18. Throughout the conspiracy, the conspirators submitted false documents to
banks when applying for loans, including fabricated bank statements listing
inflated account balances, personal financial statements containing false
information about available funds, false invoices, and false audit paperwork. For
example, on or about November 5, 2007, Co-conspirator A sent an email to a
bank that copied TODD CHRISLEY attaching a personal financial statement that
falsely claimed TODD CHRISLEY had $4,000,000 at Merrill Lynch. When the
bank employee requested account statements, Co-conspirator A sent TODD
CHRISLEY a fabricated bank statement showing that TODD and JULIE
CHRISLEY had $776,509.52 on deposit at Merrill Lynch. In response, TODD
CHRISLEY told Co-conspirator A, “you are a fricking genious [sic]!!!! Just make it
show 4 mil+.” In actuality, TODD and JULIE CHRISLEY did not have a Merrill
Lynch bank account at that time, and, after they later opened one in 2008, they
never had more than approximately $17,000 on deposit there. As a result of false
representations like these, a number of banks issued the conspirators millions of
dollars in loans, much of which TODD and JULIE CHRISLEY used for theft own
personal benefit.

19. At various points during the conspiracy, TODD CHRISLEY personally
directed Co-conspirator A to send false information to banks. For example,
when one bank provided notice in April 2008 that it would not be able to renew a
loan without updated financial information, TODD CHRISLEY instructed Co
conspirator A, “please get her the financials and I will get her the rest.” After
Co-conspirator A responded, “I don’t have financials on any of these. She has
6
Case 1:19-cr-00297-UNA Document 1 Filed 08/13/19 Page 6 of 27
tax returns,” TODD CHRISLEY wrote, “stop telling me this shite, create them like
you always have, if I don’t get these then they want [sic] renew the loans.”
When another bank provided notice in 2008 that it needed updated financial
information, Co-conspirator A told TODD CHRISLEY that he! she needed
assistance in putting the requested financials together. This prompted TODD
CHRISLEY to write, “giving me an excuse as to why you can not [sicj figure this
out does not move it off of your plate, this is not what we discussed, passing it
back and forth is not getting the results requested, if you do not know how to do
this then find a crooked accountant to do it. Ask [redacted] who her guy uses for
his crooked shite.”

20. The conspirators continued sending false information to banks even after
receiving the initial loan disbursements. At times, they did so in hopes of
renewing certain loans. At other times, they did so to conceal their financial
difficulties and to prevent the banks from seeking legal remedies to recoup the
outstanding loan balances. For example, on August 27, 2009, a bank
representative notified TODD C~-IRISLEY and Co-conspirator A that “[tjhe last
personal financial statement we have in file (June 09) looks a lot like the
12/31/08 statement we received. (cash, securities and real estate all exactly the
same) .... We have a review coming up and would like to show this accurately
so that no one asks questions as to how these could all be exactly the same 7
months later.” TODD CHRISLEY forwarded this message to Co-conspirator A
and stated, “bring the securities down significantly.” The bank representative
further notified TODD CHRISLEY and Co-conspirator A that “[w]e have a FDIC examination beginning on Monday, Sept. 14 and your file will be one they will
review. Any assistance that you can provide here to update your statement
would be appreciated.” TODD CHRISLEY forwarded this message to Co
conspirator A and stated, “this is why that pfs [personal financial statement]
needs to reflect what you sent reigions [sic] and the FDIC.” Similarly, when
attempting to provide evidence of available funds in April 2012 to a lender,
JULIE CHRISLEY forwarded a copy of a check to Co-conspirator A and TODD
CHRISLEY and instructed Co-conspirator A that the “[p]ost date is the only
thing that needs to be changed.” The attached check stated that it had posted to
a bank account on February 8,2012. TODD CHRISLEY then instructed Co
conspirator A to “make sure this is perfect before you send it to [REDACTED] as
there cant be a screw up and she looks at this stuff fairly close.” Shortly
thereafter, Co-conspirator A emailed TODD CHRISLEY an altered copy of the
same check falsely showing that it had posted to the bank account on November
1,2011.

22. Once it became clear that Chrisley Asset Management was insolvent and
the conspirators could no longer pay back the outstanding loans or obtain new loans, TODD and JULIE CHRISLEY sought to hide their involvement in the•
conspiracy by falsely claiming that they did not know that Co-conspirator A had
submitted false documents to financial institutions. For instance, in an August
14,2012 sworn affidavit, TODD CHRISLEY falsely asserted that Co-conspirator
A had used their accountant’s stationary and signature without the knowledge
or consent of TODD CHRISLEY or the accountant. However, approximately
three months earlier, TODD CHRISLEY emailed Co-conspirator A, asking,
“[C]an you place this on [the accountant’s] letterhead with his signature and then
sign Julie’s name below [the accountant’s]? address the letter to whom it may
concern.” Shortly thereafter, Co-conspirator A sent an email to a lender that
copied TODD CHRISLEY attaching letters purportedly signed by the accountant
and JULIE CHRISLEY.

This post was edited on 8/14/19 at 11:37 am