`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 1 of 19
`
`_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.
`
`
`
`18 U.S.C. § 1014 — False Statement to a
`Financial Institution; and
`
`18 U.S.C. § 1957 —Monetary Transactions
`in Criminally Derived Property.
`
`FORFEITURE ALLEGATIONS
`
`THE GRAND JURY CHARGES THAT:
`
`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 2 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 2 of 19
`
`Bac
`
`011ml Alle aliens
`
`At all times relevant to the Indictment, unless otherwise stated:
`
`1.
`
`Defendant JORGE ABRAMOVS (“ABRAMOVS”) was a United States
`
`citizen, residing in Las Vegas, Nevada.
`
`2.
`
`National Investment Group Corporation (“NIGC”) was a domestic
`
`corporation formed in the State of Nevada in 2018. Nevada Secretary of State records
`
`identified ABRAMOVS as the President, Secretary, Treasurer, and Director ofNIGC until
`
`on or about October 14, 2020, when a different individual was identified as Secretary and
`
`Treasurer with ABRAMOVS still listed as President.
`
`3.
`
`National Legal Advisors In Care Corp. (“NLA”) was a domestic corporation
`
`formed in the State of Nevada in 2019. Nevada Secretary of State records identified
`
`ABRAMOVS as the President, Secretary, Treasurer, and Director of NLA as of on or
`
`about July 1, 2019 through at least January 22, 2021. As discussed below, Abramovs
`
`submitted loan applications on behalf of NLA and entities with similar names.
`
`4.
`
`Financial Institutions A through G (the “Financial Institutions”) were all
`
`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
`
`Fund. Deposits at Financial Institution C were insured by the National Credit Union
`
`Share Insurance Fund.
`
`5.
`
`ABRAMOVS controlled, and had sole signatory authority over, Financial
`
`Institution F account ending in 975 7, Financial Institution F account ending in 9732, and
`
`Financial Institution F account ending in 9740, among other accounts.
`
`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 3 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 3 of 19
`
`Paycheck Protection Program
`
`6.
`
`The Coronavirus Aid, Relief, and Economic Security ("CARES”) Act was a
`
`federal law enacted in or around March 2020 and designed to provide emergency financial
`
`assistance to the millions of Americans who are suffering the economic effects caused by
`
`the COVID-19 pandemic. One source of relief provided by the CARES Act was the
`
`authorization of up to $349 billion in forgivable loans to small businesses for job retention
`
`and certain other expenses, through a program referred to as the Paycheck Protection
`
`Program (“PPP").
`
`7.
`
`In order to obtain a PPP loan, a qualifying business submitted a PPP loan
`
`application, which was signed by an authorized representative of the business. The PPP
`
`loan application required the business (through its authorized representative) to
`
`acknowledge the program rules and make certain aflinnative certifications in order to be
`
`eligible to obtain the PPP loan. In the PPP loan application, the small business (through its
`
`authorized representative) was required to state, among other things, its: (a) average
`
`monthly payroll expenses; and (b) number of employees. These figures were used to
`
`calculate the amount of money the small business was eligible to receive under the PPP. In
`
`addition, businesses applying for a PPP loan were required to provide documentation
`
`showing their payroll expenses.
`
`8.
`
`A PPP loan application was processed by a participating lender, such as a
`
`financial institution. If a PPP loan application was approved, the participating lender
`
`funded the PPP loan using its own monies. While the lender issued the PPP loan, the
`
`Small Business Administration (“SBA”) provided a guarantee to the lender for the PPP
`
`loan. Data from the application, including information about the borrower, the total
`
`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 4 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 4 of 19
`
`amount of the loan, and the listed number of employees, was transmitted by the lender to
`
`the SBA in the course of processing the loan.
`
`9.
`
`PPP loan proceeds were required to be used by the business on certain
`
`permissible expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP
`
`allowed the interest and principal on the PPP loan to be entirely forgiven if the business
`
`spent the loan proceeds on these expense items within a designated period of time and used
`
`a certain percentage of the PPP loan proceeds on payroll expenses.
`
`The Scheme to Defraud
`
`10.
`
`Beginning in or around April 2020 and continuing until at least in or around
`
`June 2020, ABRAMOVS knowingly executed, and attempted to execute, a scheme and
`
`artifice to obtain the money and property owned by, and under the custody and control of,
`
`Financial Institutions, namely, Financial Institutions A-G, by means of materially false and
`
`fraudulent pretenses, representations, and promises, as further described below.
`
`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.
`
`Manner and Means of the Scheme to Dgtraud
`
`12.
`
`It was part of the scheme that fi'om on or about April 16, 2020 until at least
`
`on about June 15, 2020, ABRAMOVS submitted at least six applications for PPP loans for
`
`NIGC‘. On each loan application, ABRAMOVS provided an EIN, number of employees,
`
`and average monthly payroll for NIGC.
`
`13.
`
`It was further part of the scheme that between on or about May 10, 2020 and
`
`on or about June 5, 2020, ABRAMOVS submitted at least five more applications for PPP
`
`loans on behalf of NLA or an entity with a similar name, such as National Legal Advisors
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`4
`
`
`
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 5 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 5 of 19
`
`or National Legal Advisors in Care (collectively, “the NLA entities”). ABRAMOVS signed
`
`each of the loan applications as the authorized representative of the NLA entities. On each
`
`loan application, ABRAMOVS provided an ElN, number of employees, and average
`
`monthly payroll for the NLA entities.
`
`14.
`
`On or about June 15, 2020, ABRAMOVS submitted a PPP loan application
`
`to Financial Institution G using the entity name of National Investment Group.
`
`ABRAMOVS signed the loan application as the authorized representative of National
`
`Investment Group. On the loan application, ABRAMOVS provided an ElN, number of
`
`employees and average monthly payroll for National Investment Group.
`
`15.
`
`In order to qualify for the above loans, ABRAMOVS submitted materially
`
`false information about NIGC and NLA. including the number of employees and average
`
`monthly payroll of the businesses. At times, ABRAMOVS also submitted false and
`
`fraudulent supporting documentation with the loan applications, including fraudulent tax
`
`documents. ABRAMOVS falsely certified that the loan proceeds would be used retain
`
`workers and maintain payroll or make mortgage interest payments, lease payments, and
`
`utility payments, when in fact ABRAMOVS intended to use the funds for personal
`
`expenses.
`
`16.
`
`In addition, on each loan application, ABRAMOVS certified that during the
`
`period beginning on or about February 15, 2020 and ending on or about December 1, 2020,
`
`the Applicant had not and would not receive another loan under the PPP. Instead, contrary
`
`to these certifications, ABRAMOVS received multiple loans in the name of NIGC and
`
`multiple loans in the name of NLA.
`
`17.
`
`‘If was part of the scheme that, in order to obtain multiple PPP loans for the
`
`same company, ABRAMOVS and others known and unknown to the Grand Jury created
`
`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 6 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 6 of 19
`
`multiple EINs with the IRS, using different company names in order to obtain the ENS.
`
`ABRAMOVS then used the various Ele on the loan applications and falsely claimed that
`
`they were associated with the relevant business.
`
`18.
`
`In total, ABRAMOVS received approximately $1,986,737 in PPP funds via
`
`applications submitted to seven financial institutions.
`
`19.
`
`ABRAMOVS spent proceeds of this fraud on luxury purchases for himself,
`
`including two condominiums located in the Veer Towers in Las Vegas, Nevada, the
`
`purchase of a 2020 Bentley, the purchase of a 2020 Tesla, and to pay off the mortgage on
`
`an existing home in Nevada.
`
`COUNTS ONE THROUGH FIVE
`
`Bank Fraud
`
`(18 U.S.C. § 1344(2))
`
`20.
`
`The allegations in paragraphs 1 through 19 are re—alleged and incorporated as
`
`if fully set forth herein.
`
`21.
`
`From in or around April 2020 through at least in or around June 2020, in the
`
`State and Federal District of Nevada and elsewhere,
`
`JORGE ABRAMOVS,
`
`defendant herein, knowingly executed, and attempted to execute, a scheme and artifice to
`
`obtain moneys, funds, credits, assets, securities, and property owned by, and under the
`
`custody and control of, the Financial Institutions, by means of materially false and
`
`fraudulent pretenses, representations, and promises.
`
`22.
`
`On or about the dates identified below, in the State and Federal District of
`
`Nevada, and elsewhere,
`
`JORGE ABRAMOVS,
`
`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 7 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 7 of 19
`
`
`
`defendant herein, knowingly executed and attempted to execute the above—described
`
`scheme, each execution constituting a separate violation of Title 18, United States Code,
`
`Section 1344(2).
`
`
`
`
`
`
`
`
`COUNT, APPROXIMATE
`'
`"A'FDESCRIPTIONOP EXECUTION
`DATE
`Submissionto Financial Institution A ofPPP loan
`
`
`- Apr, 16
`application on the name of National Investment Group
`
`
`
`
`Co _- oration seekin; a loan in the amount of $134,662
`Submission to Financial Institution B of PPP loan
`
`
`application in the name of National Legal Advisors In
`
`
`
`Care Co 3 ., seeking a loan in the amount of $136,200
`
`Submission to Financial Institution B of PPP loan
`
`
`application in the name of National Investment Group
`
`
`
`
`
`Co oration seekin a loan in the amount of $138,000
`Submission to Financial Institution C of PPP loan
`
`
`
`June 1, 2020
`FOUR
`application in the name of National Legal Advisors
`
`
`
`
`
`seekin a loan in the amount of $215,624
`
`
`
`Submission to Financial Institution D of PPP loan
`
`
`application in the name of National Investment Group
`June 2, 2020
`Corporation seeking a loan in the amount of
`$199,276.04
`
`
`
`
`Ma}r 21,2020
`
`Mama
`
`COUNT SIX
`
`False Statement to a Financial Imutation
`
`(18 U.S.C. § 1014)
`
` All in violation of Title 18, United States Code, Section 1344(2).
`
`23.
`
`The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
`
`if fully set forth herein.
`
`24.
`
`On or about May 25, 2020, in the State and Federal District of Nevada,
`
`JORGE ABRAMOVS,
`
`defendant herein, knowingly made a false statement and report for the purposes of
`
`influencing the action of a financial institution, namely, Financial Institution E, Whose
`
`accounts were insured by the Federal Deposit Insurance Corporation, upon an application,
`
`agreement, and loan, to wit: false statements on a Borrower Application Form for a
`
`1
`
`2
`
`3
`
`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 8 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 8 of 19
`
`
`
`$93,403.16 loan under the Paycheck Protection Program from Financial Institution E about
`
`the number of employees, the amount of monthly payroll, the ElN and tax filing history for
`
`ABRAMOVS’ business, National Investment Group Corporation, and the intended use of
`
`the loan proceeds, in violation of Title 18, United States Code, Section 1014.
`
`All in violation of Title 18, United States Code, Section 1014.
`
`COUNTS SEVEN THROUGH ELEVEN
`Monetary Transactions in Criminally Derived Property
`(18 U.S.C. § 1957)
`
`25.
`
`The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
`
`if fully set forth herein.
`
`26.
`
`From in or around April 2020 through at least in or around August 2020, in
`
`the State and Federal District of Nevada and elsewhere,
`
`JORGE ABRAMOVS,
`
`defendant herein, knowingly engaged and attempted to engage in the following monetary
`
`transactions by, through, and to a financial institution, in and affecting interstate and
`
`foreign commerce, in criminally derived property of a value greater than $10,000, that is
`
`the deposit, Withdrawal, transfer, and exchange of United States currency, such property
`
`constituting and having been derived from a specified unlawful activity, that is, the bank
`
`fraud scheme and artifice alleged herein in paragraphs 1 through 19, in violation of 18
`
`U.S.C. § 1344(2), all in violation of Title 18, United States Code, Section 1957:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`triplescruprron (JP-TRANSACTION“
`
`,
`
`-2
`
`$222,633.59 wire fiom Financial Institution F
`account ending in 9732 to Lawyer’s Title of
`Nevada Inc
`
`$251,024.21 wire from Financial Institution F
`account ending in 9732 to Towbin Motorcars.
`
`‘V‘APPROXIMATE '
`DATE
`
`
`COUNTY-é
`a
`r
`
`.1
`
`.
`
`
`
`
`
`
`May 29, 2020
`
`
`
`
`June 1,2020
`
`
`
`
`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 9 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 9 of 19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`
`
`
`$403,906.29 Wire fiom Financial Institution F
`account ending in 9740 to Lawyer’s Title of
`Nevada Inc
`
`$95,000 Electronic Withdrawal from Financial
`Institution F account ending in 9757 to
`PENNYMAC
`
`$54,804.25 Electronic Withdrawal from Financial
`Institution F account ending in 9732 to Tesla
`Motors.
`
`‘
`June 9, 2020
`
`June 16, 2020
`
`June 19, 2020
`
`6 All in violation of Title 18, United States Code, Section 1957
`
`7
`
`10
`
`11
`
`
`FORFEITURE ALLEGATION ONE
`Bank Fraud
`
`1.
`
`The allegations contained in Counts One through Five 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)(C) with 28 U.S.C. § 2461(c) and 18
`
`12 U.S.C. § 982(a)(2)(A).
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`2.
`
`Upon conviction ofany of the felony offenses charged in Counts One
`
`through Five of this Criminal Indictment,
`
`JORGE ABRAMOVS,
`
`defendant herein, shall forfeit to the United States ofAmerica, any property, real or
`
`personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
`
`§ 1344, or a conspiracy to commit such offense:
`
`defendant herein, shall forfeit to the United States ofAmerica, any property, real or
`
`20
`
`personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
`
`§ 1344, a specified unlawful activity as defined in 18 U.S.C §§ 1956(c)(7)(A) and
`
`1961(1)(B), or a conspiracy to commit such offense:
`
`defendant herein, shall forfeit to the United States ofAmerica, any property
`
`constituting, or derived from, proceeds obtained directly or indirectly, as the result of
`
`21
`
`22
`
`23
`
`24
`
`
`
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 10 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 10 of 19
`
`1
`
`2
`
`3
`
`10
`
`11
`
`12
`
`I3
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`violations of 18 U.S.C. § 1344, or a conspiracy to violate such offense, affecting a financial
`
`institution:
`
`1. an in pets onam criminal forfeiture money judgment including, but not
`
`limited to, at least $1,986,737.46;
`
`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 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.
`
`PARCEL 2:
`
`AN ALLOCATED INTEREST AS A TENANT-IN-COML/ION IN THE
`
`CONIMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
`ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
`FORTH IN THE DECLARTION.
`
`PARCEL 3:
`
`AN EXCLUSIVE BASEMENT APPURTENANT TO PARCELS 1 AND 2
`
`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:
`
`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
`
`10
`
`
`
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 11 of 19
`Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 11 of 19
`
`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