Memo written by Sam Bankman-Fried’s ex-girlfriend Caroline Ellison to form part of case against FTX founder

Prosecutors in the Sam Bankman-Fried case have provided the clearest picture yet of the strategy they plan to use to jail the disgraced cryptocurrency mogul during his October trial.

In a 70-page court file released Monday, prosecutors said they plan to use testimony from some of Bankman-Fried’s former inner circle, including ex-lover and Alameda Research CEO Caroline Ellison, 29.

Bankman-Fried, 31, had his record $250 million bail revoked Friday after he allegedly leaked Ellison’s love letters to the New York Times in an attempt, prosecutors say, to tamper with her testimony.

The state also said it planned to use notes Ellison took while working under him, including a memo she wrote after talking to him entitled “Things Sam Is Freaking Out About.”

In addition to the blockbuster testimony from Ellison and several other top FTX lieutenants, the case against the 31-year-old former billionaire includes a wealth of financial records, political donations, and private Slack messages.

Bankman-Fried faces more than 100 years behind bars on a slew of charges related to the collapse of his cryptocurrency exchange FTX in November 2022, which came after he allegedly used client funds for luxury purchases and political donations.

Sam Bankman-Fried faces testimony from several members of his former inner circle when he goes on trial in October

The 31-year-old faces a slew of charges related to the collapse of his cryptocurrency exchange FTX in November 2022

Caroline Ellison, Bankman-Fried’s ex-lover and business partner, is expected to testify against him

In the lawsuit filed Monday, prosecutors said they plan to turn members of Bankman-Fried’s cadre against him to prove he illegally and recklessly moved billions of dollars at the height of his influence.

Among the evidence to be submitted is a recording of a meeting in which Ellison told her associates at Alameda Research — the hedge fund arm of FTX — that she was working with Bankman-Fried to funnel money from clients’ accounts.

She is expected to testify against him along with other former top FTX lieutenants, including Gary Wang and Nishad Singh – all of whom have already pleaded guilty to the scheme and agreed to assist prosecutors.

The purpose of the filing Monday was to argue that the evidence gathered in recent months should be admissible in court.

The trove of documents would be one of the largest ever collected for a white-collar prosecution, and it includes financial records, spreadsheets, private messages and Google Docs.

Among the private messages was a stash of 750,000 pages of Slack messages from Wang’s laptop — which Bankman-Fried’s defense argued should be inadmissible in court because it was obtained and presented just three days ago.

His defense filed its own filing on Monday to strike prosecutors after it “repeatedly failed” to meet deadlines for handing over evidence to be used in the trial.

The 31-year-old’s lawyers argued that after July 1, the government should stop using Wang’s Slack messages — or any other evidence produced by prosecutors.

Further material related to Bankman-Fried’s resignation, which came a month before his arrest last December, was also ruled inadmissible.

“The defense does not have unlimited resources and must spend the limited time left for trial preparing its defense rather than reviewing eleventh-hour exhibits,” the defense’s filing reads.

Bankman-Fried had his record $250 million bail revoked Friday after allegedly attempting to tamper with witness statements. He is pictured for his bail hearing at the Manhattan Federal Court on August 11, 2023

Two weeks ago, prosecutors surprised Bankman-Fried’s lawyers by demanding his incarceration, saying he violated his bail by giving The New York Times Ellison’s private writings.

The judge in his case, Judge Lewis Kaplan, ordered him to await trial behind bars after determining there was “probable reason to believe that the defendant attempted to tamper with witnesses on at least two occasions.”

In the posts, Ellison detailed her life as the head of the hedge fund arm, wracked with fear and doubt, with a diary entry: “At the end of the day, I can’t wait to go home and turn off my phone and have a drink and take a break.’

She is expected to testify against Bankman-Fried when his blockbuster trial opens in October, where she may be joined by Singh and Wang.

Correspondence between the three is included in spreadsheets prosecutors say they plan to present to a jury, which “tracked illicit money flows between Alameda and FTX,” the filing said.

Bankman-Fried hangs his head in this court sketch after being handcuffed on August 11, 2023

Sam Bankman-Fried is escorted to jail by court officials in this courtroom sketch

At the height of his power, Bankman-Fried commanded billions of dollars and was seen as a leader in a new generation of financiers. He used this position to pour millions into political donations, mainly to the Democratic Party.

But prosecutors said they plan to use political donations as evidence of his alleged crimes, including a message a former FTX executive sent to a family member in November 2021 about how the donations would be used to promote cryptocurrencies in legislation, reports the New York Times.

The lyrics stated that the purpose of the donations was to “wipe out anti-crypto dems for pro-crypto dems and anti-crypto repubs for pro-crypto repubs.” The director, Ryan Salame, was seen raiding his home in April as part of an ongoing investigation, but he has not been charged with any crime.

Names cited for possible testimony in the filing included Ellison, Wang, Singh and a former employee who “regularly consulted with the defendant about FTX’s fundraising efforts.”

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