A091 (Rev.

11111) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

Western District of Tennessee

United States of America

)
v.
LISA JEANINE FINDLEY )
a/k/a LISA HOLDEN ) Case No. 2:24-cr-20145-JTF-tmp
a/k/a LISA HOWELL )
a/k/a GREGORY NAUSSANY
a/k/a KURT NAUSSANY ) FILED UNDER SEAL
a/k/a USA JEANINE SULLINS )
a/k/a CAROLYN WILUAMS )
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Between the date(s) of 07/2023 through 08/2024 in the county of Shelby in the
Western District of Tennessee , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. § 1028A Aggravated Identity Theft
18 U.S.C. § 1341 Mail Fraud

This criminal complaint is based on these facts:

See attached affidavit.

!if Continued on the attached sheet.

~+/ omp alnant s¥:lgnature

Christopher Townsend-SA FBI

Printed name and title

Attested to by the complainant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date: 08/15/2024
Judge 's signature

City and state: Memphis, TN Hon. Tu M. Pham, Chief U.S. Magistrate Jude
Printed name and title
 IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION

IN THE MATTER OF AN APPLICATION

FOR A WARRANT TO ARREST:

LISA JEANINE FINDLEY

a/kJa LISA HOLDEN Case No. 2:24-cr-20145-JTF-tmp
-----------------
alkJa LISA HOWELL
a/kJa GREGORY NAUSSANY Filed Under Seal
a/kJa KURT NAUSSANY
a/kla LISA JEANINE SULLINS
a/kJa CAROLYN WILLIAMS

AFFIDA VIT IN SUPPORT OF AN

APPLICATION FOR AN ARREST WARRANT

I, Christopher Townsend, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Federal Bureau ofInvestigation (FBr) and have been

so employed since September 2016. I am currently assigned to the FBI Field Office in Memphis,

Tennessee. During the course of my employment with the FBI, I have been assigned to investigate

white collar crime cases, including corporate fraud, mortgage fraud, wire fraud, mail fraud, health

care fraud, and money laundering cases. I have participated in numerous investigations; in the

service of arrest and search warrants; and the interviews of suspects, witnesses, and other persons

having knowledge of the violations of law relating to those violations which fall within the scope

of the FBI's jurisdiction.

2. I make this affidavit under Federal Rule of Criminal Procedure 4 ("Rule 4") in

support of a criminal complaint, and seek the issuance of an arrest and seizure warrant for LISA

JEANINE FINDLEY ("FINDLEY") (also known as "Lisa Holden," "Lisa Howell," "Gregory
Naussany," "Kurt Naussany," "Lisa Jeanine Sullins," and "Carolyn Williams") for violations of

18 U.S.c. §§ 1341 (Mail Fraud) and 1028A (Aggravated Identity Theft).

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show merely that there is sufficient probable cause for the requested warrant and does not set

forth all my knowledge about this matter.

4. Pursuant to Rule 4, the requested warrant may be executed by an "authorized

officer" and may be executed "within the jurisdiction of the United States." Special Agents with

the FBI, and Postal [nspectors with the United States Postal Inspection Service (who are also

involved in the investigation of this case), are authorized federal law enforcement officers under

18 U.S.C. §§ 3052 and 3061, respectively.

SUMMARY OF PROBABLE CAUSE

5. Using a series of aliases, email addresses, and fake documents, FINDLEY engaged

in a scheme to defraud Elvis Presley's family for millions of dollars by threatening to foreclose on

the "Graceland" estate owned by Mr. Presley's family and auction Graceland to the highest bidder

as part of a fraudulent non-judicial sale she scheduled for May 23, 2024. As part of this scheme

to defraud:

a. FINDLEY concealed and disguised from her victims her identity, the existence of

the scheme to defraud, and her involvement in the scheme, by using aliases,

including "Gregory Naussany," "Kurt Naussany," and "Carolyn Williams," and

email addresses, including [email protected],

gregoryenaussanyni pI [email protected], and

[email protected].

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b. FINDLEY used these aliases and email addresses to create the false and fraudulent

impression that "Naussany Investments & Private Lending LLC," a/k1a "NJPL

LLC" ("Naussany Investments"), was a real company engaged in the business of

making personal loans.

c. FINDLEY falsely and fraudulently represented to attorneys for D.R.K. (Mr.

Presley's granddaughter) that, before her death, L.M.P. (Mr. Presley's daughter and

D.R.K.'s mother), had (i) borrowed $3.8 million from Naussany Investments in

2018, (ii) pledged Graceland as collateral for the loan, and (iii) defaulted on the

loan.

d. FINDLEY used, without lawful authority, L.M.P.'s name and signature, as well as

the names, signatures, and notary seals of other real persons, to create fake loan

documents purporting to memorialize L.M.P.'s 2018 agreement to borrow $3.8

million from Naussany Investments and pledge Graceland as collateral for the loan,

including a fake promissory note and deed of trust.

e. FINDLEY used the fake loan documents as part of a false and fraudulent creditor's

claim filed on behalf of Nauss any Investments in the Superior Court of California,

County of Los Angeles ("California Superior Court"), in connection with the

administration of L.M.P.'s estate. FINDLEY also filed other fake documents in

support of Naussany Investments' false and fraudulent creditor's claim, including

fake bank records and mailing labels.

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f. FINDLEY proposed to D.R.K.'s attorneys, without disclosing that the creditor's

claim was false and fraudulent, that she would be agreeable to settling the claim for

$2.85 million, which represented 75% of the amount that FINDLEY falsely and

fraudulently claimed that L.M.P. had borrowed.

g. FINDLEY submitted the fake loan documents to the Shelby County Register's

Office in Memphis, Tennessee, to record fraudulently the fake deed of trust and

facilitate the fraudulent sale of Graceland.

h. FINDLEY published in The Commercial Appeal (one of Memphis, Tennessee's

daily newspapers) a fraudulent "Notice of Foreclosure Sale" that falsely and

fraudulently represented to the public that L.M.P. had borrowed $3.8 million from

Naussany Investments in 2018, pledged Graceland as collateral for the loan, and

defaulted on the loan. The false and fraudulent ''Notice of Foreclosure Sale" also

represented to the public that Graceland would be sold to the highest bidder in an

auction to be held on May 23, 2024.

1. After D.R.K. filed a lawsuit in the Shelby County Chancery Court in Memphis,

Tennessee to stop the fraudulent sale of Graceland, FINDLEY submitted to the

Shelby County Chancery Court filings and documents that contained materially

false and fraudulent representations.

J. After FINDLEY's scheme attracted global media attention, FINDLEY made false

and fraudulent representations to D .R.K. 's attorneys, the Shel by County Chancery

Court, and the press creating the false and fraudulent impression that the person

responsible for the scheme was a Nigerian identity thief located in Nigeria.

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 STATEMENT OF PROBABLE CAUSE

6. Based on witness interviews I have conducted, my review of documents obtained

from third parties, reports of interviews conducted by other law enforcement officers,

conversations with other law enforcement officers, and publicly filed documents, I have reason to

believe the following:

Elvis Presley and Graceland

7. Elvis Presley was a world-renowned singer, actor, and cultural icon. In and around

1957, Mr. Presley purchased a 13.8-acre estate in Memphis, Tennessee, known as "Grace land," as

a home for himself and his family. Mr. Presley lived at Graceland for twenty years until his death

in August 1977.

8. In and around 1982, Graceland opened to the public. Since then, Graceland has

grown to become one of the most visited private homes in America. In and around 1991,

Graceland was placed on the National Register of Historic Places. In and around 2006, it was

designated by the Secretary of the United States Department of the Interior as a National Historic

Landmark.

9. Since Mr. Presley's death, Graceland has remained in Mr. Presley's family.

Beginning in and around 1993, Graceland was owned by a revocable trust established by Mr.

Presley's only child, L.M.P. After L.M.P.'s death in January 2023, her daughter, D.R.K., became

trustee. As trustee, D.R.K. was Graceland's sole owner.

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 The Scheme to Defraud

July 2023: FINDLEY Created False Creditor's Claim and Sent to Attorneys (or D.R.K.

10. Based on my review of records provided by Microsoft, on or about July 14,2023,

the email address ••[email protected] •• was created.

11. Based on the investigation to date, including my review of records provided by

Microsoft, on or about July 14, 2023, an individual purporting to be "Kurt Naussany," Chief

Lending Officer for Naussany Investments & Private Lending LLC ("Naussany Investments" or

"NlPL"), sent an email to D.R.K.'s attorneys using this newly created Outlook email address. The

individual falsely claimed that L.M.P. had taken a collateral loan with Naussany Investments and

defaulted on her debts before her death. The individual threatened to foreclose on the property

that had been used as collateral if D.R.K. did not respond within 10 days. D.R.K. 's attorneys asked

for more information about the loan.

12. Based on my review of documents obtained during the investigation, as well as

records from the United States Postal Service ("USPS"), on or about July 28, 2023, a package

containing a "creditor's claim" and supporting documentation was mailed from a U.S. Post Office

in Kimberling City, Missouri to L.M.P.'s business manager in Woodland Hills, California. The

purported creditor's claim was captioned for filing in the California Superior Court in connection

with the administration ofL.M.P.'s estate. The creditor's claim listed "NIPL LLC/[Bank #1]" as

the claimant.

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 13. In the portion of the purported creditor's claim that required the purported claimant

to list the "Facts Supporting the Claim," the purported claimant stated:

a. L.M.P. had borrowed $3.8 million dollars from Naussany Investments in

2018;

b. L.M.P. pledged Graceland as collateral for the loan;

c. L.M.P. defaulted on the loan; and

d. Naussany Investments mailed letters notifying L.M.P. of the default and the

letters were "refused and returned" by L.M.P. or her representatives.

14. The purported creditor's claim was purportedly signed by "Gregory Naussany" and

listed his title as "Lender," and "declare[ d] under the penalty of perjury under the laws of the State

of California that the foregoing [creditor's claim] [was] true and correct."

15. Numerous documents were submitted as supporting documentation for the

purported creditor's claim, including among other documents:

a. A "Standard Promissory Note," which purported to memorialize L.M.P.'s

2018 agreement to borrow $3.8 million from Naussany Investments (the

"Promissory Note"). The Promissory Note was purportedly signed by

L.M.P. in person in Florida before K.P., a Notary Public for the State of

Florida, who purportedly notarized the document.

b. A "Deed of Trust," which purported to memorialize L.M.P.'s pledge of

Graceland as collateral for $3.8 million loan from Naussany Investments

(the "Deed of Trust"). The Deed of Trust was purportedly signed by L.M.P.

in person in Florida before K.P. and notarized by K.P.

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 c. Bank records from Bank # 1, which purported to document Naussany

Investments' disbursement of funds to L.M.P. in the amount of$3.8 million

in 2018 (the "Bank #1 Records").

d. Three mailing labels, which purported to document Naussany Investments'

repeated attempts to provide notice to L.M.P. of impending legal action for

her default on the $3.8 million loan (the "Mailing Labels").

16. The purported creditor's claim included a proposed a settlement: "Lender will

agree to a settlement arrangement to not proceed with legal action if the Trustee agrees to pay 75%

of the amount that was borrowed from namely L.M.P. and that settlement amount being

$2,850,000.00."

17. Based on the investigation to date, I respectfully submit that there is probable cause

to believe that Naussany Investments' purported creditor's claim is fraudulent and was part of a

scheme to defraud the Presley family, among others, and fraudulently obtain millions of dollars

and the Presley family's ownership interest in Graceland. Among other things:

a. There is probable cause that L.M.P.'s signature on the purported loan

documents and deed of trust is a forgery. L.M.P.'s representatives

confirmed that L. M.P. did not sign the papers or travel to Florida in 2018,

and the notary who purportedly acknowledged L.M.P.'s signature (namely,

K.P.) stated under oath that she neither notarized the papers nor ever met

L.M.P.

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 b. There is probable cause that the Bank #1 Records attached to the creditor's

claim as proof of the $3.8 million loan to L.M.P. were fake. Specifically,

information obtained from Bank #1 indicates that the purported cashier's

check and correspondence from Bank # 1 were not, in fact, issued or created

by Bank #1.

c. Based on my review of records from the Florida Department of State,

Naussany Investments was not registered as a corporate entity in Florida

until May 21, 2024, which was the day before Naussany Investments was

required to respond to an action brought by D.R.K. in Shelby County

Chancery Court to block the sale of Grace land (which is described in greater

detail below).

d. Based on information obtained from the USPS, the purported Mailing

Labels used to mail the fraudulent documents addressed to L.M.P.'s

attention to an address in Woodland Hills, CA were also fraudulent.

18. Based on the investigation date, including my review of records from USPS,

TextNow, T-Mobile, Google and Bank #2, there is probable cause to believe that FINDLEY

created or caused to be created the false creditor's claims. There is also probable cause to believe

that FINDLEY sent and filed or caused to be sent and filed the false creditor's claims. The July

28, 2023 creditor's claim used as Naussany Investments' business address the U.S. Post Office

located near FINDLEY's home and at which FINDLEY had rented a PO Box, namely PO Box

1015 in Hollister, Missouri ("PO Box #1 "). The rental application was submitted in the name of

FINDLEY's alias, "Lisa Holden," and lists a telephone number ending 7570 as her telephone

number. The July 28, 2023 creditor's claim was mailed from FINDLEY's Post Office in and

9
around Kimberling City, Missouri, to D.R.K. The July 28, 2023 creditor's claim used as Naussany

Investments' business contact a telephone number linked to FINDLEY (a telephone number

ending 7074). During the relevant time, that telephone number was assigned by TextNow (a VoiP

service provider) to a user with the [email protected]. That email is a combination of

one of FINDLEY's aliases ("Lisa J. Howell") and her birth year (1971). Google records show that

[email protected] is linked via Google Pay to bank accounts in FINDLEY's name and uses

FINDLEY's personal mobile (ending 7570) as the recovery phone number for the account. T-

Mobile records confirm that "Lisa J Holden," which is one of FINDLEY's known aliases, is listed

as the subscriber and pays for a telephone number ending 7570 and a telephone number ending

9453. Records obtained from the California Department of Motor Vehicles confirm that

FINDLEY, previously known as "Holden," continued to use that name.

19. The September 18,2023 and January 31, 2024 creditor's claims listed as Naussany

Investments' business address two PO Boxes in U.S. Post Offices located near FINDLEY's home

that FINDLEY rented and used: PO Box #1 (described above) and PO Box #514 in Kimberling

City, Missouri ("PO Box #2").

20. The rental application for PO Box #2 lists "Lisa Findley" as the "CEO" of "NIPL

LLC," and lists "Kurt Naussany" and "Carolyn Williams" as individuals authorized to receive mail

at that address. In addition, the rental application for PO Box #2 and the January 31, 2024

creditor's claim listed as Naussany Investments' contact information a telephone number linked

to FINDLEY (a telephone number ending 3857). During the relevant time, that telephone number

was assigned by TextNow to a user with the email [email protected].

Google records show that [email protected] uses FINDLEY's personal mobile

(ending 7570) as the recovery phone number for the account. Records from Bank #2 also show

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 that FINDLEY used her personal checking account (ending in 8118), in the name of her alias "Lisa

Holden," to pay fees to the California Superior Court in Los Angeles County around the same time

the January 31, 2024 creditor's claim was filed with that same court. Bank #2 records list a

telephone number ending 7570 as FINDLEY's contact telephone number.

September 2023: FINDLEY Filed False Creditor's Claim with the California Superior Court

21. Based on my review of records obtained from the California Superior Court, on or

about September 18,2023, the fraudulent creditor's claim together with the fraudulent supporting

documentation was filed with the California Superior Court. The filed version of the fraudulent

creditor's claim was signed by an individual purporting to be "Carolyn Williams Sr Collections

Officer." At the end of the false and fraudulent creditor's claim, it contained another proposal to

settle its claim for $2,850,000.00.

22. Based on my review of records provided by Microsoft, on or about September 19,

2023, one day after the alias "Carolyn Williams" was used to file the false and fraudulent creditor's

claim in California Superior Court, the email address [email protected] was

created.

November-December 2023: FINDLEY Sent Fraudulent Documents to the Shelby County

Register's Office

23. Based on my review of records provided by USPS, on or about November 30,2023,

FINDLEY applied for Post Office Box service at a United States Post Office in Kimberling City,

Missouri. In the application, FrNDLEY represented that the service was for business use by "NIPL

LLC." FINDLEY identified "Lisa Findley" as NIPL LLC's "CEO" and listed

[email protected] as NIPL LLC's email address. The Post Office assigned

PO Box #2 to NIPL LLC.

1I
 24. Based on my revIew of records provided by USPS and the Shelby County

Register's Office, later that day, FINDLEY placed in a United States Post Office in Kimberling

City, Missouri, a package that was sent and delivered by the United States Postal Service via

Certified Mail to an address in Memphis, Tennessee (the "November 30, 2023 Package"). The

mailing label, addressed to "Shelby County Register," stated that the sender was ''NIPL LLC."

FINDLEY used as NIPL LLC's business address the PO Box FINDLEY had rented earlier that

day: PO Box #2. The package contained a document titled "Authorization Agreement for Direct

Payments (ACH Debits) FY24," which authorized the Shelby County Register to debit NIPL

LLC's account for the payment of any fees incurred by NIPL LLC. The agreement was signed

using the alias "Carolyn Williams."

25. Based on my review of records provided by Microsoft, the Shelby County

Register's Office, T-Mobile, and TextNow, and witness interviews, in and around December 2023,

an individual purporting to be "Carolyn Williams" telephoned the Shelby County Register's office

with questions about setting up an e-file account and e-filing the fake Deed of Trust.

26. Based on my review of records provided by Microsoft and the Shelby County

Register's Office, and witness interviews, also, in and around December 2023, an individual sent

numerous emails about the fake Promissory Note and Deed of Trust using the alias "Carolyn

Williams" at [email protected] to the Shelby County Register's office. For

example, on or about December 19, 2023, an email was sent from "Carolyn Williams" attaching a

copy of the fraudulent Promissory Note and Deed of Trust. The fraudulent Deed of Trust was

modified to include a handwritten note listing as NIPL LLC's address "[PO Box #2], Kimberling

City, MO."

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 27. Based on my review of records provided by Microsoft and the Shelby County

Register's Office, and witness interviews, an individual using the alias "Carolyn Williams"

executed two false affidavits that accompanied the false Promissory Note and Deed of Trust that

was emailed to the Shelby County Register's office, each of which falsely and fraudulently

represented: "I, Carolyn Williams, do hereby make oath that I am a licensed attorney and/or the

custodian of the original version of the electronic document tendered for registration herewith and

that this electronic document is a true and exact copy of the original document executed and

authenticated according to law on December 15, 2023." In truth and in fact, these affidavits were

false. As explained above, there is probable cause to believe the Promissory Note and Deed of

Trust were fake.

28. Based on the investigation date, including my review of records from Shelby

County Register'S Office, TextNow, T-Mobile, and Bank #2, there is probable cause to believe

that FINDLEY created or caused to be created the fraudulent documents e-filed and emailed to the

Shelby County Register'S Office, as well as the November 30, 2023 Package mailed from

Kimberling City, Missouri to the Shelby County Register's Office in Memphis, Tennessee. There

is also probable cause to believe that FINDLEY e-filed, emailed.andmailedviaU.S.mail the

fraudulent documents submitted and sent to the Shelby County Register's Office. First, the

"authorization agreement" for payment of the fees Naussany Investments owed for filing the deed

of trust was signed by "Carolyn Williams" on behalf of NIPL LLC. The bank account number

listed on the authorization agreement (ending in 2921) was a personal checking account at Bank

#2 in the name of FINDLEY's alias, "Lisa Holden." The authorization agreement listed as

Naussany Investments' contact a telephone number that was linked to FINDLEY (ending 3857)

for the reasons described above. Second, toll records from TextNow and T-Mobile show that

13
FINDLEY used telephone numbers belonging to her to repeatedly call the Shelby County

Register's Office. These telephone numbers include a number ending 3857 (discussed

immediately above), a telephone number ending 7570 and a telephone number ending 9453. Third,

the address used by the sender of the November 30, 2023 package was PO Box #2, Kimberling

City, Missouri, which was the PO Box rented by FINDLEY using her own name and using an

application that listed "Carolyn Williams" as a person who was to receive mail using that same

PO Box.

January-May 2024: FINDLEY Threatened to Foreclose on Grace/and

29. Based on my review of records provided by Microsoft and others, on or about

January 16, 2024, an email was sent from an individual purporting to be "Kurt Naussany" at

[email protected] to D.R.K. 's attorneys threatening to foreclose on

Graceland: "[A]s of [the] date the Loan has not been taken care of which has left us no choice but

to Advertise the Notice of Foreclosure Sale, February 20, 2024, in the Tennessee Tribune. The

Loan is seriously in default and creditors claim has been filed with also being ignored. Copies of

the loan documents have been mailed out certified mail to [D.R.K.] again with no response."

30. Based on my review of records provided by the California Superior Court, on or

about January 31, 2024, a second false and fraudulent creditor's claim was filed in California

Superior Court that repeated the false and fraudulent representations made in the false and

fraudulent creditor's claim previously filed on or about September 18,2023 in California Superior

Court. It listed PO Box #2, Kimberling City, Missouri as Naussany Investments' address.

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 31. Based on my review of records provided by Microsoft, on or about April 18, 2024,

an individual purporting to be "Kurt Naussany" sent an email from

[email protected] to O.R.K. 's attorneys repeating the threat to take Graceland

from Mr. Presley's family and sell it to the highest bidder:

Please be advised that we have made numerous attempts to settle the Creditors
Claim with your Client [O.R.K.], Trustee .... We are now prepared to Foreclose
on secured property Graceland and hold Public Auction in 20 (twenty) days. We
have tried relentlessly reaching out and no cooperation.

Regards
K. Naussany
Naussany Investments LLC

Disclaimer: With a nonjudicial foreclosure, court action isn't required. Instead,

the bank will follow the out-of-court process outlined in state law. After
completing the required state procedures, the bank will sell the property at a
foreclosure sale.

In Tennessee, most banks use the nonjudicial process because it's faster and
cheaper than litigating a lawsuit.

Nonjudicial process: The lender gives the homeowner notice of their intent to
foreclose, and the process proceeds without further input from the court.

32. Based on my review of records provided by Microsoft and Gannett GP Media, Inc.,

on or about May 2, 2024, an individual purporting to be J.O. placed an order to publish a false and

fraudulent ''Notice of Foreclosure Sale" in The Commercial Appeal on May 5, 2024, May 12,

2024, and May 19, 2024, respectively. The false and fraudulent "Notice of Foreclosure Sale"

falsely and fraudulently represented to the public that L.M.P. had borrowed $3.8 million from

Naussany Investments in 2018, pledged Graceland as collateral for the loan, and defaulted on the

loan. The false and fraudulent "Notice of Foreclosure Sale" also announced to the public that

Graceland would be sold to the highest bidder in an auction to be held on May 23, 2024.

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 33. Based on my review of records provided by Microsoft, later that day, on May 2,

2024, an individual purporting to be "Carolyn Williams" sent an email from

carolyn. [email protected] to D.R.K. 's attorneys attaching a copy of the false and

fraudulent "Notice of Foreclosure Sale," the receipt reflecting the order to publish it in The

Commercial Appeal, and the publication schedule.

34. Based on my review of records provided by Microsoft, on or about May 13, 2024,

an individual purporting to be "Carolyn Williams" sent an email from

[email protected] to D.R.K.'s attorneys stating that Naussany Investments

had already published two of the three foreclosure notices and was on the verge of publishing the

third and final notice and holding the auction:

Please take notice that the Foreclosure Notice has run 2 weeks now and the 3rd and
final is May 19. The Trustee [D.R.K.] has been sent multiple certified letters return
receipt with no response from her. As you are aware the loan given to L.M.P. is
and has been defaulted. Bidding takes place May 23, 2024 from lOam to 12 pm to
highest bidder.

35. Based on the investigation to date, including my review of records from Gannett

and T-Mobile, there is probable cause to believe that FINDLEY submitted or caused to be

submitted the fraudulent "Notice of Foreclosure Sale." The Gannett receipt documenting the

advertisement submission to publish the fraudulent "Notice of Foreclosure Sale" shows that

[email protected] was the email used in connection with the transaction. Google records

establish that the recovery phone number for [email protected] is a telephone number ending

9453. As described above, T-Mobile records show that the telephone number ending 9453 belongs

to "Lisa Holden."

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May 2024: FINDLEY Filed Fraudulent Court Filings and Issued False Statements to Media

36. Based on my review of records obtained from the Shelby County Chancery Court,

on or about May 15, 2024, D.R.K. filed a lawsuit in the Shelby County Chancery Court in

Memphis, Tennessee, alleging that Naussany Investments was a fraudulent entity created for the

purpose of defrauding Mr. Presley's family and any potential purchaser of Graceland in the

non-judicial foreclosure sale then-scheduled for May 23, 2024. D.R.K. sought to enjoin the

auction. D.R.K. attached an affidavit from K.P. stating that K.P. had not met L.M.P., had not

notarized any documents signed by L.M.P., and had not notarized the Promissory Note.

37. On or about May 15, 2024, Chancellor JoeDae L. Jenkins issued an order

temporarily enjoining "Kurt Naussany" and Naussany Investments from conducting a non-judicial

foreclosure sale of Graceland pending an in-person hearing that the Chancellor scheduled for May

22,2024.

38. Based on my review of records provided by Microsoft, on or about May 20, 2024,

in response to an inquiry from a CBS News producer seeking comment on D.R.K.'s lawsuit, an

individual purporting to be "Carolyn Williams" and "Kurt Naussany" repeated the false and

fraudulent representation that "Carolyn Williams" and "Kurt Naussany" were involved in making

loans on behalf of Nauss any Investments to L.M.P.:

a. An individual purporting to be "Carolyn Williams" sent a response from

[email protected] stating that while she had "no knowledge of

any filing in Chauncery [sic] Court in Shelby County," she believed "[t]he daughter

is just trying to get out of paying her mothers [sic] bills it seems[.)" She added that

"Mr. Naussany has known L.M.P. since martiage [sic] to Michael Jackson .... We

17
 do have documentation and witnesses that can verify L.M.P. in our Florida office

in 2018 ..... [L.M.P.] has taken out several loans with Naussany Investments."

b. An individual purporting to be "Kurt Naussany" sent a separate response from

[email protected] asking when CBS News planned to air the

story so that Naussany Investments could notify Bank #3 and Bank #1, "since they

back [Naussany Investments'] loans."

39. Later that day, in response to a communication from the CBS News producer

informing "Carolyn Williams" and "Kurt Naussany" that a story would air on television and asking

whether they had any response to K.P. 's sworn affidavit stating that K.P. had not met L.M.P., had

not notarized any documents signed by L.M.P., and had not notarized the Promissory Note, an

individual purporting to be "Carolyn Williams" and "Kurt Naussany" emailed the CBS News

producer and changed her story:

a. An individual purporting to be "Carolyn Williams" sent an email from

carolyn. [email protected] denying any involvement in the loan to

L.M.P. and blaming "Gregory Naussany": "I myself did not do the loan, although

I have known L.M.P. for many years. I believe Greg Naussany did the loan process.

Greg and I are no longer partnered together. I have ventured out, [s]o whoever is

filing paperwork may need to look at documents again. Greg Naussany works out

of Jacksonville Florida office with another partner. So, they obviously have wrong

information and wrong Naussany Investments."

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 b. An individual purporting to be "Kurt Naussany" sent an email from

[email protected] similarly denying any involvement in the

loan to L.M.P. and blaming "Gregory Naussany": "I'm only going to state this,

[D.R.K.] will need to contact Gregory Naussany in Jacksonville Florida. My name

should not appear on anything with NAUSSANY INVESTMENTS AND

PRIVATE LENDING LLC! That is not my investment company and has not been

since 2015! My investment company is located on the West Coast. I did not sign

any paperwork with L.M.P. So please get the story straight before defamation

charges come about."

40. Based on my review of records provided by Microsoft, on or about May 21, 2024,

the email address ••[email protected] ••was created.

41. Based on my review of records provided by the Florida Department of State, on or

about May 21,2024, papers were electronically filed with the Florida Department of State creating

a limited liability company named "Naussany Investments & Private Lending, LLC."

42. Based on my review of records provided by Microsoft, later that day, an individual

purporting to be "Kurt Naussany" began responding to media inquiries sent to

[email protected] by directing them to "Gregory E. Naussany" In

Jacksonville, Florida at [email protected]. An individual purporting to

be "Gregory Naussany," then sent emails from [email protected] stating

that "Carolyn Williams" and "Kurt Naussany" had not been involved with Naussany Investments

since 2015 and accepting personal responsibility for the loans made to L.M.P.

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 43. Based on my review of records provided by Microsoft, later that day, an individual

purporting to be "Gregory Naussany" sent an email from

[email protected] to D.R.K.' s attorneys falsely and fraudulently

representing that "Gregory Naussany" had approved the $3.8 million loan to L.M.P. and that

neither "Kurt Naussany" nor "Carolyn Williams" have been with Naussany Investments since

2015. The individual purporting to be "Gregory Naussany" then repeated the false and fraudulent

representation that L.M.P., or "LMP" as she called her, had a history of borrowing money from

Naussany Investments and had defaulted on the most recent loan:

Please be advised that this is not the first loan or money borrowed by LMP. I will
be calling for all files from micro film [sic] in morning on LMP, for each loan she
has taken out with my company. LMP borrowing habits became more frequent in
2008. We had sent multiple certified mailing's [sic] out to LMP, each mailing was
either returned [sic] refused, not excepted [sic], there were emails sent to LMP and
again with no response. I will also be contacting my banks that back my loans to
pull all cashier's checks made out to LMP.

The individual proposed to settle with D.R.K. for $2,850,000, writing: "I have given the option

for the trust to pay 75% of the loan in the creditors claim filed."

44. Based on my review of records provided by the Shelby County Chancery Court,

later that day, an individual purporting to be "Gregory Naussany" filed in the Shelby County

Chancery Court a one-page response denying D.R.K.'s allegations that Naussany Investments'

claims were fraudulent. The filing was signed using the alias "Gregory Naussany" and listed as

his email [email protected].

45. On or about May 22, 2024, Chancellor Jenkins held a hearing on D.R.K.'s motion

In Shelby County Chancery Court. No one appeared on behalf of "Gregory Naussany" or

Naussany Investments. Chancellor Jenkins subsequently granted D.R.K.'s motion and issued an

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order enJommg Naussany Investments from conducting a non-judicial foreclosure sale of

Graceland.

46. Based on my review of records provided by Microsoft, later that day, an individual

purporting to be "Gregory Naussany" sent an email from

[email protected] to D.R.K. 's attorneys stating that Naussany

Investments was dismissing its creditor's claim.

47. Based on my review of records provided by Microsoft, Documo, and

publicly-available media sources, beginning on May 24, 2024, and continuing through at least May

29, 2024, the individual who had previously claimed to be "Gregory Naussany" made false and

fraudulent representations to D.R.K.'s attorneys, the Shelby County Chancery Court, and the press

creating the false and fraudulent impression that the person responsible for the scheme was a

Nigerian identity thief located in Nigeria.

48. Specifically, the individual who previously claimed to be "Gregory Naussany" sent

messages, written in different foreign languages, in which the individual purported to be the

Nigeria-based identity thief. These messages were sent via fax and from

[email protected].

49. Based on the above information, there is probable cause to believe that, on or about

November 30,2023, FINDLEY, and others known and unknown to your affiant, aided and abetted

by each other, in the Western District of Tennessee, and elsewhere, for the purpose of executing

the aforesaid scheme and artifice to defraud, and attempting to do so, did knowingly place and

cause to be placed in a United States Post Office or authorized depository for mail a thing to be

sent and delivered by the United States Postal Service or any private or commercial interstate

carrier, to wit a document titled "Authorization Agreement for Direct Payments (ACH Debits)

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FY24" sent and delivered by the United States Postal Service via Certified Mail from NIPL LLC,

PO Box #2, Kimberling City, Missouri to the Shelby County Register at an address in Memphis,

Tennessee.

50. Based on the above information, there is probable cause to believe that from at least

in and around July 2023 and continuing through at least in and around August 2024, in the Western

District of Tennessee, and elsewhere, FINDLEY, and others known and unknown to your affiant,

aided and abetted by each other, knowingly transferred, possessed, and used, and knowingly

caused to be transferred, possessed, and used, without lawful authority, a means of identification

that defendant FINDLEY knew belonged to another person, namely, the name of L.M.P., during

and in relation to mail fraud, a felony violation of Title 18, United States Code, Section 1341, as

set forth in this affidavit.

51. For all the reasons set forth above, there is probable cause to believe that FINDLEY

violated 18 U.S.c. §§ 1341 (Mail Fraud) and 1028A (Aggravated Identity Theft).

AUTHORIZATION REQUEST

52. Based on the foregoing, I request that the Court issue the proposed arrest warrant

pursuant to Federal Rule of Criminal Procedure 4 and authorize at least the Federal Bureau of

Investigation and the United States Postal Inspection Service to execute such warrant.

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 53. I further request that the Court order that all papers in support of this application,

including the affidavit and arrest warrant, be sealed until the defendant has been placed under

arrest. These documents discuss details about an ongoing criminal investigation that are not known

to the public nor known to all the targets of the investigation. Accordingly, there is good cause to

seal these documents until the defendant has been placed under arrest because their premature

disclosure may seriously jeopardize that investigation.

Christopher Townsend
Special Agent
Federal Bureau of Investigation
Affiant

Pursuant to Federal Rule of Criminal Procedure 4.1, the undersigned judicial officer has on this
date considered information communicated by [ ] telephone or [ ] other reliable electronic means
or [ ] both, in reviewing and deciding whether to issue an arrest warrant. In doing so, this judicial
officer has placed the affiant under oath and has confirmed by speaking personally with the affiant
on the telephone [ ] that the signatures on the arrest warrant application and affidavit are those of
the affiant or [ ] that the affiant has authorized the placement of the affiant's signatures on the
application and affidavit, the documents received by the judicial officer are a correct and complete
copy of the documents submitted by the affiant, and the information contained in the arrest warrant
appl ication and affidavit are true and correct to the best of the affiant's knowledge.

Subscribed and sworn to before me on August 15, 2024.

HONORABLE TU M. PHAM
CHIEF UNITED STATES MAGISTRATE JUDGE
WESTERN DISTRICT OF TENNESSEE

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