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3 Wachovia Bank N.A. is a division of Wells Fargo Bank, N.A. A Guide to hecks and heck Fraud

4 DISTRIT /OUNTY OURT, DENVER OUNTY, OLORADO JOHN W. SUTHERS, Attorney General NATHAN POPLTNGER, riminal Investigator 1525 Sherman Street, 7th Floor Denver, O 823 Telephone: FAX: nathan.popiinger@state.co.us A ase No OURT USE ONLY A AFFIDAVIT FOR OURT ORDER I, Nathan Poplinger, state under oath that I have reason to believe that at the place known or described as: Wells Fargo Bank 174 Broadway Denver, olorado 8274 Which is located within the ity and ounty of Denver, in the State of olorado, there is now located the following described property: Bank statements, notices, wire transfers, checks, cashiers checks, deposit slips, deposit items, withdrawal slips, loan applications, loan agreements, signature cards, and documents reflecting and relating to the use, disbursement, andlor other disposition of funds regarding Account number , in the name of Standerson Mortgage & Financial orp. The facts tending to establish the grounds for issuance of a ourt Order: Your affiant has been employed by the olorado Attorney General s Office as a riminal Investigator with the Financial Fraud Unit since April 3, 27. During employment with the Attorney General, your affiant has conducted investigations concerning securities fraud. Prior to employment with the Attorney General, your affiant was employed by the olorado Department of Revenue as a Special Agent with the riminal Tax Enforcement Section ( TE ) beginning August 8, 25. While employed with the TE, your affiant conducted investigations concerning tax fraud and complaints regarding non-compliance of the olorado tax statues. Prior to being employed with TE, your affiant was employed by the olorado Division of Securities as an investigator from April 2, 1996, to August 8, 25. During employment with

5 the olorado Division of Securities, your affiant conducted several investigations concerning securities fraud and complaints regarding securities transactions. In this case, your affiant has probable cause to believe that Stanley Fenton Anderson, DOB: 9/2/1973, is committing an ongoing securities fraud by soliciting and selling investments in his company, Standerson Mortgage & Financial orp. (SMF ). Your affiant has probable cause to believe that the records sought will be of material evidence in this investigation and possible prosecution of Stanley Anderson. On or about January 5, 21, your affiant received a telephone call from attorney David Anderson, who stated that he represented 16 clients who invested over $3 million into what he believes to be a securities fraud and Ponzi scheme. David Anderson explained that between 26 and 29, his clients were either approached by or referred to Stanley Anderson, who solicited them to invest money in SMF. Stanley Anderson promised these investors either a 3% or a 35% return on their investment, and provided investors with promissory notes as evidence of the investment. Sometime in or around 28, Stanley Anderson started defaulting on his promissory notes, and in January 29, he stopped making interest payments to his investors. On January 8, 21, D. Anderson provided your affiant with copies promissory notes and associated investment checks. Also included were eight investor statements. Review of the investor statements substantially stated that: of his clients SMF 1) Stanley Anderson stated that SMF operated a mortgage business, loan business, tax prep business, 4-wheeler business, hauling business, and a cleaning business; 2) Stanley Anderson offered either a 3% or 35% annual return on investment with monthly interest payments; 3) SMF investors stated that after they invested Stanley Anderson either requested more money for new projects or asked investors to recommend other people to invest with SMF; 4) Interest checks were timely until late 28, when they began to come in past the due date and a few months later Stanley Anderson stopped sending interest checks. At or about this same time period Stanley Anderson approached his investors and sought to renegotiate their promissory notes by reducing the annual interest rate to 2%, claiming that the economy was affecting his business; 5) Alex Arndt who invested in August 27, requested to withdraw a portion of his investment funds sometime in July 28, was told by Stanley Anderson that his cash flow was not good enough to pay him. Anderson also told Arndt that he had to wait for another investor to invest before his money could be returned; 2

6 6) In early 29, Stanley Anderson approached his investors to renegotiate the promissory note by reducing the annual interest rate to %; 7) In or about mid 29, all payments to investors had stopped and no one was able to reach Stanley Anderson. On January 1 1, 21, your affiant spoke to Archie Rick Ames, a SMF investor. Ames stated that when Stanley Anderson started missing interest payments that Stanley Anderson indicated he had been introduced by another investor to a food distribution company and that he was going to make a presentation to the company in hopes of getting investment funds. When asked by Ames how that would help SMF investors, Stanley Anderson stated that he could use these funds to pay the SMF investors. On January 15, 21, your affiant spoke with James Berkley a SMF investor. Berkley stated that when Stanley Anderson started missing interest payments Stanley Anderson told Berkley that when he gets more investors then he would be able to pay his other investors. On February 1. 21, your affiant spoke with William Kunie. Kunie stated that he was a silent partner with 49% ownership of SMF. Kunie stated that sometime in late 27, Stanley Anderson told him that he was having problems with his businesses. Your affiant asked if Stanley Anderson was still soliciting for investors, Kunie stated that he knew of investors that invested during the 28 year. When your affiant asked Kunie if Stanley Anderson ever used investor money to pay back other investors, Kunie stated that that is what he heard and believes that did happen. With 13 years of training and experience in investigating securities fraud your affiant is familiar with activities that indicate the possibility of securities fraud by committed in a manner referred to as a Ponzi Scheme. Stanley Anderson s request for more investment money and/or request for more investors; interest payments being paid late, and the need to lower interest rates all indicate the possibility of such a scheme. Based on the above, your affiant asserts that there is probable cause to believe that the above bank account contains evidence relevant to violations of olorado Revised Statute (1), whereby It is unlawful for any person, in connection with the offer, sale, or purchase of any security, directly or indirectly: (a) To employ any device, scheme, or artifice to defraud; (b) To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading; or (c) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person. 3

7 Your affiant believes that reviewing the above described bank records is necessary to establish that Stanley Fenton Anderson solicited and convinced individuals to invest in his fraudulent investment program. Your affiant therefore seeks the ourt s Order to have Wells Fargo Bank produce materials and data to include but not limited to: Bank statements, notices, wire transfers, checks, cashiers checks, deposit slips, deposit items, withdrawal slips, signature cards, and documents reflecting and relating to the use, disbursement, andlor other disposition of funds regarding Account number , in the name of Standerson Mortgage & Financial orp., from January 1, 26 through compliance with this court order. Wherefore, your affiant respectfully requests that the ourt s Order be issued for the documents as outlined. Original Duly Verified Signature of Affiant Subscribed under oath before me on in the ity and ounty of Denver, olorado. at Signature of Judge 4

8 DISTRiT /OUNTY OURT, DENVER OUNTY, OLORADO JOHN W. SUTHERS, Attorney General NATHAN POPLINGER, riminal Investigator th 1525 Sherman Street, 7 Floor Denver, O 823 Telephone: FAX: nathan.poplinger@state.co.us ase No OURT USE ONLY OURT ORDER FOR PRODUTION OF REORDS To: Wells Fargo Bank 174 Broadway Denver, olorado 8274 The court, upon review of an affidavit filed by Nathan Poplinger, a criminal investigator with the olorado Attorney General s Office in support of the issuance of this order, hereby orders the production of the following records, for which there is probable cause to believe are in your actual or constructive possession or control: Standerson Mortgage & Financial orp. Account number ; ontracts, bank statements, notices, wire transfers, checks, cashiers! checks, deposit slips, deposit items, withdrawal slips, loan applications, loan agreements, signature cards, and documents reflecting and relating to the use, disbursement, andlor other disposition of funds from January 1, 26 through compliance with this court order. The court also hereby finds probable cause to believe that the requested material constitutes records: Which would be material evidence in a subsequent criminal prosecution in this state, another state, or federal court; The seizure of which is expressly required, authorized, or permitted by a statute of this state or the United States; and that such grounds and probable cause support the issuance of this order pursuant to ,.R.S.

9 Pursuant to ,.R.S., the above-named business entity shall produce the abovedescribed records within 3 days after the date this court order is served. The records shall be delivered to the olorado criminal investigator named in this order during normal business hours. The records shall be supplied in any form or format that is convenient for the business entity and that may be accessed by the named officer or the officer s agency or department. The business entity shall also provide a notarized statement that the records produced represent complete and accurate copies of all records identified in this order that are in the actual or constructive control of the business entity. If the business entity does not produce all records identified in this order, it shall identify the records not produced. Failure to comply with this order shall support a finding of contempt of court. Pursuant to ,.R.S., the investigator named below is hereby authorized to serve this order during normal business hours of the above-named business entity, and to receive the records during normal business hours of the business entity. Service shall issue in the same manner as a summons under.r..p. 4 or by personal service on a manager or supervisor of the business entity. This order must be served within 1 days after the date it is issued and may be served during normal business hours of the above-named business entity. Upon receiving the records from the business entity, the investigator named herein shall file a return and inventory with the court indicating the records that have been received, the total number of pages if supplied on paper, and the date upon which the records were received. The investigator named herein shall also file the original of the attestation of authenticity and completeness with the court. All records shall be produced to: Nathan Poplinger, riminal Investigator olorado Attorney General s Office Special Prosecution, Financial Fraud Unit 1525 Sherman Street Denver, O By: March 5, 21 Further orders which the court deems necessary: Dated this day of, 21. By the ourt: ounty/district ourt Judge

10 DISTRIT/OUNTY ourt. DENVER OUNTY, OLORADO JOHN W. SUTHERS, Attorney General NATHAN POPLINGER, riminal Investigator 1525 Sherman Street, 7th Floor Denver, O 823 Telephone: FAX: nathan.poplingerstate.co.us ase No. OURT USE ONLY RETURN AND INVENTORY FOR PRODUTION OF REORDS FOR: Wells Fargo Bank Pursuant to section ,.RS., the undersigned Nathan Poplinger has received from Wells Fargo Bank the following business records pursuant to an order issued by this court on February 12, 21, and served on the business February 12, 21. The records were received on May 5, 21. Attached to this return and inventory is the original of the attestation of authenticity and completeness. The records received were: Bank statements, notices, wire transfers, checks, cashiers checks, deposit slips, deposit items, withdrawal slips, loan applications, loan agreements, signature cards, and documents reflecting and relating to the use, disbursement, andlor other disposition of funds regarding Account number , in the name of Standerson Mortgage & Financial orp. Nathan Poplinger Investigator olorado Attorney General s Office Dated this 1 day of June, 21

11 Statement Date Account Date leared heck Date heck No Payee!Payor Memo Signed by Endorsed by Amount Balance Source ommon Vendor ategory SD Key XXXX23 6/3/26 5/31/26 Beginning Balance 66, ,99589 Beginning Balance Beginning Balance SD Key XXXX23 6/3/26 6/1/26 5/31/ Jane Doe Rent Jane Doe Skydive Properties 1,4 68,39589 Doe, Jane Tenant Inflows SD Key XXXX23 6/3/26 6/9/26 D Shamrock (27) 68,36889 Shamrock Fuel SD Key XXXX23 6/3/26 6/29/26 D 2632 Timberline Rd Ft ollins (2.5) 68,34839 King Soopers Fuel

12 Total Tenant Inflows Property Management General Inflows Managed Property Payment Repairs & Maintenance Professional Fees Office Rent Telephone/Internet/able Auto Purchase General Outflows Investor Deposit Investor Payment Amounts from/(to) Investors Amounts from!(to) Analyzed Accounts Amounts from/(to) Other Accounts ash Withdrawal Personal Account Personal Retail Personal Outflows Beginning Balance Total ash Inflow (Outflow) BALANE