 · PX 810 · PX 820

What the jury was told in closing · Tr. 1092

The claim“[H]e never paid any of them.”
The list“Miranz, not paid. … Netki, not paid.”
The coin“[W]indow dressing,” a “coverup.”

What the Government’s own records show

DX 44 · in evidenceThe Miranz Statement of Work for the Stellar token and wallet, executed August 24–25, 2019: $4,700, half up front, half on completion.
Aug. 26, 2019 · PX 820$2,350 wired to Miranz: “Commtrade Invoice No 1193 Technology Expenses.”
Oct. 1, 2019 · PX 810The $2,350 completion payment: “Invoice No 1207 Technology Expenses.”
Oct. 8, 2019 · PX 810$5,000 to Netki.
What the payments boughtThe working wallet and coin. (PX 850; PX 851)
ID DataWeb$20,000, half later refunded. (DX 41; Tr. 877–78, 992–93)
JMJM MarketingOver $50,000. (PX 830; Tr. 708, 878–79)

The bank statements are filed with the court. This site does not reproduce them.

The exhibit

DX 44: Commtrade International statement of work with Miranz for the Stellar token and wallet, prepared August 23, 2019. Phone and email blacked out.

DX 45: Netki Master Services Agreement, first page.

DX 41: ID Dataweb Managed Services Agreement with World Sports Alliance, January 4, 2018, first page.

PX 830: JMJM Marketing Solutions agreement with World Sports Alliance, executed December 5, 2017, first page.

Cover sheet for Petitioner’s Exhibit PX 810: VO2 Global Chase statements, October 2019. Miranz completion payment October 1, 2019 and Netki payment of $5,000 on October 8, 2019. Authenticated by the Declaration of Asa Saint Clair, paragraph 10.

Cover sheet for Petitioner’s Exhibit PX 820: Commtrade International Chase statement, August 2019. Miranz upfront payment of $2,350 wired August 26, 2019. Authenticated by the Declaration of Asa Saint Clair, paragraph 11.

Phone and email are blacked out on DX 44. For PX 810 and PX 820, only the filed cover sheets are shown; the bank statements themselves are on the docket at ECF 204-2. Tap a page to read it full size.

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