WYNAR

I. BACKGROUND

1 A. Factual Background 2 1. Life Savers Concepts Association, Inc. and FBI Investigation 3 This case arises from an investigation into Life Savers Concepts Association, Inc. (“Life 4 Savers”), an organization founded to assist low-income homeowners throughout Northern 5 California and to combat foreclosures during the financial crisis. ECF No. 84, at 2. Life Savers’ 6 business model was to enter into membership agreements with homeowners, whereby members 7 transferred claims related to the members’ home loans to Life Savers. 8 Beginning in 2014, the Federal Bureau of Investigation (“FBI”), the Internal Revenue 9 Service Criminal Response Division (“IRS”), and the Monterey County District Attorney’s Office 10 (“DA’s Office”) began investigating Life Savers and Larry Brown, an individual associated with 11 Life Savers, for financial fraud. ECF No. 110-2 (“Lee Decl.”), at ¶¶ 2, 8; ECF No. 110-1 (“Kay 12 Decl.”), at ¶¶ 2, 32 and Ex. 2; and ECF No. 110-9 (“Wynar Depo.”), at 190:17–20 and 291:10–17. 13 In July of 2017, the FBI obtained a search warrant from the Northern District of California 14 to search the Sunnyvale, CA office of Life Savers and a related…