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CEASE AND DESIST LETTER

SENT VIA CERTIFIED MAIL


RETURN SIGNATURE REQUIRED

June 1, 2020

Mr. Christopher Wray


Director, Federal Bureau of Investigation
FBI Headquarters
935 Pennsylvania Avenue, NW
Washington, D.C. 20535-0001
(202) 324-3000

Dear Mr. Wray:

THE FEDERAL BUREAU OF INVESTIGATION IS HEREBY DEMANDED TO


CEASE AND STOP ITS HARASSMENT AND RACIAL DISCRIMINATORY CONDUCT
TOWARD AN AFRICAN-AMERICAN OWNED, OHIO COMPANY VIA ITS FALSE
AND BASELESS CLAIM REGARDING THE ORIGINATION OF A $4 MILLION DEBT.

Mr. Wray, CBST Acquisition LLC (“CBST”) is entitled to the same equal and fair
treatment that you and the Federal Bureau of Investigation (“FBI”) provide to
white-owned companies. In fact, based on the new evidence detailed herein below
which confirms the FBI’s disingenuous and reckless conduct , CBST is entitled to the
same immediate correcting and rightful action you are currently undertaking regarding a
former high-profile individual within the Trump Administration.

Without adequate notice, reasoned explanation, or a meaningful opportunity to


be heard, FBI Agents in Cincinnati, Ohio, namely Kevin Gormley (“Gormley”) and Janel
McBain (“McBain”), randomly claim that they have obtained​ “certified and
authenticated” ​National City Bank kna PNC Bank (“PNC”)​ records (“records”)​ which
shows the authentic origination of a $4 million debt allegedly originated between CBST,
a subsidiary of the Dynus Corporation, and PNC. These named agents, along with
Assistant U.S. Attorneys’ Richard Chema and Jennifer Barry, continue to falsely and
randomly claim the records were provided by a PNC Record Custodian under
CBST CERTIFIED CEASE AND
DESIST LETTER TO FBI
June 1, 2020

penalty of perjury to be true and correct, and that the records were kept in the ordinary
course of the bank’s activity.

Continuing to act with pretext and deception, your agents allege they obtained
said records during their Butler County, Ohio federal investigation which led to the
indictment and conviction of a Butler County, Ohio Republican politician and CBST’s
founder. As the new evidence below demonstrates, the FBI continues to act contrary
and inconsistent with its core values of fairness, integrity and rigorous obedience to the
Constitution of the United States.

It appears your agents' rogue investigation was intentionally driven by a wrongful,


hidden and failed political agenda to bring down former House Speaker John Boehner
and to injure others within the Butler County, Ohio Republican Party. Current and former
members within the Party have now informed me that the FBI along with a federal
prosecutor, who pursued and lost a congressional seat as a Democrat, sought
incriminating information on the former Speaker of the House for vengeful and
recognition purposes.

As the African-American founder of CBST with two (2) engineering degrees in


electrical and computer engineering and an MBA from Duke University, I have
consistently informed Gormely, McBain and others that no such debt ever existed.
Presumably driven by racial animus toward the African-American community, Agent
Gormely stated during the investigation that I “had to have done something wrong in
order to have accomplished all that he [I] had.”

Despite numerous efforts to obtain said records including the filing of a Freedom
of Information Act (“FOIA”) Request, the FBI fails to respond and continues to evade the
truth. As shown in FOIA Request Number 1368304-000, the FOIA request has been
outstanding for over 3 years now.

Now in light of the public announcement and confirmation by the U.S.


Department of Justice (“DOJ”) that the former high-profile individual within the Trump
Administration was a victim of FBI wrongdoing, and your recent directive for an internal
review of the FBI’s deceptive conduct regarding the same, CBST is now informing you
that the FBI has fabricated a $4 million debt against it for wrongful political and
prosecution purposes.

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CBST CERTIFIED CEASE AND
DESIST LETTER TO FBI
June 1, 2020

NEW, CREDITABLE AND SUBSTANTIATED EVIDENCE REBUTS THE FBI

A recent federal banking investigation, dating back to 2003, by and between the
U.S. Treasury Department, Office of the Comptroller of the Currency (“OCC”), PNC and
CBST confirmed ​“the only debt on file” ​originated to be the ​$250,000​ Note in
December 2003. ​(See Attached Finding by OCC, Case No. 03093509. A complete
detail of the OCC’s federal banking investigation has been provided by the OCC
pursuant to the Freedom of Information Act (“FOIA”))

Further, PNC’s Record Custodian has now provided the ​certified and
authenticated ​PNC records including an Obligation Summary for CBST showing ​only
the $250,000 Note dating back to December 2003. Said records were provided under
penalty of perjury, deemed to be true and correct, and kept in the ordinary course of the
bank’s business activity. ​(For transparency purposes, the certified and authenticated
PNC Records for CBST will be provided during a public meeting with the FBI, which
CBST seeks regarding this matter. At the time of this letter, the FBI refuses to meet.)

Moreover, a PNC Bank Officer and a PNC attorney now confirm the purported $4
million debt with CBST “does not exist” nor ever existed. A forensics examination also
supports this confirmation.

CBST has no knowledge of a Corporate Resolution provided by CBST


authorizing a $4 million debt with PNC, pursuant to Ohio Law, Ohio Revised Code 1705.
Further, as of May 30, 2020, CBST’s Independent Financial Auditor Clark Shaefer
Hackett and Company (“CSHCO”) in Cincinnati, Ohio confirmed it has no knowledge of
or said records to support the origination of a $4 million debt related to PNC.

Factually, neither the OCC, PNC, CBST, CSHCO nor forensics supports the
FBI’s claim. Further, as shown below, neither does the U.S. Attorney’s Office.

IMMEDIATE RESOLUTION SOUGHT:

Mr. Wray, CBST wishes to resolve this matter quickly. Accordingly, in light of the
new credible and substantiated evidence as detailed herein, CBST respectfully
demands that you either:

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CBST CERTIFIED CEASE AND
DESIST LETTER TO FBI
June 1, 2020

A) Provide, ​within 10 days ​of the date of this letter, the ​certified and
authenticated​ PNC records showing the origination of a $4 Million debt including a
CBST Account Number, Date of Origination, and a CBST Corporate Resolution which
authorized the purported debt pursuant to Ohio Law. Said records should be provided
by a PNC Record Custodian under penalty of perjury to be true and correct, and kept in
the ordinary course of the bank’s business activities.

Or

B) Immediately cease and desist with the FBI’s false accusation against CBST by
notifying CBST in writing at:

CBST Acquisition LLC


43 S. Franklin St
Delaware, Ohio 43015

If you are not able to authenticate the origination of a $4 million debt between
CBST and PNC as requested in Item A above, CBST formally requests that you publicly
investigate, determine and make known:

1) Who fabricated the purported $4 million debt which the federal court
relied upon and wrongfully sent a former Republican Butler County,
Ohio politician and CBST’s founder to federal prison?

2) Who, within the FBI and U.S. Attorney’s Office in Cincinnati, Ohio,
decided to present false information regarding a $4 million debt
allegedly owed by CBST to a grand jury? Was perjury committed
related to the same for wrongful indictment purposes?

and

3) Per the Court’s Order, what was the FBI’s motive for filing deceptive
and misleading FBI 302 Statements under seal of PNC executives
and others which purport the alleged authentic origination of the
$4 million debt by CBST? ​(See U.S. District Court S.D. Ohio, United
States v. Carter, Case No. 1:08-Cr-051, Docket Number 166)

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CBST CERTIFIED CEASE AND
DESIST LETTER TO FBI
June 1, 2020

U.S. Department of Justice Notification:

The FBI and the U.S. Department of Justice (DOJ) in Cincinnati, Ohio have been
made aware of the new, credible and substantiated evidence. Yet, the FBI and DOJ in
Cincinnati refuse to acknowledge the same.

Stunningly and contrary to the FBI’s claim, the U.S. Attorney’s Office in
Cincinnati, Ohio now claims it ​destroyed​ the ​certified and authenticated​ bank records
used to prosecute CBST’s founder and a Butler County, Ohio Republican politician. This
claim was made during an October 2018 meeting involving the former U.S. Attorney,
Ben Glassman and others.

As shown above, it has now been determined that no such debt ever existed.
Consequently, the U.S. Attorney’s Office is not being honest with the public by claiming
it destroyed evidence purporting the $4 million debt.

Moreover, a newly discovered internal PNC email in the FBI’s possession now
confirms that PNC executives “restructured transactions to elude improprieties,” making
it deceptively appear that CBST had a debt. ​(See email included) ​This email showing
wrongdoing by PNC was intentionally concealed from the public by your agents and
others.

DISCRIMINATORY CONDUCT BY FBI AGENTS VIOLATES FEDERAL LAW

As a going concern, CBST has never been accused by the FBI or any law
enforcement agency of any wrongdoing. Moreover, PNC nor the government has taken
any legal action against CBST related to an alleged $4 million debt. Accordingly, CBST
serves notice on the FBI that it preserves all rights in this matter.

Concerningly, the FBI did not and is not currently making the same baseless,
false and fabricated $4 million allegation against a white-owned company and its
founder. Different from a white-owned company, and in violation of basic civil rights, the
FBI acted and is acting, knowingly and intentionally, with willful malice, with reckless
disregard for the truth, and with racial animus and discriminatory conduct toward an
African-American owned company.

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CBST CERTIFIED CEASE AND
DESIST LETTER TO FBI
June 1, 2020

As an African-American owned company, CBST is a member of a


protected-class pursuant to civil rights laws. As such, the FBI’s on-going disparate
treatment toward CBST violates Title 42 of the United States Code, causing immediate
injury to CBST and its members.

Conclusion:

CBST is formally requesting that you respond to this urgent matter. Your failure
to respond will confirm your​ tacit acquiescence ​that your agents fabricated evidence in
their failed pursuit of the former House Speaker John Boehner for political reasons
which led to wrongful convictions and irreparable injury to an African-Amercian owned
business.
Should you have any questions, please contact CBST at (513) 328-9217.

Sincerely,

________________________
Orlando Carter, Founder
CBST Acquisition LLC

Cc: The Honorable Donald J. Trump, President of the United States


The Honorable William Barr, United States Attorney General
Senator Rob Portman, United States Senate
Senator Sherrod Brown, United States Senate
Congressman Jim Jordan, United States House of Representatives
Congressman Steve Chabot, United States House of Representatives
Mr. David Devillers, U.S. Attorney, Southern District of Ohio
Mr. Dominic Mango, Attorney
Mr. Chris Hoffman, FBI ​Special Agent in Charge, Cincinnati Division
Mr. Kevin Gormely, FBI Agent
Ms. Janel McBain, FBI Agent
Mr. Todd Hall, Executive Chairman, Butler County, Ohio Republican Party
Ms. Mary C. Rogers, former Butler County, Ohio Republican Auditor

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