The following declaration sworn by FBI Special Agent Jill Enyart makes

clear that the 1MDB theft is an ongoing criminal investigation.The FBI make
clear that it fears for the safety of witnesses, including law enforcement
personnel involved in the 1MDB investigation.The declaration is attached to
the recent DOJ stay application with regards its 1MDB theft related asset
seizures.

DECLARATION OF JILL ENYART

I, Jill Enyart, declare and state as follows:

1. I am a Special Agent with the Federal Bureau of Investigation (FBI). I have

read the foregoing Notice of Motion and Motion For Order Staying Civil Forfeiture
Proceedings For All Purposes Except the Filing of Timely Claims and Answers, and
know the contents thereof. The matters contained in the Motion are true to the best of
my knowledge and belief.

2. I am familiar with the allegations set out in the First Amended Complaint (FAC) in
this action, and the scope and subject matter of the related, ongoing criminal
investigation. The sources of my knowledge and information concerning the
investigation are official files and records of the United States, publicly available files
and historical information, information made known to me by other law enforcement
officers, experts, and government lawyers, as well as my own personal involvement in
the investigation, together with others, as a Special Agent of the FBI.

3. The government commenced a criminal investigation of the events described

in the FAC prior to the commencement of this and the related actions. The
criminal investigation remains ongoing.

4. The related criminal investigation is global in scope because the underlying crimes
were committed over several years in numerous jurisdictions. Perpetrators, which
includes both entities and individuals acting in individual and representative
capacities, are believed to have committed violations of both U.S. and foreign
laws. A significant amount of the evidence and Case 2:16-cv-05362-DSF-PLA
Document 121 Filed 08/10/17 Page 21 of 23 Page ID #:1236 2 1 2 3 4 5 6 7 8 9 10 11
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 witnesses with knowledge of these
violations are located in foreign jurisdictions, and will take time to pursue.

5. I believe that disclosure of any facts beyond those set forth in the FAC, whether in
response to discovery requests or otherwise, will have an adverse effect on the
1
governments ability to conduct the ongoing criminal investigation. Such disclosures
are likely to reveal potential targets and subjects of the investigation and the
investigative techniques that have been and will be used in the investigation.
Such disclosures could result in the destruction of evidence, flight of potential
subjects and targets, or the identification and intimidation of potential witnesses.
In fact, potential witnesses with knowledge of the criminal conduct and other
facts set forth in the FAC may live in jurisdictions where their safety and security
could be in jeopardy if their identities are disclosed through civil discovery in this
and the other related cases.

6. In addition, proceeding with discovery in this and the related cases could lead to the
disclosure of information relating to the sources of evidence from whom the government
obtained evidence, including foreign jurisdictions. The disclosure of such information
could prejudice those jurisdictions plans, jeopardize the safety of certain foreign
law enforcement personnel and threaten their willingness or ability to cooperate
with the government in its criminal investigation, thereby closing off sources of
evidence of the criminal and other conduct set forth in the FAC. Case 2:16-cv-
05362-DSF-PLA Document.