Prosecutors in the criminal case against Sam Bankman-Fried, the founder of the collapsed cryptocurrency exchange FTX, on Monday provided the most detailed account to date of the evidence they plan to use to convict him at trial in October.
In a 70-page court filing, prosecutors said they would seek testimony from some of Mr. Bankman-Fried’s closest advisers, as well as an expert witness and other employees of FTX and Alameda Research, a crypto hedge fund he also founded.
Prosecutors also said they plan to use notes taken by Caroline Ellison, one of Mr. Bankman-Fried, after talking to him, included a memo titled “Things That Make Sam Nervous.” And they said they would introduce a recording of a meeting where Ms. Ellison told the Alameda employees that he worked with Mr. Bankman-Fried to siphon funds from FTX customers’ accounts.
Mr. Bankman-Fried, a one-time crypto mogul who built FTX into one of the world’s largest virtual currency exchanges, was arrested in December and charged with orchestrating a sweeping scheme to use customer deposits to finance purchases of real estate, charitable giving and donations to politicians. Ms. Ellison and two other top FTX executives, Gary Wang and Nishad Singh, pleaded guilty to participating in the effort and agreed to cooperate with prosecutors.
Mr. Bankman-Fried is facing seven charges of wire fraud, securities fraud, commodities fraud and money laundering. He has pleaded not guilty and is scheduled to go on trial on October 2. Last week, he was sent to jail after the judge overseeing the case revoked his bail over allegations he was trying to intimidate witnesses.
A spokesman for Mr. Bankman-Fried. A lawyer for Ms. Ellison did not respond to a request for comment.
Prosecutors’ filing Monday argued that the evidence they gathered should be legally admissible at Mr. Bankman-Fried. The evidence included financial records, spreadsheets, Google documents and private communications, according to the filing.
The lawyers of Mr. Bankman-Fried submitted their own memo on Monday, saying prosecutors have “repeatedly failed” to meet deadlines for turning over evidence to the defense. Just three days earlier, the filing said, prosecutors produced nearly 750,000 pages of Slack messages from Mr. Wang. They said the government should not be allowed to use evidence produced in the defense after July 1, and other material, including evidence related to Mr. Bankman-Fried from FTX, should also be left on trial.
“The defense does not have unlimited resources and should spend the limited time remaining before trial preparing its defense rather than reviewing productions at the eleventh hour,” the filing said.
Over months of investigation, prosecutors have amassed millions of pages of evidence as they prepare for Mr. Bankman-Fried, one of the largest troves collected in a white-collar securities fraud case brought by federal authorities in Manhattan.
The government’s court filing Monday offered the first detailed look at the evidence and witnesses that prosecutors plan to introduce at trial. The government plans to cite spreadsheets maintained by Ms. Ellison, Mr. Singh and Mr. Wang “monitored illicit money flows between Alameda and FTX,” the filing said, and to discuss FTX advertisements that appeared on TV.
Prosecutors also plan to cite Mr. Bankman-Fried as evidence for fraud charges. The filing cited a text message sent by a high-ranking FTX executive, Ryan Salame, to a family member in November 2021, describing Mr. Bankman-Fried used political donations to promote cryptocurrencies in Washington.
The purpose of the donations is to “remove anti crypto dems for pro crypto dems and anti crypto repubs for pro crypto repubs,” Mr. Salame wrote in the message. He added that Mr. Bankman-Fried will “bring money to me to get rid of the republican side.”
Mr. Salame has been under investigation for months, culminating in a raid on his home in April, though he has not been charged with any crimes. The filing said he was “unavailable as a witness” because his attorney invoked his Fifth Amendment right not to offer self-incriminating information.
A lawyer for Mr. Salame did not respond to a request for comment.
But Ms. Ellison, Mr. Singh and Mr. Wang is all expected to testify, the filing said. Prosecutors said they will also call other former FTX and Alameda employees, including someone who “regularly consulted with the defendant about FTX’s fundraising efforts.”
The testimony from Ms. Ellison in particular is likely to be crucial to the prosecution’s case. In addition to running Alameda, Ms. Ellison was in an on-and-off romantic relationship with Mr. Bankman-Fried.
The filing provides a transcript of a meeting held by Ms. Ellison with Alameda employees in November 2022, as FTX and Alameda collapse amid a run on deposits. According to the transcript, an employee asked Ms. Ellison decided to take customer funds.
“Um … Sam, I think so,” he replied.
Matthew Goldstein contributed reporting.