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Lev Parnas’ Co-Defendant David Correia Tests the Send-Your-Phone Border Exception Work-Around

As much of a splash as Lev Parnas made during the Trump impeachment, his co-defendants are each mounting more intriguing defenses.

In the case of David Correia — who was charged in the marijuana side of the indictment — that includes an attempt to bypass the border exception (which allows authorities to search anything carried on your person through customs) by sending his attorney an iPhone, a Microsoft Surface Pro, a hard drive, and two notebooks he had with him before he returned to the United States to be arrested in October.

Are devices sent from overseas to an attorney covered by attorney-client privilege?

The issue first became public in March, when the government asked Judge Paul Oetken to order Correia’s lawyers, William Harrington and Jeff Marcus, to file a privilege claim over the package by March 23 (the government has been holding off accessing the evidence from the devices awaiting such claims). In a letter claiming that March 23 deadline was unrealistic given the COVID crisis, Correia’s lawyers claimed the government had totally misrepresented the attorney-client claim (and complained that the government had neither informed Correia right away about the seizure in October nor raised this issue at a status conference in February). With the government’s consent, Oetken gave Correia an extension.

Ultimately, Correia argued that he had sent the materials, “for the purpose of seeking legal advice,” The filing argued that because the FBI had ample notice that Marcus represented Correia (Correia lawyered up by August), and because Marcus negotiated a self-surrender upon Correia’s return from abroad, the government had to recognize that the DHL package was privileged when they obtained it. Correia further argued that because the notebooks include information that was clearly intended to solicit advice, the entire package must be privileged (that argument, however, was utterly silent about the devices). The lawyers also note that Correia did not send all the papers he had with him, which they point to as proof that the documents — to include the devices — that he did send were a selection specifically intended to get advice.

The government just submitted its response (note that one of the lawyers on this case, Nicholas Roos, also took part in the privilege fight over Michael Cohen’s devices). In it, they reveal that a privilege team reviewed the notebooks, after which prosecutors sent scanned copies of the notebooks and asked Correia’s lawyers to assert any privilege claims by January 20.

In the course of reviewing these materials for privileged information, the Government’s filter team identified items that potentially could be privileged. Accordingly, those items were withheld from the prosecution team and were redacted from the materials that are being produced in discovery. Since the filter team identified those items as only potentially privileged because the records do not contain adequate information to make a definitive assessment, the filter team will be providing the unredacted materials to you. If you believe any of the items that were redacted, or any other items, are privileged, please so indicate by January 20, 2020, and provide the factual basis for such a privilege assertion to the filter team. After that date, the materials in their unredacted form will be released to the prosecution team and produced in discovery.

After receiving that, Correia first claimed that everything in the package, including the devices, was privileged.

The government, however, cites Second Circuit and SDNY precedent holding that materials pre-existing attorney-client communications are not privileged.

Indeed, as the Second Circuit held nearly sixty years ago—rejecting a claim that the attorney-client privilege applied to various documents provided by a client to his counsel—“the attorney-client privilege protects only those papers prepared by the client for the purpose of confidential communication to the attorney or by the attorney to record confidential communications,” but “pre-existing documents and . . . records not prepared by the [client] for the purpose of communicating with their lawyers in confidence . . . acquired no special protection from the simple fact of being turned over to an attorney.” Colton v. United States, 306 F.2d 633, 639 (2d Cir. 1962); see also United States v. Walker, 243 F. App’x 261, 623-24 (2d Cir. 2007) (“putting otherwise non-privileged business records . . . in the hands of an attorney . . . does not render the documents privileged or work product (citing Ratliff v. Davis Polk & Wardwell, 354 F.3d 165, 170-71 (2d Cir. 2004))).

And it argues that they should be able to access anything pre-existing that is not privileged (the filter team continues to review the content of the devices).

The FBI’s preliminary analysis indicates that Correia’s hard drive contains tens of thousands of documents, images, and audio and video files; his iPhone contains tens of thousands of documents, images, and audio and video files, as well as other data such as internet browsing history and location information; and his Suface Pro computer contains hundreds of thousands of documents, images, and audio and video files. It is undisputed that these materials, as well as his notebooks, existed prior to Correia’s communications with counsel on this case. They were not, in toto, created at the direction or advice of counsel, and did not become privileged merely because Correia sought to send them to his counsel.

The government rejects Correia’s argument that by accessing the files, the government learned about what selection of materials Correia was seeking counsel. It argues that nothing in the package reflected instructions from Marcus to Correia (there was no note included at all), and the  government first learned that the selection of items in the package ended up there based on Marcus’ advice from Correia’s own filing.

Correia erroneously claims that by intercepting the DHL package, the Government learned what materials counsel had advised Correia to collect. On the contrary, the DHL package contained no such communication. The Government “learned” that fact—assuming it is true— only through counsel’s briefing on this motion. In any event, it is simply false to suggest that the DHL package contained a carefully curated selection of relevant documents. It contained the opposite: the entirety of Correia’s multiple devices and notebooks, with no indication as to what particular documents or portions of documents may be relevant. The seizure of those materials revealed nothing about counsel’s “defense planning” (Mot. 13)

[snip]

As counsel is well aware, the Government’s assumption had been that Correia simply sent his devices and notebooks to counsel so that they would not be in his possession and subject to seizure when he was arrested.

While the government doesn’t address the documents Correia had on his person on his arrest, they describe that he had no devices at all, just the charging cords for them.

Although Correia still had a phone case, multiple phone chargers, and charging cords with him, he did not have a single electronic device on his person.

Given how often InfoSec people have argued that this method — sending your lawyer sensitive devices before crossing a border — is the best way to protect them, the resolution of this issue has some wider legal interest.

But in this case, the resolution likely comes down to the fact that prosecutors told Judge Oetken, when getting a warrant for the DHL package, that it was sent from Correia to his lawyer.

This Court, based upon an affidavit that made clear the DHL package was sent by Correia to his counsel, found probable cause to believe that the package and its contents contained evidence, fruits, and instrumentalities of federal crimes.

[snip]

On or about October 21, 2019, the Court signed a search warrant authorizing the Government to search a package sent via DHL from Correia to his counsel (the “DHL Package Warrant”). The supporting affidavit explained the following, among other things: On October 9, 2019—the same day that Lev Parnas and Igor Fruman were arrested—agents with the Federal Bureau of Investigation (“FBI”) attempted to arrest Correia at his home, but learned from his wife that Correia was out of the country. Shortly thereafter, Jeff Marcus, Esq., contacted the FBI, identifying himself as Correia’s counsel. Counsel arranged for Correia to fly into New York on October 14, 2019, arriving on October 15, 2019, in order to surrender. Counsel confirmed that Correia was aware that he would be arrested by the FBI upon landing in the United States.1 On October 14, 2019, however, counsel advised the FBI that Correia had left his passport at a DHL store, where he was mailing something before flying back to the United States, and could not board the plane without his passport.

[snip]

The affidavit in support of the DHL Package Warrant further stated that “materials obtained from DHL” reflected that Correia had mailed the DHL package to his counsel. The affidavit noted that the package’s listed contents—provided by the sender, Correia—apparently included a phone, tablet, and hard drive, which “do not appear to be items that were created for the purpose of legal advice but rather appear to have been sent by mail so that they would not be on Correia’s person when he arrived in the United States to be arrested.” The affidavit stated that the Government would nonetheless “utilize a filter review process, including through the use of a filter team comprised of agents and prosecutors who are not part of the prosecution team, for review of the [DHL package and its contents].”

That is, Oetken has already weighed in on this matter, and the government has provided a good deal of Second Circuit and SDNY precedent far more on point than a single Fifth Circuit case, United States v. Hankins, that Correia relies on. One key detail seems to distinguish this seizure and search from any garden variety attempt to bypass the border exception: Correia knew he was going to be arrested when he landed, meaning he knew he was trying to defeat not just the border exception, but a search warrant for anything on his person.

Where did the seizure happen and under what legal authority?

All that said, there’s a detail that, while it probably doesn’t affect the legal argument, raises questions about how and when the government seized the package. As noted, Correia sent the package from a DHL office in whatever country he was in (he was somewhere in the Middle East, and wherever it is, flights to JFK all seem to involve red eyes). He left his passport at that office, so he was unable to board his scheduled flight on October 14. In explaining the one day delay in Correia’s self-surrender, Marcus unwisely told prosecutors that DHL was involved and only in later communications revised his explanation to say Correia had left his passport in a “local” store. It’s unclear whether the government seized the package in that foreign country or as it entered the US. Nor is it clear — from the scant details of the affidavit included in the government filing — whether the government had, or needed, a warrant to make that seizure. However they seized it, Correia is not challenging the legal sufficiency of the seizure itself on any but privilege grounds (though he may file suppression motions in May).

As Correia described it, when the package never arrived at Marcus’ office, they asked DHL where it had gone, and DHL ultimately claimed to have lost it.

In the following days, Mr. Marcus’s law firm never received the communication sent by Mr. Correia via DHL. Id., at ¶ 20. Mr. Correia made repeated inquiries to DHL about its status but was told several times that it was “lost” in transit and DHL was taking steps to locate the sent package. Id. Finally, on October 29, 2019, DHL informed Mr. Correia that “[a]fter conducting extensive searches of our Service Centers, including warehouses, docks, vehicles and lost and found facilities, we have not been able to locate your shipment.” Id. They also said they were ending their search.

DHL was either obeying a gag, or seem not to have received process from the government that would show up in their files.

So unbeknownst to Correia, the government somehow seized the package, and on October 21 (a week after Correia sent it), got Judge Oetken to approve a warrant to search the package and the devices in it.

Correia only learned details of what happened, serially, between December and January.

After a December 2019 court conference, the defense team learned that the Government said it was in possession of the telephone that Mr. Correia had sent to his lawyers via DHL. Id., at ¶ 21. The defense team also subsequently received a search warrant which indicated that the Government had intercepted and searched Mr. Correia’s communication to Mr. Marcus. Id., at ¶ 22. In a production letter dated January 10, 2020, the Government produced an agent’s inventory of Mr. Correia’s communication to Mr. Marcus which included two notebooks, a hard drive, a computer and a telephone.

The most likely answer, however, is that the government obtained the package with DHL’s assistance, which is not legally surprising, but something worth noting for those attempting to use this method to bypass border exceptions.

The pending superseding indictment

The government has said in past hearings that it plans to obtain a superseding indictment before May. Given how COVID has affected all legal proceedings, including grand juries, that likely will be delayed. But it seems clear that the government wants to obtain this information before that happens.

Even More Guaranteed Fraud From Parnas and Giuliani

Jim here.

Just when we think we’ve reached a full description of the many levels of fraud associated with Lev Parnas and Rudy Giuliani, new revelations appear. Yesterday, the Washington Post reported that prosecutors in the Southern District of New York asked for Parnas’ bail to be revoked because he had failed to disclose a payment of $1 million he received just prior to his arrest. And this morning, Wall Street Journal’s Shelby Holiday is out with a new video with additional details on how Fraud Guarantee tried to raise investor money off its association with Giuliani.

First, the Parnas bail story:

Federal prosecutors in New York asked a judge Wednesday to jail an associate of Rudolph W. Giuliani who is accused of violating campaign finance laws, asserting that the Ukrainian-born businessman who is on home confinement awaiting trial had lied to court officials about his financial assets.

In a court filing, federal prosecutors asked a judge to revoke the bail of Lev Parnas because he had given three separate inaccurate accountings of his financial assets to court officials. Among the assets Parnas failed to disclose, prosecutors alleged, was a $1 million payment in September 2019 from a Russian bank account, which appeared to have been used on personal expenses and buying a home.

The filing goes on to note that Parnas poses an exceptional flight risk, given his association with wealthy supporters in Ukraine and Russia and the fact that he had spent $70,000 on private air travel in the month just before his arrest.

Parnas appears to have lied about everything, including how much he was paid to act as an interpreter in the Firtash case:

Among the inaccurate information Parnas provided had to do with income he was receiving for working as an interpreter for a law firm, prosecutors alleged. He told a probation officer on Oct. 15 that he earned $50,000 annually from the law firm, but he did not disclose any income from the law firm in a signed affidavit that he submitted later that month. Prosecutors alleged that, in fact, Parnas earned $200,000 from the law firm between August and October, money that was held under the name of his wife, Svetlana.

Parnas’s lawyers have said that he was hired to work as an interpreter for conservative lawyers Victoria Toensing and Joe diGenova, when they were hired to represent Ukrainian gas tycoon Dmytro Firtash in July.

And yet, the attorney for Parnas continues to beg Congress for him to have a chance to testify in impeachment hearings. What could possibly go wrong when putting a habitual liar on the stand?

Meanwhile, Shelby Holliday has a new report today on Fraud Guarantee and how it intended to raise money off of Rudy Giuliani’s association with the company. Recall that Charles Gucciardo “invested” in Fraud Guarantee by transferring $500,000 to Giuliani Partners in September and October of 2018. Parnas and his partner in Fraud Guarantee, David Correia, were looking for much more than just getting Rudy on board. As Holliday reports, they sent out an investor letter in September 2018 that would capitalize on Rudy’s involvement even as the agreement with him was in the process of being implemented:

Just wow. In attempting to attract investors, Parnas and Correia said that they wished to “closely mirror the LifeLock model” as they paid Giuliani up to $2 million for his involvement. This letter or something very similar to it appeared to work on Gucciardo, since his attorney referenced LifeLock in justifying Gucciardo jumping on board based on Rudy’s involvement. As I noted in the comments of my Gucciardo post, the LifeLock story is a remarkable parallel to Fraud Guarantee because LifeLock’s “product” was totally worthless. At least LifeLock was selling something as a product, though, because I have yet to read a report that provides detail on any kind of software or other product that Fraud Guarantee actually intended to provide to customers.

Further, Rudy didn’t become a spokesman for LifeLock until long after the hilarious thirteen or so times that its CEO had his identity stolen after running TV ads touting his Social Security number and claiming he was immune from identity theft due to his superior product. Not only that, LifeLock had also paid a huge fine for selling a worthless product before Rudy began appearing in endorsement videos in 2013:

The Federal Trade Commission dented Lifelock with a whopping $12 million fine in 2010 for failing to deliver the identity security they promised and balking on refunds to clients.

The company was also roundly mocked after CEO Todd Davis brashly announced his Social Security number in a commercial as a sign of confidence, and then had his identity stolen repeatedly.

Still, Giuliani expressed his complete support of the enterprise after signing the consulting deal last year.

“As I continue to learn more about this crime and have assessed the current protection options available to consumers, I am convinced that LifeLock is an industry leader in identity-theft protection,” he said in a press release.

Apparently, the Fraud Guarantee investor letter brushes off the LifeLock history by saying there was simply a “compliance issue” and that Fraud Guarantee has found a way to deal with that.

How in the world anyone would put significant money into this operation is a complete mystery. Even the simplest due diligence would send a real investor running for the exits rather than getting out the checkbook. Instead, it seems more likely to me that any outside money they raised on this scheme was just a bonus and that the real reason for Fraud Guarantee was as a vessel for Parnas to get funding for his adventures in Ukraine on behalf of Trump while also funneling some of those funds to Giuliani.

Finally, I just can’t try to take on the bit about the person who supplied the letter to Holliday and their scheme to get a painting of a “Third Temple” in Jerusalem (intended as a “peace platform”?) in front of Trump. I’ll let you folks try to figure out what that one is all about. At any rate, on first blush, this person would appear to be just the kind of rich fool who would provide some of that bonus money into Fraud Guarantee, this time to the tune of $250,000.

We Can Learn A Lot From That Lev Parnas Photo With Ivana Trump

Jim here.

Yesterday, Shelby Holliday of the Wall Street Journal provided a look at a private Instagram account for Lev Parnas. There is a treasure trove of information in what was revealed there. For this post, I want to concentrate on what appears to be the earliest entry by Parnas, dated April 24, 2015:

There is just so much going on here. As far as I can tell, this is the earliest evidence of Lev Parnas reuniting with any of the Trumps since his time as a teenager working for Kings Road Realty selling co-ops owned by Fred Trump. Recall that evidence is beginning to accumulate that Lev Parnas and David Correia may have been involved in the sale of Trump condos to Russian buyers in South Florida.

But note the date of this encounter: Donald Trump didn’t declare as a presidential candidate until June of 2015, and yet here is Parnas meeting with Ivana in April. As far as I can tell, Parnas began working with the Trumps in 1988. His end date with them is fuzzy, but I’m guessing it went until just before he got his registration as a stockbroker in December of 1993. Donald and Ivana divorced in March of 1992, so there’s a good chance Lev Parnas ran into Ivana while working for them and saw the divorce taking place.

Note that Parnas mentions both the location where they are, Lique, which is a very high end restaurant in the Sunny Isles (yes, that’s where there are a number of Trump high rises) region and Fraud Guarantee. Recall that Fraud Guarantee is the entity that was used to pay Rudy Giuliani at least $500,000 recently. We have to wonder now if those payments started much earlier. Fraud Guarantee was incorporated in October of 2013 in Florida but did not list Parnas or Correia even though they feature as founders on its website. No annual report was filed, so the Florida corporation was dissolved in 2014, before Parnas mentioned it in this post.

Lique is very interesting. From the website, it is clear that it is the background in this photo. The founder, Alex Podolonyy, is Ukranian. In a remarkable parallel to what happened to the Fruad Guarantee website, the bio for Podolonyy is on the Lique site, but the link to it has been removed from the home page.

So, we know that’s Lev Parnas on the left and Ivana Trump next to him. It’s also clear that’s David Correia on the right. One might guess initially that two remaining people are the wives of Parnas and Corriea, but I think that’s only half right. I’m pretty sure that’s Svetlana Parnas next to Correia. It seems that Correia’s wife very likely was indisposed at the time of this photo. She appears to have been sentenced for writing hot checks in October of 2014. There are a couple of lawsuits back and forth between Correia and his then wife, but it looks like after they split she continued her check kiting and even became somewhat notorious.

A hint for the unknown woman between Ivana Trump and Svetlana Parnas in the photo can come to us from the timeline of Parnas and Correia company formation. Just a couple of months prior to this photo, Lev Parnas and David Correia incorporated Mendo Cali, LLC on August 19, 2014. But, as you might recall from my previous post on this issue, there’s a third person involved in this entity: Inna Ponomareva. Subsequent to writing that post, I ran across this remarkable page with a “business card” for Inna Ponomarava as a Vice President of Miama Red Square Realty, the firm most closely associated with the sale of Trump condos to Russians in South Florida. (Hover your cursor over the image to get full color.) Below, I’ve put that image for Ponomareva alongside the unknown person in the photo with Ivana Trump:


Blowing up the Instagram image came at a cost of sharpness, but it sure feels to me that we are seeing Inna Ponomareva alongside Lev Parnas, David Correia and Ivana Trump. And that makes us wonder about just what “#bigbusiness” Parnas was bragging about. I think there’s a good chance it is him getting back to his roots, selling Trump properties.

Do Lev Parnas and David Correia Have A Connection To Sale Of Trump Properties To Russians In South Florida?

 

Jim again here. 

Yesterday’s post about Fraud Guarantee, a company started by two of Rudy Guiliani’s clients who were indicted, was so much fun that I decided to do more noodling around in Florida corporate records for Lev Parnas and David Corrieia. As I noted on Twitter this morning, there are many corporate entities associated with Lev Parnas, and yet none of them seem to have active status with the state, including Fraud Guarantee itself:


One of these corporate entities stands out when looking at the names associated with it. Mendo Cali, LLC, near the middle of the list in the tweet, has this information on the state website:


Note the person listed along with Parnas and Correia: Inna Ponomareva. What an interesting-sounding name! When searching that name, especially with a South Florida preference, some interesting hits pop up:

It appears that there is a person by the name of Inna Ponomareva who worked for Miami Red Square Realty. I say worked for because it appears that Miami Red Square also is no longer an active company. Clicking on these links reveals that the real estate listings are no longer active, but it is clear that Ponomareva was associated with listings for these properties with Red Square.

And this is where it gets really interesting. Miami Red Square Realty features prominently in this Washington Post article from just around the 2016 election:

 The first of three identical 45-story Trump-branded condo buildings opened in this oceanfront city at a seemingly terrible time, just as the recession was dawning and the real estate market was starting to crumble.

Many other projects in South Florida floundered in the lead-up to the national housing collapse of 2008. But the Trump buildings were among those that survived, in part because the developers were able to turn to another business source seemingly immune to the factors dragging down the U.S. market: wealthy Russians looking to move their money out of the volatile ­post-Soviet economy.

Hey, that’s pretty interesting. There’s more:

Roman Bokeria, the Georgian-born chief executive of Miami Red Square Realty, said that ­Russian-speaking investors have been attracted to the Trump buildings because they see the brand as a safe place for their money.

“They don’t trust stocks or bonds,” Bokeria said. “They want real estate, something they can see and touch and feel. And for Russians, where is the best real estate? It’s Miami and South Florida. It’s Trump. That is the dream.”

Things get even more interesting from here. Note when Mendo Cali, LLC was incorporated: August of 2014. Just above the passage about Red Square in the Post article, we have this:

Trump does not own these buildings, but, like many Trump projects around the world, he licensed the use of his name and took a percentage of the profits from the initial sales of units. Real estate agents say there have been fewer Russian investors in Florida condos since U.S.-imposed sanctions on Russia took effect in 2014. They predict that the market will improve if Trump wins and reconsiders the sanctions.

Hmm. Things got difficult for Russians wanting to buy US properties in 2014 due to sanctions. But there’s one other interesting development regarding the market for selling Trump properties in South Florida to Russians in 2014. Remember when Reuters came out with their story in 2017 about Russians owning Trump properties? Here are a few snippets:

During the 2016 presidential campaign, Donald J. Trump downplayed his business ties with Russia. And since taking office as president, he has been even more emphatic.

“I can tell you, speaking for myself, I own nothing in Russia,” President Trump said at a news conference last month. “I have no loans in Russia. I don’t have any deals in Russia.”

But in the United States, members of the Russian elite have invested in Trump buildings. A Reuters review has found that at least 63 individuals with Russian passports or addresses have bought at least $98.4 million worth of property in seven Trump-branded luxury towers in southern Florida, according to public documents, interviews and corporate records.

The lede here is definitely buried:

The tally of investors from Russia may be conservative. The analysis found that at least 703 – or about one-third – of the owners of the 2044 units in the seven Trump buildings are limited liability companies, or LLCs, which have the ability to hide the identity of a property’s true owner. And the nationality of many buyers could not be determined. Russian-Americans who did not use a Russian address or passport in their purchases were not included in the tally.

What a coincidence! Fully a third of the Trump properties are owned by LLCs so that the identities of the true owners may be obscured. And for the three years leading up to the Reuters analysis, sanctions curtailed ownership by Russians.

The Reuters article goes on to detail one person who was particularly active in the sales of these properties [The Dezer Corporation built the properties under a license from Trump]:

Dezer and Trump got help selling the condos from Elena Baronoff, who immigrated from the Soviet Union in the 1980s. Baronoff, who grew up in Uzbekistan, had been active in Soviet cultural associations. In Miami, she soon began bringing Russian tour groups to Miami.

Gil Dezer’s father, Michael, recruited Baronoff to work alongside the Dezer corporation. She traveled to Moscow, St Petersburg, France and London to bring in Russian buyers, according to Dezer, selling apartments to them for between $1 million and $2 million. Baronoff was diagnosed with Leukemia in 2014 and died a year later.

“She was huge, she was big for them,” Dezer said, referring to Russian buyers. “No one has filled her shoes.”

Hmm. The primary mover and shaker for selling Trump properties in South Florida to Russians took ill in 2014. Although Dezer claims in the article that “No one has filled her shoes” the timing for the incorporation of Mendo Cali, LLC sure fits the window when this market opened up. And Mendo Cali, LLC just happened to have a person with a Russian name and an affiliation with Red Square Realty, which sold Trump properties to Russians. I’m sure this is just an innocent coincidence.

Update October 13

From a Washington Post article put Saturday evening, October 12:

Parnas, 47, was born in Ukraine but moved with his family to the United States as a child and grew up in Brooklyn. He told The Washington Post in an interview conducted before his arrest that he got his start in real estate, selling Trump condos for Donald Trump’s father, Fred, then worked in shipping in the former Soviet Union before becoming a securities trader. He moved to Florida in the mid-1990s.

Isn’t that interesting? We now have a connection between Parnas and the Trump family that started decades ago. And that connection is Parnas selling Trump-branded condos.

Rudy Giuliani Represents Fraud Guarantee Founder

Marcy has already hit the announced arrests of Rudy Giuliani clients Lev Parnas and Igor Fruman as they were about to leave the country. In reading the New York Times article about the arrests and indictment, I noticed that, at least at the time of that reading, David Correia,  one of the four men indicted, was still not in custody.

I hadn’t heard of Correia before, so I did some digging. It would appear that Correia’s Twitter handle is @DavidCorreia14. The account appears to have been taken down, but there was still a cached version on Google.

It would be easy to mistake his tweets for any standard Trump bot retweeting all of the usual conspiracy theories, rather than realizing he was in the middle of some of their more nefarious schemes.

A couple of weeks ago, the Miami Herald ran a story on Parnas and Fruman, where we see that they are basically con artists with a trail of lawsuits following them around. Most hilariously, Parnas had the gall to incorporate a company under the name Fraud Guarantee. Significantly, when I started searching around to find out more about David Correia, he turned out to be a co-founder of Fraud Guarantee:

Hmmm. Campaign finance indictment. Background in commercial mortgages. Founder of Fraud Guarantee. It’s not clear to me how Correia originally hooked up with Parnas and Fruman, but the commercial real estate angle and propensity for illegal activity sure seems like a good fit with the Trump organization.

It’s really hard to get over just how much outright gall it took for Parnas and Correia to name their company Fraud Guarantee. And for Parnas to be represented by Rudy Guiliani, who has been tasked with obtaining fraudulent dirt on the Biden family for Trump, the circle just keeps closing in on itself. (Note added as I was proofing the post: it appears that the Fraud Guarantee website has been scrubbed. Glad I got those screengrabs!)

As a postscript for those of us in Florida, it’s also especially juicy that the fraudulent shell company set up to funnel money to political campaigns, Global Energy Producers, also made a $50,000 contribution to the campaign to elect currentFlorida Governor Ron DeSantis.