Okay. Let's go on the record. This is the time scheduled for hearing in the matter of Anthony Frank Sandy and Sandy Ecom Incorporated. Mister Horn. With respondents? Good morning, commissioner. My name is Anthony Santee. Okay. And actually, I'm I'm the administrative law judge. I'm one of the commissioners. Oh, Edwin. Okay. Fine. Thank you. I'm not aware of any procedural matters that are, pending, but, I guess I'll check with counsel. Mister Horn, is there anything we need to address to start? Yes, your honor. Just briefly. The we swapped out in the the hard copy book that you received,
two exhibits, s three and s six. Six. We just in the hard copy versions, we just redacted some undercover information, that that was mistakenly, my fault, not fully redacted. So the electronic copies of s three and s six you received are not the redacted versions, but the hard copy that you were given that's, beside you includes is the fully redacted version of s three and s six. Okay. And has copy of that been provided to mister Sandy? Yes, sir. Okay. Any other procedural issues, mister Horn? Here. Mister Sandy, any procedural issues from you?
Okay. Mr. Sandy, can I interpret that to mean you're renewing your request to continue the hearing? Yes. Okay. Mr. Horn, do you have a response? Yes, Your Honor. Just that Mr. Sandy has had, approximately five months to prepare since his previous counsel withdrew. So, the division submits that that was sufficient time to get up to speed on the exhibits, the rules, and, basically prepare whatever case or defense he wanted to present today. Okay. Thank you. I've, as I ruled previously on the written motion to continue, this hearing was originally scheduled in September.
It was granted a one hundred and twenty day continuance at the stipulated request of the parties. That one hundred and twenty days was to, in part, allow mister Sandy your opportunity to acquire new counsel. I will note that when your previous counsel withdrew in their request to withdraw, I'm going to I'm going to pull up that document now. The motion to withdraw is counsel with consent that was filed by your previous counsel
on 08/05/2025 contained a consent to withdrawal counsel wherein you you wrote or at least signed consent to I'm aware there's a hearing set for September '16, although I've agreed per the division's request to move the hearing. I understand that that if the commission does not agree to move the hearing, I will need to be prepared to present my case in September. I'm confident in my ability to do so without counsel. And since that time, the one hundred and twenty day continuance was granted and was,
in fact, an extra two weeks beyond that, to allow Mr. Sandeep to obtain counsel. So I am, again, denying your motion to continue the hearing, and we're going to proceed today. And, I acknowledge your statement. You are free to participate in whatever manner you choose for the process of the hearing. Okay? Any other procedural issues, mister Sandy? Okay. Thank you. Alright. Mister Horn, I've I've received, I guess, now an updated collection of exhibits s one through s 17. These are the entirety of the exhibits you'll be using for this hearing?
Yes, sir. And, they have now been redacted of, personally identifying information? Yes, sir. Okay. Mister Sandy, I have not received any exhibits from you. You will not be presenting exhibits during the course of the hearing? Correct. Thank you. Mr. Horn, have there been any stipulations made between you and Mr. Sandy regarding any of the exhibits? No. Okay. Alright. I guess the only other bit of procedural procedural note I wish to make is that, subsequent days after today, to the extent that we'll be using them, will begin at 9AM. My goal is to conclude by 04:30PM every day,
depending, of course, on how our witnesses need to be scheduled. And with that, I will allow the party an opportunity to present opening statements. Mister Horn, does the division wish to make an opening statement? Yes, sir. Just very briefly. Just for, your own I may need you a little closer to the the microphone. I think I was getting, a little bit of a notice. I don't know if it'll be easier for you at the, at the podium if you wanna do it standing. Okay. Is this any better, Gunnar? I think you're coming up better. If there's an issue, I'll get a notification. I'll pass that along. Thank you. Just for your own notification, Your Honor,
this is an e commerce case. So this involves, Mr. Sandy and Sandyecom, the company that he owns, and he's the Founder and Sole Director of, basically selling the service of allowing investors to own, but basically own an e commerce store that is otherwise completely run and managed by sanddeeecom and its personnel and employees. So there are basically three things at issue from the from Mr. Sandy's answer that is in dispute: whether Mr. Sandy is a control person for sandyecomm.
You're going to hear testimony, including from words from Mr. Sandy himself, that he's the Founder, Owner and Sole Director of Sandy e comm. The other dispute is whether they're the agreements at issue here are securities. You'll see some of the agreements yourself and hear Mr. Sandy's own words that show that all four prongs of the Howey Test are met regarding the substance of these agreements and what they involve and Sandy Ecom's obligations and promises on behalf of our two investors. And then the third thing in dispute is whether Mr. Sandy and Sandy Ecom omitted material information from potential investors,
namely that they failed that Cindy e com failed to fulfill contracted obligations with previous investors to open stores, e commerce stores on different Internet platforms and that some of these e commerce stores that they were able to open were unprofitable for those clients. And again, we'll present testimony that will show that mentions of these two things that's in ecom at some point in the past failed to open stores on behalf of various on Internet platforms, on behalf of various clients and that the e commerce stores that they weren't able
to open were unprofitable were not mentioned to at least one potential investor. So I believe reading Mr. Sandy's answer that these are the three things that are basically the only substantive issues in dispute and the division submits that it will present evidence showing that all three three that the division has evidence to prove all three, to the your satisfaction, Your Honor. Thank you. Okay. Thank you. Mr. Sandy, do you wish to make an opening statement? I I don't. I I still don't feel equipped to respond without legal counsel. Okay. Thank you. Mister Horne, is the division ready to call his first witness?
Yes, Your Honor. Division calls Jody Balchick. Ms. Balchick, if you could please step over to the end of the bench, and we will have you sworn in. Am I free to proceed, sir? When you're ready. Thank you. Miss Sancia, can you state your full name and your title, please? I can't hear you. How do I turn turn this on? It shows a green light. Is it on? To you then. Okay. Let me move a little closer. Would you like me to restate? Yes. I am Jody Valsic. I'm a, investigator in the securities division. I'm I'm sorry. I mispronounced your last name. Sorry. That's okay. Threw me off for a second as well. How long have you worked as an investigator in the securities division?
I started in February '24, so coming up on two years. Can you briefly describe your background prior to starting with the securities division as investigator? Sure. Prior to being an investigator, I was a sworn police officer with the Mesa Police Department for approximately twenty years. Fifteen of those years, I was an investigator or a detective investigating crimes of persons and property. The last ten years, I was a financial crimes detective specializing in identity theft, fraudulent schemes, theft, all types of fraud. Can you briefly describe,
some of the training that you've received over the course of your career? Sure. Lots and lots of training into investigations, deception, how to research backgrounds. There's so much. Is that kind of where you wanted me to go? Specifically, and I should have specified it. Specifically regarding, any sort of financial, investigations. Oh, yes. I've had in my prior, I had lots of financial training, and I've also had it as an investigator here through the training that we're offered as an investigator for specific securities training. Can you briefly describe some of that security specific training that you've Sure.
We learn about the securities, how to determine if something is a security through the Howey Test. We learn about how to if it applies for an investment and how to work undercover, and, basically, how to build a securities case. And what are the current duties, what what are your current duties as an investigator in the securities division? So I get assigned a case, and I work it from the beginning. I review the complaints. I interview investors and anybody else involved. I review all of the evidence collected, and I collect any data or evidence that is needed for the case.
Sometimes I work undercover. That's pretty much it. Can you briefly describe, an overview of the duties you performed in this case? So I apologize. My voice is going in and out. If you need me to speak up, I will try. I initially got the case in November 2024, and I reviewed the complaint. I started by getting interviews scheduled and speaking to Washington Securities where the complaint came from. I started with background investigations, and then I eventually did an undercover on it as well. Now you you said that at least this came to your attention as an investigation
from Washington. Can you describe what you mean by that? Sure. So they have securities agencies in each state just like Arizona. So Washington Securities initially received the complaint. And because it was in Arizona that it was happening, they transferred it to Arizona. And just to clarify, was that Washington State? Washington State. Yes. And, can you briefly describe how you started this investigation? So I started by talking to the Washington, attorney that sent the case, and then I started scheduling interviews with the investors that were involved. And how did you determine who who was involved?
They were listed in the complaint. There was three investors listed in the complaint. Now are you familiar with a company called, Sandy Ecom Incorporated? Yes. And are you familiar with the individual respondent in this case, mister Sandy? Yes. How did you become familiar with Sandy Ecom Incorporated? From the case, I had the name and the name of the business, and then I started doing background research on it. Can you describe I'm sorry. Go ahead. Sorry. No. I'm sorry. I started doing a background investigation on Sandy Ecom and Anthony Sandy, to determine who the business was, who the person was. When you were doing your your initial research,
did you find out whether Cindy Ecom has a website? Yes. And did it have a website? Yes. Is mister Sandy, are any videos of him featured on this website? Yes. And in any of those videos, does he identify himself as Anthony Santee? He does. And does he identify his role within Santee Ecom? Yes. Do you remember how what are some of the words or some of the titles he used to to identify his role within Sande Ecom? The founder and owner of Sande Ecom. Do you know when, Sande Ecom was incorporated and where? Yes. In May 2022 in Wyoming.
And at some point, were were you aware whether Cindy Ecom moved its operations to Arizona? Yes. Do you know roughly approximately when? So when I initially started this investigation in November '24, all of the records that I found, although they were the Wyoming corporation, they all had a surprise address at that time. And as I started interviewing investors, they told me that during their investment in 2023, they were all aware that Sandeepom was in Surprise, Arizona. And you said, November 24. Is that 2024? 2024. My bad.
And as part of your investigation, did you determine where what city and state Mr. Sandy resided when you began your investigation? Yes. And what's what city and state were that? He lives in Surprise, Arizona. Do you know approximately how long he's been living there? Approximately April 2020. Does the Arizona Corporation Commission keep a registry of all the individuals and entities that are registered sellers and brokers of securities to your knowledge? Yes. And, let me take a step back. As part of your investigation duties, do you regularly check with the Arizona Corporation Commission,
specifically the corporation division, to see whether an individual or entity is registered with the commission? Yes. And why do you generally perform that check or that search? We're verifying if they're registered or not registered. We call it registered, nonregistered. And how do you perform that check? It's through an extensive search of the registration records that myself and another investigator, complete on their on our own, and then we at the end, we collect all of the data together so that it's verified on two different levels. And did you research,
in this case, whether Sandy Ecom registered in securities with the commission between 12/09/2022 and 06/23/2025? Yes. And what did you find? He's not registered. Sandy Ecom is not registered. Are you familiar with the contents of exhibit s 16 for identification? Yes. I am. And, just so it's clear, can you describe what you just did in terms of the the paperwork? What I did for to to get this? No. No. What what you just did to retrieve the the exhibit in front of you. Right? Oh, that I took it out of the folder? Okay. There's a folder in front of you?
Oh, I'm sorry. Yes. There's a folder in front of me containing the exhibits, and I removed s 16 so I could view it. Okay. And and what is s six at no. I'm sorry. What is exhibit s 16 for identification? It is the certification that Sandy Ecom is not registered, signed by Mark Donell, who's the director of the securities division. Did you obtain that that document? I did obtain it. I provided the nonregistration to Mark Danelle with all of the records from each investigator since there was two of us that verified it. I provide him all that information with certificate,
and then he reviews all the information and signs it. And does that exhibit s 16 for identification contain the seal of the Arizona Corporation Commission or a copy of the seal? Yes. And does Exhibit S-sixteen for identification bear the signature of Mark Dinell, the Director of the Securities Division? Yes. Now if you could set that aside briefly. Did you also research whether Anthony Sandy is a registered seller or dealer with the Arizona Corporation Commission between 12/09/2022, and 06/23/2025?
Yes. And what did you find based on that search? Anthony Sande is not registered. And just to be super specific, he's not a registered seller or dealer? He's not. Are you familiar with the contents of exhibit S-seventeen for identification? I'm gonna remove it from the folder. S-seventeen. Yes, I am. And what is that document? Exhibit s 17 for identification. It's also a certification of nonregistration for Anthony Sandy, Anthony Frank Sandy. Did you obtain that document or the copy of the document? Yes. I did. And how can you describe how you obtained that? Same way, two investigators did their own independent research of all the registration records to come to
a conclusion. All of those records are submitted to the securities director, Mark Dennell, for review. And he is also provided with the certification, which then he reviews, signs, and provides back to me. Okay. And does exhibit s 17 for identification also contain the seal of the or copy of the seal of the Arizona Corporation Commission? Yes. And does Exhibit S-seventeen for identification also bear the signature of Mark Donell, the Director of the Securities Division? Yes. Your Honor, at this time, the division would move to have Exhibits S-sixteen and S-seventeen for identification moved into evidence.
Mr. Sandy, do you have any objection to the admission of exhibits S-sixteen and S-seventeen? Respectfully will not answer just because I don't have I'm not equipped to without legal representation. K. Thank you. Exhibits s 16 and s 17 are admitted at this time. Thank you, Connor. Now, you testified before that, this case originated based off of some complaints that, were originally sent to Washington State in their, their version, their counterpart of the security division. Yes. Do you know how many complaints, were filed originally with them? We have received one complaint, but it had three investors.
So I'm guessing they received three complaints. Okay. And just based off of the general nature of the contents of the nature of the contents of the whatever you received from Washington State, did the individuals, the three investors involved, do they all claim to have invested with Sanddee e comm? Yes. Okay. And this this one isn't in the file, but are you familiar with the exhibit s one for identification? Oh, it's not in the file. Oh, yes. I reviewed that. Specifically, and and just to take a step back, did you or another investigator in the office, record a video,
featuring the CNA ecom website? Yes. And do you know roughly when that video was recorded? It was 11/13/2024. And did you yourself record the video, or did someone else do that? Another investigator. And, did you review the video? Yes. And was that video, that the other investigator took, was that a fair and accurate depiction of the CNA ecom website at least as of November 2024? Yes. And I believe, is was it specifically taken, the captured on 11/13/2024? November 13.
Okay. And have you reviewed have you actually seen how long is exhibit s one for identification, the video itself? I don't recall how long it is. Is it about a minute or two? It was a couple minutes for sure. So you've actually reviewed the entire video? Yes. Your honor, at this time, the division would move to have exhibit s one for identification moved into evidence. Mister Sani, any objection to exhibit s one being admitted? Respectfully, I will not respond without legal representation. K. Thank you. Exhibit s one is admitted. And your honor, with permission, the division would move to, publish exhibit s one.
Mister Sandy, any objection to the division publishing of this one? Respectfully, I don't feel equipped to respond with that legal representation. Okay. Thank you. You may proceed. Do you need some, type of assistance technically, or are you prepared to to go ahead and apply it? I think we're we're ready, runner. Okay. K. Just have a moment. Sure. I don't like what's That's fine. That's sufficient. Thank you. So based off of let me just ask you, did that appear to be the website that you saw back in 11/13/2024?
Yes. Yes. And, I know it was a quick scroll through it, but were you able to determine either by viewing the website itself or doing during the course of your investigation what product or service that SyndeCom was advertising, if there was one or more than one? Yes. And what were they what was in e com advertising or marketing? For e commerce stores, a passive investment in e commerce stores. I'm sorry. A passive investment? A passive investment? Let let's break that down a little bit. Can you describe what an ecommerce store is? So to my knowledge, and I've learned a lot during this case,
I just thought it was online shopping, online stores. And is that what you learned during the case, or is it It's a it's a little more intense than that. There's a lot of that goes into it. It's not just an online store like I thought. And what goes into it at least that that you found during investigation? It has to be ran and managed, and there has to be inventory. And there's a lot more steps than just me going online and buying something. And you also use the term passive investment. What did you mean by that? So it's a investment that's made that you don't have to you make the investment,
you put up the investment, but it's done for you. And so you receive money on it, but it's passive. You're not the one actually handling it. And when you say it's done for you, what what do you mean by it? Whatever the investment is. So whatever you're investing in, if it's a passive investment, you're earning money on whatever your investment is made in, but it's not something that you're actually doing. During the course of your investigation, did you obtain additional marketing materials from sandeecom? Yes. Are you familiar with the term done for you as it pertains to e commerce stores?
Yes. What does that mean, that term done for you? So kind of like how I was just describing the passive investment, it's basically done for you, that it's not something that you have to do, that it's taken care of for you. So does that mean that an investor could, purchase a store and then they would have no further involvement basically in how that store was run or operated? Yes. And who would in this specific scenario of what sandiaecom was marketing, who would be running that store, the day to day operations of that that e commerce store?
Sandiaecom. You familiar with the term automation as a in the ecommerce context? Yes. What does that mean? The the the store is ran, like, automatically. It's automated how they do drop shipping and, how they run the store for you, that it's automatic on their end of what they they have their own, advertisements, and they take care of it. So it's automatic on their part or automated on their part. It's not something that the investor is doing. And in this context, would they or their be Cinecom? Yes. Are you familiar with the exhibit s two for identification?
Another video. It's a video. Yes. And can you briefly describe what that is? I think that was the question and answer video of Sandy Ecom's question and answers. Is it the absentee owner opportunity business opportunity video? Sorry. Yes, I'm getting my videos confused. Yes, the absentee owner. I reviewed that one. Is that something that, you yourself obtained during the course of the investigation? Yes. Can you, briefly describe how you obtained it? On it all his videos were available on YouTube. And have you viewed, exhibit s two for identification? Yes. Is it a video of about two to three minutes long?
Yes. And is it a fair and accurate is Exhibit S2 for identification a fair and accurate depiction of the video that you first viewed on YouTube? Yes. And let me just take one step back from that. You said that there are several videos available on YouTube. How do you know that they were associated with or or or basically put there by Sandy Ecom? They either had the name Sandy Ecom in them or Anthony Sandy, and he was the one presenting them, and I recognized him on the videos. Do you know if at the time that you were,
viewing these videos, whether they were on a channel that identified itself as a Sandy Ecom or Anthony Sandy channel? I'm not sure about a channel because I found them on YouTube, but I did I was on his Instagram page as well. So if you consider that like a channel, they were available on there as well. Okay. Your honor, at this time, the division would move to have exhibit s two for identification be moved into evidence. Any objection, mister Sandy, to exhibit s two admitted into evidence? Respectfully, I don't feel equipped to respond with that legal representation. Okay. Exhibit S2 is admitted at this time. Your Honor, any permission to publish Exhibit S2?
Mr. Sandy, any objection to publishing Exhibit S2? Respectfully, I don't feel equipped to respond without legal representation. Okay. Proceed, Mr. Horne. I just tried to find my system. You wanna I apologize, John. Could we have a brief recess while we work out this technical issue? Okay. We'll go off the record. Okay. A CD. Place. There are two primary reasons why we started Sandy Ecom. One, we are capped on growth potential on our own. Each platform can only have one person and one address associated per store. By finding the right partners to work with us at Sandy Ecom,
we will be able to not only scale up Okay. Let's go back on the record. Mr. Horn, are we ready to proceed with publication? Yes, sir. Sorry. I believe we will be momentarily. And exhibit S2 is on a CD, and there will be other exhibits that we'll be moving into evidence that are also videos that are on CD as well. And including Guess One. We offer done for you e commerce business opportunities here at SandyEcom. These opportunities are completely done for you and come with proven expert talent and advanced 7 figure operating strategies. The SandyEcom initiative was started to scale wide with partners who want to grow long
term with us in the e commerce industry. There are many providers in the industry that advertise high profit potential without providing any shred of evidence for their claims. Our results speak louder than words, and our team's mission is to become an industry disruptor with our unique approach, which focuses primarily on organic traffic and drop shipping. To better understand Sandy eCom, you must first understand why done for you businesses exist in the first place. There are two primary reasons why we started Sandy eCom. One, we are capped on growth potential on our own.
Each platform can only have one person and one address associated per store. By finding the right partners to work with us at Sandy Ecom, we will be able to not only scale up but scale sideways with new stores and new partners. This creates an opportunity for both you and Sande Ecom to generate significant cash flow. Two, e commerce is what we do. The Sandy ecomm team has eight plus years in the ecommerce industry, and we are planning on sticking around for a long time. Ecommerce is an ever changing industry, and we are consistently learning and adapting.
Whether we are still primarily running on Etsy, Walmart, and Facebook five years from now or if we're on new platforms, we will always make sure our clients are on the top platforms for organic traffic and drop shipping. Now if you're interested, submit an application on this page and a member from our team will reach out to schedule an ecommerce strategy session with one of our experts. On this strategy session, we will share live stores with you, review some sales estimates and answer any and all questions you may have. Here's what we'll need from you to get started.
You must have at least one of the following: 65 ks in gross annual income or more, 100 in net worth, and or a six eighty plus credit score. So what are you waiting for? Schedule a free ecommerce strategy session with our team today and let's grow together long term in the ecommerce industry. Yes. Okay. I I didn't know if the, video had to cut back to the actual hearing room. Okay. There we go. Okay. Now, Now Ms. Falczyk, are you aware are you familiar with an exhibit numbered or titled Exhibit S4 for identification? Yes. And is that a video titled Q and A or Question and Answer?
Yes. And how did you obtain exhibit s four for identification? It was sent to me by Sandy Ecom. And can you describe how it was sent to you? During my undercover capacity, it was sent to me after a consultation with Anthony Sandy. Okay. So, let's let's explore that a little bit more. When you said undercover capacity, can you describe what you mean by that? So investigators pose as investors to, identify non registered people or businesses who are offering securities. And is there, I guess, why does the division and specifically investigators in the division such yourself do do things
like that, undercover capacity? To identify the people that are operating or offering under and they're not registered. And can you briefly describe what that involves? Sure. The the undercover capacity? Sure. So, we contact them in whatever way we are able to contact them. In this case, it was through his website. I scheduled a call. So we pose as an investor and, speak to them, work through all the details of what they're offering. And do you use your own name or some other name? An undercover name. And then once you make that initial contact,
how do you proceed in an undercover capacity from there? Each one is different. It depends on where it's leading. So everyone is different. It's not, like, a specific for that one that specific one because everyone is different. So Can you describe how it proceeded in this case? Sure. So, I contacted him through the website. When I say him, I'm referring to Anthony Sandy. I did a a schedule on his initial video where it said schedule a consultation. So I scheduled the consultation, and it was scheduled on 11/26/2024. And,
they call you, and it was Anthony Sandy that called me for my consultation. And, did you receive any anything leading up to the call itself? Anything, like, over email, any documents? Yes. Can you briefly describe what you received? I received a confirmation of the an email confirmation for the call scheduled. And then you mentioned at some point you received this video, that was titled q and a or question and answer? Yes. Do you know was that before or after the initial, consultation that you had? After. And, generally, can you provide an overview of what was in this q and a video,
exhibit s four for identification? He Anthony Sandia is basically, describing questions and answers that people have regarding an investment into the ecommerce world that they manage. And do you know, was this video exhibit s four for identification, was this sent to you via email, or did you have to obtain somewhere it's somewhere else online? That one was sent to me through email. And, is it about a thirty minute long video exhibit s four for identification? Sorry. I don't recall how long it is, but it was longer. Yes. Have you reviewed the contents of exhibit s four for identification?
Yes. And when I say review, have you have you watched the video? Yes. And is it a fair and accurate depiction of the video that you were sent from Sandy Ecom, of the question and answer q and a session? Yes. Your honor, at this time, the the division would move to have exhibit s four for identification moved into evidence. Mister Sande, any objection to exhibit s four? Respectfully, I don't feel equipped to respond without legal representation. Exhibit s four is admitted at this time. And your Honor, permission to publish at least, the first probably ten minutes or so of Exhibit S4. Mr. Sandy, any objection to the publication of approximately ten minutes of S4?
Respectfully, I don't feel equipped to respond without legal representation. Okay. Thank you. Mister Horn, you may proceed with publication. Thank you. And, your honor, I apologize. It looks like we're having technical issues again. I don't know if you if you would prefer to take another recess, a brief recess, five minutes or so. We will I guess we can wait and see if, if Mike, has a recommendation as to how long it might be. Video. My name is Anthony Sandy, and I'm the founder and owner of Sandy ecom. It's a pleasure to meet you, and I look forward to speaking to you soon on the call that you guys
just scheduled. And I also look forward to learning more about you and how we can help you generate more residual income. Now, let's jump into this into this video I have for you guys where I'm gonna answer a lot of the questions that you probably have right now. So number one, who is Sandy Ecom? Now, here's a little bit of a background that you may wanna know about why we started Sandy Ecom and why we focus so heavily on creating residual income for our partners. Now I've been in the ecommerce industry for over the last eight years.
And I started out with Shopify using Facebook and Instagram ads, Google ads to acquire customers to get customers to buy my products. And I've done millions of dollars online with Shopify and I've spent over 8 figures on Facebook Ads for myself as well as clients alone. Right? And over time, it just became a bit more difficult to acquire a customer profitably using this model. Right? If you think about it, you sell something for $50 and it costs $20 $25 to fulfill including fees. Fulfill means to send the product to the customer.
So you have about a $20 gross profit margin left over, and you have to acquire a customer for less than that $20 just to be profitable. And that remainder would be your profit. Right? If you acquired a customer for $10 now you have to send off the profit. A lot of cases, I spent more than that $20 in gross profit margin and became negative. Right? Many, many times that's on the video. I realized there there had to be a better way. You know, ecommerce has always been my bread and butter. It's what I've always done. And, you know, I wanted to stay in the industry, so I adapted. And what I've learned through my experiences,
as well as my old competitor, now partner, who had a Shopify automation company that was very, very successful, we came to the same realizations that we needed to focus on marketplaces that already have hundreds of millions of monthly active buyers. We don't have to go searching for these buyers. They're already on the platforms like Etsy, Facebook Marketplace, Amazon, TikTok Shop, and many more. And they're already buying, doing their thing, purchasing products that they're looking for. We just need to we don't have to find them. They're already there. We have to make sure that our products that we're trying to sell show up when they search for it. And I'll go over exactly how we do that.
And we focus, you know, specifically on kind of a drop shipping model but with some very key differences that I'll also explain later on in this video. Overall, our model wraps all of the best eCommerce platforms into just one service. Now, the next slide I have here is a very common question is, What is Digital Real Estate and how does it work? Now, the reason why we call it Digital Real Estate, I'm gonna explain. So if you think about Real Estate, Real Estate, you it's a very safe model where you can purchase,
you know, it just costs, you know, quite a bit of money. But it's a generally safe model where you can purchase a house, say, for $120,000 $150,000 $200,000 fix it, flip it, sell it, and make that profit. Right? In this situation, what we do with our stores is we build brands and build ecommerce stores that we grow and create revenue and profit with that we're able to then sell in a year, two years, three years, and get a two to four x multiple on our stores.
So you this is all online, right? Nothing physical. And it's a much lower entry point to get into digital real estate. We take the guesswork out of the whole process and make sure you guys have a very successful store using our years and years of expertise in the space. You know, worst case scenario, say, you do $30,000 $40,000 a year in a profit with your businesses, with your ecommerce stores, and you want to sell it, you can get three to four x multiple. So you're looking at hundred and twenty,
hundred and sixty thousand dollars for your store if you decide you want to sell, or you can keep it and keep generating profit. Right? That's the only difference. You wanna keep your store? Do you want you wanna keep making that that monthly profit? Or do you want to sell it, and get a big payout? Right? Now, we do have someone that actually just got their store appraised for half $1,000,000. So there is a lot of opportunity here. And he was able to generate that and build this store with us with a much lower entry point than in traditional real estate.
Right? So we have that safety of real estate as well as amazing returns. Next question, what if I have no experience with ecommerce? Now that's the beauty of what we do here at Sande Ecom. Right? We do everything from A to Z. We do it's fully done for you, hands free. We want as little from you as possible in the whole process. Your only responsibilities are just the first couple of weeks of onboarding. We we hold your hand through the whole process, get your business set up. We cover that cost for you. We get your teams all positioned and set up with your information so we can
properly run your your ecommerce stores on your behalf. And then your only responsibilities are to periodically check the team chats and just make sure that we have everything that we need. You know, it's never gonna be real work. It's just gonna be some verification information that only you can give us because you fully own the stores, the bank accounts, everything. It's a 100% your business. We are the management partners. Right? So, you don't have to worry about, really any real work on the stores. You only have to focus on checking the chats as well as paying our monthly profit split, which I'll talk a little bit more later on,
on a monthly basis for the previous month's revenue and profit. Right? So you only have really two responsibilities and it's very, very hands off. And, we want, like I said, we want as little from you as possible. Now, next question. Where do you source your products? So, we we actually source a lot of our products from The US as well as many places around the world. We use private suppliers that we've curated over many years and built really strong relationships with so we can ensure that our, partners get the highest quality products as well as the fastest shipping times.
And this is a massive advantage that you would have working with us, being able to piggyback off these relationships that we built over a long period of time being in the industry. Right? And then we also have other backup suppliers that we use like Amazon Business Prime or eBay or Walmart, Home Depot. You know, we have many different suppliers and many, different ways to get high quality, fast shipped products to our, you know, your customers that you sell on your stores. So, that's how that's where we source our products. How do we pick your products?
Now we do have a strict criteria when it comes to product research. We have a full time product research team here at Sande Ecom, and that is a huge key to finding these winning products that we that we run on these stores. Right? Our product research team constantly does product research every single day for hours every single day, building up that eye for what a winning product looks like. And I I can give you the criteria. We'll even go we can go deeper on this on on our next call. But, really, we're looking for something that's broad, that can be sold to, a large a large group of people, something that's unique,
has a real use, something that's trending. It doesn't need to be all of these things. It just needs to be, you know, match some of these characteristics as well as some others. And we're really like, this is what the criteria is, but you really get good at product research from doing it day in, day day in and day out just as our product research team does. So that's why we find such incredible products to run on our stores because of our product research team. Why do you need my investment? Why, why don't you just do it yourself? And that this must be the most popular question. It's very,
very simple. So, I have my own stores. A lot of my team members have their own stores. But the way we work on marketplaces, marketplaces only allow one store per person per personal name, personal address and IP address. So we can only have one store per platform. So you can only have one store on on each of the six platforms that we work on, right? If you want two stores on Etsy, you need to get different information to be able to run that. We can actually walk you through that process. But that's the reason why we set up Sandia eCommerce.
It's not just so we can scale up on our current stores, it scales sideways to to as many of the right partners as possible, so we can have as many stores live as possible. And right now, we actually manage over 350 stores here at Sandy eCommerce. So that's why, you know, we do do it ourselves, but we also would like to work with you, you know, as long as it's a good fit because there's a lot of opportunity here. It's a win win situation for yourself as well as us. Right? You bring the capital, and then we use our expertise over the over many, many years in the ecommerce industry,
over hundreds of thousands of dollars spent on mentorships, course courses, coaching, and then actually testing physically, testing with money to figure out what's working, what's working right now. So, that is why we have partners. That's why we created Sande Ecom. Next, Is this business completely hands free? On my end, and I already kinda said this a little bit, but, you know, to go over it again, we want as little from you as possible. As little from you as possible. After those first couple weeks of onboarding, really, after the first month, you're kind of you know, it is very minimal. Anything we would need from you the only things we need from you are things
that we can't get ourselves, like I've said. Like, a credit card for fulfillment cost or verification code sent to your phone, you know, something along those lines. But it's never real real work. It's just verification information. So, that's, you know, your only responsibilities. Again, checking the the group the team chats that with the your account managers that are managing your store, and then, paying the profits. But that's the only real responsibilities that you have. Next. How do I know your company has experience? So, I mean, for one, you can look us up on Google, on the Internet. Okay. Miss Falsic, are you familiar with,
a document or a video, titled exhibit s five for identification? Yes. And is that a video that, is itself titled avoid the trap of spending thousands on inventory? Yes. And, can you briefly describe what the contents are of that video? It basically talks about how the ecommerce store runs, hands off, passive investment. It's automated. They have the organic traffic that he was talking about that people are on there shopping. And they they do drop shipping, so you don't have to have an inventory. They need a credit card for when the stuff is when the items are purchased,
and then that's when they're bought using your credit card. And, how did you obtain, or or come to obtain s exhibit s five for identification during the course of your investigation? That was through YouTube as well. And when you say through YouTube as well, is that a video that you watched on YouTube that was associated or titled, Sandy Ecom or Anthony Sandy? Yes. And have you viewed, exhibit s five for identification? Yes. And is that video a fair and accurate depiction of the video that you originally saw on YouTube? Yes. Your honor, at this time, the division will move to have exhibit s five for identification moved into evidence.
Mister Sandy, do you have any objection to exhibit s five? Respectfully, I don't feel equipped at this time to respond with that legal representation. Okay. Exhibit s five is admitted at this time. Thank you, your honor. And, one last question I forgot to ask. Is exhibit s five, is that a video of about between two and three minutes long? It was a couple minutes. Yes. Your honor, permission to publish exhibit s five? Mister Sanjay, any objection to publishing exhibit s five? Respectfully, I don't feel equipped to respond with that legal representation. Okay. You may proceed with publishing s five. Thank you. Oh, I'm so sorry.
Of spending tens of thousands of dollars on inventory for your ecommerce business. If you are a high income w two earner and you want to build a sustainable source of passive income online, but you don't want to invest into high risk opportunities or you have available capital and you just don't know what to do with it, I'm sure you're aware that inflation is rampant and it is devaluing your savings. So I'm going to show you the diversification strategy we've developed that is responsible for our partners generating over $3,000,000 in sales as well as selling over a 100,000
products online. And the best part is we've been able to do this without spending a dime on marketing or buying any sort of inventory. If you don't know by this point, my name is Anthony Sandy and I've been in the e commerce industry since 2016. I've generated millions of dollars selling physical products. And for the past eight years, I've been buying and selling goods online all around the world. My team and I have generated over 7 figures for our partners in the last twelve months alone using the same exact diversification strategy I'm about to discuss in this
video. As we all know, starting a new business is very, very difficult. And if you're thinking of starting your very first business to build a new source of income, you have a lot in store for it. Do you really want another full time job? What if there was a better way that will allow you to generate money while you sleep? You don't want to manage a team. You don't want to deal with operations. You don't want to negotiate with suppliers. You don't wanna go through the trial and error that we have already gone through. And once again, you do not want another full time job. What you need is to add a new source of income to your portfolio without
needing to do any of the work. You need more time freedom to enjoy life with your loved ones. You need to take advantage of the rapidly growing ecommerce industry without needing to spend a dime on marketing or inventory. And, of course, you need highly profitable and consistent monthly returns month after month. The strategy that will get you there is called ecommerce diversification, and this is the same strategy that I'm about to show you that will allow you to stop worrying about the cost of inventory, grow and scale consistently with organic traffic,
and never worry about the day to day operations to run your business. Now you may have heard that the best way to sell online is to source a supplier from China, buy inventory before you've actually sold it, ship it to a warehouse, and then pay for advertising to hopefully sell out your inventory. And then the same old same old idea of selling on Amazon or Shopify is the place to be. I'm here to tell you that that is very, very far from the truth and that what most people don't know is that they can have a fully diversified portfolio across many marketplaces and set themselves up for success
instead of just depending on one sector of the market to build passive income. Now let's jump into the eCommerce diversification strategy. Alright, guys. So this is the eCommerce diversification document. And in this document, we will review the entire strategy as well as show you some profound results from our partners. Just remember, every store performs differently. Now let's jump into the eCommerce diversification strategy. So the first thing is in today's eCommerce landscape, we want to own as much digital real estate as we can. We don't want to have all of our eggs in one basket.
We want to be spread out across many websites across many stores. Would you rather own a single home or a single store or own an apartment complex, which is many stores? Right? That's exactly what we do here at Sanda Ecom is we make sure our partners are on the best platforms for ecommerce and spread across as many as possible. Now, it's very important to mention that not all platforms are equal. We don't just put our clients on any platforms. We have very strict criteria for what platforms we put our clients on. So we do have a proven formula for when it comes to picking the platforms
we're going to put our partners on. Now what we focus on primarily are platforms that allow us to sell products without needing to buy upfront inventory and this is called drop shipping. Right? Drop shipping is beautiful. The beauty of this strategy is that it requires less upfront capital and it's a very low risk business model. Now, what are some of the reasons we only focus on drop shipping? It's less risk, less capital needed, large selection of products to sell. We're not stuck with just what we bought in inventory. We can sell anything as long as it's compliant.
It's very quick to set up versus needing to buy the inventory, have it prepped, ship to the warehouse, manage it. You know, it is very tedious buying inventory and it holds a lot more risk. So there's a lot of benefits here. Now this chart here shows how simple drop shipping really is. We make a sale on your website. We fulfill that order by going to one of our suppliers, whether it's on Amazon Business Prime, Ali Express, maybe it's Walmart Plus, maybe it's one of our private suppliers. And we ship directly from that supplier to the customer. So you never touch the product going directly from supplier to customer.
We don't have to store it in a warehouse. You don't have to send it to your house, and then the customer goes directly from supplier to customer. And that's called dropshipping. Right? Now, another primary focus we have here in this strategy is we want to only focus on platforms that allow us to grow and scale primarily with organic traffic. Right? Now why do we focus on organic traffic instead of paid advertising? Paid ads would be something like Facebook ads, Google ads, YouTube ads, TikTok ads, anywhere where you're paying to put a video or an image in front of a
person, an audience, in hopes that they click on your ad and then go to your website and purchase. We don't like focusing on that because there's so much volatility and there's a lot of opportunity to end up negative and actually lose money to just acquire a customer, to get a new customer. Alright. So here are some benefits of focusing on organic traffic. There's less risk, less capital needed, fixed profit margins, which is huge because we determine the profit margin when we're listing it. Right? All we have are platform fees as well as cost of goods. So we don't have to worry about what the cost is to get a new
customer. Now this allows more sustainable growth long term and then we also only focus on marketplaces that have hundreds of millions of monthly active buyers already on the platform. So we don't have to worry about searching for these these customers, finding it, you know, hoping they we can get them to click on our website. They're already on the platform. Right? They're already doing their thing. They they purchase there regularly every single month. We just need to make sure that our products show up when they search for it. Next, let's review the five platforms that we diversify our partners onto here at Sande Econ.
Now these platforms fit our strict criteria of dropshipping and organic traffic. These platforms are TikTok Shop, Facebook Marketplace, Walmart, Etsy, and eBay. And we're always learning and adapting with the eCommerce industry and plan to add more platforms over time. We're not just stopping here. We're continuing learning and growing and finding new platforms that fit this strict criteria. Now what's required to actually get live on these platforms is just a few easy steps that are very simple that we walk you through, which is just getting your business information which we actually help you set up and
cover the cost of to set up your business. And then what our team will do is, depending on the platform, we will build an external website to then go for approval and get approved on these stores. We have to get approved before we can actually start selling. Once we submit the application and get approved, then we begin listing. Your dedicated account managers will begin listing products on your stores. Every store gets a minimum of two dedicated account managers because ecommerce, like we've mentioned before, is a full time job and nobody wants another full time job. So we make sure that we have the proper dedication on each platform to get
the results that are up to our standards. Now once we begin listing on your store, this is how the process works. Our full time product research team is going to identify what's currently working and what people are buying so your account managers know what to list on your store. Our full time product research team has been doing product research every day for years and they've built an eye for what a winning product looks like. Like Solomon here, we actually found a winning product on his Facebook Marketplace that's generated over a million clicks in the last seven days, organically,
not paid for, to his listings and over $16,000 in sales at 30% profit just the last twenty eight days alone. That's just from one single product. Imagine what you could do with two products or three winning products or five winning products. The possibilities are endless. And then across multiple platforms, remember this is just one platform, Facebook Marketplace, one of the five platforms that we work on. So like we spoke about, product research is very, very very important. So our product research team is constantly scouring our fulfillment sites,
looking for hot new products, working with our private suppliers, and follow our strict criteria for what a winning product looks like. And like I said before, they are they are scouring these websites daily and they've built an eye for it. It. So product research doesn't just come from knowing what a winning product looks like, but it comes from daily practice and and experience from doing it for years. Next, we have product listing. So this is what your account managers are doing with the products that our full time keyword research team finds. Now, how you structure a listing on these platforms is very,
very important. If you were to just take a product from a supplier and list it how they give you as is, chances of you getting visibility, getting eyeballs onto your product is slim to none. How you structure it is very, very important to get that visibility. We use our keywords in the description, in the titles, and specific images to rank our products as high as we can. I always use this example of leather jacket. If you were selling leather jackets and someone searches for leather jackets on one of these sites or on Google, you wanna be the first, second, or third person to show up as high as possible so you get the most
visibility on your product. If you show up at the bottom of page one or you show up on page two, three, four, no one's ever going to see your products. Now let's review the costs that are required to operate these businesses. So per store, you need about $1,000 available on a credit card for fulfillment. Now we never, like I said, we never purchase inventory before we've actually sold it, but we we only purchase a product after we've actually sold it called drop shipping. But we can't wait for you to get paid out from a store, from a platform like Facebook, Etsy,
Walmart to then send the product to the customer. We have to send it to them immediately, keep the customers happy, and keep the shipping times low. That's why we require a budget for fulfillment so we can fulfill orders as soon as they come in. A couple other key points is that as soon as your money is deposited, you just pay it on your credit card. Most platforms pay weekly and then daily, and then Walmart pays every two weeks. And the other point is that you wanna optimize your credit cards for the ones with the highest cashback or travel points. You're always gonna have a fulfillment cost. We're always gonna have to pay for products as we sell them.
So you wanna turn that into an additional profit stream for you. Now let's jump into why do we actually need you? I mean, if we're so great and we know what we're doing, we've been doing this for so many years, why do we need help from anybody? Right? So your two very key points. One, every platform we work on only allows one store for personal name, for personal address. Right? So that limits us. Myself as well as many of my team members have the Now, Ms. Falczyk, just to take a step back, you said that, at a certain point in your undercover capacity that you arranged for a sales call
with someone from San Diego? Yes. And, I believe, correct me if I'm wrong, that, that mister Sandy himself was on the sales call that actually came about? The first call. And can you describe how long that first call was with mister Sandy? I don't know how long it was, but it we talked for quite a quite a while, several minutes for sure, about how it all worked and how what I had for an investment and how much I could get on return for my investment using the ecommerce, Sandy ecom motto. And do you recall generally what mister Sandy said to you during this call?
Pretty much the same thing he just said in that video. He said he talked about organic traffic. We specifically talked about that in the videos that I had watched because I had watched them prior to speaking with him, which he asked me about. We talked about drop shipping. He told me about how drop shipping worked. I specifically talked to him about, that I had a $30,000 investment that I was looking for and that I wanted I didn't want another job. I just wanted to be able to make money. We talked about the return of that my expectation was, like, if I could get $2,000 a month, and we talked about that and how about how long it would take,
which he said about seven to eight months before I would get that kind of return. Yeah. And we talked about him being in Surprise and me also being in Arizona. Now, you said that was there a follow on or multiple other calls with Sandiacom after that one? Yes. Can you can you do you remember exactly how many calls there were after that? I think I had three other calls, two or three other calls with his partner, Thomas. And were they similar in in terms of duration and content? They were a little bit different because they were more specified to, like, the agreement and, committing to them as an investor.
And when you say the agreement, was did the Synodecom draft a, a draft agreement, for you based on the information that you provided? Yes. A services agreement. And what exactly, was communicated, was told to you about what services SyndEcom was was offering you in this draft agreement? So they would help me get my LLC started, and they would set up four ecommerce stores for me, using my LLC on different platforms, and they would manage. And when I say they, I'm referring to say the ecom. They would manage it using their independent contractors or their employees and,
the people who find the product. All of that research stuff is all done by them. So we discussed that. And, similar to what was described on the video, were you ever told that setting up the stores or managing any ecommerce stores, if you sign the agreement, that it would involve any effort or any, specific activities on your part? So I would have to pay a $3,500 start up fee that was nonrefundable. And then I had to transfer, 36,500 bank transfer fee as an investment to get started.
I had to have an available credit card for the purchases of product. I had to pay the fees, the monthly fees, to the platforms. And other than providing information and paying whatever fees, CNA ecom requested of you, was were you told that any other, specific actions that you had to take in order to, set up and run these ecommerce stores? No. Now, during this that sales call with mister Sandy or any other, sales call that you had with Sandy Ecom, were you told that CND Ecomm had previously failed to open an e commerce store
on one or more platforms for a particular or for any prior investor? No. Were you ever told that, that was a risk that CND E com might not be able to open one or more e commerce stores on a given platform, if you signed the agreement and paid whatever fees were required? No. During that sales call with Mr. Sandy or any other sales call that you had with sandeepcom, were you told that it was a potential that an e commerce store that was open for your behalf might not be profitable? No. Were you ever told during any sales call with Sande Ecom that prior investors had
contracted with Sande Ecom to open e commerce stores and they those stores ended up being unprofitable? No. During the sales call or any sales call with C and E e comm and I'm sorry, do you would you like to Yes, it's okay. Thank you. Sorry. During any sales call with C and E e comm, were you ever told about any particular risks in investing with C and E e comm and opening e commerce stores? No. During any sales call with Citi and Ecom, were you ever told that Citi and Ecom might not be able to open an e commerce store on your behalf on any given platform? No. During any sales call with Synd Ecom,
were you ever told that there was a risk that any funds that you paid or invested with SyndeCom, might not either receive a profit or you might just lose those funds entirely as part of the e commerce store, just endeavor? No. Now aside from the video that that you were sent, that you you testified you were sent of the q and a video, did you obtain any further documents from Sandiacom during the course of your, contact with them? I obtained the services agreement that we were just speaking of. And was that a draft services agreement that they the Sandecom prepared and sent to
you? Yes. It was sent to me via email. And did that service agreement, the draft service agreement contain anything else, like a statement of work that described exactly what they would be doing? Yes. Are you familiar with exhibit s six for identification? I'm gonna grab it from the folder. Yes. What is s six for identification? The services agreement that I received. And does that also include, in the last few pages, the statement of work as an attachment to the services agreement? Yes. Now there are some redactions on, throughout exhibit s six for identification. Can you describe what those redactions are and why they were made?
They're identifying information to my undercover identity. And was that undercover identity the one that you used, basically offered to CNDECOM when they offered to prepare this draft services agreement and statement of work for you? Yes. Now is that copy of exhibit s six for identification an accurate copy of the service agreement, the draft service agreement and statement of work that C and E come sent to you? Yes. Alright. At this time, the division would move to have exhibit s six for identification entered into evidence. Mister Sandy, objection to exhibit s s six?
Respectfully, I don't feel equipped to respond with that legal representation. Okay. So the s six is admitted at this time. Now, miss Falsick, I I think you you testified to the invested amount, that you stated to SandeCommerce SandeCommerce representatives. But does the service agreement, because of it as six, contain the investment amount that you were, basically established with Sandeepom for the purposes of the draft service agreement? Am I able to review simplify my overly wordy question, does that Exhibit S6 contain an investment amount that,
under the agreement, you would provide to SyndeCom in exchange for their services? Oh, yes, it did. It's a do you want me to find it? Yes, please. Yes. And if you could identify once you find it what page that's on. And just to simplify things, if you could turn to page 12 of the document, a 16 or a six rather. I apologize. I'm looking for the amount. I know that I saw it in here, but now I'm not finding it. If you could turn to page 12 of the document Oh, 12. 12, the, bottom right hand corner number. Oh, yes. There it is on page 12. Got it. Okay. And specifically,
under the, paragraph Roman numeral two, description of fees, subparagraph b. Yes. It states a one time fee of $36,500 Is that accurate based off of your conversations or communications with candecom? Yes. Was that for purposes of this this draft agreement, was that the investment amount that you would be, sending if you'd signed this agreement, that you would have sent to Sandeepom, that they would use to open the e commerce stores on the different platforms on
your behalf? Yes. And was that above and beyond the or in addition to the, onetime fee of $35,000 or sorry, dollars 3,500 that's in the paragraph above that? Yes. So the total fee under this draft agreement would have been approximately $41,000 Yes. Of $40,000 40,000. And going reviewing the previous page, page 11, can you describe what, in exchange for the $40,000 what Sandia eCom, would be offering to you under this draft agreement and statement of work?
Do you want me to read it, or you want me to just summarize? Summarize if you can. So they were going to open four ecommerce accounts for me on different platforms. And, specifically, is it are they the Facebook, eBay, Etsy? I'm sorry. Facebook, eBay, Walmart, and Etsy stores for Etsy platforms? Yes. They were gonna pick four of the platforms that they used, which included what you just listed. And do you remember anything else about the content of the the communications, the conversations that you had with Cinecom, representatives about setting up, the stores or this agreement,
this draft agreement? That I just had to have an LLC to start this and that they would help me and pay the fees to get that LLC started, and then they would establish the accounts for each of the platforms. So under this draft service agreement and statement of work, you wouldn't even have to set up user accounts basically on, Facebook Marketplace or eBay or Etsy or any of the others? They said they would do that once I had the LLC established. Now moving on from exhibit s six, at a certain point during your investigation, did you send a subpoena for records to Sandy Ecom?
Yes. I did. And, can you briefly describe or generally describe what documents you received from sanity.com in response to that subpoena? We received client records, bank statements, some business documents, additional videos, which were some of the ones that we had already found. I think that was it. The client the all the contact information for the clients as well. And when you say for the clients, were those, all of Cinecom's clients? Yes. Do you know approximately, when you received that that client list from SyndiEcom? I do not recall the date because there was some confusion between the attorney and who was sending what and what was coming through.
I don't know the exact date. Was it sometime in the 2025? Yes. And do you recall how many clients, were on that list that Synchronycom provided? 86. Now, of the other documents that you received, from Senior Economic response to the subpoena, do you know how many completed service agreements and and statements of work, for those 86 clients that you received? I don't recall if we received them all because, again, there was some confusion on receiving documents, so some of them didn't come through. I don't know exactly how many we received on that,
but I know that for the ones that we were involved in this case, we have theirs. We have their information. And when you say the ones involved in this case, what exactly do you mean? The investors that I've spoken to that are related to the Arizona case. And, are they the other investor witnesses Yes. Who have been listed for this hearing? Sorry. Yes. Now, can you if you can, can you estimate how many service agreements and statements of work total completed ones that you've reviewed, that were from Sandeepam? I think that they all had them, but some of them we had to get in a different manner through,
like, Google Drive or whatever. But I think that I've reviewed them for each of the each client. So I think I reviewed almost 86 of them. I'm not a 100% sure. It would it be fair to say that you reviewed several dozen? Oh, yes. And that's above and beyond the draft service agreement and statement of work that you obtained as part of your undercover, contact with San Diego? Yes. Now, reviewing all after looking at the the overall, the ones that you you did review, the service agreements and statements of work, did they all seem to use a standard template form?
Yes. Was there a typical of the ones that you reviewed, was there a typical or average investment range? Yes. And what was that typical or average investment range? They were like $15,000 to $30,000 typically. And I guess when I say investment range, let me clarify. Was there a typical range that, to use the terminology of the draft agreement that you obtained, was there a typical range of looking back to Exhibit S6, Page 12, so paragraph, Roman numeral two b as in bravo.
Was there a typical investment range of that used a onetime fee? So you're are you asking about the on paragraph b, what your investment amount was? So it was a poor question. Let me rephrase. I just wanna make sure that that we're we're we're on the same page, and and specifically that my questions are on the same page as as your testimony. When you say when I say investment range, in your understanding, is that the same basic thing as the one time fee, that the service agreement the draft service agreement is mentioned in,
paragraph Roman numeral two bravo on page 12? Yes. And that's a is it a bit s six? Yes. So was your understanding of that one time fee, is is that's the investment amount that a client such as yourself and your Undercover Capacity is investing into San Diego ecom, for purposes of opening the ecommerce stores? Yes. And just to clarify, just to confirm, you testified that the of those service agreements that you reviewed and statements of work for all the clients, at least the ones that you were able to obtain, there appeared to be an average or typical investment range of between $15,000
and $30,000? Yes. And that was under the the the rubric or or the label of the onetime fee? Under section b. Yes. Yes. Now do you know approximately how much, of the onetime fee or investment amounts, that that all 86 clients of Syndicom total invested I it was over a million dollars. I don't know the exact number, but it was over $1,000,000. Now at a certain point during your during your investigation, did you obtain an open letter from St. Ecom, addressed to all investors?
Yes. And, was Anthony Sandy's name listed as the author of that letter? Yes. Do you know approximately when that letter was sent out? February 2024. And are you familiar with exhibit s 15 for identification? I'm gonna remove it from the folder. Yes. I am. And what is that, that document? This is the letter that Sandy Ecom sent out to investors. And have you reviewed the letter, prior to today? Yes. Do you know, do you know how you obtained the the letter? It was sent to investors that provided it to me. Your honor, at this time, the division would move to have exhibit s 15 for identification entered into evidence.
Mister Sandy, any objection to exhibit s 15 being admitted? Respectfully, I don't feel equipped to respond at this time without legal representation. Exhibit s 15 is admitted into evidence. Thank you, Aaron. Now, miss Fousek, I don't want to, it's a is it a three page document, the letter? Yes. Okay. I I don't want to, go over all three pages, but I just want to highlight one portion. If you could look about three fourths of the way down the first page of exhibit S15, the paragraph that starts with the words the only risk. Yes. There are just three sentences in that that short paragraph.
Can you read those three sentences? Sure. The only risk in this ecommerce business model is time time to rank products as well as through any bumps in the road. Of the stores that are over a year old, the majority are meeting or exceeding our sales estimates. Now, you said you've reviewed this document, Exhibit S-fifteen, prior to today? Yes. Specifically, you reviewed it when you first obtained it from an investor? Yes. From sanddee.com? Does the letter contain any information about any risks, to investors, specifically with regards to Sandeepom not being able to open a store on behalf of
an investor on a given platform? No. Now the paragraph following that, the one that you just read, mentions, suspensions. Does that this paragraph contain any information about, or or the document itself contain any information about, just seeing ecom not being able to open an ecommerce store on a given platform, period? No. And does this document contain any information about the risks of, to to an investor of an ecommerce store not being profitable or not or not
basically meeting a, a sales expectation. No. Does the letter say anything about ecommerce any ecommerce stores or the risk of an ecommerce store potentially never becoming profitable? No. Okay. Now moving on from exhibit S15. You briefly touched upon this before, but I just want to go back to that. How many individuals have you spoken to, that have identified themselves as investors, with SyndeCom? Seven. And have all seven of these individuals stated that, stated to you that that for for I guess, pursuant to the service agreement they signed with CNA ECOM,
that they, feel that they're owed some sort of money from CNA ECOM? Yes. And of those seven that you spoke to, does that include any of the investor witnesses who will who are named for this hearing? Yes. Now did you cross check the names of the seven individuals that you spoke to who said that they invested with Sandeepom with the client list that Sandeepom provided you? Yes. And what was the result of that that check? They were listed in the information that was provided by Sandy Ecom. Were all seven individuals listed? Yes. Are you aware of any individual that you spoke to who claimed to be an
investor with Cinecom that was not on the client list that Cinecom provided you? No. And, if you know off the top of your head, what is the total amount of restitution, claimed by the seven individuals who said who spoke to you and said that they were investors with Sandecom? $180,000. And during the course of the investigation, did you prepare a list or any sort of spreadsheet that breaks down, what individual amount each each, individual investor is claiming, for restitution from Syndicom? Yes. And, do you happen to know off the top of your head the amount for each
individual and the name of each individual? I don't know it off the top of my head, since there's seven of them, but I do know that they are listed on my spreadsheet. Would reviewing that spreadsheet help refresh your memory? Yes. If you would like me to specifically tell the amount and the name. Yes, please. I have it I have it there if if you're able to bring it, or I can get it. Yes. That's it. Okay. And, miss Salsick, is that a document that you prepared yourself? Yes. And and what is that that you just reviewed? What is it that you just reviewed that document? It's, pieces of the investor spreadsheet that I compiled together.
So we have a larger investor spreadsheet in a case file, and I took just pieces of it so that I could have it easily visible. So, can you state by individual investor name how much each invest individual investor is seeking resolution from City of Commerce? Sure. Leonard Fernandez, $20,000. Richard Hanna, $30,000. Grant Salze, $30,000. Jorge Ortega, $35,000. Deborah Peterson, $15,000. Tighe Griffin, $35,000.
Patricia Siliberdi, $15,000. And is that all is that a list of all the individuals that you spoke to that have claimed to be investors with City Council? Yes. And if I could just have one moment, your honor. Thank you. No further questions. Mr. Sandy, do you have any questions you would like to ask this witness? Respectfully, I don't feel equipped to respond without legal representation. K. Thank you. Miss Balswick, I think I may have a question or two for you. And I'd like you to refer back to exhibit s six, if you would. Six? Sure. I have it.
And, specifically, if I could get you back to, page 12. Page 12. Got it. And I wanna make sure I I understand your testimony because I I I think what I heard was the 12 was the portion of these contracts that represented the investment amount. But I want to clarify because 12 a is also, I guess, I guess, paragraph 11 on page 12, 11 a is also looks like a a onetime fee. Are both a and b the sum total of the investments on these contracts?
So the way that I understood it is that a was the startup fee that's a nonrefundable startup fee that you just have to pay to get started. B was the investment amount, and those were different depending on how many platforms. So I was going to open four platforms, so that's why my amount was different than, like, the other investors. But the a is a I think it's a different I don't think that's included in, like, the investment amount. So when you you gave investment, restitution amounts for the seven investors, would those,
amounts be coming from a contract similar to this, the the paragraph 11 b for each of those investors? It's not including the start up fee. I didn't include that. Okay. Mr. Horn, do you have any follow-up questioning based on what I've asked? Mr. Sandy, do you have anything that you would like to ask based on what I've asked? Okay. Mister Horn, may the witness step down? Yes, sir. K. Thanks, miss Valcik. We appreciate it. You may return to the your spot at the table. Thank you. Mr. Horner, are you ready to call another, witness for the division at this time?
Your Honor, the next witness will be available at around, 01:00. So I don't know if, you wanted to, take a lunch recess now or if you didn't if you wanted to keep going. I was going to call, mister Sandy if if you did not want to take lunch or not as a witness. I suppose this might be an an opportune time to to take a lunch break. For planning purposes, what do you anticipate the witness schedule being like for the rest of the afternoon? Unfortunately, the witnesses' availability are pretty limited. We have one witness who's available this afternoon, one witness who's available tomorrow morning,
and then, one or two witnesses who are available tomorrow afternoon. And each will probably take around, anywhere between an hour and a half to two hours for their testimony. K. Are you anticipating, that we'd be finished with the investors by tomorrow afternoon then? Okay. Alright. I guess this will be an opportunity time to break for lunch until one. Are there any procedural issues that anyone wants to raise before we break, mister Horn? Mr. Sandy? Okay. We are in recess until, one then. Thank you. Yeah. Let's go back on the let's go back on the record. Mister Horn, are you ready for your next witness? Yes, sir. The division calls,
mister Grant Soleil. Hello? Mister Solay, I assume that's you. Can you hear me? Yes. I can. Okay. This is Ministry of Law Judge Mark Freni. We're gonna have you, sworn in by our court reporter. Raise your right hand, please. About to give Shelby the truth, the whole truth, and nothing but the truth, so help you God. Yes. Sir. Can you hear me okay? Yes. I can. K. Can you state your full name, please? Sure. It is Grant Saleh. And, what location, city, and state are you testifying out of today? I am located in Issaquah, Washington. And, what do you do for a living, sir? I am a user experience designer.
Are you familiar with the term accredited investor? To a small degree, I believe accredited investor needs to have, a million dollars in assets or make more than $200,000 a year. That's my understanding. Do you believe you fit fit the requirements of an accredited investor in late twenty twenty three or early twenty twenty four between that time period? Definitely no. Are you familiar with the company known as Sandy Ecom? Yes. How are you familiar with them? So I was part of an, a group of people, who were looking at investment opportunities
for, income reasons. A gentleman by the name of Steve Lawson, this was his business. He was a, previous financial adviser, and his job was to curate investment opportunities. They ranged from real estate to, investment opportunities such as online stores, and one of those was, Anthony Sandy's business, Sandy Ecom, and and that's where I heard about it in a group setting. Are you familiar with, Anthony Sandy? Yes. I am. He appeared on, Steve's program, and, then I also did have,
an entire call with him discussing the investment opportunity. And that program that you you said, Steve's program, can you describe what that was? Yes. So unbroken investing is what Steve has called his business, and it is essentially about finding, alternative investment opportunities, things that you that may be, outside of what you may normally think of such as, like, for me, my experience is investing in stocks and ETFs at Fidelity. And, his business was really about finding additional opportunities that people could invest in outside of,
I guess, what we would consider just our, you know, brokerage provider. And did you eventually come to talk to mister Sandy himself? Yes. I did. Anthony presented on Steve's program, I think, around, September 2023. And, September 24, Steve sent an email introducing me to Anthony Sandy. On 10/02/2023, I had a, Zoom call with Anthony and signed a contract on that date. Now during the Zoom call or during any previous communications that you had with mister
Sandy, did he represent himself as, the owner or and or manager of Sandy Ecom? Yes. He was the owner. Now before we get into your experience and and and your conversations with mister Sandy and anyone else from SandyEcom, can you briefly describe, which you already did, but a little bit more, your investment knowledge and background prior to dealing with Syndicom? Yeah. I think it was mostly for me, investments meant, using your brokerage account, like E Trade or Fidelity to invest in stocks, bonds, mutual funds, things like that.
That was essentially, my experience. And, specifically, when you when you heard about CinD e comm and and the service it it offered or or or the services it it was advertising, were you looking to invest at that time? Yes. I was. I was looking for, additional investment opportunities. I was actually I actually I had lost my job at the time due to a company downsizing. And so while I was looking, it was important for me and my family to find additional sources of income, and this seemed like a great opportunity at the time to do that. Now you mentioned that,
you spoke to mister Sandy on during a sales call, I believe. Yes. That was on 10/02/2023. Okay. And do you do you remember exactly or not exactly, but do you remember roughly what was said by mister Sandy during that sales call? Certainly. The main pitch was a document that, Anthony provided. It was an Excel spreadsheet that he called the Sandy ecom trifecta, and it basically described how they would set up online stores,
in particular, Etsy, Facebook, and Walmart. And this document laid out gross sales, total profit, and the profit split for his company running these stores after we made the initial investment. And is that document that you just referred to, is that what you were looking at just now when you were talking about the date? Yes. Yes. It is. I don't know if I need to submit this or this was also submitted, when this was sent to the Washington Department of Financial Institutions. I think you may have it as well. Okay.
Now, when you talked to mister Sandy, did he, did he tell you that Sandy Ecom operated at any particular place? Yes. I believe it was operated out of Arizona. And what what services or investment opportunities did did this or Sandy communicate to you, that were available through Sandy Ecom? Yeah. So, basically, it was kind of a we really didn't have to do anything at all, we being the investors. We would pay the initial fee, and Anthony and his team would set up the online stores.
In this case, that was creating accounts at Etsy, Facebook, and Walmart, and they would run those stores. So they would also take care of setting up a business for us, an LLC. These stores would be run under that business, and then they would curate products, make sure that they took photos of them, added descriptions, take care of all of the online sales, customer service. And for their effort in doing that, there would be a profit split for each of those stores. Now, during your conversations with mister Sandy or anyone else from sandyecom,
did anyone represent to you did anyone say to you that they were registered securities brokers or salespeople? Never. During your conversation with mister Sandy or anyone else at Sandecom ever, did anyone else ever mention the risks of investing in an ecommerce store that Syndicom would open and run for you? The risks were tremendously played down. Basically, the risks were if something didn't work, they would try something else. If one store didn't work for some reason, they would set up another store. So there really was no discussion of,
you know, could all of your funds be lost? There was really no, I guess, a discussion of you know, when asked how are the stores performing, they were all kinda green lighted. All the stores are performing well that we're running. I believe Anthony said we have over a 150 clients. All the stores are performing really well. We've never had a circumstance where, something is not working. I had asked questions as well as if he's selling a certain product on my store and that other product is being
sold on another store, could one of those being cannibalizing sales from another opportunity? And that was kind of a risk that that I brought up, and he said that's really not a problem. We continue to shift product in products that we're selling. And, again, the worst case scenario was, something doesn't work well, we'll we'll shift to another store. Anyone at Sande Ecom, including mister Sandy, ever mentioned the possibility or the risk that the that Sande Ecom itself would not be able to open an ecommerce store on a given platform on a client,
like, such as yourself's behalf? Yes. That was a possibility, and the answer to that was they they would just continue to move to another opportunity in a different store. Now in October, 2023, did you sign an investment service agreement with Syndicom? I did. And, specifically, did you sign a service agreement and statement of work with Syndicom on 10/02/2023? Yes. I did. Have you had a chance to look over, or do you have a copy of that service agreement and statement of work? I certainly do. And have you had a chance to review that document? Yes. And
sorry. One second. Making note to myself. Okay. Now the document has my office sent you a document that's, has a label of exhibit s 10? Yes. Okay. Have you had a chance to review that document? Yes. I'm very familiar with it. Is that a copy of the service agreement and statement of work that you signed with Sandecom on 10/02/2023? Yes. Is that a fair and accurate, copy of the service agreement and statement of work that you signed with Sandecom? Yes. And did you sign any additional agree service agreements or statements of work with Sandecom
beyond, the October '31? No. No. This is the only thing. Your Your honor, at this time, the division would move to have exhibit S 10 for identification entered into evidence. Mister Sandy, any objection to exhibit S 10? Respectfully, I don't feel equipped to respond at this time without legal representation. Okay. Exhibit S 10 is admitted into evidence. And, your honor, permission to publish exhibit s 10? For for, the witness? Oh, certainly. Yes. Okay. I'm sorry. You're right. I'm just trying to since this is Okay. Sir, so I just wanna highlight a few things. I don't wanna go over this entire agreement that you have in front of you.
But if you could just turn to page 12 of the document. Yes. Is this your esignature at the bottom of the page? Yes. It is. And does it also bear a signature of mister Sandy? Yes. It does. And is there a date beside each signature, both yours and mister Sandy's? Yes. Both of them read 10/02/2023. And if you could flip to page nine of the document. Sure. Does this this page have a title? Exhibit a statement of work. And does this page or at least the second maybe after one third or so
down of the page, does it outline what sandeepecom what what services they will be providing you as part of this agreement? Yes. It does. And specifically, what what platforms, did they did they contract with you to open an ecommerce store on? It says that they will set up a Facebook Marketplace account, Etsy seller account, and Walmart seller account. And So that was Anthony's trifecta as represented in the, their profit split. What was your understanding of what this means in terms of what you had to
do to open an account and open the store on these platforms versus what SyndiEcom had to do? I pretty much had to do nothing. Anthony was very clear that they would set up an LLC that would, operate these three businesses, and, there was really nothing for me to do. I mean, per his description and per the contract, all I had to do was essentially be responsive to the team and not delay in any responses. They would set these up. They would again, you know, per the contract, locate products. They would list those products.
They would sell those products. They would take care of the customer service for those products. The shipping of them, essentially, everything was done by them. And, sir, if we could turn to the next page, the, page number 10 at the bottom right hand corner. Yes. And, if I could direct your attention to the paragraph roman numeral two and then subsection or subparagraph b as in bravo? Yes. This one time fee of $30,000 is that what you considered your investment amount? Yes. And that was wired to Anthony on 10/05/2023.
And the the three paragraphs below that, paragraphs c, Charlie, d as in delta, and e as in echo, what what was your understanding of what those paragraphs represented? That was basically, how Anthony's company was going to make money. We were essentially giving that initial fee for them to set the stores up, run the stores, locate the products, perform customer service, and they would receive a portion of the sales. So if if one particular store of yours that that you owned, did well, made a profit, then that profit would be split between you and Cindy Ecom?
Yes. Correct. Do you know if there was any other initial fee or any other fees of any kind beyond your $30,000 investment, as part of the service agreement? That was it. Now can you describe after signing this, the service agreement and the statement of work, what happened? What was your experience with Sandeepom? So Anthony was pretty clear that there would be a slow ramp up for the stores as they began to just build out products. And, the basically, my communication was handed over from Santony to several account representatives who were all virtual
assistants, and, it was extremely slow. It took several months for there to be just one sale on one platform. Not all platforms were set up. The only platform that was set up was Etsy. There were difficulties setting up the Walmart seller account, and so Anthony proposed to set up a completely different LLC, which they did. I did not hear back on any success or rejection regarding that second LLC. There was supposed to be a,
a Facebook store. Essentially, they had used my account, but there was no, online store set up there. It also says in, the statement of work, I guess, this is section I, sub paragraph I, to create a website on Shopify for the purpose of getting the Walmart store set up. There was no Shopify store set up. This slowly turned into a complete disaster. I don't know how much detail you want me to go into, but essentially only I'm sorry. Go ahead.
I just wanna kinda kinda break that down a little bit. First, just to make sure that everyone's on the same page, the the sub paragraph I that you're referring to, is that on page 10 of the That is on page 10. Company shall create a website on Shopify store for client for purposes of getting approved by Walmart. Okay. And, did you did you say that, no such Shopify store was ever created or there was a delay? Correct. No such no. Not even a delay. No store was ever created. Okay. So, at the end of let me take a step back.
How often were you kind of supervising or just overseeing, the creation of these these different stores on these different platforms? Sure. So I would probably check-in with the team maybe about once a week. There was a WhatsApp channel that everyone communicated through, and I would continue to ask questions. What's the status? What's the status? And the responsiveness was extremely horrible. It might take several days or weeks to hear back from someone, and the response wouldn't be anything conclusive.
It would say something like, you know, we're working on it. The only concrete suggestion that ever came for the Walmart account was to set up a new LLC. They did that. Nothing ever came of that either. So there were numerous check ins with the team, none of which was effective at causing anything to happen. There was at one point in, I think, March 2024 that I began to ask for reporting. And out of the maybe nine or ten months of doing this,
I literally received only one report from the entire team. And, it said for the Etsy store, total revenue goal, nothing. For the Facebook Marketplace store, the total revenue goal was marked as not applicable. And for the Walmart store, total revenue go goal was marked as not applicable. So that this was essentially useless and telling me that they're doing nothing. So you mentioned a a WhatsApp channel. Was that a WhatsApp channel that was, either set up or or managed by,
someone from Syndicom, some employee? Yes. And, how did you learn of this WhatsApp channel? I believe Anthony created it and sent the link over, and team members were added to it. And the other team members were all virtual assistants. Now at the point of, approximately March 2024 when you mentioned that you you asked for, more reporting or regular reporting, do you know how many stores ecommerce stores have been set up, on your behalf by that point by sending ecom? Yeah. Again, this whole entire time, only Etsy had been set up.
Walmart had never been set up. Facebook had never been set up. And, was there another point that you, aside from when you received that that report, directly from Cinecom, was there another point in time where you were able to, check -in and just just oversee, the progress, if any, of setting up e commerce stores on different platforms on your behalf? So this was the only report that they ever sent. The only way for me to view any other progress was for me to log in to Etsy and view account sales on that platform.
There was nothing else provided to me after asking numerous times. And I guess the only other progress would be, I was asked at some point so during the Christmas season, the Etsy store was filled with holiday related items. After that season was over, they began to transition to, Valentine's Day with custom embroidered items. And, there were, I think, two times, maybe three, that I was asked to pay an invoice to some unknown company, and this is where things,
again, began to get really shady. I have run businesses in the past more than ten years ago, and invoices usually follow a particular format with a dollar amount and a company name and an address. And I could tell that something was happening because I was being asked to pay invoices for things that were being sold on Etsy. However, specifically in the chat, I had asked questions around, why is there no address for this. I wanted to look up just to get further information on who you guys are
outsourcing to, where this might be coming from. You know, are they within The United States? Are they overseas? Which was a concern for me because the longer shipping takes, the less happy your customers are. I received numerous runarounds asking to just pay the invoice. When I asked for addresses, none were provided. And when I got one of the invoices, you can always go into a PDF and you can look at the properties of it. And I actually found out that this was actually created, by one of the virtual assistants.
And so I don't even know that any of these companies that I was paying existed. So things started to get really, really weird at that point. Very fishy. And, you said that I I think you were referring to, the Etsy store, but you said they transitioned from a holiday That that would be yeah. That would be the same the ecomm team that I was communicating with on WhatsApp. So they meaning the virtual assistants. And and just to clarify, it was it was someone at citiecom who was managing your Etsy store who transitioned from a holiday
holiday products to Valentine's Day embroidered custom products? Yes. Yeah. That was all their work to do, again, to pick the products. Ultimately, as of today, did Sanity Walmart seller account on your behalf? No. And I I believe you testified that at at a certain point, Sandecom did set up an Etsy account or the Etsy seller account on your behalf. Right? Do you know if There was also a no Shopify store created, which was also in the contract. Do you know approximately when the Etsy seller account was set up on your behalf? Behalf? Yeah. I believe the Etsy account as a matter of fact,
let me check. And I guess, just to save you time, sir, if you just if you can I would say November 2023? Okay. So the first sale was 11/28/2023. Now, of the one store, that was opened on your behalf, the one e commerce store, did it make a profit? If you consider the $30,000 investment, no. It never did. The total sales of all time in that store gross were, I think, around $1,700.
So that would be from November until the time the storm, the store was permanently suspended, which was May 2024. There were around $1,700 of sales, well below the expectations that Anthony Sandy placed. And, do you know why the Etsy store Etsy seller account was permanently suspended? Oh, absolutely. So I did not know this until the suspension occurred, but every single product listed on the Etsy store was in violation of Etsy's policies.
So they suspended the store Let me get that, sir. I just wanna break that down. Just to kind of, slow things down, how did you find out first that your Etsy seller account was suspended? Etsy sends an email out, and there was an email address that I had access to, but, this was also set up by, Anthony Sandy's team to manage the store. It was a generic Gmail address, and so all notifications from Etsy, Alibaba, other
basically, everything was coming into that single Gmail account. And so as, we went on toward April and May trying to coax them into, you know, more sales and what's the progress and what's the plan, what are you guys going to do. I began to look in there more frequently. And upon one of my regular check ins, I found the suspension email from Etsy. And did the email from Etsy say why the suspension was occurring? Yes. It was violations of their store policies,
and I did not want know what that meant at the time. But upon reading into that, I would like to reference Etsy's seller policy, which is available on their website. And, it specifically says Etsy is a marketplace where you can sell the items you've made, designed, and handpicked or sourced directly to buyers around the world. There's a section that says what can be sold on Etsy, and, there are certain things you need to do. If as if you sell on Etsy,
you need to provide the following information for each of your items. One, an accurate representation of how the item was made, by whom, and where it is being shipped from. Two, an accurate description of any shop members who are involved in making your items or running your business. Three, if you work with a production partner, you must disclose that production partner in your relevant listings. Four, your own photographs or video content, not stock photos, artistic renderings, or photos used by other sellers or sites. Essentially, everything that was being sold on the store was being purchased from mainly AliExpress over
in China. None of it was being created by anyone. And if you reference Etsy's website, there's a page called Etsy's creativity standards. And one of the things that they specifically say there of that you cannot do is, you cannot sell anything that is made in bulk. And, essentially, every single thing that was being sold on this store was being made in bulk with photographs from AliExpress, which again was prohibited. So, essentially, everything
violated Etsy's policies. And how did you discover that the, listings and photographs and any other material that were being used or or published on your Etsy seller account to sell products, was in violation or or or did violate any of these policies? So in this generic email address, the Google email that the team set up, there were orders for AliExpress, and you could essentially match the order at Etsy to an order at AliExpress.
You could go view that item at AliExpress. For example, Christmas wreaths or Christmas decorations were very popular, during the winter months, and you could go find those orders and those things listed in bulk. Essentially, AliExpress is like Amazon, except that's the big vendor of, like, everything over in China. Those things were being purchased there, shipped in into The United States, and then and then sent to customers. So you could easily find here's the Christmas wreath, match it to an order from AliExpress, and find all the pictures, descriptions,
everything. All of this was a sent Just copied, including photos and descriptions. And, again, all of that is expressly prohibited by Etsy. And you said that, the email from Etsy that that suspended your seller account, actually, did you say, roughly when was that that email received or when you first That was exactly 05/26/2024. Ultimately, did Syndicom ever reach out to you, ever communicate to you, about that that suspension and whether it could be resolved?
As a matter of fact, no. They didn't. Not a single person on that team reached out to me. I was the one who discovered it and alerted them. And what was the response from anyone, any agent or employee of Synd Ecom? I'm looking through some records here. Well, just off the top of your head, you know roughly approximately what what they responded with. They basically responded. So this was on 05/31 that they finally responded back to me, so May 31. So it was several days later, and they wrote back the complaints arose.
Let's see here. No. That was me. They simply wrote back the option to appeal is not available. So I have emailed Etsy regarding this issue and waiting from their response. We have not violated Etsy policies, which is completely a lie. Every single thing that they did was in violation. Ultimately, was there any resolution to the suspension of your Etsy seller account? No. Did, SendEcom or anyone at SendEcom offer to open up a store, an ecommerce store on your behalf on a different platform to substitute for the suspended one at at at Etsy? Yes. I at that point,
I wrote to Anthony. And, as a matter of fact, I had even written to him earlier than this date. I had written to him in 03/29/2024, discussing my basically, alerting him to that the performance of the stores were grossly below the expected returns that he had shown all of us. And at that point, let's see here. I had actually suggested that we that he issue me a refund and go different
ways. Anthony had offered to set up additional stores, and there was not a single thing in this business that passed the sniff test. Everything to me was just a red light, and I did not even want Anthony to set up an additional store. So my suggestion was a refund, and we part ways. Was there any response either from mister Sandy directly or anyone from sandycom to that? The group chat was essentially turned off,
and Anthony's response to he had offered the additional setup of stores. I did not want that. I wanted a refund into part ways completely. And Anthony said if I did not agree with that, then I should consult my attorney. So that was not helpful. Ultimately, how many ecommerce stores, did Tin ecom open on your behalf on any platform? One. And that was the Etsy seller account that was suspended? Yes. That's correct. So in total, how much of your your in your initial investment or your total investment in with Syndicom, were you able to recoup?
I probably through the store, maybe about 1,000 or so dollars. Of the 30,000 that was invested? Yes. And, overall, I think you mentioned it briefly before, but how did this how did this experience impact you during this time? This was catastrophic for myself and my family. I was unemployed at the time, due to a downsizing of the company that I had worked for. I was looking for work. Anthony had presented this opportunity in Steve's show, if you will.
I had a conversation with him. I had asked others in this investment group who also had conversations with him. I would guess there were maybe around 30 to 40 members of this group who took this opportunity to to work with Sandy. Everyone seemed extremely positive about it. Anthony had, even said, and I do have a quote from one of the other investors that he allowed me to share, and this is as they were reviewing the profit splits.
And I will quote this. Anthony said, this is Etsy, Facebook, and Walmart. This is what you can expect toward months nine through 12 on a monthly basis, about 7,400 after the split between all three stores. The other person whose name is Kevin said, and those are, what you're seeing on the lower side. And Anthony said, yes. These are conservative. And I quote again, Anthony said, these are more conservative. We don't want to over exaggerate what the possibilities are. So it was very clear that this was the low end and that we should
expect at least this, if not better. And myself and my family were really looking for other sources of income to get through the time that I was searching for unemployment. I was also taking care of my mom who is on fixed income through Social Security. I'm responsible for kind of maintaining, you know, some of the her costs of living. And this was catastrophic, which I tried to resolve in a gentlemanly fashion between the two of us. There was more than one email where where I proposed.
Anthony, in essence, you guys didn't do hardly anything of what you said you would do. The profits are and I actually ran a calculation. It was approximately 3% of what you told us we should expect, So absolutely horrible. And I said, why don't we part ways? But I would like you to think about a refund that you think is fair and equitable. I understand, that you and your team did some work. You didn't do all of this, but you did something. So why don't you come back to me with something that you think is fair? And at the end of that,
number one, he responded, well, we'd be happy to set up other stores. I did not want that because I didn't think that they were operating ethically at all. They're not an organized business. I think the whole thing is just a sham. Again, not being able to get a single valid report, no financials from the company, invoices were being made up, customer service was horrible, took days, if not weeks, to hear from people. I did not want to continue with other stores. I wanted a refund. And Anthony's response to that was go consult your attorney. And at any point,
prior to you signing the service agreement and statement of work, did anyone from San Diego comm disclose or or mention that that there was a risk that you might not receive virtually any of your investment back? No. No. Never. Thank you, sir. I don't have any further questions. Is there anything else you wanted to to say that I didn't cover with any of my questions? No. I think that was all. Thank you. Okay. And please stand by. There might be, additional questions. Mr. Sandy, do you have any questions to ask this witness? I respectfully decline to respond because I don't have legal representation. Okay. Thank you. Mr. Shlai, I think I just have one quick question for you.
You said you're testifying today from, the state of Washington. Is that where you were residing at the time you made your investment? Yes. That is correct. Okay. Thank you. Mister Horn, anything additional based on my one question? May this witness be excused? Yes, sir. Mister Soleil, thanks so much for taking time out of your day to appear and testify. You're free to disconnect from the conference call at this time. Okay. Thank you very much. Mister Horn, do you have an additional witness that you'd like to call today? Yes, your honor. Did you call us mister Sandy? Mister Sandy, would you like to testify today? I I respectfully just decline to testify at this time.
I'm an I'm unrepresented and not in a position to safely respond to legal or factual questions without proper legal counsel. I'm invoking my right to remain silent. Mister Horn, you could respond to that? Your honor, we're certainly not gonna the division is not gonna make him testify, but he was listed, as a witness on the division's disclosure statement, and he did not object or his attorneys, prior to the withdrawal, did not object to us listing him as a witness or otherwise say that they objected to him being considered as a witness. K. Well, he seems to object to it today,
and, I presume you you have not subpoenaed him to testify at this proceeding. So I don't think I'm going to, force him to testify if he doesn't want to. So with that in mind, mister Horn, is there another witness you'd like to present today? There's no other available witness, today, your honor. There will be tomorrow morning. Who can you, let me know what the schedule you're planning for tomorrow? Yes, your honor. Unfortunately, we just had a witness, drop another witness drop out due to illness. So Richard Hanna is the only other witness, that the division plans on calling at this point. For not just tomorrow, you mean for the For the duration of the hearing.
Yes, sir. Okay. And and what time do you expect mister Hanna to be available? I I'm still waiting to hear back. He he had a, a medical issue with his wife who's who's receiving treatment at this point. So I'm I'm hoping he'll be available at nine, but it might be, a little bit later, maybe at ten. K. It sounds like we have nothing to do except to adjourn until tomorrow morning unless there's procedural issue. Yes, Your Honor. Can I have just a moment? Actually, can we just have a brief recess, Andrew? I apologize. How much time do you think you need? Five minutes. Okay. We're in recess for five
minutes. Yeah. Let's go back on the record. Mister Horn? Governor, thank you for the break. I apologize for the delay. First, regarding mister Sandy's, objection or refusal to testify, I would just request that tomorrow morning, I'd be allowed to present a list of questions that I intended to ask, mister Sandy during his testimony and just verify with with mister Sandy the basis of his objection and, which questions, if all or any, that he's objection to testify and what the grounds are for his objections. Mister Sandy, do you wanna respond to that at all? Respectfully, I do not feel equipped to respond with that legal counsel.
Okay. I guess, mister Horn, if you wanna prepare a list of questions and present them, we can discuss them tomorrow. Beyond that, I think it's a little premature for me to make any decisions until we have something in hand. So Yes, sir. Any other procedural issues today, mister Horn? I guess, sir, one brief one. In in talking with miss Falcak, she mentioned, that there was a clarification she wanted to make regarding her testimony and regarding specifically to one of your your questions, your honor. So I would just ask the, permission for the division to recall her as a witness. Any objection, mister Sandy?
Sandy? Respectfully, I I don't have a response because I don't have legal counsel. Okay. Thank you. I suppose we can do that. Which do you wish to recall her at this time, Ms. Doran? Yes, sir. Okay. You may return to your spot from before, Ms. Valczyk, and were sworn in previously, and you remain under oath for your continued questioning now. Good afternoon. Do you recall a question from the judge regarding the restitution amounts and claims and regarding, specifically whether the the onetime initial fee,
for the was included with the restitution, amounts that you provided by the the investors that you spoke to? Yes. And, was there a clarification that you wanted to make regarding your previous answer Yes. To that question? What is that clarification? So the start up fee is part of the investment. On some of the service agreements, the startup fee was zero, and it had the investment amount. And on others, which was the one that we were specifically referring to as far as my service agreement under my undercover, it was all part of the investment. The start up fee was part of the investment.
So was the overall restitution claims that these the investors that you spoke to, were making, did that include did that was that encompassing of all of fees that they were seeking restitution for? For both sections, yes. Was there any other clarification No. Thank you. No further questions. I may be opening up another can of worms, but, since you're testifying on the subject, the restitution amounts that you had testified to earlier, are those do those include a reduction for any amounts those investors may have received,
as payment from their stores? One of them did, and I looked at the one that testified today, and his did not include the thousand dollars. Based on his testimony I know you're not the one who's going to make the decision on behalf of the division, but based on your having testified previously as to the amounts of restitution, now having heard, mister Soleil's testimony, do you believe that reduces the amount of restitution owed to mister Soleil that you had testified to earlier? Yes. By the $1,000. Which of the other investors? I believe you said that there was an investor who had received restitution,
would have a restitution reduction, which of the investors would that be? It was Debbie Peterson, and hers was $695 Bear with me a moment while I No worries. Double back to my notes. I think you said her original when you testified previously, you said her restitution amount would have been 15,000, so it would be 15,000 less than 695? Yes. Okay. I think that answers my questions. Mister Horn, do you have anything additional based on my questioning? I just won, Your Honor. Now the overall restitution amount I can give you two questions.
Of the overall restitution amount for all the investors that you spoke to, I think you said it was around $180,000 It was, yes. In that total both the total overall and the individual totals, for miss Peterson, did you already factor in when you gave a specific restitution amount for her? Did you already factor in that that $605.95 dollars, that she was able to recoup on in sales? So I during the my testimony, I said a 180,000 just to give the estimate.
But on my spreadsheet, I have the 695 listed on there that would come off as part of her restitution. Okay. So the original figure that you gave for miss Peterson as to the amount of restitution she was claiming, that already that it was already included deduction of the 690 It would hers was, like, 14,300 and something. Okay. Yes. So your your original, restitution figure for her, though, already included the who recouped sales figure? On my spreadsheet, but in the amount that I testified to,
180,000, it included her full 15,000. Okay. I didn't take out the 695. Okay. But in the individual amount for her, when you testified previously, that that accounted for her sales, what sales she could recoup? Yes. On my spreadsheet. Okay. Yes. Okay. Thank you. Mhmm. K. So if I understand correctly, restitution total as revised based upon what investors received through their stores would be $180,000 minus $16.95 dollars Yes.
Okay. And per my calculator, that would be 178,305 thousand dollars Does that sound correct? That sounds right. Okay. Mr. Hornton, anything additional based on my questioning? There you go. Mr. Sandy, do you have any questions you'd like to ask based on my questioning? No. Thank you. May the witness step down? Yes, sir. Thank you for your clarifications, Mr. Vowelczyk. You may resume your spot at the table. Mister Horn, is there anything additional, you have today? No further witnesses, doctor. No further procedural matters from the division. K. Mister Sandy, do you have anything you'd like to place on the record, procedural issue or statement,
today? Just to get on the record, I didn't participate because, or at least participate more because I don't feel equipped due to not having legal counsel. K. Thank you. Mister Horning, your next witness, you believe, is at nine? Yes, sir. I will confirm, this afternoon, and, I don't know if you prefer I I email, someone at the division at the hearing division, to just provide confirmation prior to tomorrow morning. Yes, this I I I guess I have no qualms starting at either nine or ten or whenever
would be best for your witness. Can we you expect in to know that, at some point this afternoon Yes. Perhaps? Will you be able to get in touch with mister Sandy and let him know as well? At least via email. Yes, sir. You won't be able to accept the an email that you've received email from Yeah. Email. School. Okay. Alright. And and I guess you can email the hearing division, and that'll get back to me. And, I'm going to I I guess, I will adjourn us until nine. However, with the caveat that if I receive an email, saying that we'll be won't have a witness until ten,
we'll resume at ten. And, I I guess I'll alert the broadcast division, so they'll be informed. I think that's as clear as I can make it until we hear for something further. So, so we are adjourned until nine possibly ten. Thank you. Thank you, Aaron. I will alert hearing the vision to alert