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Trial Access: Caroline Ellison's List of 'Things That Scare Sam

By Jerry McNeill
Aug 17, 2023
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Prosecutors are planning to utilize the personal notes and diaries of former Alameda Research CEO, Caroline Ellison, as evidence in the criminal trial of Sam Bankman-Fried, the co-founder of FTX.

According to an August 14 filing, the prosecution intends to present a compilation of Ellison's personal notes and to-do lists as part of their evidence. This includes a note titled "Things That Drive Sam Crazy," which summarizes a conversation between Bankman-Fri ed and Ellison about business concerns, fundraising, Alameda's hedging, and negative reports regarding the relationship between the hedge fund and FTX.

The collection of evidence also encompasses an audio recording of Ellison's all-hands meeting on November 9, 2022, just two days prior to FTX and Alameda filing for bankruptcy. During the meeting, an Alameda employee asked Ellison who else was aware of the shortage of funds for FTX users. Ellison's response reportedly included Bankman-Fried, as well as other individuals directly involved in the company.

Prosecutors emphasized that this body of evidence, including diaries and notes, is not hearsay as Ellison took these notes to remember information and fulfill her role in the alleged conspiracy. They argued that evidence about Bankman-Fried's alleged activities, such as making false statements to A bank, bribing Chinese officials over frozen Alameda accounts, manipulating FTX's native token, and prioritizing creditor payments, should also be admitted.

Bankman-Fried's legal team responded with their own filing on August 14, requesting that evidence obtained after July 1 be excluded from the trial. They contended that the prosecution's delays in providing specific information, including the contents of Gary Wang's laptop and Elli son's encrypted Telegram chats , hindered their ability to adequately prepare for the trial. Bankman-Fried is currently awaiting trial in October at the Metropolitan Detention Center in Brooklyn after his bail was revoked due to allegations that he leaked parts of Ellison's diary to The New York Times.

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