Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 1 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 1 of 19
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`_FILED
`__ENTERED
`
`NICHOLAS A. TRUTANICH
`
`United States Attorney
`Nevada Bar Number 13644
`
`JESSICA OLIVA
`
`Assistant United States Attorney
`501 Las Vegas Boulevard South, Suite 1100
`Las Vegas, Nevada 89101
`Telephone: (702) 388-6336
`Email: jessica.oliva@usdoj.gov
`
`DANIEL S. KAI—1N
`
`Acting Chief, Fraud Section
`Criminal Division, US. Department of Justice
`JOSEPH MCFARLANE
`
`Trial Attorney
`1400 New York AveNW
`Washington, DC. 20530
`Telephone: (202) 368-6049
`Email: joseph.mcfarlane@usdoj.gov
`Attoqusfor the United States
`
`
`
`RECEIVED
`___SERVED 0N
`COUNSEL/PARTIES OF RECORD
`
`
`
`
`
`JAN 27 2021
`
`
`
`CLERK US DISTRICT COURT
`DISTRICT OF NEVADA
`BY
`i—‘MDEPUW
`
`
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NEVADA
`
`UNITED STATES OF AMERICA,
`
`CRIMJNAL INDICTMENT
`
`Plaintiff,
`
`vs.
`
`Case No.: 2:21-cr-yy
`
`VIOLATIONS:
`
`JORGE ABRAMOVS,
`
`18 U.S.C. § 1344(2) — Bank Fraud;
`
`Defendant.
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`
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`18 U.S.C. § 1014 — False Statement to a
`Financial Institution; and
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`18 U.S.C. § 1957 —Monetary Transactions
`in Criminally Derived Property.
`
`FORFEITURE ALLEGATIONS
`
`THE GRAND JURY CHARGES THAT:
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`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 2 of 19
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`Bac
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`011ml Alle aliens
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`At all times relevant to the Indictment, unless otherwise stated:
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`1.
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`Defendant JORGE ABRAMOVS (“ABRAMOVS”) was a United States
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`citizen, residing in Las Vegas, Nevada.
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`2.
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`National Investment Group Corporation (“NIGC”) was a domestic
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`corporation formed in the State of Nevada in 2018. Nevada Secretary of State records
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`identified ABRAMOVS as the President, Secretary, Treasurer, and Director ofNIGC until
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`on or about October 14, 2020, when a different individual was identified as Secretary and
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`Treasurer with ABRAMOVS still listed as President.
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`3.
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`National Legal Advisors In Care Corp. (“NLA”) was a domestic corporation
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`formed in the State of Nevada in 2019. Nevada Secretary of State records identified
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`ABRAMOVS as the President, Secretary, Treasurer, and Director of NLA as of on or
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`about July 1, 2019 through at least January 22, 2021. As discussed below, Abramovs
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`submitted loan applications on behalf of NLA and entities with similar names.
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`4.
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`Financial Institutions A through G (the “Financial Institutions”) were all
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`financial institutions as defined by Title 18, United States Code, Section 20. Deposits at
`Financial Institutions A, B, D, E, F, and G were insured by the Federal Deposit Insurance
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`Fund. Deposits at Financial Institution C were insured by the National Credit Union
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`Share Insurance Fund.
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`5.
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`ABRAMOVS controlled, and had sole signatory authority over, Financial
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`Institution F account ending in 975 7, Financial Institution F account ending in 9732, and
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`Financial Institution F account ending in 9740, among other accounts.
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`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 3 of 19
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`Paycheck Protection Program
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`6.
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`The Coronavirus Aid, Relief, and Economic Security ("CARES”) Act was a
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`federal law enacted in or around March 2020 and designed to provide emergency financial
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`assistance to the millions of Americans who are suffering the economic effects caused by
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`the COVID-19 pandemic. One source of relief provided by the CARES Act was the
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`authorization of up to $349 billion in forgivable loans to small businesses for job retention
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`and certain other expenses, through a program referred to as the Paycheck Protection
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`Program (“PPP").
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`7.
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`In order to obtain a PPP loan, a qualifying business submitted a PPP loan
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`application, which was signed by an authorized representative of the business. The PPP
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`loan application required the business (through its authorized representative) to
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`acknowledge the program rules and make certain aflinnative certifications in order to be
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`eligible to obtain the PPP loan. In the PPP loan application, the small business (through its
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`authorized representative) was required to state, among other things, its: (a) average
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`monthly payroll expenses; and (b) number of employees. These figures were used to
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`calculate the amount of money the small business was eligible to receive under the PPP. In
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`addition, businesses applying for a PPP loan were required to provide documentation
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`showing their payroll expenses.
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`8.
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`A PPP loan application was processed by a participating lender, such as a
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`financial institution. If a PPP loan application was approved, the participating lender
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`funded the PPP loan using its own monies. While the lender issued the PPP loan, the
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`Small Business Administration (“SBA”) provided a guarantee to the lender for the PPP
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`loan. Data from the application, including information about the borrower, the total
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`amount of the loan, and the listed number of employees, was transmitted by the lender to
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`the SBA in the course of processing the loan.
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`9.
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`PPP loan proceeds were required to be used by the business on certain
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`permissible expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP
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`allowed the interest and principal on the PPP loan to be entirely forgiven if the business
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`spent the loan proceeds on these expense items within a designated period of time and used
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`a certain percentage of the PPP loan proceeds on payroll expenses.
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`The Scheme to Defraud
`
`10.
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`Beginning in or around April 2020 and continuing until at least in or around
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`June 2020, ABRAMOVS knowingly executed, and attempted to execute, a scheme and
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`artifice to obtain the money and property owned by, and under the custody and control of,
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`Financial Institutions, namely, Financial Institutions A-G, by means of materially false and
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`fraudulent pretenses, representations, and promises, as further described below.
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`Purpose of the Scheme to Defmud
`
`11.
`
`It was the purpose of the scheme for ABRAMOVS to unjustly enrich himself
`
`and others by fraudulently obtaining PPP loan proceeds.
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`Manner and Means of the Scheme to Dgtraud
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`12.
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`It was part of the scheme that fi'om on or about April 16, 2020 until at least
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`on about June 15, 2020, ABRAMOVS submitted at least six applications for PPP loans for
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`NIGC‘. On each loan application, ABRAMOVS provided an EIN, number of employees,
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`and average monthly payroll for NIGC.
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`13.
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`It was further part of the scheme that between on or about May 10, 2020 and
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`on or about June 5, 2020, ABRAMOVS submitted at least five more applications for PPP
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`loans on behalf of NLA or an entity with a similar name, such as National Legal Advisors
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`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 5 of 19
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`or National Legal Advisors in Care (collectively, “the NLA entities”). ABRAMOVS signed
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`each of the loan applications as the authorized representative of the NLA entities. On each
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`loan application, ABRAMOVS provided an ElN, number of employees, and average
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`monthly payroll for the NLA entities.
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`14.
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`On or about June 15, 2020, ABRAMOVS submitted a PPP loan application
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`to Financial Institution G using the entity name of National Investment Group.
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`ABRAMOVS signed the loan application as the authorized representative of National
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`Investment Group. On the loan application, ABRAMOVS provided an ElN, number of
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`employees and average monthly payroll for National Investment Group.
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`15.
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`In order to qualify for the above loans, ABRAMOVS submitted materially
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`false information about NIGC and NLA. including the number of employees and average
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`monthly payroll of the businesses. At times, ABRAMOVS also submitted false and
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`fraudulent supporting documentation with the loan applications, including fraudulent tax
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`documents. ABRAMOVS falsely certified that the loan proceeds would be used retain
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`workers and maintain payroll or make mortgage interest payments, lease payments, and
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`utility payments, when in fact ABRAMOVS intended to use the funds for personal
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`expenses.
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`16.
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`In addition, on each loan application, ABRAMOVS certified that during the
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`period beginning on or about February 15, 2020 and ending on or about December 1, 2020,
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`the Applicant had not and would not receive another loan under the PPP. Instead, contrary
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`to these certifications, ABRAMOVS received multiple loans in the name of NIGC and
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`multiple loans in the name of NLA.
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`17.
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`‘If was part of the scheme that, in order to obtain multiple PPP loans for the
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`same company, ABRAMOVS and others known and unknown to the Grand Jury created
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`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 6 of 19
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`multiple EINs with the IRS, using different company names in order to obtain the ENS.
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`ABRAMOVS then used the various Ele on the loan applications and falsely claimed that
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`they were associated with the relevant business.
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`18.
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`In total, ABRAMOVS received approximately $1,986,737 in PPP funds via
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`applications submitted to seven financial institutions.
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`19.
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`ABRAMOVS spent proceeds of this fraud on luxury purchases for himself,
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`including two condominiums located in the Veer Towers in Las Vegas, Nevada, the
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`purchase of a 2020 Bentley, the purchase of a 2020 Tesla, and to pay off the mortgage on
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`an existing home in Nevada.
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`COUNTS ONE THROUGH FIVE
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`Bank Fraud
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`(18 U.S.C. § 1344(2))
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`20.
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`The allegations in paragraphs 1 through 19 are re—alleged and incorporated as
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`if fully set forth herein.
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`21.
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`From in or around April 2020 through at least in or around June 2020, in the
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`State and Federal District of Nevada and elsewhere,
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`JORGE ABRAMOVS,
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`defendant herein, knowingly executed, and attempted to execute, a scheme and artifice to
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`obtain moneys, funds, credits, assets, securities, and property owned by, and under the
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`custody and control of, the Financial Institutions, by means of materially false and
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`fraudulent pretenses, representations, and promises.
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`22.
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`On or about the dates identified below, in the State and Federal District of
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`Nevada, and elsewhere,
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`JORGE ABRAMOVS,
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`defendant herein, knowingly executed and attempted to execute the above—described
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`scheme, each execution constituting a separate violation of Title 18, United States Code,
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`Section 1344(2).
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`COUNT, APPROXIMATE
`'
`"A'FDESCRIPTIONOP EXECUTION
`DATE
`Submissionto Financial Institution A ofPPP loan
`
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`- Apr, 16
`application on the name of National Investment Group
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`
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`Co _- oration seekin; a loan in the amount of $134,662
`Submission to Financial Institution B of PPP loan
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`application in the name of National Legal Advisors In
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`Care Co 3 ., seeking a loan in the amount of $136,200
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`Submission to Financial Institution B of PPP loan
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`application in the name of National Investment Group
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`Co oration seekin a loan in the amount of $138,000
`Submission to Financial Institution C of PPP loan
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`June 1, 2020
`FOUR
`application in the name of National Legal Advisors
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`seekin a loan in the amount of $215,624
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`Submission to Financial Institution D of PPP loan
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`application in the name of National Investment Group
`June 2, 2020
`Corporation seeking a loan in the amount of
`$199,276.04
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`Ma}r 21,2020
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`Mama
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`COUNT SIX
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`False Statement to a Financial Imutation
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`(18 U.S.C. § 1014)
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` All in violation of Title 18, United States Code, Section 1344(2).
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`23.
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`The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
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`if fully set forth herein.
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`24.
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`On or about May 25, 2020, in the State and Federal District of Nevada,
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`JORGE ABRAMOVS,
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`defendant herein, knowingly made a false statement and report for the purposes of
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`influencing the action of a financial institution, namely, Financial Institution E, Whose
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`accounts were insured by the Federal Deposit Insurance Corporation, upon an application,
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`agreement, and loan, to wit: false statements on a Borrower Application Form for a
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`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 8 of 19
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`$93,403.16 loan under the Paycheck Protection Program from Financial Institution E about
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`the number of employees, the amount of monthly payroll, the ElN and tax filing history for
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`ABRAMOVS’ business, National Investment Group Corporation, and the intended use of
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`the loan proceeds, in violation of Title 18, United States Code, Section 1014.
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`All in violation of Title 18, United States Code, Section 1014.
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`COUNTS SEVEN THROUGH ELEVEN
`Monetary Transactions in Criminally Derived Property
`(18 U.S.C. § 1957)
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`25.
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`The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
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`if fully set forth herein.
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`26.
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`From in or around April 2020 through at least in or around August 2020, in
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`the State and Federal District of Nevada and elsewhere,
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`JORGE ABRAMOVS,
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`defendant herein, knowingly engaged and attempted to engage in the following monetary
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`transactions by, through, and to a financial institution, in and affecting interstate and
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`foreign commerce, in criminally derived property of a value greater than $10,000, that is
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`the deposit, Withdrawal, transfer, and exchange of United States currency, such property
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`constituting and having been derived from a specified unlawful activity, that is, the bank
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`fraud scheme and artifice alleged herein in paragraphs 1 through 19, in violation of 18
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`U.S.C. § 1344(2), all in violation of Title 18, United States Code, Section 1957:
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`triplescruprron (JP-TRANSACTION“
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`,
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`-2
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`$222,633.59 wire fiom Financial Institution F
`account ending in 9732 to Lawyer’s Title of
`Nevada Inc
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`$251,024.21 wire from Financial Institution F
`account ending in 9732 to Towbin Motorcars.
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`‘V‘APPROXIMATE '
`DATE
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`COUNTY-é
`a
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`.1
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`May 29, 2020
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`June 1,2020
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`$403,906.29 Wire fiom Financial Institution F
`account ending in 9740 to Lawyer’s Title of
`Nevada Inc
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`$95,000 Electronic Withdrawal from Financial
`Institution F account ending in 9757 to
`PENNYMAC
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`$54,804.25 Electronic Withdrawal from Financial
`Institution F account ending in 9732 to Tesla
`Motors.
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`‘
`June 9, 2020
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`June 16, 2020
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`June 19, 2020
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`6 All in violation of Title 18, United States Code, Section 1957
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`FORFEITURE ALLEGATION ONE
`Bank Fraud
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`1.
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`The allegations contained in Counts One through Five of this Criminal
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`Indictment are hereby realleged and incorporated herein by reference for the purpose of
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`alleging forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18
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`12 U.S.C. § 982(a)(2)(A).
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`2.
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`Upon conviction ofany of the felony offenses charged in Counts One
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`through Five of this Criminal Indictment,
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`JORGE ABRAMOVS,
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`defendant herein, shall forfeit to the United States ofAmerica, any property, real or
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`personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
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`§ 1344, or a conspiracy to commit such offense:
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`defendant herein, shall forfeit to the United States ofAmerica, any property, real or
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`20
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`personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
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`§ 1344, a specified unlawful activity as defined in 18 U.S.C §§ 1956(c)(7)(A) and
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`1961(1)(B), or a conspiracy to commit such offense:
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`defendant herein, shall forfeit to the United States ofAmerica, any property
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`constituting, or derived from, proceeds obtained directly or indirectly, as the result of
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`violations of 18 U.S.C. § 1344, or a conspiracy to violate such offense, affecting a financial
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`institution:
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`1. an in pets onam criminal forfeiture money judgment including, but not
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`limited to, at least $1,986,737.46;
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`2.
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`real property located at 3726 South Las Vegas Boulevard, Unit 509,
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`Las Vegas, Nevada; and
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`MORE PARTICULARLY DESCRIBED AS:
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`PARCEL 1:
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`UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON THAT
`CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT
`CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF PLATS, PAGE 42
`AND AS SET FORTH IN THE DECLARATION OF COVENANTS.
`CONDITIONS, AND RESTRICTIONS AND RESERVATION OF
`EASEMENTS FOR VEER TOWERS RECORDED MAY 03, 2010 IN BOOK
`20100503 AS INSTRUIWENT NO. 0002036, BOTH IN THE OFFICE OF THE
`COUNTY RECORDER, CLARK COUNTY, NEVADA.
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`PARCEL 2:
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`AN ALLOCATED INTEREST AS A TENANT-IN-COML/ION IN THE
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`CONIMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
`ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
`FORTH IN THE DECLARTION.
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`PARCEL 3:
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`AN EXCLUSIVE BASEMENT APPURTENANT TO PARCELS 1 AND 2
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`DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS
`LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS 1
`AND 2 IN THE DECLARATION AND AS SHOWN AND DELINEATED
`UPON THE MAP REFFERED TO ABOVE.
`PARCEL 4:
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`NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
`OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
`CERTAW (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
`DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
`20091201 AS INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
`AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION
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`OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07, 2010 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
`DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
`INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
`SUPPORT AND ENCROACHIMENT EASEIVIENTS, DATED DECEMBER 01,
`2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
`INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
`THAT CERTAIN FIRST AIVIENDMENT TO DECLARATION OF SUPPORT
`AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2020 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`00005 78 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
`SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED
`DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
`OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
`AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
`DATED JANUARY 07,2010 AND RECORDED JANUARY 07,2010 IN BOOK
`20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL
`IMPROVEIVIENTS AND APPURTENANCES THEREON, APN: 162-20-714—020.
`
`3.
`
`real property located at 3726 South Las Vegas Boulevard, Unit 1803,
`
`Las Vegas, Nevada
`
`MORE PARTICULARLY DESCRIBED AS:
`
`PARCEL I:
`
`UNIT ONE THOUSAND EIGHT HUNDRED THREE (1803) IN BUILDING
`“W” IN VEER TOWERS, AS SHOWN ON THAT CERTAIN FINAL MAP OF
`THE VEER TOWERS, A RESORT CONDOMINIUM SUBDIVISION ON FILE
`IN BOOK 142 OF PLATS, PAGE 42 (THE “MAP”) AND AS SET FORTH IN
`THE DECLARATION OF COVENANTS, CONDITIONS, AND
`RESTRICTIONS AND RESERVATION OF EASEMENTS FOR VEER
`
`TOWERS (THE “‘DECLARATION”) RECORDED MAY 03, 2010 IN BOOK
`20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
`COUNTY RECORDER, CLARK COUNTY, NEVADA (THE “OFFICIAL
`RECORDS”.
`
`PARCEL 11:
`
`AN ALLOCAT‘ED INTEREST AS A TENANT—IN-COMIMON IN THE
`
`COMIMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
`ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
`FORTH IN THE DECLARTION.
`
`11
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 12 of 19
`Case 2:21-cr-OOO27-RFB-DJA Document 16 Filed 01/27/21 Page 12 of 19
`
`PARCEL III:
`
`AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS ONE (1) AND
`TWO (2) DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED
`AS LIMITED COWON ELEMENTS, IF ANY, ALLOCATED TO PARCELS
`ONE (1) AND TWO (2) IN THE DECLARATION AND AD SHOWN AND
`DELINEATED UPON THE MAP REFFERED TO ABOVE.
`
`PARCEL IV:
`
`NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
`OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
`
`CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
`DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
`20091201 AS lNSTRUIVIENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
`ABIENDED BY THAT CERTAIN FIRST AMENDIVIENT TO DECLARATION
`
`OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07, 2010 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEIVIENT,
`DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
`INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
`SUPPORT AND ENCROACHMENT EASEIVIENTS, DATED DECEMBER 01,
`2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
`INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
`THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
`
`AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2010 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
`SYSTEMS EASEMENTS, DATED DECEMBER 1, 2009 AND RECORDED
`DECEMBER 1, 2009 IN BOOK 20091201 AS INSTRUIVIENT NO. 0002886 OF
`OFFICIAL RECORDS, AND AS AlVIENDED BY THAT CERTAIN FIRST
`AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
`
`DATED JANUARY 07, 2010 AND RECORDED JANUARY 7, 2010 IN BOOK
`20100107 AS INSTRUMENT NO. 0000579, AND ALL IMPROVEMENTS AND
`APPURTENANCES THEREON, APN: 162-20-714-153.
`
`(all of which constitutes property).
`
`3.
`
`If any property being subject to forfeiture pursuant to 18 U.S.C. §
`
`981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18 U.S.C. § 982(a)(2)(A), as a result of any act or
`
`omission of the defendant -
`
`a.
`
`b.
`
`cannot be located upon the exercise of due diligence;
`
`has been transferred or sold to, or deposited with, a third party;
`
`12
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 13 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 13 of 19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`c.
`
`d.
`
`e.
`
`has been placed beyond the jurisdiction of the court;
`
`has been substantially diminished in value; or
`
`has been commingled with other property which cannot be divided
`
`without difficulty;
`
`it is the intent of the United States of America, pursuant to 21 U.S.C. § 853(1)), to seek
`
`forfeiture of any other property of the defendant for the property listed above.
`
`All pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c); 18 U.S.C. §
`
`982(a)(2)(A); 18 U.S.C. § 1344; and 21 U.S.C. § 853(p).
`
`FORFEITURE ALLEGATION TWO
`False Statement to a Financial Institution
`
`l.
`
`The allegations contained in Count Six of this Criminal Indictment are
`
`12
`
`hereby realleged and incorporated herein by reference for the purpose of alleging forfeiture
`
`13
`
`pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18 U.S.C. §
`
`14
`
`982(a)(2)(A).
`
`15
`
`2.
`
`Upon conviction of the felony offense charged in Count Six of this Criminal
`
`16
`
`Indictment,
`
`17
`
`18
`
`JORGE ABRAMOVS,
`
`defendant herein, shall forfeit to the United States ofAmerica, any property, real or
`
`19
`
`personal, Which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
`
`20
`
`§ 1014, or a conspiracy to commit such offense:
`
`21
`
`defendant herein, shall forfeit to the United States of America, any property, real or
`
`22
`
`personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
`
`23
`
`§ 1014, a specified unlawful activity as defined in 18 U.S.C. § 1956(c)(7)(D), or a
`
`24
`
`conspiracy to commit such offense:
`
`13
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 14 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 14 of 19
`
`1
`
`defendant herein, shall forfeit to the United States of America, any property
`
`constituting, or derived from, proceeds obtained directly or indirectly, as the result of
`
`violations of 18 U.S.C. § 1014, or a conspiracy to violate such offense, affecting a financial
`
`institution:
`
`an in personam criminal forfeiture money judgment including, but not limited to, at
`
`least $93,403.16 (property).
`
`3.
`
`If any property being subject to forfeiture pursuant to 18 U.S.C. §
`
`981(a)(1)(C) with 28 U.S.C. §2461(c) and 18 U.S.C. § 982(a)(2)(A), as a result of any act or
`
`omission of the defendant -
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`cannot be located upon the exercise of due diligence;
`
`has been transferred or sold to, or deposited with, a third party;
`
`has been placed beyond the jurisdiction of the court;
`
`has been substantially diminished in value; or
`
`has been commingled with other property which cannot be divided
`
`Without difliculty;
`
`it is the intent of the United States of America, pursuant to 21 U.S.C. § 853(p), to seek
`
`forfeiture of any other property of the defendant for the pr0perty listed above.
`
`All pursuant to 18 U.S.C. §981(a)(1)(C) with 28 U.S.C. § 2461(c); 18 U.S.C.§
`
`982(a)(2)(A); 18 U.S.C. § 1014; and 21 U.S.C. § 853(p).
`
`FORFEI'I'U'RE ALLEGATION THREE
`
`Engaging in Transactions in Unlawfi! Proceeds
`
`1.
`
`The allegations contained in Counts Seven through Eleven of this Criminal
`
`Indictment are hereby realleged and incorporated herein by reference for the purpose of
`
`alleging forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A)with 28 U.S.C. § 2461(c); 18 U.S.C.
`
`l4
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 15 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 15 of 19
`
`§981(a)(1)(C) with 28 U.S.C. §2461(c); and 18 U.S.C. § 982(a)(l).
`
`2.
`
`Upon conviction of any of the felony offenses charged in Counts Seven
`
`through Eleven of this Criminal Indictment,
`
`JORGE ABRAMOVS,
`
`defendant herein, shall forfeit to the United States of America, any property, real or
`
`personal, involved in transactions or attempted transactions in violation of 18 U.S.C. §
`
`1957, or any property traceable to such property:
`
`defendant herein, shall forfeit to the United States of America, any property, real or
`
`personal, Which constitutes or is derived fiom proceeds traceable to a violation of 178 U.S.C.
`
`§ 1957, a specified unlaWfiil activity as defined in 18 U.S.C §§ l956(c)(7)(A) and
`
`1961(1)(B), or a conspiracy to commit such offense:
`
`defendant herein, shall forfeit to the United States of America, any property, real or
`
`personal, involved in violations of 18 U.S.C. § 1957, or any property traceable to such
`
`property:
`
`1. an in personam criminal forfeiture money judgment including, but not
`
`limited to, at least $978,834.31;
`
`2.
`
`real property located at 3726 South Las Vegas Boulevard, Unit 509,
`
`Las Vegas, Nevada; and
`
`MORE PARTICULARLY DESCRIBED AS:
`
`PARCEL 1:
`
`UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON THAT
`CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT
`CONDOMINIUM SUBDIVISION ON FILE 1N BOOK 142 OF PLATS, PAGE 42
`AND AS SET FORTH IN THE DECLARATION OF COVENANTS,
`CONDITIONS, AND RESTRICTIONS AND RESERVATION OF
`EASEIVIENTS FOR VEER TOWERS RECORDED MAY 03, 2010 IN BOOK
`
`IS
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 16 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 16 of 19
`
`20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
`COUNTY RECORDER, CLARK COUNTY, NEVADA.
`
`PARCEL 2:
`
`AN ALLOCATED INTEREST AS A TENANT-IN-COMIVION IN THE
`
`COWON ELEMENTS OF VEER TOWERS (INCLUDING ANY
`ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
`FORTH ]N THE DECLARTION.
`
`PARCEL 3:
`
`AN EXCLUSIVE BASEMENT APPURTENANT TO PARCELS 1 AND 2
`DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS
`LIMITED CONIMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS 1
`AND 2 IN THE DECLARATION AND AS SHOWN AND DELINEATED
`UPON THE MAP REFFERED TO ABOVE.
`
`PARCEL 4:
`
`NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
`OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
`
`CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
`DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
`20091201 AS INSTRUIVIENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
`AMENDED BY THAT CERTAIN FIRST AMENDLIENT TO DECLARATION
`
`OF CENTRAL PLANT EASELIENTS, DATED JANUARY 07, 2010 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
`DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
`INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
`SUPPORT AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01,
`2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
`INSTRUIVIENT NO. 0002885 OF OFFICIAL RECORDS, AND AS ALIENDED BY
`THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
`
`AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2020 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
`SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED
`DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
`OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
`AIVIENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
`
`DATED JANUARY 07, 2010 AND RECORDED JANUARY 07, 2010 IN BOOK
`20100107 AS INSTRUIVIENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL
`IIVIPROVENIENTS AND APPURTENANCES THEREON, APN: 162—20-714-020.
`
`3.
`
`real property located at 3726 South Las Vegas Boulevard, Unit 1803,
`
`16
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 17 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 17 of 19
`
`Las Vegas, Nevada
`
`MORE PARTICULARLY DESCRIBED AS:
`
`PARCEL I:
`
`UNIT ONE THOUSAND EIGHT HUNDRED TI-LREE (1803) IN BUILDING
`“W” IN VEER TOWERS, AS SHOWN ON THAT CERTAW FINAL MAP OF
`THE VEER TOWERS, A RESORT CONDOMINIUM SUBDIVISION ON FILE
`IN BOOK 142 OF PLATS, PAGE 42 (THE “MAP”) AND AS SET FORTH IN
`THE DECLARATION OF COVENANTS, CONDITIONS, AND
`RESTRICTIONS AND RESERVATION OF EASEMENTS FOR VEER
`
`TOWERS (THE “DECLARATION”) RECORDED MAY 03, 2010 IN BOOK
`20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
`COUNTY RECORDER, CLARK COUNTY, NEVADA (THE “OFFICIAL
`RECORDS”.
`
`PARCEL 11:
`
`AN ALLOCATED INTEREST AS A TENANT—IN-COMIMON IN THE
`
`COMLMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
`ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
`FORTH IN THE DECLARTION.
`
`PARCEL III:
`
`AN EXCLUSIVE BASEMENT APPURTENANT TO PARCELS ONE (1) AND
`TWO (2) DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED
`AS LIMITED COMIVION ELEMENTS, IF ANY, ALLOCATED TO PARCELS
`ONE (1) AND TWO (2) IN THE DECLARATION AND AD SHOWN AND
`DELINEATED UPON THE MAP REFFERED TO ABOVE.
`
`PARCEL IV:
`
`NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
`OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
`
`CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
`DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
`20091201 AS INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
`AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION
`
`OF CENTRAL PLANT EASEIWENTS, DATED JANUARY 07, 2010 AND
`RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
`0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
`DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
`INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
`SUPPORT AND ENCROACPMENT EASEMENTS, DATED DECENIBER 01,
`2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
`
`17
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`

`

`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 18 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 18 of 19
`
`INSTRUMENT NO. 0002885 OF