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Case 3:19-cr-00028-JAM Document 37-1 Filed 03/18/20 Page 1 of 14

Fair Market Value Appraisal Report

United States v. Harold Gordon


Case No. 3:19CR28(JAM)

FAIR MARKET VALUE:


$2,500

Effective Date:
6 June 2019

Prepared on 15 July 2019 by:


Jennifer Garland Ross, AAA

Art Peritus, LLC


143 West 29th Street, Seventh Floor • New York, NY 10001
telephone: 212.566.6626 • info@artperitus.com
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TABLE OF CONTENTS

I. TITLE PAGE PAGE(S) 1

II. TABLE OF CONTENTS PAGE 2

III. STATEMENT OF WORK PAGE 3-5

IV. VALUATION SUMMARY PAGE 6-10

V. SPECIALIST BIOGRAPHY PAGE 11

VI. DISCLAIMER, LIMITING CONDITIONS AND ASSUMPTIONS PAGE 12-13

VII. AFFIDAVIT PAGE 14

EVERY PAGE OF THIS DOCUMENT IS AN INTEGRAL PART OF THIS APPRAISAL AND THEREFORE,
SHOULD NOT BE SEPARATED

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SCOPE OF WORK: APPRAISAL METHOD & DEFINITION OF VALUE

PROBLEM TO SOLVE: ART PERITUS was asked to examine an antique American secretary that was later embellished and faked as a commemorative folk-art
secretary called the “Bingham Secretary” to establish fair market value for the work.

CATEGORIES OF ITEMS EXAMINED: American Furniture

CLIENT: Department of Justice, Samuel D. Wharton, Special Agent FBI New Haven, 600 State Street, New Haven, CT 06511, and

Harold Chen, U.S. Attorney’s Office, 1000 Lafayette Boulevard, 10th Floor, Bridgeport, CT 06604

OWNER: Allan Katz Americana

OWNERSHIP INTEREST/ART LOSS REGISTRY: The question of title was not an issue. As such, the appraiser did not do a title search with Art Loss Registry.

EFFECTIVE DATE OF APPRAISAL: The Value expressed in this appraisal is effective as of the date of inspection 6 June 2019.

USE OF APPRAISAL: Court testimony

USER(S) OF APPRAISAL: This appraisal can be used and relied upon by the client and a designated broker, agent, accountant, attorney, and/or underwriter. Any
other user is considered an unintended user

GENERAL ASSIGNMENT CONDITIONS AND METHOD OF EXAMINATION: Appraiser Jennifer Garland Ross examined the works in person at 21 North Plains
Industrial Road, Wallingsford, CT on June 6, 2019. Examination consisted of visual inspection to identify medium, style, quality, date and condition. Items
were not deconstructed during inspection.

SPECIFIC ASSIGNMENT CONDITIONS (ASSUMPTIONS): Appraisers were given adequate time to research the items. The following assumptions were taken by
the Art Peritus and its specialists as facts. If these assumptions are found to be untrue, the appraiser’s opinions and analysis, including, but not limited to value,
will not be affected.

The appraisers assume the mediums to be as represented. A scientific analysis of the chemical compounds of the materials were not conducted as the
correct medium was apparent.

SPECIFIC ASSIGNMENT CONDITIONS (EXTRAORDINARY ASSUMPTIONS): The following extraordinary assumptions were taken by the appraiser as facts. If these
Extraordinary Assumptions are found to be untrue, the appraiser’s opinions and analysis, including, but not limited to value, may be affected.

The appraisers assume any information provided by the client, written or verbal, to be accurate and correct.

The appraisers assume that these articles are not now, nor will they ever, be substituted with other articles.

The appraisers assume the Allan Katz Americana retains full title to the works and all inherent rights to these works, except as indicated.

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SPECIFIC ASSIGNMENT CONDITIONS (LIMITING CONDITIONS): The following Limiting Conditions exist in this assignment. These conditions limited the
examination, research, and/or writing of the Appraisal Report. Some are also considered to be Extraordinary Assumptions and were taken by the appraisers
as facts. If these Limitations and Extraordinary Assumptions are found to be untrue, the appraisers’ opinion, including the opinion of value, may be affected.

The report is limited by the factual and relayed information supplied by the client and owner.

The appraisers did not remove all works from the wall due to their size or location. The appraisal is limited by what appears on the recto. Works not
examined on verso will be identified as such in the individual descriptions.

The appraisers did not examine undersides, and back rails of furniture for signatures and condition (when applicable) (This is also considered an
Extraordinary Assumption).

The appraisers did not remove all drawers (This is also considered an Extraordinary Assumption).

The appraisers did not move heavy furniture to thoroughly examine for condition (when applicable) (This is also considered an Extraordinary
Assumption).

The appraisers did not examine each work under mounts or protective bases/backings if not readily removable for condition (This is also considered
an Extraordinary Assumption).

PHOTOGRAPHY: No photographs have been altered (except cropping) or modified unless noted.

TERMINOLOGY: The language and terminology used in this report is based upon the generally accepted conventions of descriptions used by the major auction
houses.

METHOD OF RESEARCH: According to USPAP Standard 7-4e, objects bearing the most significance to the assignment result will be the subject of greater and
appropriate depth of research and analysis. Items of inconsequential value will be included without significant description, research, or analysis.

Research was conducted in the offices of Art Peritus which are equipped with an extensive library of research books and auction catalogues. Additional
research was conducted on the Internet using standard search engines as well as pricing databases to which Art Peritus and the listed specialists subscribes
(including artnet, invaluable, artprice, askart, artinfo, p4a, and antiqueclockpriceguide.com). Appropriate galleries, auction houses, and artists were contacted for
information when necessary. Minimal outside library/museum research was conducted for this specific assignment. Consultation with an Americana specialist
was performed for this appraisal and for content in the Market Analysis. However, the consultant was not involved in the final determination of value.

APPROACH TO VALUE: The appraisers considered all three approaches to value. Given the items and the purpose of the assignment, each employed the
"market comparison" approach to arrive at the appraised “fair market value". The "income" approach was not considered appropriate because the items at
present are not income-generating. The “cost” approach was not considered appropriate as there is no need to determine value of the subject property
based on the cost of manufacturing or recreating an identical object at this time.

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DEFINITION OF MARKET DATA COMPARISON APPROACH AND MARKET EXAMINED: The "market data and sales comparison" approach analyzes recent sales of
comparable articles at major international and regional fine art auctions, private and public sales, shows and exhibitions, as well as prevailing prices at retail
shops and galleries where the article may normally be traded. For this particular Appraisal Report, the appraisers primarily examined the appropriate
International gallery and auction markets. Adjustments are then made for each article which consider age, condition, rarity, artistic merit, technical workmanship,
current trends and availability of an article as compared to such recent sales.

TYPES OF VALUATION: Appraised “fair market value” (FMV) as defined by IRS Section 1.170 and 20.2031 (b) is “the price at which the property would change
hands between willing buyer and willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts:
According to Technical Advisory Memorandum 9235005 (May 27, 1992), fair market value should include the buyer’s premium.

VALUATION PROCEDURES: The estimate of value of the property described in this report has been determined on the basis of the following criteria and
procedures:

1. Identification – an essential initial step in the appraisal is the identification of each item as to:
a. Authenticity or authorship
b. Regional origin
c. Style
d. Materials
e. Period and date
f. Provenance, when available

2. Qualitative assessment – after identification of property has been completed can assessment be made of:
a. Artistic merit or desirability
b. Rarity or scarcity
c. Quality
d. General attractiveness
e. Suitability

APPRAISAL FEE: Compensation for this appraisal is not contingent upon the report of a predetermined value or in direction of value that favors the cause of
the clients, the amount of the value estimate, the attainment of a stipulated result, or the occurrence of a subsequent event. The fee is based on an
hourly/project/etc. rate, plus expenses. Any discounts given were as a courtesy to the client via their relationship with a preferred organization. However, no
person, group, or organization was given a fee in connection with the procurement of this appraisal assignment.

ETHICAL STANDARDS: This appraisal has been prepared in conformity with, and is subject to the requirements of the Principles of Appraisal Practice and Code
of Ethics of the Appraisers Association of America, Inc.

USPAP COMPLIANCY: The report was written by Jennifer Garland Ross, whose USPAP qualification is valid through 8 February 2020. This Appraisal Report
follows the guidelines of 2018-2019 USPAP in that the report provides all of the necessary information/analysis to satisfy the “current” report development
requirements as defined in Standard 7 (Personal Property, Development) and the writing requirements of an Appraisal Report as defined in Standard 8
(Personal Property, Reporting).

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VALUATION SUMMARY

American Step-Back Secretary


The cabinet late 19th century, all embellishments late 20th/early 21st century by Harold Gordon,
Known as the “Bingham Family Civil War Memorial Secretary”
Walnut, maple, tiger maple, oak, engraved and applied bone, horn and abalone
96.75 in high, 42.25 in wide, 23.5 in deep

Provenance:
Harold Gordon
Allan Katz Americana
Wadsworth Atheneum, Hartford
Allan Katz Americana

FAIR MARKET VALUE:

$2,500

BEFORE embellishments AFTER embellishments


added by Harold Gordon added by Harold Gordon

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Market/Comparables Analysis:
Americana is generally defined as furniture, folk art and decorative arts (including but not limited to silver, ceramics, glass, textiles, wooden objects & implements
and metal wares) made in America – for American use – from the late Seventeenth Century to the early Twentieth Century. The height of the Americana
market was prior to the fall of 2008, when prices fell – often considerably – and which generally have not rebounded to pre-2008 levels. In addition to lower
prices, the market has contracted, with several long-standing collectors dying or selling off collections and increasingly fewer buyers entering the market,
particularly at the higher end. This phenomenon has also been witnessed by smaller representations of Americana at leading art fairs in the United States, as
discussed in “Where Is The Americana In Americana Week?”, Antiques and the Arts Weekly, 23 October 2018.

The purpose of this appraisal is to provide a fair market value for this secretary given its recent history identified as a period secretary embellished to deceive
as a period Civil War memorial work of folk art. This secretary started its life in the late 19th century as a simple, unadorned American walnut, maple and
oak step-back secretary. Such a piece in today’s softened market has very little value or importance and would likely sell on the open market for $500 as
can be seen in the four comparables listed directly below:

Comparables Without Embellishments:

American Carved Cherry Step-back Wall American Cherry Two-Piece Chest American Walnut Stepback Secretary American Step Back Pennsylvania Dutch
Cupboard, Mid-19th Century with Step-back Cupboard Top 89.5 in high, 51 in wide, 18.5 in deep Cupboard, Chester County, 1790-1820s
Possibly Ohio 91.75 in high, 48.5 in wide, 21.5 in deep 90 in high, 54 in wide, 20.5 in deep
90.5 in high, 55 in wide, 15.25 in deep
Jeffrey S. Evans & Associates, Mt. Crawford, Langston Auction Gallery, Wilson, Kaminski Auctions, Beverly M, 14 Oct Ransberger Auction, Watauga, TX, 3 Jun 2006,
VA, 22 Jun 2019, Lot 1554 NC, 4 Jul 2012, Lot 534 2017, Lot 2248A, Est. $1,000- $1,200 Lot 350, Est. $1,000- $1,200
Sold for $498 (including premium) Sold for $920 (Including premium) Sold for $687.50 (including premium) Sold for $1,800 (Including premium)
NOTE: Sale was before market decline

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Americana collectors typically follow several criteria – known in the field as ‘points of connoisseurship’ – when buying furniture and decorative arts: provenance
(history), rarity, craftsmanship, ornamentation, design, and original condition. In those relatively few instances where Americana lots have sold at auction at
prices commensurate with pre-2008 levels, works could be characterized by at least one, if not more, points of connoisseurship desirable to collectors. For the
purposes of this Market Analysis, the points of connoisseurship relevant to the Bingham Secretary are as follows: original condition, ornamentation, rarity and
provenance.

Original Condition
In most cases, original condition is the most salient factor driving a buyer’s initial interest and indicating whether or not additional parameters are met that
dictate closer inspection. Pieces in original, untouched condition are valued more highly than those which have been restored, including but not limited to
repairs of broken parts, replacement of missing elements, repainting or regilding, or updating to accommodate changing fashions and tastes. Accommodations
are occasionally made for honest repairs or restorations made in the lifetime of an object that reflect its history and typical and normal use.

Those items that demonstrate unusually little wear despite age and use, and which have survived in fully original condition, often warrant a premium in the
Americana market and preference among collectors. Examples of the above can be seen in the following:

A William & Mary diminutive paint decorated pine chest of drawers, signed by Robert Crossman, Taunton, Massachusetts, dated 1729, from the collection of
Mrs. J. Insley Blair, Christie’s NY, 21 Jan 2006, Lot 519, Sold for $2,928,000 against an estimate of just $500,000-800,000.
The Fisher Fox Tea Table at Christie’s NY, 3 Oct 2007, Lot 94, Sold for $6,761,000 against an estimate of just $2-3M.
The Mansfield-Merriam Pilgrim Century Wainscot Chair, Sotheby’s NY, 18 Jan 2018, Lot 723, Sold for $375,000.
The Powel-Griffits family Queen Anne compass seat side chair, Christie’s NY, 18 Jan 2019, Lot 1233, Sold for $348,500.

Ornamentation
Works of Americana that exhibit more original ornamentation typically bring higher prices at auction than those that are comparatively plainer. This is because
the additional effort of the cabinetmaker would have been an extra cost to the original owner.

Items that have been considerably altered, either from original form or because of additional ornamentation, may retain market value and interest among
Americana collectors only if the augmentation expresses the history of the piece or if the additional ornamentation adds to the artistic expression of the piece.

Examples of this can be seen in the works of Ralph Cahoon, an American folk artist living and working on Cape Cod, from the 1950s until his death in 1982.
Cahoon took what were primarily ordinary pieces of furniture of modest or low value and transformed them into whimsical pieces with various decorative
painting. Cahoon’s painted furniture and folk art paintings often incorporated mermaids and were sought after by prominent Americana collectors, including
Jacqueline Kennedy Onassis, Paul Mellon and members of the DuPont family. The market for Ralph Cahoon’s works has dropped significantly for two reasons:
the 2008 market drop that affected art and antiques markets globally and the 2007 death of a leading dealer of Cahoon’s works.

Had the ivory, bone and horn inlay on the Bingham secretary been original, it would have significantly enhanced the value of the otherwise unadorned secretary.

Removal of ornamentation
Items in which ornamentation – original or otherwise - is removed will, in almost all instances, lose value. While an American example of this is not readily
available, the phenomenon extends to furniture made in other countries and can be aptly demonstrated by an important English Chest of Drawers by Thomas
Chippendale for which the original ivory inlay was removed prior to sale due to restrictions on ivory. The piece originally sold in 1991 for a record price of
£935,000 and was expected to make upwards of £5 million when reoffered in 2018. However, removal of the ivory most likely caused the work to fail to sell.

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Rarity
Collectors frequently want items that are rare but an item that is singular or unique – without comparable examples – can deter buyers who may need
reassurance of an item’s value, particularly for higher-priced items.

Provenance
Value can be added to an item when the history of the item includes its original owner, or an owner of historical prominence or a collector of renown.
Examples of this can be seen in the following sales:

The Waln-Ryerss Family Queen Anne carved mahogany side chair, Philadelphia, carving attributed to the Garvan Carver, circa 1760, Christie’s NY, 4 Dec 2003,
Lot 1, Sold over the estimate for $679,500.
The Important Matthew Brady studio carved oak armchair, Made by Bembe & Kimbel, NY, Circa 1857, Bonhams, 26 Oct 2015, Lot 1215, Sold for $449,000.
The Important Burnham-Manning family Chippendale carved and figured mahogany bombe bonnet-top chest-on-chest, probably Salem, Mass., Circa 1770,
Property from the Collection of Irvin & Anita Schorsch, Sotheby’s NY, 20-22 Jan 2016, Lot 697, Sold for $970,000.

Comparable Folk-Art Furniture:


The four comparable pieces listed below represent works of folk-art furniture that retain some, but not all, of the elements of the ‘points of connoisseurship’
mentioned above.

Tramp Art Military Desk Antique Folk Art Child’s Chest American Folk Art Parquetry Inlaid Buffet, Inlaid Cherrywood Folk Art Chest of
Made by Civil War Veteran Stephen M. Inscribed "Made and Presented by Early 20th Century Drawers, Mid-19th Century
Miles, Late 19th/Early 20th Century father to Ada Seatrer" 52 in high, 42 in wide Third drawer with sunburst and "E. Miles",
95% of existing tramp work original 22 in high, 29 in wide, 10 in deep 44.75 in high, 43.625 in wide, 17 in deep
68.75 in high, 25.75 in wide, 15 in deep

Dan Morphy Auctions, Denver, PA, 25 Feb MV Auctions, Buzzards Bay, MA, 30 Mar John McInnis Auctioneers, Amesbury, MA, 2 Neal Auction Company, New Orleans, 12
2017, Lot 869, Est. $1,000- $2,000, Unsold 2008, Lot 72, Est. $2,000- $3,000 Mar 2012, Lot 449, Est. $200- $400 Feb 2011, Lot 387, Est. $3,000- $5,000
Sold for $3,600 (Including premium) Sold for $295 (Including premium) Sold for $13,530 (Including premium)

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The key difference between the comparable works above and the “Bingham Secretary” is that the when the Bingham Secretary was believed to be authentic
and completely of the period, it appeared to have hit all the key points of connoisseurship necessary to be marketed and sold as a rare and important
representation of civil war folk art memorabilia. Those ‘points of connoisseurship’ are what is needed to create a competitive market and subjective pricing.

Conclusion:
To repeat, the purpose of this appraisal is to provide a fair market value for this secretary given its recent history identified as a period secretary embellished
to present as a period civil war memorial work of folk art. Given that the “Bingham Secretary” no longer carries any of the points of connoisseurship necessary
for a folk-art buyer, that market can no longer be considered in valuation. Some might even argue that the work should be destroyed as it is considered a
fake and should not reappear mis-catalogued on the open market. Whereas this appraiser does not fully disagree with that opinion, much could be learned
by comparing the techniques of the “fake” with other works that may appear in the future. Additionally, the work does still retain a value on the decorative
market. This value is still somewhat subjective, however, given the elaborate ornamentation, together with its added notoriety as a fake, and values for the
folk-art style works listed below, it is this appraiser’s opinion that a current Fair Market Value would fall at $2,500.

Comparables in a Folk Art Style:

Folk/Tramp-Art Style Cabinet Folk Art Desk with Cabinet Top, American Folk Art Three-Part Cabinet, Early Baker American Folk Art Style Painted Cabinet,
71 in high, 31 in wide Bench-Made, 20th Century 20th Century, Attributed to Van Patten Williamsburg Reproduction
88 in high, 30 in wide, 18.5 in deep 89 in high, 55 in wide, 20 in deep 93.5 in high, 79.75 in wide, 21.5 in deep

William J. Jenack Auctioneers, San Rafael Auciton Gallery, San Hutter Auctions, NYC, 25 Aug 2016, Lot 94, Susanin’s Auctions, Chicago, 14 May 2011, Lot 961057,
Chester, NY, 16 Feb 2014, Lot 73 Rafael, CA, 26 Oct 2014, Lot 843, Est. $1,000- $1,500 Est. $1,000- $1,500
Sold for $1,573 (Including premium) Est. $400- $800, Unsold Sold for $615 (Including premium) Sold for $1,905 (including premium)

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SPECIALIST BIOGRAPHY

Jennifer Garland Ross, AAA


Jennifer Garland Ross is the Founder and Managing Director for Art Peritus, LLC, an art advisory and appraisal consortium comprising of over forty high-level
specialist appraisers and advisors covering all areas of fine and decorative arts, jewelry and wine providing services for Insurance Companies, Museums, Bank &
Trust Officers, Corporations, and Private Collectors.

Prior to opening Art Peritus, Jennifer began her arts career in 1997 after leaving a successful position as the chief administrative officer for a multi-million-dollar
consulting firm. She moved to London, England where she earned a post Graduate Diploma in 17th & 18th Century Decorative Arts, and a Master’s Degree
in Fine and Decorative Arts from Sotheby’s Institute, and the University of Manchester. Whilst studying in London she was offered a position at The Historic
Royal Palaces Textile Conservation Studio, at Hampton Court Palace, gathering and consolidating information on State Beds in Country Houses throughout
Britain. She also took a part-time sales position in the London showroom of La Maison, an establishment specializing in 18th Century French and Italian beds.

Upon returning to New York after graduate school, Jennifer was hired as a specialist in the European Furniture and Decorative Arts Department at Christie’s
East, where she was responsible for monthly sales, each comprising of approximately 300-500 lots of furniture and decorative arts. When Christie’s East closed,
Jennifer was integrated into the European Furniture Department at Rockefeller Center where she remained until December of 2002 when she left to start her
own consulting business, J. Garland Ross Antiques.

J. Garland Ross Antiques started initially with brokering antiques and exhibited at antique shows throughout the country including the Miami Beach and NY
Armory Antiques Shows, and in gallery spaces at Harbor View Antiques Center, Stamford, CT, and The Showplace in NYC. During the first five years Jennifer
focused on sales and consulted regularly with Doyle New York and Christie’s Auction House as a valuation’s specialist. However, in 2007 Jennifer was retained
as an appraiser, specialist and qualified legal expert witness of European Furniture and Decorative Arts, for a complex court case; which in turn redirected her
business focus to appraising, and the eventual opening of Art Peritus, LLC.

Jennifer is Certified member and former Board member of the Appraisers Association of America; has a Master’s Degree in Fine and Decorative Arts from
Sotheby’s Institute, London and the University of Manchester, UK; and has over 12 years of experience at Christie’s Auction house as a European Furniture
specialist and on-call consultant. For the past seven years Jennifer, has served on the continental furniture vetting committee for the Winter Antiques Show in
NYC, as well as serving on the committee for the International Art & Antiques Show in NYC, and most recently for the new TEFAF show in NYC. Jennifer
has published several articles and led seminars on furniture identification and authentication and in February 2018, she updated her USPAP (Uniform Standards
of Professional Appraisal Practice) status, granting her a qualified USPAP compliant appraiser.

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DISCLAIMER, LIMITING CONDITIONS, AND ASSUMPTIONS

This appraisal is prepared solely for insurance purposes using the comparative market approach to arrive at a fair market value as of the date of inspection, 6
June 2019. It is to be used solely by the clients and the agents (broker, accountants, attorneys) for these purposes. No permission is granted or implied for any
usage of this appraisal other than for the purpose stated.
The client shall indemnify, defend and hold Art Peritus, LLC harmless from and against any actions, claims, liabilities or expenses incurred as a result of claims
based on or arising from the appraisal, by third parties unrelated to the immediate purpose of this appraisal.
To the appraiser’s knowledge, scientific laboratory testing has not been performed on any item.
Unless otherwise stated herein, this document is based only on the readily apparent identity of the item appraised and no further opinion or guarantee of
authenticity, genuineness, attribution or authorship is made. Information furnished by others is assumed to be reliable but is not guaranteed by the appraiser.
This appraisal is made at the request of the parties named for their use. It is not an indication or certificate of title ownership. The identification of the interest
of the requesting parties is simply represented to the appraiser by such parties and no inquiry or investigation has been made or is any opinion given as to the
truth of such representation. Therefore, unless otherwise stated herein, the appraised value is based on the whole ownership and possessory interest
undiminished by any liens, fractional interests, or other form of encumbrance or alienation.
The values expressed herein are based upon the appraiser’s best judgment and opinion and are not a representation or warranty that the item will realize that
value if offered for sale at auction or otherwise. The values expressed herein are based on current information on the date made and no opinion is hereby
expressed as to any future value or, unless otherwise expressly stated, to any past value.
The appraiser recognizes that there are distinct levels of trade in the marketplace for the objects in this report. The market level selected for this assignment
is based on the property’s current use and alternative uses as relevant to the type and definition of value and the intended use of the Appraisal Report. As
such, the appraiser considered the most appropriate, common, and legal marketplace given the purpose of the assignment.
The appraisal was researched and prepared by the appraisers named on the cover page of this report. No other person supplied significant assistance in
preparation of this report. Consulting sources are listed within the scope of work of this report. Information furnished by consulting sources is assumed to be
reliable but is not guaranteed by this appraiser or her firm. The appraiser is not responsible for the accuracy of information regarding provenance of the
articles listed within this report that was provided by the client.
The appraiser is not required to give testimony, be present in any court of law, or appear before any commission or board by reason of this appraisal, unless
prior arrangements have been made with the appraiser. Should this report be challenged in any way, not limited to litigation, it is understood that the appraiser
is prepared to defend her appraisal, if required. Courtroom testimony, mediation proceedings, and the necessary preparation are considered to be separated
assignments and will be billed at the then current normal hourly rate plus expenses as required.
Possession of this report, or copy thereof, does not include the right of publication without the written consent of Art Peritus. This report in its entirety, or
any part thereof, including the identity of all appraisers and Art Peritus, shall not be made public through advertising, public relations, news releases, sales, or
other distributive or information media without the written consent of the Jennifer Garland Ross.
The appraiser has no past interest, no present interest, nor any future financial interest in the appraised property. This Appraisal Report was prepared without
personal interest or bias with respect to the parties involved. This Appraisal Report was done objectively, according to the rules of the IRS (in the Pension
Protection Act of 2006 H.R. 4, Public Law 109-280), and in accordance with the 2018-2019 Uniform Standards of Professional Appraisal Practice. Further, the
appraiser has no other interest which might tend to prevent making fair and unbiased appraisal opinions.

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All matters treating the duties, responsibilities, and liabilities of the appraiser are in accord with the Valuation Standards and Professional Practices as outlined
by the Appraisal Foundation in the 2018-2019 Uniform Standards of Professional Appraisal Practice and the Principles of Practice and the Code of Ethics of
the Appraisers Association of America.
Copies of this Appraisal Report and notes pertaining to the appraisal, written and electronic, will be kept in the offices of Art Peritus and its specialists for a
minimal period of five (5) years after the date of issue or two (2) years after final disposition of any judicial proceedings involving the appraiser, whichever
period expires last. Art Peritus and its specialists will make every effort to store the clients’ records in a safe and secure environment. However, the firm is not
responsible for acts of war, terrorism, or other such unexpected catastrophes which may affect the safekeeping of this report.
Acceptance of this appraisal and any use thereof releases the appraiser from any liability or damages whatsoever arising out of or related to the appraisal
furnished, and Art Peritus, LLC and its representatives are to be indemnified and held harmless from any claims, actions, liabilities, damages or expenses incurred
as a result of claims by third parties based on or related to the appraisal.
Submission of this Appraisal Report concludes this appraisal assignment. Additional services related to this appraisal shall constitute a new assignment and shall
be invoiced according to the appraiser's current fee schedule at that time.

United States v. Harold Gordon, Case No. 3:19CR28(JAM) – Fair Market Value Appraisal Report – 6 June 2019
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143 West 29th Street, 7th Floor, NYC 1001 | 212.566.6626 | info@artperitus.com | artperitus.com
Case 3:19-cr-00028-JAM Document 37-1 Filed 03/18/20 Page 14 of 14

AFFIDAVIT
I, Jennifer Garland Ross, owner of Art Peritus LLC, EIN#26-1436261 do hereby certify to the best of my knowledge that:

The statements of fact contained in this report are true and correct, and is our professional judgment and opinion, a complete and accurate description of the property and its
condition when examined.
The reported analyses, opinions, and conclusions are limited only by the reports assumptions and limiting conditions, and are the personal, impartial and unbiased professional
analyses, opinions and conclusions found by the specialists of Art Peritus.
Art Peritus, LLC holds itself out to the public as an agency of appraisers who perform appraisals on a regular basis; and that because of our qualifications as described in the
appraisal, Art Peritus, LLC is qualified to make appraisals of the type of property being valued.
Art Peritus, LLC has no past interest, no present interest, nor any future financial interest in the appraised property. This Appraisal Report was prepared without personal
interest or bias with respect to the parties involved. This Appraisal Report was done objectively, according to the rules of the IRS (in the Pension Protection Act of 2006 H.R.
4, Public Law 109-280), and in accordance with the 2018-2019 Uniform Standards of Professional Appraisal Practice. Further, the appraiser has no other interest which might
tend to prevent making fair and unbiased appraisal opinions.
Art Peritus, LLC has no bias with respect to the property that is the subject of this report or to the parties involved with this assignment.
Art Peritus, LLC engagement and compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in
value that favors the case of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the
intended use of this appraisal.
Art Peritus, LLC analyses, opinions, and conclusions were developed, and this report has been prepared, in complete compliance with the 2018-2019 Uniform Standards of
Professional Appraisal Practice, written by the Appraisal Standards Board of the Appraisal Foundation in Washington, D.C. The Appraisal Foundation is a congressionally
sanctioned, not-for-profit organization, established in 1987 and dedicated to the advancement of professional valuation for appraisers and users of appraisal services to ensure
public trust in the work performed by appraisers.
Art Peritus, LLC hereby subscribes to the Code of Ethics of the Appraisers Association of America, Inc.
Although these certification pages include salient information regarding the methodology of the report, additional information regarding the scope of work, assignment
conditions, and disclaimers are important to understand the entire appraisal process. As such, the entire report is required to fully understand the assignment and these
certification pages do not encompass the entire report and are not valid without reading and understanding the entire report.

GRAND TOTAL
1 item listed herein, as defined on pages 6-11 of this report:

Effective Date: 6 June 2019


Jennifer Garland Ross
ART PERITUS, LLC #26-1436261 FAIR MARKET VALUE
Two Thousand Five Hundred Dollars ($2,500)

United States v. Harold Gordon, Case No. 3:19CR28(JAM) – Fair Market Value Appraisal Report – 6 June 2019
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143 West 29th Street, 7th Floor, NYC 1001 | 212.566.6626 | info@artperitus.com | artperitus.com

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