Complete FBI submission

Relator summaries

RELATOR SUMMARY 1

• Subject: Bradford Charles Adams, age 69 • Addresses: o 1012 De Haro St C, San Francisco, CA 94107; o 1350 N Town Center Dr #2091, Las Vegas, NV 89144 (synthetic NV identity) • Federal Proceeding: Adv. Pro. No. 24-12007-nmc, District of Nevada (U.S. Dept. of Education as adverse party) This document presents a qui tam-style evidentiary record organized around three independently verifiable claims regarding Bradford Charles Adams— Jennifer Pan Adams's father—who is currently defrauding the U.S. Department of Education in a live, docketed federal adversary proceeding in the District of Nevada.

Claim I — Active Federal Fraud

False Claims Act; 18 U.S.C. §§ 1001, 152) Bradford Charles Adams, age 69, of San Francisco, California, filed Adv. Pro. No. 24-12007-nmc seeking to discharge $48,493 in federal student loans under a synthetic identity—Bradford Charles Adam, age 64, of Las Vegas, Nevada— and a fabricated hardship narrative claiming his wife suffers from stage-four spinal cancer rendering her unable to work. Five days after the filing, his wife published a public Instagram post describing her final consultation following four months of H. pylori treatment. The age discrepancy, the name variant (Adams vs. Adam), the fabricated Nevada domicile, and the false cancer narrative are each independently verifiable from public records. Identity convergence between the 69-year-old San Francisco man and the 64-year-old Las Vegas filer is established on 13 independently corroborating grounds, each grounded in primary source documentation.

Claim II — Synthetic Identity Construction

RICO Predicate; 18 U.S.C. § 1962 The synthetic Nevada identity Bradford used to defraud the DOE was constructed jointly with Alan H. Adams—patriarch of the historic Adams gaming family of Carson City—who sponsored Bradford as a legitimate family member to obtain Nevada gaming licensure and real property positions restricted by law to family members. That identity was then operationalized through a network of shell entities—including Doppelgangers Charitable

Corporation and AA Gaming, Inc.—as vehicles to offload debt, shift assets, and launder funds through layered real property transfers, trust instruments, and a Special Power of Attorney granting a Minden, Nevada attorney sweeping control over Bradford's entire estate and government affairs.

Claim III — Municipal Corruption Entanglement

The Adams family infrastructure underlying the scheme—through the Hop Mae Adams Foundation—was deeply entangled in development decisions and public appropriations in Carson City throughout Mayor Robert "Bob" Crowell's 12- year tenure, including a $250 million downtown redevelopment plan in which the Foundation pledged $5 million toward a public parking garage. The Foundation's trustees, the mayor, and Bradford's own attorney-in-fact are documented in the same EB-5 investment attorney directories, the same entity filings, and the same public-record instruments—placing private financial interests, public redevelopment funds, and regulatory access in the hands of a tightly connected network throughout the period of active synthetic identity usage. The $48,493 at issue in the bankruptcy is not the measure of the fraud—it is a moment Bradford Charles Adams made a federal record of the scheme under penalty of perjury.

RELATOR SUMMARY 2

• Subject: Ping Xiao Adams, age 63 • Addresses: o 1036 Carolina Street, San Francisco, CA 94107 (primary/current) o 870 Market Street, Suite 353, San Francisco, CA 94102 (commercial — Pacific Acupuncture Center) o 155 South Court Avenue, Unit 2807, Orlando, FL 32801 (joint title co-owner) • Relationship to Other Subjects: Former wife of Bradford Charles Adams (married November 19, 1993, Carson City, Nevada; divorced 2019); mother of Jennifer Pan Adams This document presents an evidentiary record establishing Ping Xiao Adams as a direct participant in multiple independently documented categories of fraud operating within the same family enterprise as Bradford Charles Adams and Jennifer Pan Adams.

Count 1 — Health Care Fraud / Wire Fraud: Real-Time Participant in

Laughter-Filled Medical Fraud Account

18 U.S.C. §§ 1347, 1343

On November 17, 2024, Jennifer Pan Adams was audio-recorded code- switching between English and Mandarin while addressing her mother, Ping Xiao Adams, as the primary audience for a laughter-filled, first-person account of a premeditated scheme to manipulate a patient into purchasing a $600 veterinary ultrasound machine by fabricating a medical premise—extracting $140 for a fraudulent consultation, then blocking the patient to "wait until he forgets." The recording is in the public court record. Ping Xiao Adams was not an inadvertent recipient of this information. She was the person to whom Jennifer Adams was speaking, in real time, while describing the commission of healthcare fraud for financial gain.

Count 2 — Workers' Compensation Insurance Fraud / Health Care Fraud

(Pacific Acupuncture Center)

18 U.S.C. §§ 1347, 1341, 1343

Ping Xiao Adams is the owner and operator of Pacific Acupuncture Center, 870 Market Street, Suite 353, San Francisco, California—the commercial address shared by Bradford Charles Adams's entity filings across both his California and Nevada record footprints. Jennifer Adams used her personal ChatGPT account to generate: (a) fraudulent workers' compensation dispute letters to carriers including Liberty Mutual, falsely asserting that the clinic had submitted required authorization forms and demanding payment for denied services; and (b) canned patient visit summaries and treatment plans for fictitious whiplash and neck pain injuries—the most commonly feigned soft-

tissue injury in insurance fraud—structured as reusable multi-patient templates, strongly indicating systemic billing fraud for nonexistent services. The clinic is Ping Xiao Adams's business. The fraudulent billing infrastructure was built at her address, for her clinic, by her daughter.

Count 3 — Fictitious Name Perjury — Third-Degree Felony (Fla. Stat. §

817.155): Co-Owner on False Sworn Filing

18 U.S.C. § 1001

On May 15, 2025, Jennifer Pan Adams filed an Application for Registration of Fictitious Name—DOLL LAB, Registration No. G25000064892—with the Florida Department of State, executing a sworn certification under penalty of perjury that the fictitious name had been advertised in a qualifying newspaper as required by Chapter 50, Florida Statutes. Ping Xiao Adams, 1036 Carolina Street, San Francisco, CA 94107, is listed as co-owner on that application. Exhaustive searches of all qualifying publishers within Orange County and the statewide archive at floridapublicnotices.com confirm that no such advertisement was ever placed. The social media accounts associated with DOLL LAB were not created until June 2025—weeks after the sworn certification. Ping Xiao Adams's name appears on a fictitious name registration executed through a false sworn statement constituting a Third-Degree Felony under Florida law, for an unregistered sex doll review platform.

Count 4 — Bank Fraud / Asset Concealment / False Hardship Narrative

(Concurrent with Federal Bankruptcy Fraud)

18 U.S.C. §§ 1344, 152

On July 24, 2024, Warranty Deed Instrument No. TN5495279, recorded in Orange County, Florida, conveyed Unit 2807, Solaire at the Plaza Condominium, 155 South Court Avenue, Orlando, Florida 32801, to Ping Adams, an unmarried person, and Jennifer Adams, an unmarried person, as Joint Tenants with full rights of survivorship, for a cash purchase price of approximately $240,000 (confirmed by document tax of $1,680.00 with zero mortgage document tax and zero intangible tax). This transaction closed while Bradford Charles Adams was simultaneously prosecuting a federal adversary proceeding in the District of Nevada—Adv. Pro. No. 24-12007-nmc—swearing under penalty of perjury that his family was in catastrophic financial distress and unable to repay $48,493 in student loan debt. Ping Xiao Adams's documented real estate holdings in San Francisco—including 1034–1036 Carolina Street (awarded to her in the 2019 divorce and currently valued at approximately $1,600,000) and 1012 De Haro Street (a four-unit investment property with total valuations between $4,000,000 and $6,190,000)—place her personal real property portfolio in excess of $7,790,000, exclusive of the Orlando condominium. The sworn indigency representation in the bankruptcy proceeding is irreconcilable with the concurrent all-cash real estate acquisition by a joint title co-owner in the same family network.

Count 5 — Perjury in Judicial Proceeding

Cal. Rules of Court, rules 3.55, 8.818 In March 2023, Ping Xiao Adams and Jennifer Pan Adams filed a joint small claims action against All Nippon Airways—Case No. 23-SCS-00196—seeking $1,299.00 arising from a discretionary international trip to Japan. Jennifer Adams executed a sworn declaration of indigency to obtain a court fee waiver. Because the action was brought jointly, the multi-million-dollar assets of Ping Xiao Adams were inherently subject to the indigency determination. The sworn assertion of financial hardship is irreconcilable with a concurrent portfolio exceeding $7,790,000 in documented San Francisco real property, active ownership and management of a commercial acupuncture clinic in the historic Flood Building, and the capacity to fund a discretionary international journey to Japan—the very trip that gave rise to the litigation.

RELATOR SUMMARY 3

• Subject: Jennifer Pan Adams, M.D. • License No.: ME175142 • Current Position: PGY-3 Diagnostic Radiology Resident, AdventHealth Orlando • Address: 155 S Court Ave, Unit 2807, Orlando, FL 32801 The main federal offenses are:

Count 1 — Health Care Fraud / Wire Fraud

18 U.S.C. §§ 1347, 1343

On November 17, 2024, Adams was audio-recorded laughing while describing a premeditated scheme to manipulate a patient into purchasing a $600 veterinary ultrasound machine by fabricating a medical premise—invoking fear of diabetes and heart disease, extracting $140 for a consultation, and then blocking the patient to “wait until he forgets.” The recording is in the public court record. It is a self-narrated, real-time confession.

Count 2 — Federal Student Aid Fraud / Wire Fraud (~$50,000)

20 U.S.C. § 1097; 18 U.S.C. § 1343

The Adams family manufactured a false Texas domicile in December 2017 by acquiring 2176 Abadeer Trail, San Antonio, TX, to qualify Adams for in-state tuition at UTRGV School of Medicine—a Title IV-funded institution. The property sold in August 2019, the same month as Adams's White Coat Ceremony. Fraudulent benefit: approximately $50,000. The scheme is corroborated by deed records, enrollment records, and the UTRGV Class of 2023 official commencement program, which lists her hometown as San Antonio, TX—a city Adams demonstrably never lived in, as confirmed by her own Stanford Daily biography, her San Francisco address record, and the fact that in her UTRGV commencement interview published the same month the property sold, she told UTRGV she was drawn to border health because she "grew up in China on the border of Tajikistan."

Counts 3–7 — Health Care Fraud, Workers' Compensation Insurance

Fraud, Institutional Forgery, Mail Fraud, Wire Fraud

18 U.S.C. §§ 1341, 1343, 1347

Adams used her personal ChatGPT account to generate: (a) fraudulent workers' compensation dispute letters for her mother's acupuncture clinic; (b) fabricated whiplash and neck-injury treatment plans for billing nonexistent patient services; (c) a forged letter on AdventHealth letterhead impersonating a Residency Program Director; and (d) a fictitious commercial shipping carrier notification. Each scheme is documented by the ChatGPT logs themselves— immutable, timestamped, and produced by Adams.

Count 9 — Bank Fraud / Aggravated Identity Theft

18 U.S.C. §§ 1344, 1028A

On November 23, 2024, Adams impersonated her 62-year-old mother on a 30- minute recorded call with a bank employee to execute a fraudulent chargeback—asserting she was a Chinese-speaking acupuncture clinic owner who did not recognize or know what the RSNA charge was. She did not alter her voice. When told she could "slip in and out of character so easily," she beamed with pride and said it was "necessary to be Machiavellian to get into schools like Stanford." Independently verifiable through carrier records. A complete RICO predicate analysis is included. The enterprise spans Adams, her father Bradford Charles Adams, and her mother Ping Xiao Adams, operating through Pacific Acupuncture Center, the manufactured Texas domicile, and the AdventHealth residency position as instrumentalities, across a documented period of at least 2014 through 2025.

Submission 1 — Bradford Charles Adams

RELATOR SUMMARY 1 – BRADFORD CHARLES ADAMS

This summary presents an evidentiary record built from primary source records spanning more than thirty years across California, Nevada, Idaho, Ohio, and Florida. The entry point is a live, docketed federal adversary proceeding in the District of Nevada (Adv. Pro. No. 24-12007-nmc), in which Bradford Charles Adams, age 69, of San Francisco, California, is seeking to discharge $48,493 in federal student loans by filing under a synthetic Nevada identity decades in the making. That fraud is visible on the face of the filing itself. The underlying bankruptcy case caption identifies the debtors: Bradford Charles Adams and Fatima Almeida Adams The adversary complaint filed in that same case—the case bearing his full legal name in the caption directly above—identifies the plaintiff: Bradford Charles Adam That single dropped letter is not a typographical error. Throughout every sworn paragraph of that complaint, Bradford Charles Adams, age 69, of San Francisco, asserts the fabricated persona of “Bradford Charles Adam,” age 64, Las Vegas resident, Uber driver, primary caregiver for a wife rendered unable to work by stage-four spinal cancer, and father of a dependent 14-year-old daughter with special needs—none of whom correspond to any verifiable public record—publicly contradicted by his wife within days of the filing and objectively contradicted by public records spanning three decades. (Exhibit A,

2024-09-20 – Bankruptcy #4 (2:24-bk-12007) – Ch. 7 ($48,493) – Bradford Charles Adam vs. US DOE – Adversary Complaint) The adversary proceeding is a federal crime—but it represents a fraction of the fraud it exposes. The synthetic identity Bradford Charles Adams deployed to defraud the U.S. Department of Education in Adv. Pro. No. 24-12007-nmc is the same identity he has operated under for thirty- three (33) years: embedded into the succession structure of the historic Adams gaming family, operationalized through gaming licensure and real property conveyances structured around fraudulent familial tax exemptions, extended through a network of shell entities used to shift assets and offload debt, and culminating in a foundation-municipal entanglement that has directed hundreds of millions in public and private redevelopment funds through a tightly connected network. The $48,493 at issue in the bankruptcy is not the measure of the fraud, but the moment Bradford Adams made a federal record of it under penalty of perjury. While the student-loan discharge alone presents clear, treble damages FCA exposure on the face of the filing, behind it lies substantial civil R.I.C.O. exposure across several documented fraudulent schemes and a network of identified participants. The broader scheme was a coordinated arrangement between Bradford Charles Adams and Alan H. Adams. The Adams family’s Carson City connections include their association with the Carson Nugget Casino, which was acquired by Howard Adams and Hop Adams in 1957 and whose 1999 succession—occurring in the same narrow window as Bradford

and Ping Xiao Adams’ San Francisco property transactions—was conducted with extraordinary privacy, no public obituary issued, and no comment from casino officials. Beginning in 1993, Alan H. Adams sponsored Bradford as a member of the historic Adams gaming family in Carson City. This sponsorship included recorded deeds that claimed first-degree consanguinity (father-to-son) tax exemptions, providing Bradford access to gaming licensure, real property positions, and influence within the Carson Nugget structure that Nevada law and Gaming Commission practice restrict to family members. The primary value was the prime downtown Carson City real estate and associated political influence held through the Hop & Mae Adams Foundation and related trusts. During Mayor Bob Crowell’s three terms, the Foundation pledged $5–8 million toward the $250 million downtown redevelopment plan, including support for a public parking garage, while participating in development decisions and public-private funding allocations. Key supporting entities included Doppelgangers Charitable Corporation (Alan H. Adams as President, Bradford C. Adams as Secretary), ABB ATM LLC (co-managed by Alan H. Adams, Bradford C. Adams, and Steven G. Neighbors in 2009 during the Nugget ownership transition), and layered real estate transfers through trusts. The documented sequence (2004–2011) includes consanguinity-based deeds on Carson City properties (2004 gift deed and 2007 “Son to Father” transfer), the 2008 conveyance of properties recorded at a transaction value of

$900,000 to Larry Goodnight as Trustee of the Sunflower Trust—real estate assets currently valued at over $2.35 million—while simultaneously retaining a $600,000 promissory note via an All-Inclusive Deed of Trust, a broad Special Power of Attorney to Justin M. Clouser, and California mortgage payoffs and refinancing shortly after the Nugget sale to Dean DiLullo. The synthetic Nevada identity served as the vehicle for this regulatory access, asset movement, and its later use in federal filings. The evidentiary record is organized around three distinct and independently verifiable claims:

I. BRADFORD CHARLES ADAMS (AGE 69, OF SAN FRANCISCO) IS

PRESENTLY DEFRAUDING THE U.S. DEPARTMENT OF EDUCATION

UNDER A SYNTHETIC IDENTITY, “BRADFORD CHARLES ADAMS,” (AGE

64, OF LAS VEGAS).

II. THE SYNTHETIC NEVADA IDENTITY BRADFORD CHARLES ADAMS IS

USING TO DEFRAUD THE U.S. DEPARTMENT OF EDUCATION WAS

CONSTRUCTED JOINTLY WITH ALAN H. ADAMS, WHO SPONSORED

BRADFORD AS A LEGITIMATE MEMBER OF THE HISTORIC ADAMS

GAMING FAMILY OF CARSON CITY, NEVADA TO OBTAIN GAMING

LICENSURE AND INFLUENCE; THAT IDENTITY WAS THEN

LAUNDERED THROUGH A NETWORK OF ENTITIES—INCLUDING

“DOPPELGANGERS” AND RELATED SHELL COMPANIES WITH NO

LEGITIMATE BUSINESS FUNCTION—AS VEHICLES TO OFFLOAD

DEBT, SHIFT ASSETS, AND LAUNDER FUNDS.

III. THE ADAMS FAMILY INFRASTRUCTURE UNDERLYING THAT SCHEME,

VIA THE HOP & MAE ADAMS FOUNDATION, WAS DEEPLY

ENTRENCHED IN DEVELOPMENT AND APPROPRIATIONS DECISIONS

WITHIN CARSON CITY THROUGHOUT MAYOR ROBERT “BOB”

CROWELL'S 12-YEAR TENURE, AND REMAINS SO TODAY, INCLUDING

INVOLVEMENT IN A $250 MILLION REDEVELOPMENT PLAN AND

CONTINUED OPERATION OF THE NORTHERN NEVADA DEVELOPMENT

AUTHORITY FROM THE ADAMS HUB BUSINESS CENTER.

The threshold question underlying every claim in this submission— and the predicate upon which the False Claims Act violation, the RICO enterprise, and the public corruption entanglement all depend—is identity. The individual who filed Adv. Pro. No. 24-12007-nmc in the District of Nevada, identifying himself as “Bradford Charles Adam,” age 64, of Las Vegas, Nevada, is Bradford Charles Adams, age 69, of San Francisco, California. That convergence is established by thirteen (13) independently corroborating grounds, each grounded in primary source documentation, each capable of standing alone, and each mutually reinforcing the others. Taken together, these thirteen (13) grounds establish identity convergence. Tracing backward from that entry point reveals a coordinated network involving Bradford Charles Adams, Alan H. Adams, and Steven G. Neighbors— the individual judicially appointed Guardian of Alan H. Adams's estate in November 2011 and sole trustee of the Hop and Mae Adams Foundation, which pledged up to $8 million toward the Carson City downtown redevelopment project (later specified as $5 million for a public parking garage) valued at $250 million that Carson City Mayor Bob Crowell personally championed through three terms. The documented connections among all three men extend to a shared formal business entity: ABB ATM LLC, formed August 25, 2009, with Alan H. Adams, Steven G. Neighbors, and Bradford C. Adams listed as co-managers—placing all three in a registered business relationship at the precise moment the Nugget Project was being structured for Board of Supervisors approval. The same attorney, Justin M. Clouser of Minden,

Nevada, served as Bradford C. Adams's attorney-in-fact by recorded Special Power of Attorney, co-officer of the Doppelgangers Charitable Corporation alongside Alan H. Adams (President) and Bradford C. Adams (Secretary), and registered agent for multiple Adams-connected entities—all documented by public record and corporate filing. Carson City’s own citizens and press sensed this entanglement in real time, while lacking the evidentiary record to name it. When residents filed a petition in June 2010 to force a public vote on the Nugget Project, the Carson City Board of Supervisors moved swiftly to suppress it, with Mayor Crowell telling reporters: “There is no proposal or project right now. None of those decisions have been made.” (Exhibit B, 2010-06-07 - Reactions to Nugget Project petition: last update) A contemporaneous op-ed published February 25, 2011 by Nevada journalist Guy W. Farmer called Steve Neighbors “the Pied Piper of Boise” and described the scheme as “the Nugget Bailout Project”—characterizing it as requiring the city to put more than $30 million in taxpayer dollars at risk over 30 years while the private fundraising component quietly collapsed. (Exhibit C, 2011-02-25 - Steve Neighbors, the pied piper of Boise) On February 2, 2012, when a second citizen group filed a formal ordinance petition demanding that no public funds be spent on the City Center/Nugget Project without a majority vote of the people, Mayor Crowell's published response was not to address the democratic legitimacy of the process, but to immediately defend the financial terms of the project itself:

“In these economic times I don't think our community should ignore the opportunity to have $21 million in private capital invested in our city in a project structured to create no debt for our citizens.” The private capital Crowell was publicly defending included the Hop Mae Adams Foundation pledge—the same Foundation whose sole trustee, Steven G. Neighbors, was co-manager of ABB ATM LLC alongside Bradford C. Adams and Alan H. Adams at the precise moment the Nugget Project was being structured for Board of Supervisors approval. By February 2012, that private capital component had already been documented as collapsing—Guy Farmer had characterized it as the “Nugget Bailout Project” a year earlier, and Kirk Caraway would document within months that the funding structure had quietly shifted from half-funded by private sources to requiring double the sales tax originally rejected. Crowell's response is consistent with his documented pattern of active public advocacy for a project whose private capital anchor was the Foundation controlled by his network. (Exhibit D, 2012-02-02 – Group Files Petition to Put Nugget Project to a Vote of the People – Carson Now) By April 2012, local journalist Kirk Caraway was documenting a funding structure that had quietly shifted from “half-funded by private sources and didn’t require any tax increases” to a proposal requiring double the sales tax originally rejected—writing that project supporters appeared to have changed their position on a public vote not out of principle, but because “it’s about the money.” (Exhibit E, 2012-04-14 - Nugget Project: it’s about the money)

Meanwhile, Neighbors himself was authoring public Q&A columns explaining the opaque three-entity structure (Nugget, Trust, Foundation) in language that answered nothing while presenting the arrangement as straightforward civic philanthropy. (Exhibit F, 2010-02-21 - The Nugget Project: Ask Steve Neighbors: How casino, trust, foundation fit together) The citizens were right, they just didn’t have what the Relator has—a smoking gun. Relator initially reported the bankruptcy fraud detailed herein by telephone in September 2025 to the Office of the Assigned Prosecutor, Summer Allegra Johnson. The matter was referred to the Financial Crimes Division and an agent identified as Mike Garth. During that call, Relator provided the case number and advised that the United States Department of Education was being defrauded through the use of a synthetic identity. As of the date of this submission, no follow-up has been received, no documentation has been requested, and no further action has been taken. Relator is now formally reporting this matter and is prepared to provide the complete evidentiary record upon request. Relator is the original source of this evidence. The evidentiary record consists of several hundred primary source documents—property deeds, marriage records, bankruptcy filings, corporate formation instruments, Nevada Gaming Commission records, court orders, and metadata-verified digital artifacts—spanning more than thirty years across California, Nevada, Idaho, Ohio, and Florida.

Claim I — Federal filing

I. BRADFORD CHARLES ADAMS, 69 OF SAN FRANCISCO IS PRESENTLY

DEFRAUDING THE U.S. DEPARTMENT OF EDUCATION UNDER A

SYNTHETIC IDENTITY, “BRADFORD CHARLES ADAMS,” 64, OF LAS

VEGAS.

Bradford Charles Adams, age 69, of San Francisco, California, is currently defrauding the U.S. Department of Education in a pending federal adversary proceeding—Adv. Pro. No. 24-12007-nmc, District of Nevada—by filing under a synthetic identity that reduces his age by five years, anchors him to a manufactured Nevada domicile, and pleads a fabricated stage-four cancer caregiving hardship that his own wife publicly contradicted in a verified social media post five days after the filing. On September 20, 2024, Bradford Charles Adams filed an adversary proceeding, Adv. Pro. Case No. 24-12007-nmc, seeking to discharge $48,493 in federal student loan debt owed to the United States Department of Education under 11 U.S.C. § 523(a)(8) on grounds of undue hardship. The loans were incurred while purportedly attending Arizona State University, where Bradford Adams—allegedly—completed a bachelor’s degree in May 2022. He was, by his own filing’s representation, 64 years old at the time of degree completion— meaning he enrolled and completed a degree program in his early-to-mid sixties while simultaneously claiming to be an Uber driver earning $4,500/month gross with $5,563/month in expenses and making only $250 in total loan payments across 5 payment events. (Exhibit A, 2024-09-20 – Bankruptcy #4 (2-24-bk-120007) – Ch. 7 ($48,493) – Bradford Charles Adam vs US DOE – Adversary Complaint)

The hardship narrative pleaded to justify discharge is materially false in at least two independently verifiable respects. First—the stage-four cancer claim. The adversary complaint alleges that Plaintiff is the primary caregiver for his wife, who suffers from “stage four cancer affecting her spinal cord, ribs, hips, nose, and throat, rendering her unable to work and requiring constant care,” and that these caregiving obligations “severely limit Plaintiff’s ability to work full-time.” On September 25, 2024, five days after Bradford Charles Adams swore under penalty of perjury in federal court that his wife suffered from stage-four cancer affecting her spinal cord, ribs, hips, nose, and throat—rendering her unable to work and requiring constant care—Fatima Almeida Adams published a public social media post from the Instagram account @fattyma11almeida— belonging to Fatima Almeida Adams, Bradford’s wife and bankruptcy co- debtor—stated: Today, following four months of treatment for H. pylori bacteria, I have my final consultation with my doctor. Hopefully, I will be cleared of this debilitating condition that has affected me for months… I urge everyone to prioritize their health, as ignoring symptoms can lead to severe consequences like stomach cancer. —Exhibit G, 2024-09-25 (@fattyma11almeida)

The post from Fatima Almeida Adams described not metastatic cancer treatment but a final consultation following four months of treatment for a bacterial infection. The post also referred to stomach cancer only as a possible consequence of untreated infection and advised readers to obtain what it called an “upper respiratory endoscopy” for confirmation. H. pylori is commonly evaluated through stool testing, urea breath testing, or upper endoscopy with

gastric biopsy, whereas laryngoscopy is used to examine the larynx and vocal cords. The stark contrast between the sworn stage-four cancer narrative and Fatima's own contemporaneous public statement is irreconcilable. The post was plainly intended to function as a health update that provided plausible cover—a way to acknowledge some illness in the public record while walking back the specificity of what Bradford had sworn. It accomplished the opposite, as the account intended to provide cover became the primary source document contradicting the sworn narrative. The attempted manufacture of exculpatory evidence is demonstrated again on December 10, 2024, Fatima posted a photograph of a check for $23,886.87, dated February 10, 2024, drawn on a KeyBank account, with a St. Jude Children's Research Hospital donation pad visible in the background. (Exhibit H, 2024-12-10 – @fattyma11almeida) The caption identifies the signatory as “Eric” and offers an explanation—that the check covered three months of home care expenses for his aunt in Manhattan— framed as something Fatima had walked in on and was troubled by. The post was plainly intended to provide innocent cover for a large financial transaction involving Eric Sparling—the same Eric Sparling who purchased Fatima's foreclosed home out of Fannie Mae inventory in 2011, held it for a decade, transferred it back to her for nothing in 2021, and—in 2016, between those two transactions—was declared the winner of a brand new Lexus CT200 Hybrid in a televised Las Vegas giveaway sponsored by Lexus of Las Vegas, selected by

key from a pool of finalists, reported by KTNV News Las Vegas1. A check for exactly $23,886.87 described as three months of home care is not how legitimate caregiving expenses are paid or documented. It is how a specific financial obligation—a promissory note installment, a debt settlement, a structured transfer—looks when it is moving through a personal check with a narrative attached after the fact. The check is dated February 10, 2024—seven months before the adversary complaint was filed, placing it squarely within the pre-petition period during which all assets and financial transactions were required to be disclosed to the bankruptcy court. The Instagram account that was supposed to be cover is in fact the evidentiary record. The stark contrast between the sworn stage-four cancer narrative in the adversary complaint and the wife’s own contemporaneous public statement describing a resolved bacterial infection is, with certainty, an attempted cover for the hardship story presented to the bankruptcy court, though the hardship narrative pleaded in the adversary complaint is facially difficult to reconcile even on its own terms. The complaint alleges that Plaintiff is 64 years old, works as a self-employed Uber driver, owes $48,493 in student-loan debt, can afford only a $250 monthly payment, and is the primary caregiver for a wife alleged to suffer from stage-four cancer, while also caring for a 14-year-old daughter. At the same time, the complaint alleges that Plaintiff enrolled at Arizona State University and completed his degree in May 1 KTNV News Las Vegas, Winner declared in 13 Action News Lexus giveaway, https://www.ktnv.com/news/winner-declared-in-great-las-vegas-lexus-giveaway

2022, meaning Plaintiff purportedly undertook higher education borrowing very late in life, while already situated in severe financial distress and while allegedly bearing extraordinary caregiving obligations—an irrational and incoherent narrative. Second—the synthetic age and synthetic identity. The bankruptcy filing identifies Plaintiff as “Bradford Charles Adam,” age 64, of Las Vegas, Nevada. The actual individual is Bradford Charles Adams, age 69, of San Francisco, California. The Nevada identity is synthetic and has been constructed over decades through manufactured real property activity. The trail includes: • a November 1993 marriage to Ping Xiao in Carson City, Nevada (Document No. 120114M); (Exhibit I, 1993-11-19 – Marriage – Ping Xiao & Bradford Charles Adams – Carson City) • an April 1995 published marriage license notice for Bradford Charles Adams, age 33, of Carson City, and Elizabeth Ann Becker, age 29, of Sparks—creating an early documented marital identity inconsistency; (Exhibit J, 1995-04-04 – Reno Gazette-Journal – Page 35) • a December 2004 gift deed placing Bradford C. Adams into title on 7140 San Antonio Ranch Road, Carson City, Nevada, via a first-degree consanguinity transfer from Alan H. Adams as trustee; (Exhibit K, 2004-12-28 – 7140 San Antonio Ranch Rd – Gift Deed) • an April 2006 tenants-in-common acquisition of Kutcher Manor property in Carson City alongside Alan H. Adams as trustee of the Alan H. Adams Family Trust, with shared mailing infrastructure at 800 North Carson Street; (Exhibit L, 2006-04-19 – Grant, Bargain, and Sale Deed (352628)) • a November 2007 transfer of Bradford’s Kutcher Manor interest back to Alan H. Adams Trust, deed language expressly characterizing the transaction as “son to father”; (Exhibit M, 2007-11-02 – Declaration of Value – Declaration of Value (‘Son to Father’))

• April 2008 conveyances of both 7140 San Antonio Ranch Road and 3784 Paradise View to Larry Goodnight as trustee of the Sunflower Trust, within days of each other (Exhibit N, 2008-04-29 – Grant, Bargain, and Sale Deed) (Exhibit O, 2008-04-30 – All-Inclusive Deed of Trust with Assignment of Rents); and • a May 2008 Special Power of Attorney executed by Bradford C. Adams from 7140 San Antonio Ranch Road, appointing Justin M. Clouser as attorney-in-fact with sweeping authority over real estate, business, and tax matters—establishing San Antonio Ranch Road as his declared residential anchor in formal legal instruments. (Exhibit P, 2008-05-06 – Bradford Charles Adams—Justin M. Clouser – Special Power Of Attorney) The adversary complaint, filed under penalty of perjury, identifies the plaintiff as “Bradford Charles Adam,” age 64. This stated age matches neither identity: Bradford Charles Adams (born August 1956) was 68 at filing, while the synthetic Nevada identity (born July 1961) would have been 63 years old in September 2024. This active fraud is not an isolated event, but the most recent entry in a documented pattern of serial bankruptcy conduct spanning four separate cases across multiple federal districts and two decades—including a Chapter 7 case filed by Fatima Almeida Hein in the District of Nevada in 2005 (Case 05-51513) (Exhibit Q, 2005-05-16 – Bankruptcy #2 – Fatima Almeida Hein (05-51513)), a Chapter 13 filed by Fatima Almeida Adams in the Southern District of Ohio in 2010 (Case 2:10-bk-56738) (Exhibit R, 2010-06-03 – Bankruptcy – Fatima Almeida Adams (2_10-bk-56738)), and prior Chapter 7 filings under the Bradford Charles Adams identity—each accompanied by the same name-

13 grounds of identity convergence

variant and financial-misrepresentation patterns present in the current proceeding. The synthetic Nevada identity underlying the current filing first appears in public records in Carson City in November 1993 and is sustained through a continuous chain of documented marriage records, recorded property deeds, corporate filings, and gaming commission appearances—all produced in Relator’s evidentiary record. Identity convergence is established on thirteen (13) distinct and independently corroborating grounds: 1. Five (5) Carson City public records spanning 1993 to 2007 across property deeds, a power of attorney, and two marriage records established Bradford Charles Adams as the same individual across every instrument. A Carson City public records search for “Adams, Bradford” returns five (5) results spanning 1993 to 2007, all bearing the middle name Charles and all involving the same individual across property deeds, a Special Power of Attorney, and two marriage records—including the November 19, 1993 marriage of Bradford Charles Adams to Ping Xiao (Document No. 120114M) and the July 5, 2007 marriage of Bradford Charles Adams to Fatima A. Hein (Document No. 137797M)—each record corroborating the same Carson City identity chain. The same search returns a May 6, 2008 Special Power of Attorney granted by Bradford Charles Adams to Justin M. Clouser (Document No. 379365)—the same attorney who served as co-officer of the Doppelgangers Charitable Corporation and registered agent for multiple Adams-connected entities. Records 1 and 2 in the same search reflect Grant Bargain & Sale Deeds involving Alan H. Adams as Trustee—the Carson City gaming patriarch who sponsored Bradford Charles Adams as a member of the historic Adams gaming family to obtain Nevada gaming licensure—placing Bradford, Alan, and Clouser in the same public record chain from a single search query. (Exhibit S, BRADFORD CHARLES ADAMS – Carson City)

2. Public data aggregator records for “Bradford Charles Adams” (born August 1956, age 69) append Nevada parcel APN 138-30-214-001—a Clark County, Las Vegas property identifier belonging exclusively to the Nevada-facing profile's address at 1350 N Town Center Dr #2091, Las Vegas, NV 89144, where the subject is listed as “Bradford C. Adams” (born July 1961, age 64)—to the subject's California address at 1012 De Haro St #C, San Francisco, CA 94107, constituting independent third-party confirmation that the California and Nevada identities resolve to a single individual. The California-facing profile lists 1012 De Haro St #C, San Francisco, CA 94107 as the subject’s current address. However, the property record block appended to that San Francisco address displays the following metadata: • Subdivision: Summerlin Village 3 Unit #1a • School District: Clark County School District

• APN: 138-30-214-001

• Lot Square Feet: 760,122 • Ownership Type: Corporate • Land Use: Apt House 100+ Units Every one of those data fields belongs exclusively to 1350 N Town Center Dr #2091, Las Vegas, NV 89144—the address listed as current on the Nevada-facing “Bradford C Adams,” born July 1961, age 64 profile. APN 138-30-214-001 is a Clark County, Nevada parcel number. The Clark County School District serves Las Vegas, Nevada. Summerlin Village is a Las Vegas master-planned community. None of these descriptors have any relationship to a property located at San Francisco, CA 94107. The San Francisco parcel number for 1012 De Haro St is APN 4159 003, assigned by the San Francisco County Assessor—a wholly distinct jurisdiction. This cross-contamination occurs in public aggregator databases through one mechanism: the deduplication engine that builds and maintains these profiles determined—through its own internal matching logic across name, phone, relative, business, and address signals—that the California-facing identity and the Nevada-facing identity resolve to the same underlying individual, and merged their property records accordingly. The system is not confused about whether these are two

different people, the identities are entangled because it recognizes they are one. This constitutes independent third-party corroboration—produced by an automated commercial system with no stake in this matter—that the two Bradford Adams public-record profiles are a single person managing a bifurcated identity across state lines for purposes that include, at minimum, the synthetic age reduction deployed in the fraudulent hardship narrative filed in Adv. Pro. No. 24-12007-nmc. An investigator can verify this in under sixty seconds by pulling Clark County Assessor APN 138-30-214-001 and confirming it maps to Las Vegas, Nevada—not San Francisco. 3. Bradford Charles Adams of San Francisco has a documented criminal history that reflects a pattern of fraud-adjacent conduct predating the Nevada identity construction by decades and establishing the behavioral predicate for the scheme that follows. Bradford Charles Adams (age 17, DOB 08/06/1956) and his brother Blake John Adams (age 15, DOB 11/10/1957) were arrested at a Greyhound Bus Station in Omaha, Nebraska, after an employee notified officers of thirty-two pounds of marijuana concealed in a duffel bag tied to the brothers. (Exhibit T, Police Find Pot in Duffel) Bradford Adams was later convicted of Destruction of Evidence in Sonoma County, California in 1988. Blake John Adams appears as co- defendant in the Sonoma County record, independently corroborating the sibling identity connection established in the Omaha arrest. (Exhibit U, Destruction of Evidence—Bradford Charles Adams) These records are offered as predicate context establishing that the individual now before a federal bankruptcy court under a synthetic identity and a fabricated hardship narrative has a documented history of concealment, destruction of evidence, and willingness to operate outside legal boundaries. 4. Public aggregator data reflects a Nevada-facing “Bradford Charles Adams” identity deliberately but narrowly distinct from the California identity—linked to thirty-five (35) addresses across thirty-

four (34) years, following a single continuous life trajectory across state lines, not the parallel existence of two independent individuals. Public aggregator data reflects a Nevada-facing “Bradford Charles Adams” identity—born July 1961, age 64 at time of capture—that is deliberately but narrowly distinct from the California-facing “Bradford Charles Adams” identity—born August 1956, age 69—yet both profiles trace a single continuous life trajectory across the same states, the same cities, and in several instances the same street addresses, spanning thirty-five (35) addresses across thirty-four (34) years. (Exhibit V, Bradford C Adams (64) – 35 Addresses, 34 Years) The two profiles do not diverge geographically—they overlap. Both records register activity in San Francisco during the same periods: the Nevada profile shows a 1628 Grant Avenue San Francisco address from April 2004 through March 2008, while the California profile shows continuous San Francisco residency at 1034–1038 Carolina Street from June 1999 through January 2020. Both profiles list Capital City Electric at 870 Market Street, Suite 353, San Francisco as a business connection. Two independent individuals sharing a name would not share a single business address registered under the same entity name across two separate public-record profiles spanning the same decade. The geographic continuity, address movement patterns, and temporal cadence of the Nevada record trail are consistent with one person managing two public-record footprints, not two persons sharing a common name. IDENTITY A—“Bradford C Adams” DOB: July 1961 (Age 64) Nevada-Facing Profile | TruePeopleSearch • 1992–1993—PO Box 575, Seal Beach, CA 90740 (Orange County) • 1992–2000—8705 E Avenue T6, Littlerock, CA 93543 (Los Angeles

County)

• 1993—743 Languid Ln #524, Simi Valley, CA 93065 (Ventura County) • 1993—2844 Knoxville Ave, Long Beach, CA 90815 (Los Angeles County) IDENTITY B—“Bradford Charles Adams” DOB: August 1956 (Age 69) California-Facing Profile | TruePeopleSearch • 1985–1993—2190 Fleetwood Dr, San Bruno, CA 94066 (San Mateo County) • 1985–1993—PO Box 421346, San Francisco, CA 94142 • 1990–2016—PO Box 78211, San Francisco, CA 94107 • 1994–2001—525 Leavenworth St #5, San Francisco, CA 94109 • 1994–1999—7547 Muirfield Way, Sacramento, CA 95822

• 1993–2001—13906 Polk St, Sylmar, CA 91342 (Los Angeles County) • 1993–2012—PO Box 2825, Carson City, NV 89702 • 1995–2001—1240 Pullman Dr, Sparks, NV 89434 (Washoe County) • 1995–2017—7140 San Antonio Ranch Rd, Carson City, NV 89704 (Washoe

County)

• 1997–2004—961 Mandalay Beach Rd, Oxnard, CA 93035 (Ventura County) • 1998–2004—2831 Knoxville Ave, Long Beach, CA 90815 (Los Angeles County) • 1999–2002—1755 E Plumb Ln #233, Reno, NV 89502 (Washoe County) • 2003—1390 Market St #2923, San Francisco, CA 94102 • 2004—418 Union St #A, San Francisco, CA 94133 • 2004–2008—1628 Grant Ave, San Francisco, CA 94133 • 2004—5301 Lewis Rd, Agoura Hills, CA 91301 (Los Angeles County) • 2006–2007—516 S Richmond Ave, Carson City, NV 89703 • 2007–2008—1202 N Carson St #200, Carson City, NV 89701 • 2008—PO Box 2071, Carson City, NV 89702 • 2008—2440 Vassar St #3B, Reno, NV 89502 • 2008–2017—PO Box 129, Minden, NV 89423 • 2009—224 Meridian Blvd, Minden, NV 89423 • 2009—306 E William St, Carson City,

NV 89701

• 2010—6155 Plumas St #122, Reno, NV 89519 • 2012—4750 Bradford Ln, Reno, NV 89519 • 2012—4530 Thoreau Park Dr #201, Orlando, FL 32839 • 1995–1999—944 Market St #508, San Francisco, CA 94102 • 1999–2020—1034–1038 Carolina St, San Francisco, CA 94107 • 2001–2011—166/180 Geary St #300– 320, San Francisco, CA 94108 • 2004–2020—1012 De Haro St #1, San Francisco, CA 94107 • 2005–2020—1036 Carolina St, San Francisco, CA 94107 • 2008–2022—870 Market St #355, San Francisco, CA 94102 • 2017—Pine St, San Francisco, CA 94109 • 2017—870 E Market St #353, San Antonio, TX 78205 • 2017–2020—2176 Abadeer Trl, San Antonio, TX 78253 (Bexar

County) (fraudulent Texas domicile)

• 2025—870 Market St #353, San Francisco, CA 94102 • 2025—1034 Carolina St #1036, San Francisco, CA 94107 • 2025—1575 Pine St #11, San Francisco, CA 94109 • 2025 (current)—1012 De Haro St #C, San Francisco, CA 94107 Business AES LLC, 870 Market St Ste 353, San Francisco, CA 94102 Capital City Electric, 870 Market St Suite 353, San Francisco, CA 94102 (shared with NV identity)

• 2012–2015—4028 Promenade Square Dr #4422, Orlando, FL 32837 • 2012–2024—13348 Colony Square Dr #2712, Orlando, FL 32837 • 2015–2022—2800 Shearwater Way, Fairfield, CA 94533 • 2019–Current—1350 N Town Center Dr #2091, Las Vegas, NV 89144 • 2021–2025—1350 N Town Center Dr #1108, Las Vegas, NV 89144 • 2025—418 Union St #C, San Francisco, CA 94133 • 2025—800 N Carson St #416, Carson City, NV 89701 Business 1993—Zero Defects Software, Inc., 1202 N Carson St Ste 200, Carson City, NV 89701 2006—Capital City Electric, 870 Market St Ste 353, San Francisco, CA 94102 (business—shared with CA identity) 2009—Opmba LLC, PO Box 129, Minden,

NV 89423

5. The temporal alignment of the death of Howard Adams and Bradford Charles Adams’s San Francisco real property transactions; and the coordinated public identity performance of Bradford Charles Adams and Alan H. Adams in December 2001, in direct contradiction to the Adams family’s documented practice of strict privacy. The timing of major events in the Nevada Adams family and the financial activity of Bradford Charles Adams (69, of San Francisco) strongly suggests activity across two jurisdictions and identities by a single individual, and the specific instruments in the record make that connection concrete rather than inferential: ▪ On June 11, 1999, Bradford Adams acquired 1575 Pine Street, Unit 11, San Francisco, identified in the grant deed as “a married man as his sole and separate property.”

(Exhibit W, 1999-06-11 – 1575 Pine St #11 – Grant Deed (1999605454)) ▪ Three days later, on June 14, 1999, Bradford Charles Adams’ wife Ping Xiao Adams executed an interspousal transfer deed on the same property. (Exhibit X, 1999-06-14 – 1575 Pine St #11 – Interspousal Transfer Deed)) ▪ Six days after that—on June 17, 1999—the Las Vegas Sun reported that Howard Adams had died “last week” at his home in Idaho, that services had already been held the preceding Monday in Boise, that no obituary had been issued, and that Carson Nugget officials declined to comment. (Exhibit Y, 1999-06-17 – Carson Nugget owner Howard Adams dies (prior week) at 90) Accordingly, Howard Adams did not die on June 17, 1999. Both San Francisco instruments were executed before the death was publicly reported—during the precise window in which Howard Adams had already died but that fact had not yet been announced. The temporal proximity of those deeds to an unpublicized succession event is not coincidental. By December 2001, Bradford Adams was publicly identified as assistant vice president of the Carson Nugget, and the Nevada Gaming Control Board approved stock transfers placing Alan Howard Adams at forty- eight percent (48%) of Carson Nugget stock. Bradford Adams performed the family identity for the press on December 19. Alan Adams performed it for the Gaming Control Board on December 20. The two public appearances—one civic, one regulatory—occurred on consecutive days, presenting a coordinated and consistent family narrative to two independent audiences simultaneously. That coordination is documented in two independent published records dated one day apart: ▪ On December 19, 2001, a feature article published in the Tahoe Daily Tribune identified “Brad Adams” as assistant vice president of the Carson Nugget and quoted him describing the casino's 42-year Thanksgiving tradition as something started by “his grandfather and great-uncle”— performing the family identity in the press, by name, in

direct quotation. (Exhibit Z, 2001-12-19 – Brad Adams “Assistant VP” Carson Nugget – Tradition becomes Carson City's golden nugget) ▪ One day later, on December 20, 2001, the Nevada Appeal reported that the Nevada Gaming Control Board had voted to recommend approval of a stock transfer placing Alan Howard Adams at forty-eight percent (48%) of Carson Nugget stock— with Alan Adams quoted telling gaming officials: “Our family has been there 45 years and we plan to stay.” That same article disclosed, for the first time in any public record reviewed by Relator, that Howard Adams and his wife had died within fifteen days of each other the prior June at their home in Boise, Idaho. (Exhibit AA, 2001-12-20 – Nugget ownership stays in family) More generally, San Francisco property records begin in the mid-1990s and continue through 2015—the same period during which Bradford Charles Adams appeared in Carson City marriage records, property deeds, gaming commission filings, and corporate formations. The cessation of active Carson City filings coincides with the 2015 sale of the Carson Nugget to Dean DiLullo. The timing and cadence of the Nevada record trail mirror the California activity as phases of a single life course, not the independent chronology of a separate individual. 6. Lineage precedent establishes that the methodology underlying the synthetic identity is a documented family pattern with antecedents spanning at least three generations. The evidentiary thread for this ground begins with a newspaper story buried on Page 12 of the Beckley Post-Herald on April 30, 1937, under the headline “Lost Girl Back at Parents' Home.” The article reports that a young woman from Eccles, West Virginia—identified in that article as “Mrs. Tracy Westmoreland”—had returned home to visit her parents, and to present her infant daughter, Deanna Jean, to her grandparents. The article casually brushes past a bizarre, two-year disappearance, explaining that since she went missing from Beckley on August 12, 1935—at which time she was only 18 years old and he was 36, twice her age—she had obtained a divorce from Westmoreland, who was serving a prison sentence, and had remarried—“this time to Arthur Wellington

Adams, engineer for the Skelly Oil Company of Tulsa, Oklahoma.” (Exhibit AB, Beckley Post-Herald — April 30, 1937) This account immediately arrested the attention of the Relator, who is from Tulsa and graduated from the University of Tulsa, where he was a scholarship placekicker for the football team and played on Skelly Field— named for the oil company founder. Following this interest, Relator discovered the underlying records; specifically, the falsified marriage license used to construct this ancestral identity. The woman identified in that article as “Tracy Westmoreland” is the same individual who appears as “Shirley Arvada Dillon” on the April 12, 1937 Oklahoma County marriage record for Arthur Wellington Adams II, and who appears in at least one additional record under the first name “Bernice.” By the time she reached nineteen, the same individual had three distinct first names—Bernice, Tracy, and Shirley Arvada—across a marriage license, a newspaper account, and genealogical records. (Exhibit AC, 1937-04-12 — Marriage — Shirley (Bernice, Tracy) Arvada Dillon — Arthur Wellington Adams II) The man she married—Arthur Wellington Adams II, Bradford Charles Adams's grandfather—executed that April 12, 1937 application for marriage license under the truncated form “A.W. Adams,” not his full legal name, and swore to a known lie by stating his age was 36. Independent records confirm he was born on August 18, 1898, meaning he was nearly 39—an age discrepancy completely irreconcilable with clerical error. (Exhibit AD, Ferris Genealogy, 1.1.3.1.4.4.1.7 at 127) (Exhibit AE, Arthur Wellington Adams II - Find a Grave) (Exhibit AF, Arthur Wellington Adams II (Slayback)) The infant daughter presented to the Dillon grandparents in that April 1937 visit—Deanna Jean—is the same Deanna Jean Adams (Holm) who appears, decades later, within the Ferris Genealogy (Exhibit AD, 1.1.3.1.4.4.1.7.3 at p. 128) as a family historian and genealogist. One of only two familial connections within Bradford Charles Adams's Facebook connections: (1) Sister – Lonnie Catherine Adams (1.1.3.1.4.4.1.7.2.3) (2) Half-Aunt – Deanna Jean Adams (Holm) (1.1.3.1.4.4.1.7.3)

Deanna Jean Adams (Holm) is Bradford Charles Adams's half-aunt: Arthur Wellington Adams, Jr. was born in 1928 to Arthur II's second wife, Ruth Gross; Deanna Jean was born in 1937 to Arthur II's third wife, Shirley Arvada Dillon—the woman whose multiple identities surfaced through the 1937 missing persons story. The family historian actively curating that lineage record today is within Bradford Charles Adams's immediate personal network. The structural parallel to Bradford Charles Adams's conduct is direct and specific. Both instruments: • are marriage licenses • use name truncation • contain age discrepancies irreconcilable with independently verifiable records • place a specific name and age into a permanent, independently searchable public record in a jurisdiction where the signer was not known. The license executed in Oklahoma in 1937 served the same function as the Carson City marriage registry entry of November 1993 and the Reno Gazette-Journal notice of April 1995—a marriage instrument deployed to create a public record anchor with a minimized evidentiary footprint. 7. On April 4, 1995, the Reno Gazette-Journal published a marriage license notice identifying Bradford Charles Adams, age 33, of Carson City, and Elizabeth Ann Becker, age 29, of Sparks, Nevada—placing the name “Bradford Charles Adams,” at an age consistent exclusively with the 1956 San Francisco birth year, into a permanent, newspaper-of-record public entry at the precise moment the 1993 Ping Xiao marriage remained legally extant. That notice performed a specific structural function within the identity architecture: it anchored Bradford Charles Adams to a Carson City residential identity through an independently searchable public instrument, while the prior marriage record remained in the same public record system unextinguished. It is also the direct contemporary application of the same method documented in his grandfather’s Tulsa license sixty years earlier—the strategic use of a marriage instrument to

place a specific name, age, and geographic anchor into the permanent public record. (Exhibit J, 1995-04-04 – Reno Gazette-Journal – Page 35) 8. Physical presence in the Nevada nexus is established by forensic digital evidence. On December 1, 2024, Jennifer Adams sent Relator five (5) childhood pictures after discussing their childhoods earlier in the day. These photos were taken by Complainant, with her device at the time (an Apple iPhone 5s) and contained their original embedded metadata. The last image, IMG_1968.heic, contains the following metadata: Capture Date: 2015-06-20 Device: iPhone 5s Location: 39°13’33.0”N, 119°56’01.1”W IMG_1968.heic is an image produced by Bradford Charles Adams’ (69, of San Francisco) daughter’s (Jennifer Pan Adams) device and sent by her to Relator in the ordinary course of communication. (Exhibit AG,

IMG_1968.HEIC)

IMG_1968.heic has a capture date of June 20, 2015 with GPS coordinates of 39°13’33.0”N, 119°56’01.1”W. When these coordinates are plotted using a standard GIS platform, they correspond to the Lake Tahoe shoreline immediately west of 7140 San Antonio Ranch Road, Carson City, Nevada 89704—the property at the center of the Sunflower Trust transfer chain and the address Bradford Charles Adams (64, of Las Vegas) declared as his residential anchor in the May 6, 2008 Special Power of Attorney appointing Justin M. Clouser as attorney-in-fact. This location represents the nearest shoreline point on Lake Tahoe relative to the property located at 7140 San Antonio Ranch Road, Carson City, Nevada. A gift deed recorded December 28–29, 2004, conveyed a fifty-percent undivided interest in 7140 San Antonio Ranch Road, Carson City, from Alan H. Adams as trustee to Bradford C. Adams—a first-degree consanguinity transfer. (Exhibit J, 2004-12-28 – 7140 San Antonio Ranch Rd – Gift Deed) On November 1–2, 2007, Bradford C. Adams transferred his interest in the Kutcher Manor property at 516 South Richmond, Carson City, back

to Alan H. Adams, trustee of the Alan H. Adams Family Trust, in a tax- exempt transaction whose recorded deed language expressly characterizes the conveyance as “son to father.” (Exhibit M, 2007-11-02 – Declaration of Value – Declaration of Value (‘Son to Father’)) On April 29, 2008, Bradford C. Adams conveyed 7140 San Antonio Ranch Road to Larry Goodnight as trustee of the Sunflower Trust. (Exhibit M, 2008-04-29 – Grant, Bargain, and Sale Deed) On April 30, 2008, Bradford C. Adams conveyed 3784 Paradise View— valued at $900,000—to the same Goodnight/Sunflower Trust instrument. (Exhibit N, 2008-04-30 – All-Inclusive Deed of Trust with Assignment of Rents) These four transactions, executed across a four-year window, place Bradford C. Adams in documented title activity with Alan H. Adams and Larry Goodnight through a series of interlocking conveyances that bear the structural characteristics of coordinated asset movement rather than ordinary real property transfers. 9. The semantic obfuscation pattern running across the documentary record. The semantic obfuscation pattern running across the documentary record is not a single mistake—it is a recurring, multi-context technique applied to reduce the searchability and cross-referenceability of Bradford Charles Adams's identity across jurisdictions and filing systems. Four distinct instances are documented. Instance 1: The bankruptcy caption—"Bradford Charles ADAM” The adversary proceeding filed September 20, 2024, in the District of Nevada—Adv. Pro. No. 24-12007-nmc—identifies the plaintiff throughout as "Bradford Charles Adam," without the terminal "s" on Adams. The underlying Chapter 7 case caption likewise reads "Bradford Charles Adam." This is not a typographical error made by the court; it is the name the plaintiff provided to his attorney, who filed under it. The practical effect is to create a federal court record that does not return in a name search for "Bradford Charles Adams"—the name that appears on thirty-plus years of property deeds, marriage records, gaming commission filings, and corporate instruments in California and Nevada. (Exhibit A, 2024-09-20 – Bankruptcy #4 (2-24-bk-120007) – Ch. 7 ($48,493) – Bradford Charles Adam vs US DOE – Adversary Complaint)

Instance 2: The California Secretary of State filing for Answer Electric Inc.—“BRADORD Charles Adams” The California Secretary of State's current entity record for Answer Electric Inc. (Entity No. 4105858), incorporated January 16, 2018, lists the agent of record as “BRADORD Charles Adams”. The name as entered is effectively unsearchable from either direction. The California contractor license closed-business records for the same entity list the owner as “ADAMS, BRADFORD C”—the correct spelling— creating an internal inconsistency within the same entity's public record across two California government databases. (Exhibit AH, Answer Electric Inc. – California Secretary of State) The Answer Electric Inc. corporate structure names Bradford's daughter Jennifer Pan Adams as Secretary, with her address of record in Orlando, Florida. Instance 3: The manufactured Texas domicile—“870 E Market St #353, San Antonio, TX 78205”—a transposition of the family's actual San Francisco office address (870 Market St #353, San Francisco, CA 94102), deployed in December 2017 in coordination with the acquisition of 2176 Abadeer Trail, San Antonio, to manufacture a false Texas domicile for Jennifer Pan Adams's UTRGV Medical School in-state tuition application. The address 870 E Market St #353, San Antonio, TX 78205 appears in Bradford Charles Adams's aggregator address record for exactly one month: December 2017. No other entry before or after it reflects any San Antonio business presence. The address is not a coincidence and not a clerical artifact—it is the San Francisco office address with a single letter added (“E”) and the city substituted from San Francisco, CA to San Antonio, TX. The San Francisco original—870 Market St #353, San Francisco, CA 94102—is the address of Ping Xiao Adams's acupuncture clinic, Pacific Acupuncture Center, and a hub address for multiple Bradford Adams–linked business entities including AES LLC and Capital City Electric, documented in Bradford's own aggregator record as a business address spanning at least 2006 through 2025.

The single-month December 2017 aggregator entry for the San Antonio variant is temporally precise. In the same month—December 2017—the Adams family acquired 2176 Abadeer Trail, San Antonio, Bexar County, and the San Antonio business address variant first appears in Bradford's aggregator record—the same month the manufactured Texas domicile was fed into institutional channels with sufficient success that by the time Jennifer Pan Adams graduated from UTRGV School of Medicine in 2023, the official commencement program printed and distributed by the university lists her hometown as San Antonio, TX. This is notable because Jennifer Pan Adams grew up and lived her entire life in San Francisco, California, as documented by her own Stanford Daily biography identifying her as “hailing from the hip-central San Francisco,” her attendance at Lowell High School, and an unbroken San Francisco address record spanning her entire childhood and undergraduate years. The manufactured San Antonio domicile was, apparently, sufficiently internalized—right up until it wasn't needed anymore. The UTRGV White Coat Ceremony commencement program lists her hometown as San Antonio, TX. The commencement article published alongside it identifies her as a Stanford graduate from San Francisco—correctly noting that “Jennifer Adams, who graduated from Stanford University with a bachelor's degree in biomechanical engineering” was drawn to UTRGV for its border location—while in the same breath quoting her explaining that draw by reference to a third, entirely different hometown: “I grew up in China on the border of Tajikistan, on the very westernmost border of China, so I've always been drawn to the health issues that arise in that sort of environment.” To summarize what the single UTRGV White Coat Ceremony record simultaneously establishes Jennifer Pan Adams is: i. From San Antonio, Texas: per the Commencement program. ii. From San Francisco, California: the accompanying article correctly identifies her as a Stanford graduate—where her own self- authored Stanford Daily biography announced she was “hailing from the hip-central San Francisco”; iii. From the China-Tajikistan border: the quote provided for that same article says she grew up on the Chinese-Tajikistani border.

The Tajikistan claim is self-refuting without requiring an external source. Jennifer's Stanford Daily biography identifies Shanghainese as her heritage dialect, a language spoken exclusively in the Yangtze River Delta on the eastern seaboard of China, ~2,500 miles from the Xinjiang- Tajikistan border she was apparently raised on. Xinjiang and Shanghai are separated by the entire width of the Chinese landmass, roughly the same distance as New York to Los Angeles. A person raised on the Xinjiang-Tajikistan border does not grow up speaking Shanghainese; a person raised in San Francisco by a mother from Shanghai does. (Exhibit AI, UTRGV Class of 2023 Commencement Program, at 9) (Exhibit AJ, UTRGV Class of 2023 White Coat Ceremony) (Exhibit AK, Bradford Charles Adams (69)) (Exhibit AL, 2019-08-08 – Sale – 2176 Abadeer Trail – Warranty Deed with Vendor's Lien – Bexar County Records) 10. Shell entity cross-contamination. “Capital City Electric” appears in public aggregator data tied to both the California and Nevada identities as a result of internal filing inconsistencies—an operational defect that surfaces precisely because the two identities share a common source. Entities do not bleed across independent persons’ public records absent a shared filing history. The contamination is the artifact of a single actor managing two record footprints imperfectly. (Exhibit V, Bradford C Adams (64) – 35 Addresses, 34 Years) 11. The operational visibility cycle and heavy public and media presence during active asset-acquisition phases followed by abrupt disappearance from Carson City news and filings once liabilities are offloaded. The cycle mirrors Alan H. Adams’s own visibility pattern and is consistent with coordinated management of public exposure across a shared enterprise. Bradford Charles Adams's public presence in Carson City follows a precise and documentable cycle: heavy visibility during active asset- acquisition phases, followed by abrupt disappearance from local press and public filings once those assets have been transferred and liabilities offloaded. That cycle is not the behavior of a Carson City resident—it is the behavior of someone managing a public-record footprint from outside the jurisdiction.

The record of named appearances in Carson City press begins with the December 2001 Nevada Appeal article identifying “Brad Adams” as assistant vice president of the Carson Nugget, serving Thanksgiving meals to 3,500 people—a civic, family-facing public appearance tied directly to the Adams gaming identity. It continues through the July 2004 Waterfall fire coverage, again naming “Brad Adams, vice president of Carson Nugget,” donating meals to firefighters—another civic-facing, family-embedded appearance during the period of maximum property acquisition activity. His last named appearance in Carson City press is October 28, 2010, in Nevada Appeal and Carson Now coverage reporting that "Doppelgangers owner Brad Adams" had approached a third party to take over the Doppelgangers location—a handoff announcement, not a civic presence. Alan H. Adams's last named press appearance is January 8, 2010, in the Nevada Appeal article reporting his sale of a 50% Nugget stake to Steve Neighbors—with the notation that “Alan Adams was unavailable for comment.” By January 2011 he appears only passively, referenced as “former Carson Nugget co-owner” in a land transfer story. By November 2011 he is under court-appointed guardianship. The pattern is identical across both men and maps precisely onto the documented asset and liability sequence: public visibility peaks during the 2001–2008 period of maximum property acquisition and gaming licensure activity, and terminates in 2010 as the final asset transfers and operational handoffs are completed. Bradford Adams does not appear in Carson City press after October 2010. The Nevada Gaming Control Board complaint against AA Gaming was filed in January 2012. Neither Bradford Adams nor Alan Adams is named in that coverage. The entity that bore their names absorbed the regulatory consequences; the individuals had already exited the record. 12. The name “Doppelgangers”—chosen for the entity through which Bradford C. Adams was formally embedded as Secretary alongside Alan H. Adams as President—is not incidental. A doppelgänger is a double: an identical counterpart occupying a second identity. The relator does not assert that the name is a confession. The relator asserts that the name of the entity used to operationalize Bradford’s insertion into the Adams gaming licensure structure is, on its

face, the most precise single-word description of the mechanism the relator has spent thirty pages documenting. 13. Multi-Generational Nevada roots and family fraud conduct that are, collectively, incompatible with independent action. The lineage established in Ground 6 (Exhibit AD, Ferris Genealogy) connects Bradford Charles Adams to two collateral relatives whose documented federal and state enforcement records independently corroborate the behavioral pattern at the center of this submission: the systematic use of false representations to government bodies, the manipulation of legal identity and jurisdictional footprint, and the deployment of layered procedural positions to obstruct legitimate regulatory and judicial processes. A. Linda Jean Lightfoot — FTC Civil Enforcement Action (2002) The first collateral record belongs to Linda Jean Lightfoot, a/k/a Linda J. Beasley, who married Mark Edwin Holm on May 19, 1979, in Carson City, Nevada. (Exhibit AD, Ferris Genealogy, 1.1.3.1.4.4.1.7.3.1) Mark Edwin Holm is the son of Deanna Jean Adams (Holm)—Bradford Charles Adams's half-aunt—making Linda Jean Lightfoot the spouse of Bradford's first cousin once removed, and placing her squarely within the documented family network. The Ferris Genealogy records this Carson City marriage, the same jurisdiction that anchors the synthetic Nevada identity at the core of this submission. On March 29, 2002, the Federal Trade Commission filed a civil enforcement action in the United States District Court for the Southern District of Ohio, Western Division, against Linda Jean Lightfoot, individually and d/b/a Universal Direct, and Charles F. Childs, individually and d/b/a Universal Direct, both operating out of 4132 Pompton Court, Dayton, Ohio, for violations of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). (Exhibit AM, 2002-03-29 — FTC v. Lightfoot & Childs — Complaint, Case No. C-3-02-145) The Commission alleged that since at least February 1999, Lightfoot and Childs operated a chain mail pyramid scheme under the trade names “Universal Direct” and “MegaDirect,” promoted through mass unsolicited commercial email and associated websites. The complaint set forth five

counts: (I) affirmative misrepresentation of likely substantial income; (II) the chain mail structure as a per se deceptive practice; (III) material omission — failure to disclose that the program's structure made financial success impossible for most participants; (IV) furnishing the means and instrumentalities for further deceptive acts by participants; and (V) express false representation that the scheme was legal, when it in fact violated the FTC Act, the Mail Fraud Statute (18 U.S.C. § 1341), and the Lottery Statutes (18 U.S.C. §§ 1301–02). (Exhibit AM) On April 12, 2002, the Court entered a Stipulated Preliminary Injunction freezing Lightfoot's assets, enjoining further participation in any prohibited marketing scheme, and requiring full financial disclosure to the Commission — signed by Lightfoot individually and entered by Chief Judge Walter Herbert Rice. (Exhibit AN, 2002-04-12 — FTC v. Lightfoot & Childs — Stipulated Preliminary Injunction Freezing Assets, Case No. C-3- 02-145) B. Mark Edwin Holm — California Office of Tax Appeals (2018) The second collateral record belongs to Mark Edwin Holm directly. A California Office of Tax Appeals opinion issued August 10, 2018—OTA Case No. 18011033—documents that Mark Edwin Holm had failed to file California income tax returns for at least sixteen tax years: 1995, 1996, 1997, 1998, 2002, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, and 2013, with all years except 2013 having already gone to final assessment at the time of the 2018 proceeding. (Exhibit AO, 2018-08-10 — Mark Edwin Holm — California Office of Tax Appeals, OTA Case No. 18011033) Holm's submissions to the Office of Tax Appeals spanned more than 1,100 pages across multiple filings, plus a compact disc containing over 3,000 pages of supplemental material—a volume of procedural obstruction that the tribunal characterized explicitly as a pattern of filing frivolous appeals and failing to comply with California's tax laws. (Exhibit AO) Holm's positions included claims that he was not a “taxpayer,” that the identifying number the FTB was using was “WRONG,” that he was a “nonresident alien” under the Internal Revenue Code despite living and working in California, that wages do not constitute income, and that FTB lacked statutory authority to impose penalties—arguments the Office of

Tax Appeals catalogued as among the most comprehensively discredited positions in California tax jurisprudence. The tribunal imposed the maximum statutory frivolous appeal penalty of $5,000, noting that Holm had previously been sanctioned $750 and $2,500, respectively, for frivolous appeals of his 2007 and 2008 tax years, and had continued to advance the same positions despite explicit prior warnings. (Exhibit AO) These two records, considered alongside the conduct of Bradford Charles Adams in Adv. Pro. No. 24-12007-nmc, establish a consistent behavioral methodology operating across three individuals within the same family network: false or manipulated representations to federal and state authorities; deployment of name variants and jurisdictional ambiguity to reduce evidentiary footprint; fabricated legal positions asserted under penalty of perjury or in formal proceedings; and systematic use of procedural volume to obstruct regulatory response. The conduct documented in the FTC enforcement action against Linda Jean Lightfoot and the California tax proceedings against Mark Edwin Holm is not coincidental to the conduct of Bradford Charles Adams—it is corroborative of it. C. Ping Xiao Adams and Jennifer Pan Adams Nuclear family records establish shared fraud patterns and operational entanglement across Bradford, his former wife Ping Xiao Adams, and his daughter Jennifer Pan Adams as participants in a single shared infrastructure. Ping Xiao Adams is the owner and operator of Pacific Acupuncture Center, located at 870 Market Street, Suite 353, San Francisco, California—the same commercial address that appears across Bradford Charles Adams's California and Nevada entity filings, including Capital City Electric. Jennifer Pan Adams used her personal ChatGPT account to generate fraudulent workers' compensation dispute letters to carriers including Liberty Mutual, falsely asserting that the clinic had submitted required authorization forms, and to generate canned patient visit summaries and acupuncture treatment plans for fictitious whiplash and neck injury presentations—structured as reusable multi-patient templates—for billing workers' compensation carriers for nonexistent services at her mother's clinic. (FBI Tip — Jennifer Pan Adams, Counts 3 and 4) The clinic is Ping Xiao Adams's business. The fraudulent billing infrastructure was constructed at her address, for her clinic, by her daughter.

The operational entanglement extends beyond the shared address. Jennifer Adams is listed as Secretary of Answer Electric, Inc.—a Bradford Charles Adams entity—with her Orlando, Florida address as the registered contact. Jennifer Adams is also named as co-owner alongside Ping Xiao Adams on both the July 2024 all-cash Orlando condominium purchase and the May 2025 Doll Lab fictitious name filing executed through a false sworn certification. (FBI Tip — Jennifer Pan Adams, Count 8) On November 17, 2024, Jennifer Pan Adams was audio-recorded in a seven-minute, laughter-filled account of a premeditated medical fraud scheme—describing how she manipulated a patient using fabricated clinical premises to extract $140 in fees and induce purchase of a $600 veterinary ultrasound machine—code-switching between English and Mandarin to deliver the account directly to Ping Xiao Adams in real time, as her mother's audience. (FBI Tip — Jennifer Pan Adams, Count 1) The recording is in the public court record. Ping Xiao Adams was not an inadvertent recipient. She was the person to whom Jennifer Adams was speaking while describing the commission of healthcare fraud for financial gain—laughing. The behavioral signature across all three members of the nuclear family is consistent: false sworn representations to government bodies; exploitation of shared commercial infrastructure to facilitate fraud; and the deployment of layered legal and procedural positions to obstruct legitimate oversight. Bradford manufactures identities and hardship narratives in federal court. Ping operates the commercial address that anchors the fraud infrastructure and holds the real estate portfolio that makes the hardship narrative false. Jennifer generates the fraudulent billing documentation, executes the perjured state filings, and was recorded laughing while describing the scheme to her mother. D. Additional Ties I — Image Geolocation (Reno, NV) On October 18, 2013, Bradford Adams’ (69, of San Francisco) daughter Jennifer Adams posted a collage of three photographs on Facebook with the caption: “East to West like a pro… #foreverathirdculturekid.” One image depicts her wearing a cowgirl hat in an arid, rolling-hills landscape identified through artificial intelligence image geolocation as the Great Basin region near Reno. E. Additional Ties II — Hobart Killing in Washoe County (1882)

Bradford Adams’ (69, of San Francisco) great-grandfather Dr. Arthur Wellington Adams, M.D. killed a man in Washoe County. In July 1882, a man named Hobart died after being thrown from a wagon driven by Dr. Wellington Adams in Long Valley. Witnesses reported that the wagon passed over Hobart’s head, neck, and face, crushing him instantly. One observer noted, “Saw the man Adams drive off at a lively pace as though the wagon was empty.” Adams later gave a guarded statement to reporters, claiming limited awareness of the incident. A coroner’s jury ultimately ruled the death at the scene as accidental. The record demonstrates a striking pattern of narrative manipulation and selective credulity. In the 1892 Reno inquest concerning the death of Hobart, the testimony attributed to Adams is riddled with implausibilities: a purported threat with a non-existent knife, a “sudden jolt” conveniently timed to eject the deceased from the wagon, and an astonishing claim of complete unawareness thereafter. The inquest report itself betrays the tension between observable fact and the narrative offered, noting Adams’ reticence and guarded demeanor, yet ultimately labeling the death as “accidental” and discharging him. Even in this restrained, contemporaneous account, the investigative record signals the implausibility of the declarant’s story—the temporal mechanics, the claimed nonchalant reaction, and the inherently self-serving account all defy reasoned expectation of ordinary behavior, particularly for someone in a position of responsibility. These historical circumstances mirror the present case. Under modern legal reasoning, the combination of (1) a non-credible, uncorroborated “threat,” (2) the application of lethal force through a moving vehicle, and (3) the actor’s failure to stop or render aid, would raise substantial questions as to culpability that extend well beyond mere accident. The inability of the inquest to determine whether the decedent “fell” or was “thrown” underscores that the proceeding did not resolve the central issue of causation. The parallel is directly relevant here, where dispositive credibility has been lent to a narrative that is internally contradictory, unsupported by reliable corroboration, and resistant to logical scrutiny. (Exhibit AP, 1882-08-05 – Nevada State Journal)

Third—the concealed asset and the nominee ownership structure. The adversary complaint's poverty narrative requires the Court to find that Bradford Charles Adams cannot maintain a minimal standard of living while repaying $48,493 in student loans. That narrative rests on a household income of approximately $4,500 per month, expenses of $5,563 per month, and total loan payments of approximately $250 across five payment events. It omits entirely that Fatima Almeida Adams—Bradford's co-debtor in the underlying bankruptcy, the woman Bradford swore was rendered unable to work by stage-four cancer—holds title to a single-family residence in Las Vegas, Nevada currently estimated at over $546,000, returned to her without consideration through a nominee ownership structure that ran for a decade during and after their prior federal bankruptcy proceedings. The property is 3863 Galiceno Drive, Las Vegas, Nevada 89122—Lot 164 of Stallion Mountain Estates II, Unit 4, Clark County, APN 161-15-311-005. On July 28, 2006, Maria F. Hardina and John W. Hardina, wife and husband as joint tenants, executed a deed of trust on that property (Instrument No. 20060731-0006173). Maria F. Hardina is Fatima Almeida Adams. The Hardina name is the name under which Fatima held title at 3863 Galiceno before the foreclosure, and the name under which she received it back. On May 28, 2004, a Tampa Bay Times notice referenced Maria Hardina and John W. at 22018 Yachtclub Terrace for $240,000.

The Hardinas defaulted. On June 21, 2010, the property was sold at trustee's sale and conveyed to Fannie Mae for $411,538.71 in unpaid debt. (Exhibit __, 2010-06-30 – Trustee's Deed Upon Sale) On January 28, 2011—less than eight months after Bradford and Fatima filed their Chapter 13 bankruptcy in the Southern District of Ohio (Case 2:10- bk-56738) on June 3, 2010—Fannie Mae conveyed 3863 Galiceno Drive to Eric D. Sparling, a single man, for $195,000. (Exhibit AQ, 2011-01-28 – Grant, Bargain and Sale Deed) On September 5, 2012, Sparling conveyed the property to himself as sole trustee of The Eric Sparling Trust for $10.00. (Exhibit AR, 2012-09-05 – Grant, Bargain and Sale Deed) On October 26, 2021, Eric D. Sparling, as trustee of The Eric Sparling Trust, quitclaimed the property without consideration to Maria F. Hardina— both grantor and grantee listing 3863 Galiceno Drive as their address of record, claiming a trust-transfer tax exemption under NRS 375.090, Section 7. (Exhibit AS, 2021-10-26 – Quitclaim Deed, Inst. No. 20211026-0002812) That October 2021 transfer has no innocent explanation. Sparling purchased the house for $195,000, took out a mortgage on it, held it for ten years while it appreciated to a current estimated value exceeding $546,000, and then conveyed it to the woman whose name was on the original foreclosure—for nothing. Zero consideration. No mortgage. No transfer tax. The tax exemption claimed—NRS 375.090, Section 7, “transfer to or from a trust without consideration”—is the exemption a person uses to move their own

asset into their own trust. It does not authorize transferring a fully appreciated asset you purchased, mortgaged, and held for a decade to a third party for free. The exemption was misapplied on the face of the instrument. What the transaction describes is nominee ownership: holding title to property in one person's name for the benefit of someone else who cannot, or strategically chooses not to, hold it in their own name. Fatima could not hold title to 3863 Galiceno Drive after the 2010 foreclosure without triggering scrutiny from the Ohio bankruptcy court, the bankruptcy trustee, or her creditors. Sparling held it for her. When sufficient time had passed—the Ohio bankruptcy concluded, the foreclosure had aged, and Bradford's 2024 adversary proceeding had not yet been filed—the property came back. For nothing. Through a quitclaim deed dressed as a trust transfer, using a tax exemption it does not qualify for, executed ten years after a man with no documented independent connection to Fatima purchased her foreclosed home out of government inventory at the precise moment she was in bankruptcy and could not hold it herself. The use of a third-party nominee to hold title to real property during a period of legal and financial exposure, followed by a no-consideration transfer back to the beneficial owner once that exposure has passed, is a textbook real estate money laundering structure under 18 U.S.C. § 1956—specifically, a transaction designed to conceal the nature, ownership, and control of an asset from creditors, courts, and federal oversight. The concealment of that asset from the 2024 bankruptcy proceeding is independently criminal under 18

U.S.C. § 152, which prohibits the knowing and fraudulent concealment of assets from a bankruptcy court. A debtor who omits a $546,000 house from their bankruptcy schedules while swearing to undue hardship has not made a paperwork error. They have committed bankruptcy fraud on the face of the filing. The structure is identical in function to what Bradford and Alan H. Adams executed in Carson City: an asset moves off the visible record of the person who actually controls it, sits in a nominee's name through a period of legal or financial exposure, and returns through a no-consideration instrument that minimizes the paper trail. The Carson City vehicle was the Sunflower Trust and Larry Goodnight. The Las Vegas vehicle was The Eric Sparling Trust and Eric D. Sparling. The mechanism is the same. The purpose is the same. The subdivision in which all of this occurs is Stallion Mountain Estates II—built on land sold by Golf Club of Nevada, Inc. to Pulte Homes of Nevada for $61 million on March 15, 2004. Golf Club of Nevada was Billy Walters's Stallion Mountain golf course—purchased from the City of Las Vegas in 1999 for $894,000, approximately $5,600 per acre, in a transaction sealed by then- Mayor Jan Jones, who personally poured Walters a glass of water when he addressed the council while cutting off members of the public objecting that the land was worth more than $40,000 per acre. When Walters returned in 2005 to ask the current council to lift the deed restriction so he could build homes on land now worth $300,000 to $400,000 per acre—a potential windfall of $54 to $64 million at taxpayer expense—then-Mayor Oscar Goodman,

described by the reporting journalist as having “close ties to Walters,” tabled the item only after hundreds of public complaints. Walters faced three separate federal money laundering indictments from 1986 to 2002, all dismissed or thrown out, before his 2017 federal conviction for insider trading. The attorney who represented Walters throughout the 1980s money laundering proceedings was Oscar Goodman—who served as Mayor of Las Vegas from 1999 to 2011, the precise window during which the Hardina deed of trust was executed, the foreclosure occurred, and Sparling purchased the REO. Bradford swore in federal court that Fatima was homebound and dying, that the household had $4,500 in monthly income against $5,563 in expenses, and that he had made only $250 in total loan payments. That poverty narrative is contradicted on multiple levels by the public property record. The co-debtor he described as unable to work holds a Las Vegas house currently estimated at over $546,000—returned to her without consideration through a decade-long nominee arrangement at the precise moment it could not be held in her own name. The man filing that poverty narrative is the same individual who, between 2004 and 2008, juggled title to two Carson City properties that are today valued at approximately $1.95 million (7140 San Antonio Ranch Road, current Zestimate $1,949,200) and approximately $2.32 million (3784 Paradise View, current Zestimate $2,324,300)—properties he conveyed to the Sunflower Trust in 2008 for a recorded transaction value of $900,000 while retaining a $600,000 promissory note, simultaneously paying off California mortgage debt and refinancing San Francisco real property shortly after the Nugget sale

closed. The combined current market value of those three properties—the two Carson City estates and the Galiceno house—exceeds $4.8 million. A man who routed multimillion-dollar Nevada real estate through a trust while retaining a $600,000 secured interest, whose co-debtor holds a half-million-dollar Las Vegas home through a nominee structure, is not a 64-year-old Uber driver who cannot afford his student loans. Thus, the poverty narrative presented to the bankruptcy court is contradicted by recorded deeds in three jurisdictions.

Claim II — Nevada identity and network

II. THE SYNTHETIC NEVADA IDENTITY BRADFORD CHARLES ADAMS IS

USING TO DEFRAUD THE U.S. DEPARTMENT OF EDUCATION WAS

CONSTRUCTED JOINTLY WITH ALAN H. ADAMS, WHO SPONSORED

BRADFORD AS A LEGITIMATE MEMBER OF THE HISTORIC ADAMS

GAMING FAMILY OF CARSON CITY, NEVADA TO OBTAIN GAMING

LICENSURE AND INFLUENCE; THAT IDENTITY WAS THEN LAUNDERED

THROUGH A NETWORK OF ENTITIES—INCLUDING “DOPPELGANGERS”

AND RELATED SHELL COMPANIES WITH NO LEGITIMATE BUSINESS

FUNCTION—AS VEHICLES TO OFFLOAD DEBT, SHIFT ASSETS, AND

LAUNDER FUNDS.

Established in 1954, the Carson Nugget is one of the oldest continuous gaming unrestricted licenses in the state of Nevada. The Adams family occupied a central position in Carson City’s gaming and development landscape for decades through the Carson Nugget Casino and affiliated trusts and foundations. Howard Adams and Hop Adams acquired the Carson Nugget in 1957 after prior gaming operations in Idaho, Oregon, and Las Vegas, and over the ensuing decades expanded it into the largest casino in Carson City and one of the longest continuously operating casinos in Nevada. The family maintained extraordinary privacy concerning its operations, wealth, and internal affairs. As documented by the Las Vegas Sun when Howard Adams died in June 1999 at age ninety, “The Adams family has always cherished privacy to an extreme and Howard's death brought no change to that. No obituary was issued and Carson Nugget officials would not comment.” (Exhibit X, 1999-06-17 – Carson Nugget owner Howard Adams dies at 90 - Las Vegas Sun). The family’s influence extended beyond gaming through the Hop and Mae Adams Foundation and related trusts, which later emerged as major

funding vehicles for redevelopment activity in Carson City. The Carson Nugget itself had already drawn regulatory scrutiny in 1996, when it became the first Carson City casino cited by undercover State Gaming Control Board agents for money-laundering violations. (Exhibit AT, 1996-06-13 – First Carson City casino hit with laundering sting – Las Vegas Sun) This Adams Family is wholly distinct from the Adams Family and lineage of Bradford Charles Adams, which is documented in the Ferris genealogy and is extraordinary in its own regard. (Exhibit AD, Ferris Genealogy) That lineage includes: Dr. Joseph Flavius Adams, M.D.—one of the most prodigious Freemasons of the nineteenth century, appearing in Albert Mackey's American Quarterly Review of Freemasonry alongside Freemasonry's preeminent chronicler; Dr. Arthur Wellington Adams, M.D.—great- grandfather of Bradford Charles Adams of San Francisco, inventor of the hub motor and holder of U.S. Patent No. 300,827 (1884), cited in the Ferdinand Porsche Wikipedia as the conceptual originator of the electric wheel-hub motor, referenced in the Edison Papers, and named by Thomas Commerford Martin— the editor who collaborated with both Thomas Edison and Nikola Tesla—as a foundational figure in electric railway development; Colonel Alonzo W. Slayback—Confederate cavalry commander, founder of the Veiled Prophet Ball in St. Louis, best friend and law partner of James Overton Broadhead, the first President of the American Bar Association, and the man shot dead in the offices of Joseph Pulitzer's St. Louis Post-Dispatch in a killing whose controversy, per the family genealogy, “still rages today, especially within this

family”; Electa Ferris—direct ancestor of Bradford Charles Adams and wife of John Thompson, founder and principal organizer of Chase National Bank, now JPMorgan Chase; and Mary Astrid Thompson—granddaughter of Electa Ferris and John Thompson, who married George Randolph Hearst Jr., merging the Thompson banking dynasty into the Hearst media empire. However, the smokescreen that the common surname provides has allowed Bradford Charles Adams, age 69, of San Francisco, California, to indulge in decades of synthetic identity-based fraud schemes. The Nevada identity trail begins to crystallize in late 1993. On November 19, 1993, the authentic Bradford Charles Adams (of San Francisco, DOB: August 6, 1956) married Ping Xiao in Carson City, Nevada, in a marriage recorded under Document No. 120114M. Less than two years later, on April 4, 1995, the Reno Gazette-Journal published a marriage-license notice for Bradford Charles Adams, age thirty-three (33), of Carson City, and Elizabeth Ann Becker, age twenty-nine (29), of Sparks. The coexistence of the 1993 Carson City marriage record and the 1995 published license notice creates an early public-record inconsistency in Bradford Charles Adams’s marital history. Meanwhile, Alan H. Adams’s property activity in Carson City was already underway. In August 1995, Alan H. Adams acquired 1533 Chaparral Drive in Carson City and shortly thereafter encumbered the property with a $350,000 deed of trust. In July 1998, he transferred Parcel 2 on Empire Ranch Road to AA Storage, LLC, claiming exemption from documentary transfer tax on the basis that he owned one hundred percent of the entity.

In September 1998, he refinanced 1533 Chaparral Drive through a new deed of trust in the principal amount of $349,000, later associated with the First National Bank of Chicago as trustee. These transactions show Alan H. Adams moving property between individual and entity forms while simultaneously leveraging the same real estate through substantial secured debt. The chronology then reflects a significant timing cluster in June 1999. On June 11, 1999, Bradford Adams acquired 1575 Pine Street, Unit 11, in San Francisco, with the grant deed identifying him as “a married man as his sole and separate property.” (Exhibit V, 1999-06-11 – 1575 Pine St #11 – Grant Deed (1999605454)) Three days later, on June 14, 1999, Ping Xiao Adams executed an interspousal transfer deed conveying the same property to Bradford Adams, again identifying him as a married man taking title as his sole and separate property. (Exhibit W, 1999-06-14 – 1575 Pine St #11 – Interspousal Transfer Deed)) On June 17, 1999, the Las Vegas Sun reported that Howard Adams had died the prior week, not that day, at age ninety at his home in Idaho; (Exhibit X, 1999-06-17 – Carson Nugget owner Howard Adams dies (prior week) at 90) However, Howard Adams did not die on June 17, 1999. Rather, a Las Vegas Sun article published on June 17, 1999 reported that Howard Adams, co-owner of the Carson Nugget Casino, had died “last week” at his home in Idaho and that services had already been held the preceding Monday in Boise. Thus, the

June 11, 1999 grant deed and June 14, 1999 interspousal transfer deed concerning 1575 Pine Street in San Francisco were executed before the public reporting of Howard Adams’s death and during the same narrow period in which his death had already occurred but had not yet been publicly announced. Given the article’s further statement that no obituary was issued and Carson Nugget officials would not comment, the temporal proximity of those deeds to the unpublicized death of the Carson Nugget patriarch strengthens the inference that title activity was occurring against a backdrop of closely held family knowledge rather than ordinary public succession timing. Notably, both deeds use the address “1575 Pine Street, #11,” but this unit number makes no sense because the actual legal description in Exhibit One transfers a single, undivided 25-by-100-foot commercial parcel on Carolina Street with no condominium structure or fractional units. By inserting a specific apartment number (“#11”) into a transaction that actually conveys an entire land parcel miles away, the deeds create a deliberate geographic and structural mismatch designed to make a whole-building property transfer look like a routine, low-value residential condo purchase. Given the Las Vegas Sun's report that no obituary was issued and Carson Nugget officials refused to comment, the immediate execution of these conflicting deeds following the patriarch's unpublicized death indicates that this structural camouflage was deployed to quickly obscure the transfer of a major family asset from public scrutiny.

By 2001, the record also places “Brad Adams” publicly inside Carson Nugget operations. A December 19, 2001 article identified Brad Adams as assistant vice president of the Carson Nugget (Exhibit Z, 2001-12-19 – Brad Adams “Assistant VP” Carson Nugget – Tradition becomes Carson City's golden nugget), and a December 20, 2001 report stated that Nevada Gaming Control Board approval of stock transfers left Alan Howard Adams with forty-eight percent of Carson Nugget stock after Howard Adams and his wife died, thereby keeping the casino in the family. (Exhibit AA, 2001-12-20 – Nugget ownership stays in family) This is important because it ties Bradford/Brad Adams not merely to scattered personal records, but to the public-facing operations and succession structure of the Adams casino enterprise. In May 2004, during this same period, Bradford Adams and Ping Xiao Adams obtained a $200,000 home equity line of credit from Chase Manhattan Bank secured by 1034 Carolina Street, San Francisco, simultaneously maintaining active San Francisco real property financing while Bradford was publicly serving as vice president of a Nevada gaming operation, as confirmed by his July 2004 appearance in Carson City press coverage of the Waterfall fire relief effort. The core three-party property chain becomes especially clear from 2004 through 2008. On December 28-29, 2004, records reflect a gift deed and declaration of value involving 7140 San Antonio Ranch Road, identified as Lot 5 of San Antonio Ranch Estates. The transfer reflected a first-degree consanguinity exemption and conveyed a fifty-percent undivided interest from

Alan H. Adams, as trustee, to Bradford C. Adams. That transaction placed Bradford directly into title on a property that later reappears as a central address in his own filings. On April 19, 2006, Melissa Shaw Granat conveyed Kutcher Manor property in Carson City to Alan H. Adams, as trustee of the Alan H. Adams Family Trust, and to Bradford C. Adams as tenants in common, each holding an undivided one-half interest. The deed directed mailing and tax statements to “Alan H. Adams Trust/Bradford Adams” at 800 North Carson Street. (Exhibit L, 2006-04-19 – Grant, Bargain, and Sale Deed (352628)) That entry is a clean docume67ntary link joining Alan H. Adams and Bradford C. Adams in shared ownership and shared mailing infrastructure. The next year, on November 1 and 2, 2007, Bradford C. Adams transferred his one-half interest in that same Kutcher Manor property—516 South Richmond / APN 3-036-02—to Alan H. Adams, trustee of the Alan H. Adams Family Trust, in a tax-exempt transaction described as “son to father.” (Exhibit M, 2007-11-02 – Declaration of Value – Declaration of Value (‘Son to Father’)) The recorded declaration of value and deed language are notable because they do not merely reflect a transfer between two unrelated actors or arms-length entities; they expressly characterize the relationship within a family structure while moving the property back into trust-held form under Alan H. Adams. The record then widens. On July 5, 2007, Bradford Charles Adams married Fatima Almeida Hein in Carson City, even though the prior Ping Xiao

marriage remained part of the same public-record trail. By September 2007, Fatima Almeida Adams appears in Washoe County traffic records. That continuity of names and geography places Bradford, Fatima, and the Nevada property trail in the same time window. The most important convergence occurs in spring 2008. On April 29, 2008, Bradford C. Adams conveyed 7140 San Antonio Ranch Road to Larry Goodnight, as trustee of the Sunflower Trust. On April 30, 2008, Bradford C. Adams likewise conveyed 3784 Paradise View, currently valued at more than $2.3MM, to Larry Goodnight, again through the Sunflower Trust, accompanied by financing instruments including all-inclusive deeds of trust and assignment-of-rents provisions. Thus, within a relatively compact timeframe, the same network shows: (1) Alan H. Adams placing Bradford into title on 7140 San Antonio Ranch Road, (2) Bradford moving other jointly linked Carson City property back to Alan’s trust, and then (3) Bradford transferring the San Antonio Ranch Road and Paradise View properties onward to Larry Goodnight through the Sunflower Trust. The sequence ties together the three actors—Alan H. Adams, Bradford Charles Adams, and Larry Goodnight—as participants in an interlocking transfer pattern. Doppelgangers: Gaming Licensure, Corporate Structure, and the Name That Defines the Scheme

Doppelgangers is not a peripheral entity in this record. It is the vehicle through which Bradford Charles Adams was formally, publicly, and officially embedded into the Adams gaming licensure structure—as a named corporate officer, on a Nevada Gaming Commission filing, alongside Alan H. Adams— while simultaneously operating under a synthetic identity that the Nevada Gaming Commission did not know existed. On April 6, 2008, AA Gaming, Inc. filed an application with the Nevada State Gaming Control Board for a gaming license authorizing operation of Doppelgangers, located at 302 N. Carson Street, Carson City, Nevada—the street address of the Carson Nugget Casino. The application identified Alan H. Adams as President and Bradford C. Adams as Secretary of AA Gaming, Inc. The Nevada Gaming Control Board heard the matter across two days— June 4-5, 2008—and forwarded it to the Nevada Gaming Commission, which issued a conditional approval on June 19, 2008. (Exhibit AU, 2008-04-06 – NGC Gaming License – Doppelgangers – AA Gaming Filing); (Exhibit AV, 2008- 06-19 – NGC Gaming License – Doppelgangers – AA Gaming Approval, Conditioned) The significance of that licensing proceeding cannot be overstated. Nevada gaming licensure is among the most rigorous identity and background vetting processes in any regulated industry in the United States. Every individual named as a principal, officer, or key employee of a licensed gaming entity is subject to mandatory background investigation—including verification of identity, age, financial history, criminal history, and the existence of any

undisclosed affiliations or interests. Bradford Charles Adams submitted to that process, or caused it to be submitted on his behalf, as Secretary of AA Gaming, Inc., under the same name he has used to execute real property transactions, marry multiple women in Carson City, and ultimately file a fraudulent federal bankruptcy adversary proceeding—a name attached to a birth year that does not match the San Francisco birth record, a state of origin that is manufactured, and a family relationship to Alan H. Adams that the documentary record does not support. The Nevada Gaming Commission conditionally approved Doppelgangers. That conditional approval is a record produced by a state regulatory body following background investigation. Whatever representations were made to the Gaming Control Board about Bradford Charles Adams—his age, his domicile, his identity, his relationship to Alan H. Adams—are embedded in a state regulatory record and are capable of being subpoenaed and compared directly against the evidentiary record assembled here. On August 25, 2009, ABB ATM LLC was formed in Nevada with Alan H. Adams, Steven G. Neighbors, and Bradford C. Adams listed as managers— placing Bradford inside the governance structure connecting Alan Adams and Neighbors at the precise moment the Carson Nugget ownership transition was being negotiated. On January 8, 2010, Alan Adams agreed to sell his fifty-percent stake to Steve Neighbors, a deal that had closed December 31, 2009.

The Doppelgangers entity did not spring into existence in isolation. On March 22, 2010—less than two years after the gaming approval— Doppelgangers Charitable Corporation was incorporated in Nevada, with Alan H. Adams as President, Bradford C. Adams as Secretary, and Justin M. Clouser—Bradford's own attorney-in-fact under the May 6, 2008 Special Power of Attorney—as a co-officer. Mayor Bob Crowell attended the Tap Room opening at 302 N. Carson Street in January 2010. The same attorney who held sweeping durable authority over Bradford's entire estate, business affairs, and government dealings simultaneously served as a named officer of the charitable entity operating out of the Carson Nugget premises. The entity's name is not incidental. A doppelgänger is a double: an identical counterpart occupying a second identity. The relator does not assert the name is a confession. The relator asserts that the entity chosen to formally embed Bradford Charles Adams as a licensed gaming officer and charitable corporate officer—operating from the address of the Carson Nugget Casino, under the presidency of Alan H. Adams, staffed by Bradford's own attorney-in- fact—is named, precisely and on its face, for the mechanism Relator has spent this entire submission documenting. (Exhibit AU, 2008-04-06 – NGC Gaming License – Doppelgangers – AA Gaming Filing) The April through June 2008 record reflects a coordinated liquidation of Bradford C. Adams's Nevada real property and business positions, executed through a network of instruments that collectively transferred all identifiable Nevada assets, delegated total legal authority to a single Minden attorney, and

layered in new Delaware-origin entity structures—all within a 75-day window during which Bradford and Alan H. Adams simultaneously obtained conditional gaming approval for Doppelgangers through AA Gaming, Inc. from the Nevada Gaming Commission. On April 29, 2008, Bradford C. Adams conveyed 7140 San Antonio Ranch Road to Larry Goodnight, Trustee of the Sunflower Trust, for $900,000, listed as seller at 800 N. Carson Street—the Carson Nugget administrative address. On May 1, 2008, NW & BA, LLC was registered as a Nevada foreign entity domesticated from Delaware, with Bradford as Managing Member at 800 N. Carson Street, permanently revoked June 1, 2015. On May 6, 2008—six days after conveying 7140 San Antonio Ranch Road—Bradford executed a durable Special Power of Attorney from that same address, appointing Justin M. Clouser of Minden as attorney-in-fact with authority to manage all real estate, operate Bradford's entire personal and business estate, file all government documents, negotiate with any government agency, and designate Bradford's own Social Security Representative Payee. (Exhibit O, 2008-05-06 – Bradford Charles Adams—Justin M. Clouser – Special Power Of Attorney) On May 20, 2008, C & B Final Touch, LLC and C & B Quick Fix, LLC— twin Delaware-origin foreign entities with identical membership—registered in Nevada on the same day, both listing Washoe Property Development as a member company.

On May 21, 2008, Alan H. Adams, Trustee, conveyed the Kutcher Manor property—the same parcel Bradford had transferred back to Alan under "Son to Father" six months earlier—to Darren D. Bell and Brenna E. Litz for $256,000, no exemption claimed. On February 15, 2011, Bradford Adams and Ping Xiao Adams secured a new Deed of Trust for $712,500 from U.S. Bank National Association on 1012 De Haro Street, San Francisco. On February 17, 2011—Bradford and Ping Xiao Adams paid off the $320,000 mortgage on 1034 and 1036 Carolina Street, San Francisco. The California financial instruments that mark the conclusion of the Carson City phase reflect the behavior of a single individual cycling liquidity between two jurisdictions across a single continuous financial life— consolidating San Francisco real property positions at the precise moment Nevada operational activity wound down following the Nugget sale. (Exhibit AW, 2011-02-15 – Deed of Trust (2011139952) – Bradford Charles Adams —Ping Xiao Adams – $712,500) In January 2015, after years of cycling between Alan H. Adams, Bradford C. Adams, and Larry Goodnight as trustee of the Sunflower Trust, 7140 San Antonio Ranch Road ultimately landed in Rosehaven Properties LLC for $817,500. Rosehaven Properties LLC is owned by Steve Zissis. Steve Zissis is not an obscure local titleholder. He is the founder, President, and Chief Executive Officer of BBAM, one of the world's largest aircraft leasing and aviation asset-management firms, a global asset-finance platform with more than $21 billion in aviation assets under management. Zissis bought 674

Alpine View Drive, Incline Village, an 11,136-square-foot residence for $17.5 million in 2022. The endpoint of the San Antonio Ranch chain is therefore an entity tied to a billionaire-class northern Nevada wealth network and to a globally sophisticated asset-finance executive whose business is the acquisition, holding, financing, and disposition of high-value assets.

Summary of 7140 San Antonio Ranch Rd. Ownership

Sept 28, 2001: Alan H. Adams, as Trustee of The Alan H. Adams Family Trust, acquires 7140 San Antonio Ranch Road. (Grant Deed, Doc. No. 2601584, Washoe County Records) Dec 28–29, 2004: Alan H. Adams, as Trustee of The Alan H. Adams Family Trust, executes a Gift Deed conveying an undivided one-half (1/2) interest in 7140 to Bradford C. Adams, described in the instrument as "a gift to his son." The accompanying Declaration of Value (Doc. No. DV-3149789) claims a transfer tax exemption under NRS 375.090, Section 6, stating: “This is a transfer from a trust without consideration. This is also a transfer from Alan H. Adams to his son Bradford C. Adams, which is within the first degree of consanguinity.” The deed is recorded December 29, 2004. (Doc. No. 3149789, Washoe County Recorder.) May 6, 2008: Bradford C. Adams executes a Special Power of Attorney from 7140 San Antonio Ranch Road, appointing Justin M. Clouser as attorney-in-fact with broad authority over real estate, business, and tax matters—establishing 7140 as his declared Nevada residential anchor in a formal legal instrument. Apr 29–30, 2008: Bradford C. Adams, by Grant, Bargain, and Sale Deed, conveys 7140 San Antonio Ranch Road to Larry Goodnight, Trustee of The Sunflower Trust of April 1985 (executed May 3, 1985, amended February 22, 1993). The deed is executed April 29, 2008 and recorded April 30, 2008. The Real Property Transfer Tax paid is $3,690.00. (Doc. No. 3645549, Washoe County Recorder.) The Sunflower Trust's address of record on the instrument is 3784 Paradise View, Carson City, NV 89703—the same property Bradford conveyed to the Sunflower Trust the following day. Jan 15, 2015: Larry Goodnight conveys 7140 San Antonio Ranch Road to Rosehaven Properties LLC for $817,500, through Northern Nevada Title Co., as First Centennial — Reno. (Washoe County public records.) The closing date falls in the same window as the sale of the Carson Nugget to Dean DiLullo, the

transaction that closed out the Adams gaming era in Carson City. The Sunflower Trust structure did not outlast the Nugget. 7140 cleared out of the Adams-connected trust chain contemporaneously with the Nugget's transfer, and landed in a Zissis-connected entity. Taken together, these records support a coherent factual proposition: by at least 2004 and continuing through 2008, a recurring property-transfer pattern linked Bradford Charles Adams, Alan H. Adams, and Larry Goodnight through direct conveyances, trust-held interests, family-relationship tax treatment, shared mailing infrastructure, and the reappearance of the same core Nevada properties—especially 7140 San Antonio Ranch Road—across multiple legal instruments. The significance of that pattern is not any single deed in isolation, but the cumulative structure the deeds reveal when read chronologically. Alan H. Adams sponsored Bradford Charles Adams into the public record of Carson City— through shared property title, family-relationship tax treatment, and joint gaming licensure—providing the documentary infrastructure Bradford needed to operate as a legitimate member of a historic Nevada gaming family. The entities that followed—Doppelgangers, AA Gaming, NW & BA LLC, C & B Final Touch, C & B Quick Fix, ABB ATM LLC—offloaded real property, delegated legal authority, layered corporate structures across two states, and generated the paper trail of a Nevada life that Bradford Charles Adams did not actually live.

Claim III — Carson City infrastructure

III. THE ADAMS FAMILY INFRASTRUCTURE UNDERLYING THAT SCHEME,

VIA THE HOP & MAE ADAMS FOUNDATION, WAS DEEPLY

ENTRENCHED IN DEVELOPMENT AND APPROPRIATIONS DECISIONS

WITHIN CARSON CITY THROUGHOUT MAYOR ROBERT “BOB”

CROWELL'S 12-YEAR TENURE, AND REMAINS SO TODAY, INCLUDING

INVOLVEMENT IN A $250 MILLION REDEVELOPMENT PLAN AND

CONTINUED OPERATION OF THE NORTHERN NEVADA DEVELOPMENT

AUTHORITY FROM THE ADAMS HUB BUSINESS CENTER.

The foundation governing the $250 million Carson City redevelopment was not administered by independent charitable stewards. The 2015 Form 990-PF for the Hop & Mae Adams Foundation identifies four trustees: Andrew MacKenzie (Trustee Emeritus, Carson City), Steven G. Neighbors (Co-Trustee, Boise), Edward D. Ahrens (Co-Trustee, Boise), and Christopher MacKenzie (Co- Trustee, Carson City). (Exhibit AX, 2015 - Hop & Mae Adams Foundation, Form 990-PF) The foundation’s legal services were provided exclusively by Ahrens DeAngeli Law Group LLP—Ed Ahrens’s own firm—which also prepared and signed the return, billing $53,383 for the privilege. The same individuals—Neighbors, Ahrens, and Chris MacKenzie—appear together on a Nevada EB-5 attorney and professional directory, all listed at the same Carson City address: 704 W. Nye Lane, Suite 201. (Exhibit AY, Nevada EB-5 Attorneys) Former Mayor Robert L. “Bob” Crowell, who personally championed the Hop & Mae Adams Foundation-backed redevelopment projects throughout his 12-year tenure, is also listed in the same EB-5 directory. Crowell served on the Board of Directors of the Northern Nevada Development Authority (which operates from the Adams Hub) and was appointed to the

Board of Directors of the Nevada State EB-5 Regional Center in 2011—during the height of the Nugget Project negotiations. EB-5 is the federal visa program through which foreign nationals obtain U.S. residency in exchange for qualifying capital investment in domestic development projects. A $250 million downtown redevelopment plan structured around land donated by a foundation whose trustees are EB-5 professionals, administered through a redevelopment process personally steered by a mayor who is himself an EB-5 attorney, is not a coincidence of civic virtue. While it is not inherently improper for attorneys to serve as trustees of a private foundation, or for a former mayor to appear in the same professional directories, the specific configuration here is far more concerning. Steven G. Neighbors also served as Guardian of Alan H. Adams’s estate and co-manager of ABB ATM LLC alongside Bradford C. Adams and Alan H. Adams during the critical Nugget ownership transition. These same individuals maintained documented business and personal relationships with Bradford Charles Adams and Alan H. Adams during the period of synthetic identity usage, fraudulent consanguinity claims, and layered asset transfers. Mayor Bob Crowell’s unwavering public support and aggressive advancement of the Foundation- backed redevelopment plan throughout his 12-year tenure adds another layer of entanglement. A 1997 property record raises further questions about the depth of the relationship between the Neighbors and Adams families. On April 21, 1997, Miles A. Neighbors, an unmarried man, executed a Grant, Bargain and Sale

Deed conveying property at APN 8-292-21 on Empire Ranch Road in Carson City to Alan H. Adams for nominal consideration of $10.00, with tax statements directed to Adams at 800 N. Carson Street—the central address used by the Adams enterprise for decades. (Exhibit AZ, 1997-04-21 – Grant, Bargain and Sale Deed) This transfer occurred twelve years before Steve Neighbors publicly presented himself as an “outsider from Idaho” with no prior Carson City connections, who was brought in as Mae Adams’s business manager. (Exhibit C, 2011-02-25 - Steve Neighbors, the pied piper of Boise) When viewed alongside the documented use of a fabricated familial identity to secure gaming licensure, claim tax exemptions on real property transfers, and move assets through layered entities, the overall picture is one of a long-term, coordinated arrangement in which personal identity fraud, family- controlled entities, and municipal governance became deeply entangled. These relationships suggest a closed network in which private interests, public resources, and regulatory access were coordinated through overlapping personal, business, and political ties.

Submission 2 — Ping Xiao Adams

RELATOR SUMMARY 2 – PING XIAO ADAMS

Overview and Nexus to Insurance Fraud, Medical Fraud, and Perjury Ping Xiao Adams, age 63, currently residing at 1036 Carolina Street, San Francisco, California 94107, is the former wife of Bradford Charles Adams— married November 19, 1993, Carson City, Nevada—and the mother of Dr. Jennifer Pan Adams, a PGY-3 Diagnostic Radiology Resident at AdventHealth Orlando. Ping Xiao Adams is not a peripheral figure in the documented conduct of her former husband and daughter, she is a direct and independent participant in several schemes.

1. The November 17, 2024 Audio Recording—Medical Fraud Described to Ping Xiao Adams in Real Time On November 17, 2024, a seven-minute audio recording captured Jennifer Pan Adams laughing while describing a scheme to manipulate a male target into purchasing a $600 veterinary ultrasound machine by fabricating a medical premise—minimizing his cholesterol bloodwork, invoking fear of diabetes and heart disease, fabricating a promise of a microvascular disease assessment, extracting $140 for consultation, and then blocking him to “wait until he forgets.” (FBI Tip - Jennifer Pan Adams, Count 1) The recording captures Adams code-switching between English and Mandarin to address her mother, Ping Xiao Adams, as the account of the deception is delivered—with Ping present as the real-time audience for a laughter-filled first-person account of calculated medical fraud for financial gain. The audio and supporting transcript are part of public court filings available on myorangeclerk.com. Ping Xiao Adams was not an accidental recipient of this information. She was the person to whom Jennifer Adams was speaking when she described the scheme.

2. The Doll Lab Fictitious Name Filing—Ping Xiao Adams Listed as Co- Owner Under a False Sworn Certification On May 15, 2025, Jennifer Pan Adams filed an Application for Registration of Fictitious Name for the assumed name DOLL LAB—Registration No. G25000064892—with the Florida Department of State. (FBI Tip - Jennifer Pan Adams, Count 8) The Application lists Jennifer Adams at 155 South Court Avenue, Suite 2807, Orlando, Florida, and lists her mother, Ping Xiao Adams, at her current address, 1036 Carolina Street, San Francisco, California 94107. In filing this application, Jennifer Adams executed a sworn certification—under penalty of perjury pursuant to Fla. Stat. § 817.155—that DOLL LAB had been advertised in a qualifying newspaper as required by Chapter 50, Florida Statutes. Exhaustive searches of all qualifying publishers within Orange

County and the statewide public notice archive at floridapublicnotices.com

confirm that no such advertisement was ever placed. The social media accounts associated with DOLL LAB—a sex doll review platform—were not created until June 2025, weeks after the sworn certification of legal compliance. Ping Xiao Adams is named as a co-owner of an unregistered fictitious business whose registration was executed through a false sworn statement constituting a Third-Degree Felony under Fla. Stat. § 817.155.

3. The July 2024 Orlando Condominium On July 24, 2024, a Warranty Deed recorded in Orange County, Florida (Instrument No. TN5495279) reflecting a transaction value of $240,000— conveyed Unit 2807, Solaire at the Plaza Condominium, 155 South Court Avenue, Orlando, Florida 32801, to Ping Adams, an unmarried person, and Jennifer Adams, an unmarried person, as Joint Tenants with full rights of survivorship. (Exhibit A, Warranty Deed, 155 S. Court Ave., Unit 2807) The document tax of $1,680.00 on a deed recorded with zero mortgage document tax and zero intangible tax confirms this was an all-cash transaction. Ping Xiao Adams is a title co-owner of a $240,000 cash-purchased condominium in Orlando, Florida—purchased at the precise moment Bradford Charles Adams was simultaneously filing a federal adversary proceeding asserting catastrophic financial hardship to discharge $48,493 in student loan debt. The convergence of a seven-figure San Francisco real estate portfolio, a cash condominium purchase in Orlando by a co-titleholder in the same family network, and a concurrent sworn hardship narrative in federal bankruptcy court is unlikely to be coincidental.

4. Pacific Acupuncture Center and the Insurance Fraud Infrastructure at 870 Market Street Ping Xiao Adams is the owner and operator of Pacific Acupuncture Center, located at 870 Market Street, Suite 353, in San Francisco's historic Flood Building—the same address shared by multiple business entities listing Bradford Charles Adams, Ping Xiao Adams, and Jennifer Adams as owners or operators. (FBI Tip - Jennifer Pan Adams, Counts 3 and 4) Jennifer Adams used ChatGPT to generate dispute correspondence to workers' compensation insurers—including Liberty Mutual—falsely asserting that the clinic had submitted required authorization forms and demanding payment for denied acupuncture services, with the drafts structured as reusable templates covering multiple patients, strongly suggesting systemic medical billing fraud. Jennifer Adams also used ChatGPT to generate canned patient visit summaries and acupuncture treatment plans for fictitious whiplash and neck pain injuries—the most commonly feigned soft-tissue injury category in insurance fraud—to fraudulently bill workers' compensation carriers for nonexistent services at her mother's clinic. Pacific Acupuncture Center is Ping Xiao Adams's business. The fraudulent billing infrastructure was built at her address, for her clinic, by her daughter.

5. The ANA Small Claims Action—Sworn Indigency Assertion Filed Jointly with Jennifer Adams In March 2023, Ping Xiao Adams and Jennifer Adams filed a joint small claims action against All Nippon Airways (Case No. 23-SCS-00196) as co- plaintiffs, seeking $1,299.00 in damages arising from a discretionary international trip to Japan. (FBI Tip - Jennifer Pan Adams, Count 11) Jennifer Adams executed a sworn declaration of indigency to obtain a court fee waiver. Because the action was filed jointly, the multi-million-dollar real property assets of Ping Xiao Adams—including 1034–1036 Carolina Street, awarded to her in the 2019 divorce from Bradford Charles Adams, and 1012 De Haro Street, a four-unit investment property with total valuations between $4,000,000 and $6,190,000—were inherently subject to consideration in the indigency determination. The sworn assertion of financial hardship by a joint plaintiff who holds a documented real estate portfolio exceeding $7,790,000, while simultaneously co-purchasing a cash condominium in Orlando, constitutes a materially false statement made under penalty of perjury in a judicial proceeding.

6. Insurance Fraud Network: Howard Shelly Golden, Brock FIS, Inc., and the 870 Market Street–Broderick Street–Dod Fraser Insurance Network Jennifer Pan Adams traces in the public Ferris family genealogy directly from Arthur Wellington Adams, M.D. (1.1.3.1.4.4.1) to present generation. The identical genealogy documents Electa Ferris (1.1.1.4.8)— Jennifer Adams’s direct cousin within the Ferris tree—marrying John Thompson, founder and principal organizer of Chase National Bank (predecessor to JPMorgan Chase). Thompson's granddaughter Mary Astrid Thompson married George Randolph Hearst Jr., merging the Thompson banking dynasty into the Hearst media empire. (Exhibit B, John Ferris Genealogy, at 0033-0036) Howard Shelly Golden (“Golden”) is a 75-year-old San Francisco native, insurance broker, and the owner/sole operator of “Brock FIS, Inc.”—which bears the name of his wife Wende Brock Golden (“Brock”)—and one of three (3) listed associates of Jennifer Adams’s mother, Ping Xiao Adams, on the popular data aggregator Whitepages.com—who shared acupuncture clinic address (870 Market St), warranty deed/condo, and fictitious name filing (doll lab, no other activity)—operated Brock FIS Insurance from that address. Golden's 2816 Broderick property transferred to Dod Pettibone Fraser, son of Chase Manhattan Managing Director Dod Allan Fraser (Global Oil/Gas practice lead). Ferris genealogy verified Electa Ferris (Jennifer Adams's ancestor) married Chase founder John Thompson, linking her mother's insurance adjacency to Jennifer Adams's banking lineage.

In 2013, Jennifer Adams was 16 years of age and an incoming Senior at Lowell High School, a public magnet school with merit-based admissions and one of the most prestigious high schools in the country with an alumni list to match. (Lowell High School Alumni) At that time, Jennifer Adams was preparing to enter her Senior year of high school and preparing to apply for “early admission”, a non-binding early application option, to the nation’s top universities, also known as an application for Restrictive Early Action (REA). Jennifer Adams publicly solicited classmates via social media while falsely presenting a sham nonprofit as the “International Youth Foundation” and invoking emotionally manipulative narratives involving children with leukemia and charitable medical work. This activity was used to create the appearance of leadership and nonprofit involvement for inclusion in elite college admissions materials, including Restrictive Early Action. By age 18, Jennifer Adams expanded this pattern to online fundraising activity. On July 15, 2013, and August 28, 2013, Jennifer Adams made the following public posts on her Facebook account soliciting funds from her classmates at Lowell High School High School two socially bereft posts regarding spontaneous organizational ventures—a fraudulent “International Youth Foundation” trip to China that “will donate part of the participants' program free [sic] to City of Hope, a SF cancer research center, and Home of Hope, an organization that provides for patients suffering from CML (chronic myelogenous leukemia” The first of the two posts regards “The International

Youth Foundation”. These posts remain publicly available and are shown below: The domain name registration record for “internationalyouthfoundation.org”—a record of the registered owner and registration details for the domain—shows that this domain was purchased on September 5, 2013, 3:05 AM PT by Bradford Adams, Jennifer Adams’s father, under the email badboyadams@yahoo.com. Public data aggregators (corroborated across a half-dozen sources, including those derived from public filings and governmental record) confirm the e-mail address badboyadams@yahoo.com belongs to Jennifer Adams’s father, Bradford Charles Adams, age 69, of San Francisco, California. (Exhibit C, Bradford C

Adams (69) – TruePeopleSearch), (Exhibit D, Bradford C Adams (69) – Cyber BC), (Exhibit E, Bradford C Adams (69) – Men Stopping Violence) Exhibit C, Bradford C Adams (69) – TruePeopleSearch Jennifer Adams is shown self-titled as “Director” of “International Youth Foundation” dating back to April 2013 on a LinkedIn profile separate from her active, professional LinkedIn, where this falsehood remains active today alongside her medical credentials (Jennifer Adams – Director at International Youth Foundation). This is not because the credential is dated or irrelevant— Jennifer Adams’s active LinkedIn contains employment history dating back to a dubious role as a yoga instructor at Gold’s Gym while this same age.

The timing and presentation of these representations are consistent with an effort to manufacture the appearance of sustained “leadership” for use in elite college admissions, including Stanford’s Restrictive Early Action process. The domain name was not purchased until September 5, 2013, seven weeks later, underscoring that the representations preceded and continued through the later creation of supporting infrastructure. Exhibit F, LinkedIn – Jennifer Adams – Director at International Youth Foundation www.linkedin.com/in/jennifer-adams-0b038176 Exhibit G, internationalyouthfoundation.org – WHOIS By linking participation to the appearance of helping vulnerable patients, Jennifer Adams induced classmates to contribute time and money to an underlying illegitimate organization. This manipulative emotional inducement exploited the trust and goodwill of minors for deceptive purposes. In 2019, Operation Varsity Blues exposed a nationwide admissions-fraud scheme involving the submission of materially false information to elite universities in order to obtain competitive admissions advantages. Federal prosecutors

charged more than fifty individuals with conspiracy to commit mail fraud, wire fraud, and honest services fraud based on fabricated credentials, sham charitable activity, and falsified leadership representations relied upon by admissions offices. The prosecutions established that knowingly submitting a falsified background in admissions materials pursuant to a scheme to defraud—such as leadership roles in entirely illegitimate, manufactured nonprofits—constitutes criminally actionable fraud when used to influence admissions decisions. Exhibit H, Ping Xiao Adams – Whitepages Howard Shelly Golden (“Golden”) is a 75-year-old San Francisco native, insurance broker, and the owner/sole operator of “Brock FIS, Inc.”—which bears the name of his wife Wende Brock Golden (“Brock”)—and one of three (3) listed associates of Jennifer Adams’s mother, Ping Xiao Adams, on the popular data aggregator Whitepages.com. Brock FIS, Inc., has an online footprint best described as hardly existent, with a website that is defunct (404 – Does

Not Exist), and a Facebook Business Page that makes “404: Does Not Exist” appear preferable: We specialize in selling both Life and Health Insurance Products and maintain associations with seve [sic] e [sic] specialize in finding the best insurance service to meet your needs. With access to our database of over 1,500 insurers, you can be sure that we can provide for you the best coverage to meet your particular financial and health care [sic] needs. Call today for immediate service or fill out our online form and we will contact you shortly. In 22 years of “business”, Brock FIS, Inc’s., Yelp page contains two written (2) reviews (Exhibit I, Golden Howard CLU CHFC Brock Financial Ins. Service). The first, a five-star review, from twelve (12) years ago that is overtly manufactured from a Yelp user “David S.” with no profile picture, zero (0) connections, and two (2) total reviews: Jan 4, 2014

Howard is a major gem in the insurance business! He has handled my insurances for several years and got me insurance when all the carriers had turned me down. He knows the system extremely well and how to make it work for his clients. Most recently he helped me obtain insurance through the new insurance laws, saving a lot of time and problems thousands of people were having with the new exchanges. I would recommend him to anyone and everyone! The second, a one-star review from a Yelp user “Kim S.,” with one hundred and twenty-eight (128) connections, sixty-seven (67) total reviews, and a profile picture of the user: Nov 19, 2016 Howard Golden LOST HALF MY LIFE SAVINGS (just said he was 'sorry') trading aggressively in equities without my knowledge. I tried to file a complaint with FINRA (the retaliatory agency for brokers but he had withdrawn his membership). He still does not seem to be a member. Very sad for my future. Golden’s business address at 870 Market St, Ste 1288 (the historic San Francisco Flood Building) is the location of Ping Adams’ acupuncture clinic, Pacific Acupuncture Center,” and a number of other businesses listing Bradford Charles Adams, Ping Xiao Adams, and Jennifer Adams as owner(s), 870 Market St #353. A nonprofit entity known as “City of Hope aka 184 HOWARD S GOLDEN” (EIN: 94-2847838) is documented at 1500 Duarte Rd, Duarte, CA. Its federal tax-exempt status was automatically revoked by the IRS on February 15, 2025, for failure to file Form 990 for three (3) consecutive years. This is the same City of Hope Jennifer Adams referenced in her aforementioned Facebook

advertisement of a sham version of a global charitable organization, International Youth Foundation. Howard Shelly Golden’s personal email (goldenhoward@hotmail.com) appeared in public breach datasets for MyHeritage.com and Zeeroq.com along with a leaked password “swordfish”. This serves as a triple entendre: i. Golden’s education is in Marine Science (AB in Marine Science, MS in Ichthyology) ii. Golden’s choice of the password “swordfish” suggests a deliberate “nod and wink” to the 2001 film Swordfish—a cultural touchstone for sophisticated, high-level financial deception and the manipulation of national-security-grade systems. iii. Finally, the choice of “swordfish” serves as a meta-joke referencing the 1932 Marx Brothers film Horse Feathers. In the film’s famous speakeasy scene, "swordfish" is the password that everyone knows but pretends is a secret, making its use here a self-aware commentary on the illusion of security and the predictable nature of "hidden" codes in popular culture. Golden resided at 2816 Broderick St. from 1992 to 2015, when the property passed to Dod Pettibone Fraser. The significance of that transfer is not incidental. The Fraser household is, in the precise sense of the phrase, a Chase Manhattan Bank family. Dod Allan Fraser—Dod Pettibone’s father—was not merely affiliated with Chase; he was a Managing Director and Group Executive at Chase Securities, Inc., where he oversaw Chase’s entire Global Oil and Gas practice from 1995 to 2000, one of the most consequential industry verticals at one of the most powerful financial institutions in the world. He arrived at Chase after seventeen years as a General Partner at Lazard Frères & Co. (1978–1995)—

among the most elite tenures available in American investment banking— before building Chase’s global energy banking practice and later serving on the boards of Forest Oil, Smith International, OCI NV, and Subsea 7, and as Chairman of Rayonier Inc. Dod Allan Fraser and his son, Dod Pettibone Fraser, are Princeton graduates—a distinction that, within this network, carries weight beyond the credential itself. The Thompson–Fraser–Ferris genealogical line that connects to Jennifer Adams’s network runs directly through Princeton’s institutional history: Samuel Clark Thompson was among the founding shareholders and first president of the Chase National Bank in 1877, and co-founder of the First National Bank of New York in 1863 (the direct institutional predecessor to Citibank). He thus sits uniquely at the founding origin of both institutions that eventually became JPMorgan Chase—a concentration of American financial founding history in a single individual with few parallels. His son, Ferris Sherman Thompson (Princeton Class of 1888), upon his death in Paris in 1913, left $3 million to Princeton University—equivalent to roughly $100 million today—funding endowments, Bicentennial Preceptorships, and the Ferris Thompson Faculty Apartments on College Road, which remain standing on campus. Susan Marie Pettibone Fraser—Dod Pettibone’s mother—worked at the Chase Manhattan Bank at the time of her 1978 marriage to Dod Allan Fraser, making 2816 Broderick St. a home in which Chase Manhattan’s institutional gravity was not background context, but lived biography. Their son, Dod

Pettibone Fraser, carried that pedigree into the modern technology and real estate data ecosystem. After more than eight years at Opendoor—the PropTech giant that disrupted residential real estate at institutional scale—he co-founded Mainstay from within Opendoor, spinning it out in July 2024 as an independent, venture-backed company focused on market intelligence for the single-family rental industry, with Fraser as co-CEO. The property at 2816 Broderick Street thus connects Golden—insurance broker, the sole listed associate of Jennifer Adams’s mother, whose business address is shared with Bradford and Ping Adams’ commercial entities—directly to one of San Francisco’s most embedded institutional financial families, across three generations of elite capital network.

Submission 3 — Jennifer Pan Adams

1

RELATOR SUMMARY 3 – JENNIFER PAN ADAMS

1. Adams Gave a Laughter-Filled Account of Defrauding a Man Under Color of Legitimate Medical Care On November 17, 2024, an audio recording (November 17, 2024 – Audio) captures Adams laughing while describing a scheme to manipulate a male target into purchasing a $600 veterinary ultrasound machine by fabricating a medical premise. She minimized his cholesterol bloodwork as “just a number,” invoked fear of diabetes and heart disease, claimed the device would visualize visceral fat, promised a “return” microvascular disease (MVD) assessment as a “special service,”, extracted $140 for consultation, then blocked him to “wait until he forgets.”1 The recording shows Adams using her medical status to induce fear and payment, code-switching English/Mandarin to her mother (Ping Xiao Adams), and boasting about the deception with repeated hysterical laughter. The audio and supporting transcript are part of public court filings. 1 YouTube, AdventHealth Orlando Physician Caught on 7-minute, Laughter-Filled Recording Detailing Medical Fraud, https://youtu.be/Bdtw96KY_w8?si=AY5lo7i_QLu4Umyf Reddit, AdventHealth Orlando Physician Caught on 7-minute, Laughter-Filled Recording Detailing Medical Fraud, https://www.reddit.com/r/AskFlorida/comments/1tgx6wn/nothing_to_see_here_adven thealth_orlando_dr/?utm_source=share&utm_medium=web3x&utm_name=web3xcss&u tm_term=1&utm_content=share_button

2 2. Adams Fraudulently Obtained In-State Tuition at UTRGV Medical School by Manufacturing a False Texas Domicile Adams’ acquired 2176 Abadeer Trail, San Antonio (Bexar County) and simultaneously registered a San Antonio business address—both in December 2017—to manufacture Texas domicile for in-state tuition. Adams’ name is explicitly provided on the deed. During this exact period (May 2017-September 2019), Relator resided and worked in San Antonio, primarily at the USAA Headquarters. Adams never once mentioned a word of visiting San Antonio, let alone living there, in the numerous occasions Relator discussed San Antonio. In August 2019, the property sold the same month as UTRGV White Coat Ceremony, having served its purpose. Both parents executed the deed before a San Francisco County, California notary. Jennifer signed from Hidalgo County—where UTRGV is located—not from her claimed San Antonio domicile. Compounding the manufactured nature of the domicile, the August 8, 2019 sale was recorded as a Warranty Deed with Vendor’s Lien. Under Texas law, this allowed the grantors (the Adams family) to retain a lien and superior title until the buyers fully satisfied the purchase price obligations—hardly the hallmark of a family treating the property as their genuine primary residence. (Exhibit A, 2019-08-08 – Sale – 2176 Abadeer Trail Rd (SATX) – Warranty Deed with Vendor's Lien – Bexar County Records)

3 Several contemporaneous data aggregator records list an unmistakable attempted address semantic obfuscation: 2176 Abadeer Trl San Antonio, TX 78253 870 E Market St # 353 San Antonio, TX 78205 870 E Market St # 353 San Francisco, CA 94102 870 Market St #353 is the location of Ping Adams’ acupuncture clinic, Pacific Acupuncture Center,” and a number of other businesses listing Bradford Charles Adams, Ping Xiao Adams, and Adams as owner(s), 870 Market St #353, Flood Building, San Francisco, CA 94102. In total, Adams effectively defrauded the state of Texas to the tune of ~$50,000 in fraudulently obtained Texas in-state tuition across her UTRGV enrollment.

4 3. Adams used ChatGPT to draft communications intended to pressure insurers, such as Liberty Mutual, to pay supposed Worker's Compensation claims for her mother's–Ping Xiao Adams—acupuncture clinic, “Pacific Acupuncture Center” (http://www.acupuncture- sf.com/), listed in the historic Flood Building in San Francisco at 870 Market St #353. Adams used ChatGPT to generate documentation and correspondence for the express purpose of fraudulent disputes against workers’ compensation insurers (Liberty Mutual), claiming denied payment for acupuncture services provided by her mother’s clinic, Pacific Acupuncture Center at 870 Market St #353, Flood Building, San Francisco, CA. (Exhibit B, Adams’ ChatGPT – Generation of Workers Compensation Correspondence) This includes drafting generic, reusable medical summaries for multiple patients, strongly suggesting systemic medical billing fraud: Write a detailed letter of dispute to Worker's Compensation stating that they need to pay us for our acupuncture services from dates 6/28 to 7/27/23 and that their reason for rejection of our claim incorrectly states that we did not submit a request for authorization form. We submitted an RFA form signed by the patient's referring MD provider. During the Adams’ relationship to Relator, Adams routinely used a personal laptop belonging to Relator, on which her ChatGPT account remained signed in; In December 2024, Relator observed and preserved existing chat conversations visible on the device. The chats demonstrated a fairly rigid, highly patterned usage with

5 the intent to deceive and defraud. Amongst those chats is Adams using ChatGPT to draft multiple dispute letters to workers’ compensation carriers falsely asserting that an RFA authorization form had been submitted and that the insurer had “forgotten” to pay for a sequence of identical procedure codes from June 14 through July 27, 2023, to coerce additional payments.

6 4. Adams used ChatGPT to generate false whiplash and neck- injury treatment plans for patients at Pacific Acupuncture Center, located at 870 Market Street, Flood Building, San Francisco, California, as part of an insurance-fraud scheme designed to bill workers’ compensation carriers and other insurers for nonexistent or exaggerated injuries. Using ChatGPT, Adams drafted canned “patient visit” summaries and acupuncture treatment plans for fictitious whiplash and neck pain injuries to fraudulently collect insurance payments at her mother’s clinic, Pacific Acupuncture Center, for non‑existent services. (Exhibit C, Adams’ ChatGPT – Generation of Whiplash Treatment Plan for Acupuncture) It is not a coincidence that Adams specifically requested a summary for an “old whiplash injury.” Whiplash is the most feigned injury in medico-legal domains and the “holy grail” of insurance fraud because it relies almost entirely on soft-tissue reports that are difficult to disprove. By generating a narrative of “localized stiffness in the cervical spine” via AI, Adams is providing the clinic with the exact “Social Engineering Prop” needed to bill workers’ compensation carriers for chronic, high-payout treatments that have no basis in actual patient contact.

ADAMS:

Write a two-sentence summary of patient visit, including objective findings and plan of acupuncture treatment for a list of common condition. Be specific and concise.

CHATGPT:

During the patient visit, objective findings revealed signs of tension and restricted range of

7 motion in the neck and shoulders, indicative of chronic neck pain. The plan for acupuncture treatment includes targeting specific acupoints along the meridians associated with pain relief and relaxation, with a focus on reducing muscle stiffness and promoting circulation to alleviate discomfort effectively.

ADAMS:

Write a two-sentence summary of patient visit, including objective findings and plan of acupuncture treatment for neck pain from old whiplash injury. Be specific and concise.

CHATGPT:

During the patient visit, objective findings confirmed muscle tenderness, reduced range of motion, and localized stiffness in the cervical spine, consistent with symptoms of neck pain from an old whiplash injury. The plan for acupuncture treatment involves targeting key acupoints to alleviate muscle tension, promote tissue healing, and improve mobility, with a focus on addressing both acute and chronic aspects of the injury for comprehensive relief.

ADAMS:

Write a two-sentence summary of patient visit, including objective findings and plan of acupuncture treatment for a foot pain. Be specific and concise.

CHATGPT:

During the patient visit, objective findings revealed localized tenderness, swelling, and limited mobility in the foot, suggestive of plantar fasciitis. The plan for acupuncture treatment involves targeting specific acupoints in the foot and lower leg to reduce inflammation, relieve pain, and improve overall foot function, with a focus on addressing underlying musculoskeletal imbalances for long-term relief.

8 5. Adams used ChatGPT to draft a letter on AdventHealth letterhead impersonating a residency program director, promising a resident a four‑year contract in Florida, one month of free housing, and a $1,500 relocation stipend, thereby attempting to induce a move or illegitimate relocation expense reimbursement based on forged official employment representations. Write a professional letter to resident stating that they will need to move to adventhealth florida for 4 year contract. Apologize for the extreme short notice. Offer 1 month stay free of cost until they can find their own housing. and offer $1500 relocation fee. Be empathetic and professional. There were 4 spots in Chicago that went to residents with established families here. The prompt from Adams’ ChatGPT demonstrates a calculated effort to manufacture a fraudulent “official” instrument through the use of generative artificial intelligence for the purpose of professional impersonation. By using ChatGPT to draft a letter on AdventHealth letterhead, Adams intentionally simulated the authority of a Residency Program Director to create a fictitious professional crisis. This generated content was intended as a forgery designed to facilitate a “forced relocation” narrative. (Exhibit D, Adams’ ChatGPT – Generation of Fraudulent Correspondence from AdventHealth) Adams manually provided a highly specific prompt, instructing it to apologize for “extreme short notice” and to manufacture a sympathetic justification for the move. Specifically, Adams directed AI to claim that residency spots in Chicago were being prioritized for “residents with established families.” The prompt’s inclusion of a

9 $1,500 relocation fee and one month of free housing—figures that precisely mirror actual AdventHealth Graduate Medical Education (GME) reimbursement policies—proves an intent to create a document that would withstand basic verification by third parties, such as landlords or financial institutions. The fraudulent nature of this letter is underscored by the irreconcilable discrepancy between the "extreme short notice" claimed in the text and Adams's actual financial behavior in the physical world. While the forgery characterizes the transfer as a sudden, involuntary requirement, public records confirm that Adams closed on the purchase of a condominium in Orlando, Florida, in July 2024. (Exhibit E, Warranty Deed – 155 S Court Ave Unit 2807) This predicate for forgery falls squarely within the violations defined by Fla. Stat. § 458.331(1)(h) (making fraudulent representations in the practice of medicine) and Fla. Stat. § 817.06 (Deceptive Practices). Impersonating the leadership of a major healthcare institution to manufacture a false professional reality is a fundamental breach of the "good moral character" required for medical licensure in the State of Florida. It reveals a physician who views her professional identity and institutional affiliations not as a set of responsibilities, but as tools for personal and financial deception.

10 6. Adams used ChatGPT to Manufacture fictitious shipping carrier notifications to facilitate mail fraud. Adams used ChatGPT to impersonate a commercial shipping entity for the purpose of deceptive communication. Adams directed ChatGPT to “Write a message from a mail carrier company” claiming that a package was withheld due to “improper packaging” (specifically a Styrofoam box). (Exhibit F, Adams’ ChatGPT – Mail Fraud) Notably, Adams instructed the AI to include a "Hurricane Helene" weather alert to provide a veneer of institutional legitimacy and external excuse for the delay. This constitutes Carrier Forgery and Mail Fraud; by manufacturing a fictitious official notification from a third-party shipping service, Adams sought to deceive a recipient regarding the status of a shipment, likely to circumvent a contractual obligation or to facilitate a fraudulent refund claim.

11 7. Adams used ChatGPT to draft fraudulent “concierge” narratives to defraud peptide suppliers. Adams used ChatGPT to generate two draft complaint emails directed at a peptide supplier. (Exhibit G, Adams’ ChatGPT – Peptide Fraud) In the first conversation, Adams prompted ChatGPT as follows: Write an email to peptide company [sic] explaining why its very unprofessional to assume that just because a package was signed for at the pool concierge, it was delivered to the right person. Do you have evidence that the signature provided belonged to me? In the second conversation, Adams prompted ChatGPT: Write a email [sic] to peptide company explaining how I did not receive my package even though someone signed for me at the concierge. Give plausible explanations for why. These drafts were created as part of Adams’ pattern of manufacturing false non-receipt or hardship narratives to obtain unearned refunds, replacements, or other financial benefits from suppliers.

12 8. Adams filed a Fictitious Name “Doll Lab” without any registered business entity or lawful operation and executed a False Sworn Certification to the Florida Department of State (Third-Degree Felony Under Fla. Stat. § 817.155) On May 15, 2025, Adams filed an Application for Registration of Fictitious Name (“the Application”) for the Assumed Name “DOLL LAB” (Registration No. G25000064892) with the Florida Department of State. (Exhibit H, Fictitious Name Filing – DOLL LAB – Jennifer Adams – 155 S Court Ave Ste2807) Exhibit H, Fictitious Name Filing – DOLL LAB – Jennifer Adams

13 As owner, the Application lists Adams at her current address—the address of her condominium—“155 South Court Ave. Ste2807”, and her mother, Ping Xiao Adams, at her current address, 1036 Carolina Street, San Francisco, CA 94107 (Adams’ childhood home). In doing so, Adams certified under penalty of perjury pursuant to Fla. Stat. § 817.155 that the fictitious name had been advertised in a newspaper as required by Chapter 50, Florida Statutes. On July 24, 2025, Relator discovered the Fictitious Name Filing while on www.sunbiz.org. Subsequently, Relator searched both “Notices from last 35 days” and “Archived (older than 35 days up to 3 years)” on floridapublicnotices.com, the statewide website created under subsection 50.0211(3)(c) to “maintain a searchable archive of all legal notices posted on the publicly accessible website on or after October 1, 2014, for 18 months after the first day of posting . . . searchable archive shall be provided and accessible to the general public without charge.” Finding no results of any public notice for the Fictitious Name “DOLL LAB” or any variant, Relator then performed extensive searches across the websites of all qualifying publishers within Orange County, including Orlando Sentinel, The Business Observer, The Pine Hills Press, The West Orange Times & Observer, The Apopka Chief/Planter, The Orlando Times, The Heritage Florida Jewish News, The Orlando Advocate, and The Community Paper.

14 On August 27, 2025, Relator repeated said search, again finding no public notice of the Fictitious Name. Relator did, however, discover the following online accounts with content for a highly technical, anatomically-focused sex doll review business launched under the “DOLL LAB” name, with all accounts showing creation dates of June 2025—mere weeks after the May 15 Fictitious Name Filing. With the slogan, “We Test. You Enjoy.”, DOLL LAB provides sex doll reviews, testing, and buying guides. The branding employs a logo styled to resemble the Pornhub logo, the most visited pornography website in the world. • X: @DollLabOfficial; Created June 2025 • Website: www.dolllabstudio.com; Created Dec 15. 2025 • Facebook: www.facebook.com/groups/dolllab; Created Dec 12, 2025 • YouTube: @DollLab; Created June 2025 • Reddit: r/DollLab; Created Jun 13, 2025 A comprehensive search of all qualifying publishers in Orange

County and the statewide public notice archive confirms that no such

advertisement was ever placed. Records from the Florida Department of State (Sunbiz.org) confirm

15 that “DOLL LAB” is not associated with any registered corporation, limited liability company, or other legal business entity. Publicly available information establish that the social media platforms associated with this “ghost” registration were not created until June 2025, weeks after Adams’ sworn certification of legal compliance. The record establishes that Adams executed a false certification, punishable as a Third-Degree Felony under Fla. Stat. § 817.155 to bypass a minor administrative requirement for an unregistered sex-doll review platform. Adams engaged in this documented felony conduct while maintaining her status as a physician—a position of significant social and financial privilege—demonstrating a disregard for the legal consequences of a sworn declaration. This documented willingness to provide false testimony to a state agency over a matter with negligible incentive is a matter of public record, as is her true home address—155 S Court Ave #2807. § 817.155, Fla. Stat. (2024). Matters within jurisdiction of Department of State; false, fictitious, or fraudulent acts, statements, and representations prohibited; penalty; statute of limitations. A person may not, in any matter within the jurisdiction of the Department of State, knowingly and willfully falsify or conceal a material fact, make any false, fictitious, or fraudulent statement or representation, or make or use any false document, knowing the same to contain any false, fictitious, or fraudulent statement or entry. A person who violates this section is guilty of a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.

16

ADDITIONAL PATTERN EVIDENCE

9. Adams Committed Bank Fraud and Identity Impersonation to Execute a Fraudulent Chargeback and Deceive Her Employer Regarding the 2024 RSNA Conference. On November 23, 2024, Adams initiated a fraudulent bank chargeback for this same RSNA conference registration in front of Relator while pacing through his apartment at 1208 E Central Blvd #4 over the course of an approximately 30-minute phone call with a bank employee. During this phone call, Relator directly witnessed Adams repeatedly assert that she was her then-sixty-two (62) year-old mother, Ping Xiao Adams, a Chinese native unable to speak fluent English despite thirty- three (33) years in America since her November 19, 1993 marriage to Adams’ father, Bradford Charles Adams, in Carson City,

NV.

While pressuring the bank employee to issue a chargeback for the RSNA Conference cost, Adams did not alter her voice in effort to “sell” the false representation that she was her mother. Adams repeatedly falsely asserted she did not recognize the charge, did not know what “RSNA” is, that she owns an acupuncture clinic, and pretended to be baffled by the RSNA charge on her card. This chargeback incident is independently verifiable through carrier records reflecting calls from Adams to financial institutions exceeding fifteen (15) minutes in duration on or about this date,

17 together with confirmation from the relevant financial institution that a chargeback claim was initiated. After the call, Relator stated, verbatim or near verbatim, “well that was scary.” Adams questioned what Relator meant, to which Relator replied, verbatim or near verbatim, “that you can slip in and out of character so easily,” and remarked how much she seemed to enjoy manipulating the bank employee. Adams beamed with pride at these remarks and Relator’s subsequent characterization that she was “so Machiavellian,” and Adams claimed that it was necessary to be Machiavellian to get into schools like Stanford. Adams was simultaneously lying to her employer, AdventHealth Orlando, about conference attendance and coverage; since the RSNA Conference offered virtual attendance, Adams had communicated to Relator that the days she was set to “attend” would functionally serve as “days off.”

18 10. Adams publicly endorsed and facilitated a fraudulent GoFundMe narrative by lending her credibility to a campaign based on false claims of financial hardship and withdrawal of parental support. In October 2024, Adams told Relator that her freshman year roommate at Stanford, Gabriella Sabatini Schreiner, ran a fraudulent GoFundMe during college. Relator learned of this campaign solely because Adams voluntarily disclosed it during a conversation, providing Schreiner’s full name and noting that Schreiner was from Norman, Oklahoma (while Relator is from Broken Arrow, Oklahoma). Adams described the campaign as fraudulent and stated that donor complaints and reports led to police involvement. The GoFundMe page was subsequently removed from the platform. According to Adams, not all funds were recovered. On December 24, 2014, Gabriella Sabatini Schreiner launched a GoFundMe campaign titled, “Please help me stay at Stanford” seeking $25,000.2 The campaign was predicated on the claim that Schreiner’s father had "pulled all financial support" to force her to drop out, despite her alleged participation in high-level biomechanical cancer research. While the GoFundMe fundraiser was removed, shares of it on Tumblr remain publicly searchable3, as well as Facebook posts on Adams and 2 original URL: www.gofundme.com/j7ymfg) 3 @conradricanora, My name is Gabriella Schreiner and I just finished my first quarter at Stanford University..., TUMBLR (Dec. 22, 2014), https://www.tumblr.com/conradricanora/106028311319/my-name-is- gabriella-schreiner-and-i-just-finished

19 her roommates’ accounts. (Exhibit I, GoFundMe Fraud) Post by @conradricanora My name is Gabriella Schreiner and I just finished my first quarter at Stanford University, where I hope to continue studying pre-med with a degree in Biomechanical Engineering. My father has always told me I wasn’t special, I would never be able to compete at a big university, and if I try I’ll never get a good job. This is why three days ago he decided to pull all financial support for me unless I drop out. Not only have I worked extremely hard to get accepted to the college of my dreams, but I wish to continue my education there because I believe at Stanford I will be able to maximize my potential and, therefore, what I am able to contribute to society. I have already been accepted to work in a lab at Stanford next quarter where I would be able to help a team of bioengineers create a protein that targets cancer cells, which is exactly the type of work I’m interested in doing for the rest of my life, and not to mention the opportunity of a lifetime. I believe it is my right as a hardworking young woman to achieve the best education available to me without my own father trying to tear me down. The odds were already against me when I applied considering that the year I applied Stanford had the lowest acceptance rate of any university in history: 5.07%, but I never expected it to be harder to obtain approval from my father than the admissions officers. Please support me in my endeavor to prove not only to my father, but to myself that I can succeed at Stanford. Any donations are appreciated, though if you are unable to donate, I would also be eternally grateful if you would kindly share this link with any friends or family. or, if you cant, reblog! This behavior was documented as early as December 2014, during Adams’ enrollment at Stanford University.

20 Adams publicly endorsed the fundraiser via Facebook, actively soliciting donations from her personal and professional network. In her post, Adams stated: Please help out my best friend!!!... I promise you she's worth it. She deserves every moment of her education at Stanford. In the campaign description, Schreiner claimed that three days earlier her father had withdrawn all financial support unless she dropped out of Stanford. She stated she was pursuing pre-med studies with a degree in Biomechanical Engineering. She further claimed she had been accepted to work in a Stanford lab the following quarter on a team developing a protein that targets cancer cells. The post referenced Stanford’s acceptance rate for the Class of 2018 as 5.07% and framed the situation as an effort to prove to her father and herself that she could succeed at Stanford despite his opposition. A contemporaneous screenshot of the campaign shows a photograph of Schreiner wearing a Stanford shirt, with $885.00 raised by 19 donors in just 5 hours. The campaign text encouraged both donations and sharing/reblogging the link. The full text was reblogged on Tumblr on with hashtags including #reblog please, #donate, #gofundme, and #signal boost. When recounting the incident, Adams laughed in the same manner as she did throughout the November 17th audio recording

21 (referenced as Count 1), in which she details a medical fraud scheme. Relator expressed strong distaste for the conduct, stating that he detests taking from others what is not rightfully theirs, and found Adams’ laughing reaction inappropriate given the seriousness of soliciting donations under what she claimed was a false narrative. Adams did not disclose her own public endorsement or role in helping promote the campaign. Gabriella Sabatini Schreiner’s father is Dr. Darrel Eugene Schreiner, a psychiatrist with over 35 years of experience practicing in the Lexington/Norman/Chickasha, Oklahoma area. On April 16, 2015, Stanford Chi Omega posted a photo of Gabriella Sabatini Schreiner, identifying her as a member and listing her activities including Kayumanggi (Filipino Dance) and IM Dodgeball. Gabriella Sabatini Schreiner completed her Bachelor’s degree in Biomechanical Engineering at Stanford University (2014–2018). She subsequently earned her MD from Tufts University School of Medicine (Class of 2025) and has matched into an Orthopaedic Surgery residency program. The core narrative of the campaign—a sudden, complete withdrawal of all financial support by her father, a practicing psychiatrist, as an ultimatum to force her to drop out over her pursuit of Biomechanical Engineering (a practical, high-achieving STEM field that directly led to medical school and Orthopaedic residency)—is

22 inconsistent with Schreiner’s uninterrupted completion of the Stanford degree, her active participation in Stanford Chi Omega, and her successful progression into medicine. This sequence renders the claimed family crisis implausible on its face. By providing a personal guarantee ("I promise you"), Adams lent her own credibility to a narrative that she knew to be fraudulent. The 2014 GoFundMe incident is not an isolated event but a foundational example of Adams’ modus operandi. The narrative structure of that fraud—manufacturing an artificial "financial crisis" involving a father’s withdrawal of support to elicit unearned relief—parallels the 2024 Bankruptcy Fraud currently being executed by Bradford Charles Adams. In both instances, the Adams family and their immediate circle utilize “hardship” as a strategic instrument for financial subversion.

23 11. Adams Perjured Herself in a Small Claims Action Against All Nippon Airways (Indigency Waiver) – March 16, 2023 On March 16, 2023, Adams and her mother, Ping Xiao Adams, initiated a small claims action against All Nippon Airways (Case No. 23- SCS-00196) as co-plaintiffs. Adams alleged the airline “did not allow [them] to board” a San Francisco-Japan flight “despite the fact” they provided “proof of the vaccination series,” seeking $1,299.00 in rebooking costs, Uber fares, and PCR testing fees they claimed the airline “caused.” The court ruled against Adams, finding that ANA correctly denied boarding based on their failure to satisfy Japan’s published entry requirements. In the matter, Adams executed a sworn declaration of indigency to obtain a court fee waiver (Cal. Rules of Court, rules 3.55, 8.818). Because the action was brought by Adams and her mother, Ping Xiao Adams, as co-plaintiffs, the multimillion-dollar assets of Ping Xiao Adams were inherently subject to consideration in the court’s indigency determination. The assertion of financial hardship—made under penalty of perjury—is rendered further absurd by the context of the litigation: a claim for damages arising from a discretionary international trip. The notion that Adams lacked the marginal liquidity to cover basic court filing fees is fundamentally incompatible with the substantial financial resources required to fund a multi-thousand-dollar excursion from San

24 Francisco to Japan. Public records and recorded deeds reveal that, within less than a quarter mile of her childhood home / Ping Xiao Adams’ current residence alone, the family continues to hold a cluster of high-value, income-generating assets: i. 1012 De Haro St: A four-unit investment property with individual unit valuations between $977,200 and $2,234,200, totaling approximately $4,000,000 to $6,190,000+. ii. 1034 & 1036 Carolina St: Assets with a combined value of approximately $1,600,000, specifically awarded to Ping Xiao Adams in her 2019 divorce from Bradford Charles Adams. Notably, 1034 Carolina St Carolina St has operated as a rental property with a documented history of eviction proceedings dating back to the 1990s. Combined with the Carolina Street properties, the family’s documented Potrero Hill real estate portfolio exceeds $7,790,000. Adams’ sworn assertion of poverty for the purpose of avoiding court costs is irreconcilable with the family’s ongoing ownership and management of a multi-million dollar property portfolio and their capacity for international travel.

25 12. Adams Used ChatGPT to Solicit Venture Capital Vernacular for the Purpose of Manufacturing a False Perception of Industry Expertise. Adams used ChatGPT to menu of venture capital industry terminology, specifically requesting “advanced buzzwords and vernacular” such as “Pari Passu,” “Growth Hacking,” and “Cohort Analysis”. (Exhibit L, Adams’ ChatGPT – Venture Capital Phonyism) 13. Adams Used ChatGPT to Solicit a List of Technical Property Defects to Fabricate Leverage for a Condo Price Reduction. Adams used ChatGPT to gather specific technical justifications to demand a price reduction on a condo at the Solaire in Orlando, Florida, explicitly requesting a “list of reasons for seller to lower their price” with “detailed and explicit examples.” (Exhibit M, Adams’ ChatGPT – Condo) This behavior exemplifies her documented pattern of strategic information harvesting, where she inventories potential problems—such as foundation issues, leaky pipes, or outdated wiring—regardless of whether they are actually present. By soliciting these hypothetical grievances, Adams was seeking deceptive pretext for financial negotiation. This calculated use of AI to manufacture a “legitimate” complaint list reveals a strategic mindset aimed at future manipulation.