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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA,
v.
THE REAL PROPERTY LOCATED AT
225 VALLEY ROAD, N.W., ATLANTA,
FULTON COUNTY, GEORGIA; 1418
DRESDEN DRIVE, N.E., NUMBER
A310, ATLANTA, DEKALB COUNTY,
GEORGIA; 3464 PACES PLACE, N,W.,
ATLANTA, FULTON COUNTY,
GEORGIA; 4536 EAST BROOKHAVEN
DRIVE, ATLANTA, FULTON AND
DEKALB COUNTIES, GEORGIA; 2385
HEATHER DRIVE, DECATUR,
DEKALB COUNTY, GEORGIA; 48
SHINBONE COURT, PANAMA CITY
BEACH, WALTON COUNTY,
FLORIDA, 7 LA GARZA COURT,
PANAMA CITY BEACH, WALTON
COUNTY, FLORIDA; THE 2006
CESSNA CITATION XLS,
MANUFACTURER'S SERIAL NUMBER
560-5623, BEARING REGISTRATION
NUMBER N562VP; THE GIPPS AERO
PARTY LIMITED MODEL GA8TC-320
BEARING TAIL NUMBER N68GA
AND SERIAL NUMBER GA8-TC-320-
12-187; THE EXTRA
FLUGZEUGPRODUKTIONS UND
MODEL EA300/LT BEARING TAIL
NUMBER N330TY AND SERIAL
NUMBER LT020; THE BLACK 2012
Civil Action No.
1:15-CV-
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 1 of 48
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MERCEDES BENZ GL550 BEARING
VEHICLE IDENTIFICATION NUMBER
4JGBF8GE5CA785200 AND GEORGIA
TAG NUMBER PAK5506; THE SILVER
2012 SILVER MERCEDES BENZ SLS
AMG BEARING VEHICLE
IDENTIFICATION NUMBER
WDDRJ7HA1CA008056 AND
GEORGIA TAG NUMBER BXY3941;
THE BLACK 2013 AUDI SS QUATRO
BEARING VEHICLE IDENTIFICATION
NUMBER WAUD2AFD2DN020235
AND GEORGIA TAG NUMBER
PMC8546; AND ALL RIGHT, TITLE
AND INTEREST OF STERLING
CURRENCY GROUP, LLC, STERLING
ONLINE PROCESSING SERVICES,
LLC, GID PARTNERS, LLC, ALEX
CAPITAL HOLDINGS LLC,
LULLWATER HOLDINGS LLC,
CURTIS CREEK HOLDINGS, LLC,
VALLEY TRUST, LULLWATER TRUST,
TYSON RHAME, JAMES SHAW,
CAROLE LAURETTE SHAW,
AND/OR FRANK BELL IN ALEX
CAPITAL HOLDINGS LLC; STERLING
CURRENCY GROUP LLC, STERLING
ONLINE PROCESSING SERVICES
LLC, GID PARTNERS LLC, CURTIS
CREEK HOLDINGS LLC, LULLWATER
HOLDINGS LLC, VALLEY TRUST,
LULLWATER TRUST, SPRINGLAKE
TRADING, LLC, JS REAL ESTATE
INVESTMENTS, LLC, SR EQUIPMENT
LEASING, LLC, PRIMESTONE
PROPERTIES LLC, WINGOVER
CAPITAL LLC, NORTHWEST
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 2 of 48
3
CAPITAL LLC, THE TAR REVOCABLE
TRUST, BROADWAY TRADER 4Z,
LLC, YARDS AT NODA, LLC,
SHERRILLS FORD HOLDINGS LLC,
SCOTCH COVE, LLC, RG CLASSICS
LLC, ISOLVEIT.COM LLC,
STERLINGFUNDER LLC, TRINVEST
LLC, SKY COMBAT BLUE LLC, TR
EAST POINT REAL ESTATE LLC, TR
INTERACTIVE TECHNOLOGIES LLC,
POLARIS AVIATION LLC, SKY
COMBAT RED LLC, CASCADES AT
REA, LLC, ARROWOOD STATION
HOLDINGS LLC , ARROWHEAD
STATION HOLDINGS LLC, MIRACLE
CHARTERS, LLC, TR REAL ESTATE
LLC, WHISTLEJACKET, INC., J-BREM
LLC, THERRELL FARMS ESTATES
LLC, ZONOLITE HOLDINGS LLC,
SUSTAINABILITY SOLUTIONS LLC,
GVEST HOLDINGS LLC, GVEST
PARTNERS LLC, GVEST CAPITAL
LLC, 200WEST LAND DST,
PRIMESTONE FIFECO REALTY FUND
LLC, PREFERRED CAPITAL LLC,
RECLAIM GROUP LLC, WINGOVER
RANCH, LLC, SHAW CAPITAL &
GUARANTY, LLC, SHAW
IRREVOCABLE TRUST, SHAW ALYS
BEACH LLC, TRINVEST PARTNERS,
LLC, AND GID ASSOCIATES LLC.
VERIFIED COMPLAINT FOR FORFEITURE
COMES NOW, the United States of America, the Plaintiff in this matter, by
John A. Horn, Acting United States Attorney the Northern District of Georgia,
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 3 of 48
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and Thomas J. Krepp and Jenny Turner, Assistant United States Attorneys, and
files this Complaint for Forfeiture. In support thereof, the United States shows
the following:
I. Introduction
1. This Complaint seeks forfeiture of the below-listed properties to the United
States as proceeds of specified unlawful activities and properties involved in
money laundering offenses of Sterling Currency Group, LLC (“Sterling”); Sterling
Online Processing Services, LLC (Sterling Online); GID Partners, LLC (GID); Alex
Capital Holdings LLC (Alex); James Shaw (J.Shaw); Carole Laurette Shaw
(C.Shaw); Tyson Rhame (Rhame); Frank Bell (Bell), and other entities controlled by
these same businesses and individuals that have used the facilities of interstate
commerce in a scheme to defraud investors in the Iraqi dinar by publishing and
disseminating false information about the viability of that currency as an
investment:
a. The real property located at 225 Valley Road, N.W., Atlanta,
Fulton County, GA 30305, and all buildings and appurtenances
thereto (the Valley Road Property), described more particularly
as follows:
225 Valley Road, NW, Atlanta,
Fulton County, Georgia
Tax Parcel ID No.: 17-0116LL0675
ALL THAT TRACT OR PARCEL OF LAND LYING AND
BEING IN LAND LOT 116, 17TH DISTRICT, FULTON
COUNTY, GEORGIA, BEING LOT 16 AND PART OF LOT 15,
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 4 of 48
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BLOCK 6, ACCORDING TO THE PLAT FOR TUXEDO PARK
CO., AND VALLEY ROAD CO., RECORDED AT PLAT
BOOK 17, PAGE 60, FULTON COUNTY, GEORGIA
RECORDS AND BEING MORE PARTICULARLY
DESCRIBED AS FOLLOWS:
BEGIN AT THE INTERSECTION OF THE
NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY
ROAD (A 50-FOOT RIGHT OF WAY) AND THE
NORTHWESTERLY RIGHT-OF-WAY LINE OF TUXEDO
ROAD (A 50-FOOT RIGHT-OF-WAY), SUCH
INTERSECTION BEING THE "TRUE POINT OF
BEGINNING", FROM SUCH TRUE POINT OF BEGINNING,
RUN THENCE ALONG THE NORTHEASTERLY RIGHT-OF-
WAY LINE OF VALLEY ROAD NORTH 46 DEGREES 13
MINUTES 13 SECONDS WEST A DISTANCE OF 125.21 FEET
TO A POINT ON THE NORTHEASTERLY RIGHT-OF-WAY
LINE OF VALLEY ROAD; RUN THENCE ALONG THE
NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY
ROAD AND FOLLOWING THE CURVATURE THEREOF
AN ARC DISTANCE OF 71.00 FEET TO A 1 INCH CRIMP
TOP FOUND ON THE NORTHEASTERLY RIGHT-OF-WAY
LINE OF VALLEY ROAD (SUCH ARC BEING SUBTENDED
BY A CHORD BEARING NORTH 51 DEGREES 07 MINUTES
43 SECONDS WEST A CHORD DISTANCE OF 70.93 FEET
AND HAVING A RADIUS OF 475.48 FEET); RUN THENCE
NORTH 24 DEGREES 48 MINUTES 15 SECONDS EAST A
DISTANCE OF 504.46 FEET TO A 1 INCH PIPE FOUND;
RUN THENCE SOUTH 70 DEGREES 26 MINUTES 36
SECONDS EAST A DISTANCE OF 211.47 FEET TO A ONE
INCH PIPE FOUND ON THE WESTERLY RIGHT-OF-WAY
LINE OF TUXEDO ROAD; RUN THENCE ALONG THE
WESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD
SOUTH O1 DEGREE 31 MINUTES 47 SECONDS WEST A
DISTANCE OF 144.55 FEET TO A POINT ON THE
WESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD;
RUN THENCE ALONG THE NORTHWESTERLY RIGHT OF
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 5 of 48
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WAY LINE OF TUXEDO ROAD AND FOLLOWING THE
CURVATURE THEREOF AN ARC DISTANCE OF 186.75 TO
A POINT ON THE NORTHWESTERLY RIGHT-OF-WAY
LINE OF TUXEDO ROAD (SUCH ARC BEING SUBTENDED
BY A CHORD BEARING SOUTH 21 DEGREES 10 MINUTES
41 SECONDS WEST A CHORD DISTANCE OF 186.51 FEET
AND HAVING A RADIUS OF 1,049.76 FEET); RUN THENCE
ALONG THE NORTHWESTERLY RIGHT OF WAY LINE OF
TUXEDO ROAD AND FOLLOWING THE CURVATURE
THEREOF AN ARC DISTANCE OF 284.09 FEET TO THE
INTERSECTION OF THE NORTHEASTERLY RIGHT OF
WAY LINE OF VALLEY ROAD AND THE
NORTHWESTERLY RIGHT OF WAY LINE OF TUXEDO
ROAD AND THE TRUE POINT OF BEGINNING (SUCH
ARC BEING SUBTENDED BY A CHORD BEARING SOUTH
44 DEGREES 09 MINUTES 02 SECONDS WEST A CHORD
DISTANCE OF 278.57 FEET AND HAVING A RADIUS OF
414.81) SUCH PROPERTY IS MORE PARTICULARLY
DELINEATED ON THAT CERTAIN BOUNDARY SURVEY
(PLAT NO. 99-0470405 R) FOR ROBERT P. GUYTON, JR.
AND EMILY W. GUYTON PREPARED BY WILLIAM W.
DELOACH GRLS NO. 1711, OF PEARSON & ASSOCIATES,
INC., DATED MAY 24, 1999;
b. The real property located at 1418 Dresden Drive, N.E., Number
A310, Atlanta, DeKalb County, Georgia, and all buildings and
appurtenances thereto (the Dresden Property), described more
particularly as follows:
1418 Dresden Drive, NE, Unit A310
Atlanta, DeKalb County, Georgia
Tax Parcel ID No.: 18-238-18-072
ALL THAT TRACT OR PARCEL OF LAND LYING AND
BEING IN LAND LOT 238 OF THE 18TH DISTRICT OF
DEKALB COUNTY, GEORGIA, AND BEING MORE
PARTICULARLY DESCRIBED AS FOLLOWS:
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 6 of 48
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CONDOMINIUM UNIT A-310 OF BUILDING A, THE
CONDOMINIUMS AT VILLAGE PLACE BROOKHAVEN, A
CONDOMINIUM, AS MORE PARTICULARLY DESCRIBED
AND DELINEATED IN THE DECLARATION OF
CONDOMINIUM FOR THE CONDOMINIUMS AT
VILLAGE PLACE BROOKHAVEN, RECORDED IN DEED
BOOK 21154, PAGE 494, ET SEQ., DEKALB COUNTY,
GEORGIA RECORDS, AS MAY BE AMENDED, TOGETHER
WITH ALL RIGHT, TITLE AND INTEREST IN THE
COMMON ELEMENTS AS SET FORTH IN SAID
DECLARATION.
THIS CONVEYANCE IS MADE SUBJECT TO THE
DECLARATION AND ALL MATTERS REFERENCED
THEREIN, ALL MATTERS SHOWN ON THE PLAT
RECORDED IN CONDOMINIUM PLAT BOOK 209, PAGES
80-86, DEKALB COUNTY, GEORGIA RECORDS, AS MAY BE
AMENDED, AND THE FLOOR PLANS RECORDED IN
CONDOMINIUM FLOOR PLAN BOOK 209, PAGE 87,
AFORESAID RECORDS, AS MAY BE AMENDED;
c. The real property located at 3464 Paces Place, N,W., Atlanta,
Fulton County, Georgia, and all buildings and appurtenances
thereto (the Paces Place Property), described more particularly as
follows:
3464 Paces Place, NW, Atlanta, Fulton County, Georgia
Tax Parcel ID No.: 17-019800030227
ALL THAT TRACT OR PARCEL OF LAND LYING AND
BEING IN LAND LOT 198 OF THE 17TH DISTRICT,
FULTON COUNTY, GEORGIA, BEING UNIT C-105 OF
PACES PLACE CONDOMINIUM AS PER PLAT OF SURVEY
MADE BY ERNEST L. BOGGUS, P.E. & L.S., DATED JUNE,
1966, AND SHOWN AS "PROPERTY OF MARGARET P.
HITT" RECORDED IN CONDOMINIUM PLAT BOOK 1,
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 7 of 48
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PAGES 2 AND 3, AND AS REVISED AND RECORDED IN
CONDOMINIUM PLAT BOOK 1, PAGE 16, AFORESAID
RECORDS, TOGETHER WITH ALL RIGHT, TITLE AND
INTEREST CONTAINED IN DECLARATION OF PACES
PLACE CONDOMINIUM RECORDED IN DEED BOOK 4461,
PAGES 161-226, INCLUSIVE, AND AS AMENDED BY
INSTRUMENT RECORDED IN DEED BOOK 4347, PAGE
295, AFORESAID RECORDS, SAID DECLARATION BY THIS
REFERENCE BEING INCORPORATED HEREIN AND
MADE A PART HEREOF. THE INTEREST HEREIN
CONVEYED INCLUDES WITHOUT LIMITING THE
GENERALITY OF THE FOREGOING, AN UNDIVIDED 2.776
PERCENT INTEREST IN THE COMMON AREAS AND
FACILITIES OF SAID CONDOMINIUM.
d. The real property located at 4536 East Brookhaven Drive, Atlanta,
Fulton and DeKalb Counties, Georgia, and all buildings and
appurtenances thereto (the Brookhaven Property), described
more particularly as follows:
4536 East Brookhaven Drive, NE, a/k/a 3060 Mabry Road
Atlanta, Fulton and DeKalb Counties, Georgia
Fulton County Tax Parcel ID No.: 17-001300020262
DeKalb County Tax Parcel ID No.: 18-275-02-001
ALL THAT TRACT OR PARCEL OF LAND LYING AND
BEING IN LAND LOT 13 OF THE 17TH DISTRICT, FULTON
COUNTY, GEORGIA, AND LAND LOT 275 OF THE 18TH
DISTRICT, DEKALB COUNTY, GEORGIA, BEING LOT 2 OF
THE C.H. WATFORD PROPERTY, AS PER PLAT
RECORDED IN PLAT BOOK 20, PAGE 107, DEKALB
COUNTY RECORDS, MORE PARTICULARLY DESCRIBED
AS FOLLOWS:
BEGINNING AT THE INTERSECTION OF THE NORTH
SIDE OF EAST BROOKHAVEN DRIVE WITH THE
NORTHWESTERN SIDE OF MABRY DRIVE (ROAD), IF
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 8 of 48
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SAID STREET LINES WERE EXTENDED TO FORM AN
ANGLE INSTEAD OF A CURVE; RUNNING THENCE
WESTERLY ALONG THE NORTH SIDE OF EAST
BROOKHAVEN DRIVE 94.2 FEET TO AN IRON PIN AT
THE SOUTHEAST CORNER OF LOT 1, SAID SUBDIVISION;
RUNNING THENCE NORTHWESTERLY ALONG THE
LINE DIVIDING LOT 1 AND LOT 2, SAID SUBDIVISION,
206.5 FEET TO LOT 3, SAID SUBDIVISION; RUNNING
THENCE SOUTHEASTERLY ALONG THE LINE WHICH
DIVIDES LOT 2 AND LOT 3, SAID SUBDIVISION, 220.0
FEET TO THE NORTHWESTERN SIDE OF MABRY DRIVE
(ROAD); RUNNING THENCE SOUTHWESTERLY 200.0
FEET TO THE NORTH SIDE OF EAST BROOKHAVEN
DRIVE AND THE POINT OF BEGINNING, BEING
IMPROVED PROPERTY KNOWN AS 4536 EAST
BROOKHAVEN DRIVE, ACCORDING TO THE PRESENT
SYSTEM OF NUMBERING HOUSES IN THE CITY OF
ATLANTA AND FULTON AND DEKALB COUNTIES;
e. The real property located at 2385 Heather Drive, Decatur, DeKalb
County, Georgia, and all buildings and appurtenances thereto
(the Heather Drive Property), described more particularly as
follows:
2385 Heather Drive
Decatur, DeKalb County, Georgia 30033-2701
Tax Parcel ID Number: 18 113 09 015
ALL THAT TRACT OR PARCEL OF LAND LYING AND
BEING IN LAND LOT 113 OF THE 18TH DISTRICT OF
DEKALB COUNTY, GEORGIA, BEING LOT 15, BLOCK G,
ADDITION NO. 5 OF LEAFMORE HILLS SUBDIVISION,
ACCORDING TO PLAT RECORDED AT PLAT BOOK 25,
PAGE 150, DEKALB COUNTY RECORDS, WHICH PLAT IS
HEREBY REFERRED TO AND MADE A PART OF THIS
DESCRIPTION, BEING KNOWN AS 2385 HEATHER DRIVE,
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 9 of 48
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ACCORDING TO THE PRESENT SYSTEM OF NUMBERING
HOUSES IN DEKALB COUNTY, GEORGIA.
f. The real property located at 48 Shinbone Court, Alys Walton
Beach, Walton County, Florida, and all buildings and
appurtenances thereto (the Shinbone Property), described more
particularly as follows:
48 Shinbone Court, Panama City Beach,
Walton County, Florida
Tax Parcel ID No.: 27-3S-18-16420-0JJ-0150
LOT 15, BLOCK JJ, ALYS BEACH PHASE 2B, ACCORDING
TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK
16, PAGES 81 AND 81A, OF THE PUBLIC RECORDS OF
WALTON COUNTY, FLORIDA.;
g. The real property located at 7 La Garza Court, Alys Walton
Beach, Walton County, Florida, and all buildings and
appurtenances thereto (the La Garza Property) described more
particularly as follows:
7 La Garza Court, Panama City Beach,
Walton County, Florida
Tax Parcel ID No.: 27-3S-18-16420-0NN-0060
LOT 6, BLOCK NN, ALYS BEACH PHASE 2B, ACCORDING
TO THE MAP OR PLAT THEREOF, AS RECORDED IN
PLAT BOOK 16, PAGES 81 AND 81A, OF THE PUBLIC
RECORDS OF WALTON COUNTY, FLORIDA;
h. The 2006 Cessna Citation XLS, Manufacturer's Serial Number
560-5623, bearing registration number N562VP (the Cessna);
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 10 of 48
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i. The Gipps Aero Party Limited Model GA8TC-320 bearing tail
number N68GA and serial number GA8-TC-320-12-187 (the
Gipps Aero);
j. The Extra Flugzeugproduktions Und Model EA300/LT bearing
tail number N330TY and Serial Number LT020 (the Extra);
k. The black 2012 Mercedes Benz GL550 bearing vehicle
identification number 4JGBF8GE5CA785200 and Georgia tag
number PAK5506(the Black Mercedes);
l. The silver 2012 silver Mercedes Benz SLS AMG bearing vehicle
identification number WDDRJ7HA1CA008056 and Georgia tag
number BXY3941(the Silver Mercedes);
m. The black 2013 Audi SS Quatro bearing vehicle identification
number WAUD2AFD2DN020235 and Georgia tag number
PMC8546 (the Black Audi);
n. All right, title and interest of Sterling, Sterling Online, GID, Alex
Capital Holdings LLC (Alex); Lullwater Holdings LLC
(Lullwater); Curtis Creek Holdings, LLC (Curtis Creek); Valley
Trust; Lullwater Trust, Rhame, J.Shaw, C.Shaw, and/or Bell in
the following:
i. Sterling;
ii. Sterling Online;
iii. GID;
iv. Alex;
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 11 of 48
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v. Lullwater Holdings;
vi. Lullwater Trust;
vii. Curtis Creek;
viii. Valley Trust;
ix. Springlake Trading, LLC (Springlake Trading);
x. JS Real Estate Investments, LLC (JS Real Estate
Investments);
xi. SR Equipment Leasing, LLC (SR Equipment Leasing);
xii. Primestone Properties LLC (Primestone Properties);
xiii. Wingover Capital LLC (Wingover Capital);
xiv. Northwest Capital LLC (Northwest Capital);
xv. The TAR Revocable Trust (TAR);
xvi. Broadway Trader 4Z, LLC (Broadway Trader);
xvii. Yards at Noda, LLC (Yards at Noda);
xviii. Sherrills Ford Holdings LLC (Sherrill’s Ford);
xix. Scotch Cove, LLC (Scotch Cove);
xx. RG Classics LLC (RG Classics);
xxi. Isolveit.com LLC (Isolveit);
xxii. Sterlingfunder LLC (Sterlingfunder);
xxiii. Trinvest LLC (Trinvest);
xxiv. Sky Combat Blue LLC (Sky Combat Blue);
xxv. TR East Point Real Estate LLC (TR East Point);
xxvi. TR Interactive Technologies LLC (TR Interactive
Technologies);
xxvii. Polaris Aviation LLC (Polaris Aviation);
xxviii. Sky Combat Red LLC (Sky Combat Red);
xxix. Cascades at Rea, LLC (Cascades at Rea);
xxx. Arrowood Station Holdings LLC (Arrowood Station
Holdings);
xxxi. Arrowhead Station Holdings LLC (Arrowood Station
Holdings);
xxxii. Miracle Charters, LLC (Miracle Charters)
xxxiii. TR Real Estate LLC (TR Real Estate);
xxxiv. Whistlejacket, Inc. (Whistlejacket);
xxxv. J-Brem LLC (J-Brem);
xxxvi. Therrell Farms Estates LLC (Therrell Farms Estates);
xxxvii. Zonolite Holdings LLC (Zonolite Holdings);
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 12 of 48
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xxxviii. Sustainability Solutions LLC (Sustainability Soultions);
xxxix. Gvest Holdings LLC (Gvest Holdings);
xl. Gvest Partners LLC (Gvest Partners);
xli. Gvest Capital LLC (Gvest Capital);
xlii. 200West Land DST (200 West Land);
xliii. Primestone FifeCo Realty Fund LLC (Primestone-FifeCo);
xliv. Preferred Capital LLC (Preferred Capital);
xlv. Reclaim Group LLC (Reclaim Group);
xlvi. Wingover Ranch, LLC (Wingover Ranch);
xlvii. Shaw Capital & Guaranty, LLC (Shaw Capital and
Guaranty);
xlviii. Shaw Irrevocable Trust (Shaw Irrevocable Trust);
xlix. Shaw Alys Beach LLC (Shaw Alys Beach);
l. Trinvest Partners, LLC (Trinvest Partners); and
li. GID Associates LLC (GID Associates).
(collectively the Defendant Properties).
2. Based on the evidence described below, the Defendant Properties are subject
to forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) as proceeds of
specified unlawful activity traceable directly and indirectly to violations of 18
U.S.C. §§ 1341, 1343, 1349, 1956, and 1957.
3. Additionally, the Defendant Properties are subject to forfeiture to the United
States pursuant to 18 U.S.C. § 981(a)(1)(A) as property involved in money
laundering offenses in violation of 18 U.S.C. §§ 1956 and 1957.
4. This Court has jurisdiction over this action and the claims raised herein by
virtue of 28 U.S.C. §§ 1345 and 1355(a).
5. Venue is proper in the Northern District of Georgia as to the Valley Road
Property, the Dresden Property, the Paces Place Property, the Brookhaven
Property, the Heather Drive Property, the Black Mercedes, the Silver Mercedes, and
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 13 of 48
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the Black Audi because those properties are located and remain herein. See 28
U.S.C. §§ 1395(a) and (b).
6. Additionally, venue is proper in the Northern District of Georgia as to all of
the Defendant Properties because acts in furtherance of the conspiracies and
substantive offenses alleged above occurred herein and because the offenses
subjecting that property are properly chargeable in the Northern District of
Georgia. See 28 U.S.C. §§ 1355 (b) and 1395(a) and (b).
II. Facts Giving Rise to Forfeiture
A. The Business of Sterling Currency Group
7. Since at least 2004, Sterling Currency Group, LLC (“Sterling”), an Atlanta,
Georgia-based business that also does business under the name Dinar Banker, has
become one of the largest sellers of Iraqi dinar in the United States. While Sterling
also offers the sale of what its website calls “other exotic currencies,” including the
Vietnamese Dong, Indonesian Rupiah, Afghani, and Chinese Yuan, the bulk of
Sterling’s business comes from the sale of the Iraqi dinar.
8. Sterling is one of several money service businesses in the United States that
purchases the Iraqi dinar abroad for sale to customers in the United States and
Canada.
9. Sterling purchases its inventory of dinar notes from exchangers in the Middle
East, transports the notes in bulk to the United States via commercial carrier,
retrieves the notes from Hartsfield Jackson International Airport, and trucks them
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 14 of 48
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for storage to a business location in Atlanta, Georgia, where they remain available
to fill customer orders placed on its websites (initially at www.dinarbanker.com
and now at www.sterlingcurrencygroup.com) and over the telephone.
10. Sterling operates in partnership with Sterling Online Processing (“Sterling
Online”), which provides administrative services for Sterling, as well as GID
Partners (“GID Partners”), which is an Iraqi dinar exchanger purchased by
Sterling.
11. Tyson Rhame (Rhame) and James Shaw (J.Shaw) are the co-owners and co-
founders of Sterling. Rhame and Shaw share ownership of Sterling through their
respective interests in several corporations, including Alex Capital Holdings
(“Alex”), Lullwater Holdings (“Lullwater”), and Curtis Creek Holdings (“Curtis
Creek”) as well as the trusts “Valley Trust” and “Lullwater Trust.”
12. Carol Laurette Shaw (C.Shaw) is married to J. Shaw and is also a co-owner of
Sterling through her interests in Alex, Curtis Creek, and Valley Trust. As recently
as 2011, C.Shaw played an active role in Sterling’s operations.
13. Frank Bell (Bell) began working for Sterling in 2010 and is presently
Sterling’s Chief Operating Officer (COO). Bell presently runs the day-to-day affairs
of Sterling.
14. Since at least 2010, Rhame, J.Shaw, C.Shaw, and Bell have shared control of
Sterling’s operations.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 15 of 48
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B. Knowledge of the Scam
15. Sterling’s success is at least partially attributable to its use of the facilities of
interstate commerce, including wire communications, both directly and indirectly,
to disseminate false and misleading information about the possibility of a
revaluation of the dinar and to steer customers toward choosing Sterling over its
competitors.
16. The revaluation (or simply, “RV”) theory has spread throughout the Internet
and is promoted by a variety of internet blogs and individuals who hold
themselves out to be currency experts or “dinar gurus.” According to the RV
theory, the dinar will experience an abrupt, exponential rise in value against the
U.S. dollar and hence yield enormous profits for dinar holders.
17. An individual who worked for Sterling from approximately 2013 to 2015
confirmed that Bell at one point told customer service center representatives in a
meeting that there would never be an Iraqi dinar revaluation. Bell instructed the
representatives not to tell callers that the revaluation will never occur but to tell the
callers to do their own research.
18. Email communications between Rhame, J.Shaw, C.Shaw, and Bell confirm
that these individuals know that the concept of the dinar revaluation is a scam.
a. For instance, C.Shaw sent an October 20, 2010, email to Rhame
that stated, in part, “I cant [sic] watch these folks be so stupid”
and then stated “3 orders all for 100,000 at 200 each and 1 order
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 16 of 48
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for 10 notes at 330 shipping overnight each at 43.00 and to the
same address.”
b. On November 3, 2010, J.Shaw sent an email to Rhame entitled,
“Discussion Point,” an email that he also forwarded to C.Shaw,
which read, in part:
Ty,
The point of my call was not to talk about net worth. We have a
business that I valued at $8-10 million in that formula (SCG).
Laurette and I do not think about how much is hers and mine as
you do in your relationship (like I should give her 99% of profits).
We are 50-50 partners on everything and if we ever split up we
would divide all assets as such. She has lately been very nervous
and was crying last night because she knows we are running an
illegal operation.
The point is that her [sic] and I have worked way too hard in life
for us to risk everything based on your belief (even if I agree with
you) that the Iraqi dinar will not RV and it is ok to make millions
of dollars in false promises to our customers. Not only are we
risking everything we own, we are risking serious jail time as
promoters of a ponzi scheme. . .
Jim
19. A series of emails sent on November 30, 2010, further shows knowledge and
intent.
a. On that date, Rhame sent an email to J.Shaw that J.Shaw then
forwarded to C.Shaw, which read in part, “Our business is
chicken shit and we got CRUSHED in a conference call on
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 17 of 48
18
Sunday night---not because of anything said against us, but
because we operate small minded and haven't been growing. We
are not a real company. I got beat up in a conference call again
last night because of our limited growth.”
b. J.Shaw’s response to Rhame, one that he forwarded to C.Shaw,
stated, in part, “Laurettes [sic] job is just as important as yours. I
am sick of seeing her work most days and nights just to have you
pretend to be doing so much more than anyone.” The email also
stated, “I am not sure how much bigger this business needs to be
until it can be managed properly. We are at risk for lawsuits and
other problems. We are not selling Coca Cola.”
c. On that same date, another email from J.Shaw to Rhame, one that
J.Shaw ultimately forwarded to C.Shaw more than a year later on
December 20, 2011, read as follows:
Ty,
The more I think of your bullshit emails the more it disgusts me. I
bankrolled this entire business at its inception by putting up 80%
of initial capital (500/630). Throw in Zurich and I bankrolled 95%
of all finances. Laurette has done at least 50% of the work and I
was instrumental in our website and getting the business
growing. Our agreement was that you and Laurette would work
the business. How much work has Bonnie done? AS SOON AS
THE BUSINESS STARTS TO DO REALLY WELL, YOU START
THROWING OUT YOUR CONTROL FREAK EMAILS.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 18 of 48
19
FYI: Laurette and I are concerned about getting letters to you
thanking you for helping them with their hospital with their
purchase of $20k for a $200k layaway and other similar letters.
We are not Charlatans and I do not like making money under
false pretenses. I DONOT WANT TO BE ALI. Our life is happy
without swindling people.”
20. Additionally, a March 22, 2011, set of emails further shows that Rhame and
C.Shaw were aware of Sterling’s wrongdoing.
a. Specifically, on that date, Rhame sent C.Shaw an email that
copied J.Shaw with the subject, “Comments related to
AMENDED Operating Agreement” in which he asserted, “This
amendment is complete bullshit written for the purpose of
obtaining banking. Jim and Ty are operation [sic] under the
original partnership agreement. We are 50% partners and his ass
will go to prison if mine does.”
b. Thereafter, C.Shaw replied, “and won't your asses have an
interesting time there. NOT.”
21. Likewise, on August 6, 2012, J.Shaw sent Bell an email with the subject line,
“not great article,” that contained a hyperlink to a news article entitled, “You Can’t
Fix Stupid – The Iraqi Dinar Scam Lives.”
C. Sterling’s Unlawful Business Practices
22. Sterling’s unlawful business practices fall into at least two categories. First,
Sterling unlawfully used at least one revaluation promoter to disseminate false
information and steer prospective dinar purchasers toward Sterling. Second,
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 19 of 48
20
Sterling used telephone conversations and its own web site to make false
representations and false promises to its customers.
i. Sterling’s Use of the RV Promoters’ Web Sites
23. Sterling has knowingly benefitted from false representations made by web
sites and blogs, including “The GET Team.”
24. The GET Team, which is led by an individual known as TerryK, runs an
internet chat room and weekly conference calls in which information about the
Iraqi dinar is discussed. During those chats and conferences, TerryK spreads false
information suggesting that the revaluation is about to occur.
25. In a September 13, 2010, email, TerryK introduced himself to Rhame:
Ty, My name is TerryK, I own the worlds [sic] largest Dinar web site
going….we have currently 7200 members and currently we hold two calls a
week with about 1500 on the call and 100’s if not 1,000’s on skype listening
in…what I would like to do is open a discussion with you and maybe have
you on a call this coming wed night. It starts at 9pm and thought maybe 10-
15 min on how you operate, how to cash in with your firm and then a
question and answers session….let me know via email [sic].
terryk.
26. Thereafter, beginning at least as early as 2011, Sterling began making
monthly payments in the amount of $4,000 to TerryK. In total, Sterling has paid
TerryK more than $150,000 since 2011.
27. Since TerryK’s 2010 email, Sterling employees, including Bell and Rhame,
have routinely spoken on the GET Team’s weekly conference calls. For example,
on the May 27, 2015, GET Team conference call, Bell stated that Sterling would be
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 20 of 48
21
offering a “fire sale” in early June 2015. During this conference call, TerryK stated
that listeners should purchase currency from Sterling, that he trusted his friends
“Ty” and “Frank” at Sterling, and that he had so much trust in Bell that he would
be comfortable giving Bell his bank account information.
28. In the GET Team chat room and during the weekly conference calls, TerryK
also passed along false information purportedly received from sources about the
revaluation of the Iraqi dinar and other currencies (such as the Vietnamese dong).
a. For example, on the January 8, 2014, conference call, TerryK
stated that a source at Wells Fargo said that it would take at most
10 to 15 minutes to process the exchange of Iraqi dinar.
b. Additionally, on the March 12, 2014, conference call, TerryK
stated that a source at Wells Fargo had told him “it” was
supposed to happen but that the time kept changing.
c. Likewise, on the April 16, 2014, conference call, TerryK said that
he had heard from the “UST,” a reference to the U.S. Department
of Treasury, that the rate was good and that everything would be
released that week.
29. On June 3, 2015, TerryK acknowledged during an interview with the Federal
Bureau of Investigation (FBI) that he had fabricated source information on GET
Team online postings and conference calls.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 21 of 48
22
30. In fact, the U.S. Department of Treasury is not preparing and has never
prepared for an Iraqi dinar revaluation.
31. Similarly, Wells Fargo does not trade in the Iraqi dinar and also warns its
customers not to invest in it. In fact, a publicly available Well Fargo Advisors
Memorandum dated March 10, 2014, states that Wells Fargo is not preparing for an
Iraqi dinar revaluation and has no plans whatsoever to exchange the Iraqi dinar.
32. Moreover, a November 7, 2011, email exchange between TerryK, Rhame and
Bell confirms that TerryK and Sterling have sought to keep the specific nature of
their relationship secret.
a. On that date, TerryK sent an email to Rhame and Bell that read:
“I want to make sure that our arrangement is between us and no
one else...As no one else needs to know about our arrangement...
Please confirm...
Thanks for all you guys do... [sic]”
b. Bell’s reply, sent that same day, read, “Absolutely noone [sic] but
us [sic].”
33. Although on May 28, 2015, Bell represented to the FBI during an interview
that Sterling maintains a “firewall” between itself and revaluation promoters, email
records belie his assertions.
a. For instance, on May 22, 2012, TerryK sent an email to Rhame
and Bell that read as follows:
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23
You should have gotten a lot of business on the reserves the past
week, been pushing it hard on the site bro…..make sure TY is not
selling dinar from the middle table that one is mine…..[sic]”
Bell’s reply, sent the following day, read, “TK, Will do, thanks for
your support.”
b. Likewise, on March 11, 2013, TerryK sent Bell an email that read,
FYI Received payment today, thanks for following up..What else
can I do to help sales for your team? Just let me know buddy, I
will be in the room later today to get some things moving as well
[sic].
c. Also, on July 22, 2013, TerryK sent Bell an email reading as
follows:
Frank, please find attached the banner invoice for the month of
August 2013, I trust things are going well, as we keep promoting
the heck out of Sterling.. [sic] If there is anything you need let me
know.
34. On June 3, 2015, Bell acknowledged to FBI agents that Sterling should not
have continued to do business with the dinar promoters.
ii. False Representations and Promises on Sterling’s Website
35. Sterling’s business practices have included publishing information on its
own website that its principals knew to be untrue and disseminating false
information over the telephone.
36. For instance, though Sterling’s website now warns customers that “Sterling
Currency Group / DinarBanker is not an accredited financial consultant” and that
“that the value of the currency may go down or go up depending on circumstances
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 23 of 48
24
beyond our control,” in 2010, Sterling, used its former website,
www.dinarbanker.com, to suggest that a revaluation could occur in the near future.
37. Furthermore, on of December 27, 2010, Sterling’s website displayed an article
titled “Iraqi Dinar Revaluation” that cited Tyson Rhame as its primary source and
that stated, in part:1
To put it simply, the Iraqi Dinar is currently worth less than
1/10th of a US penny (Approximately $1000 US dollars buys 1
million Iraqi Dinar). Historically, the Iraqi Dinar has been worth
over 3 US dollars for every Iraqi Dinar (Over $3,000,000 US
dollars purchased 1 million Iraqi Dinar). Put another way, 1
million Iraqi Dinar is currently worth a little less that 1000 US
dollars and historically 1 million Iraqi Dinar has been worth well
over $3,000,000.00 US dollars. So, the question is: Will the Iraqi
Dinar increase in value? And if so, how? And when?
* * * *
The bottom line is that the Iraqi Dinar is currently at an extremely
low valuation compared to the US Dollar. The currency has
steadily increased in value since inception in late 2003. Iraq is a
country with phenomenal wealth potential; and additionally,
has the backing and support of the major political and
economic powers of the world. There currently seems to be
minimal risk that the Iraqi Dinar will decrease in value. The
tremendous potential upside return compared to the minimal
downside risk seems to make the Iraqi Dinar a compelling
investment opportunity worth investigating.
* * *
In determining when the Iraqi Dinar will increase in value, all
indicators point toward something happening in the near
future (next 12 months) if not the very near future (next 3
1 All emphases are in the original material.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 24 of 48
25
months). The appreciation of the Iraqi Dinar has been
unprecedentedly flat over the past 8 months despite low Iraqi
inflation and a weakening US economy and US dollar. The Iraqi
economy has been on a continual surge of economic growth for
the past couple of years as Iraq has continued to stabilize and
rebuild. The news coming out of Iraq from numerous returning
military members with various reliable sources indicates a rapid
move and increase in valuation occurring prior to, or in
conjunction with US troop reductions. Indicators also point to an
increase in the Iraqi Dinar exchange rate occurring prior to, or
shortly after Iraqi elections. It appears that administratively, the
IMF, WTO, and other world financial entities are working in
close conjunction with the Iraqi Government to bring Iraq’s
financial system online with the rest of the world. The
expectation is that the Iraqi Dinar will soon be freely traded
through banks worldwide---further accelerating their recovery
and economy, and adding to overall stability.
* * *
To answer the question of ‘How’ and ‘How high?’ the Iraqi Dinar
will revaluate, some speculation is in order. Based on historical
precedents, an initial sudden significantly (overnight/over
weekend) high revaluation seems very possible. This initial
move could be anywhere along the entire spectrum of rumored
possibilities from $.01 to $1.49. After this initial revaluation, it
seems likely there will be numerous significant incremental
increases in valuation over a period of time. This continual
increase in value after an initial base valuation will prevent an
overwhelming surge on the world financial system. By
incrementally increasing the value of the dinar, it will limit the
number and amount of Iraqi Dinar exchanges as many investors
and currency traders will choose to hold their Iraqi Dinar or
purchase more as they anticipate further valuation increases. In
other words, a steady increase in the value of the Iraqi Dinar will
create a free flowing market as some investors cash-out, others
hold on, and others purchase Iraqi Dinar for the first time.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 25 of 48
26
38. In contrast, since that time, Bell has told FBI agents that he believes that the
Iraqi dinar will never revalue. In a May 28, 2015, interview with the FBI, Bell
explained that based upon his education and experience with international finance,
he believes that the Iraqi dinar will never be revalued to the extent that dinar
promoters commonly claim. Furthermore, in a June 3, 2015, interview with the FBI,
Bell used the term “mythology” when discussing the concept of an Iraqi dinar
revaluation.
39. In 2010, Sterling’s website also represented that following the revaluation,
customers would be able to exchange their Iraqi dinars at kiosks or “remote
satellite offices” located at airports around the country.
40. Postings to Sterling’s website are illustrative.
a. For instance as of January 3, 2010, Sterling’s website displayed an
article titled, “Complete Guide To Exchanging Iraqi Dinar After
Revaluation” that stated, in part,
Dinar Banker has the ability to set up secure remote satellite
offices at numerous airport locations nationwide within 24
hours. They have a long history of transporting and securing
currency all over the world through their global operations and
are prepared for any exchange needs.2
b. Similarly, as of October 21, 2010, Sterling’s website displayed an
article titled, “Iraqi Dinar Exchange Locations” that stated, in
part:
2 Emphasis in original.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 26 of 48
27
DinarBanker will have secure remote satellite offices
set up at numerous airport locations nationwide as
soon as possible in the event of a revaluation. You
will not have to go through security in the airport
exchange locations – You can simply come in with
Dinar in a briefcase or luggage and come to the
exchange location set up in the office area of each
airport. We will have de la Rue machines to quickly
count and verify your Dinar and all equipment
needed to perform fast and secure wire transfers.
c. That same article then represented that the “Current Exchange
Locations” that Sterling planned “in the Event of an RV
include[d]:”
City, State - Airport Code
Atlanta, GA - ATL
Boston, MA - BOS
Chicago, IL - ORD
Cincinnati, OH - CVG
Dallas / Forth Worth, TX - DFW
Denver, CO - DEN
Detroit, MI - DTW
Houston, TX - IAH
Las Vegas, NV - LAS
Los Angeles, CA - LAX
Miami, FL - MIA
Minneapolis, MN - MSP
New Orleans, LA - MSY
New York, NY - JFK
Phoenix, AZ - PHX
Salt Lake City, UT - SLC
San Francisco, CA - SFO
Seattle, WA - SEA
St. Louis, MO - STL
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 27 of 48
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Tampa, FL - TPA
Washington, DC - DCA (Ronald Reagan)
Washington, DC - IAD (Dulles)
International Locations
Calgary, Canada - YYC
Vancouver, Canada - CYVR
Toronto, Canada - CYXZ
San Juan, Puerto Rico
41. In 2010, Rhame told a Sterling customer over the telephone that Sterling
would open a kiosk at John F. Kennedy International Airport in New York
following the revaluation to exchange Iraqi dinars for U.S. dollars.
42. Despite these representations, a former Sterling employee has confirmed that
Sterling never had any arrangements with airports to operate remote satellite
offices or kiosks. Furthermore, representatives from three of the above-listed
airports have confirmed that Sterling never had arrangements to operate remote
satellite offices or kiosks.
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37
Isolveit.com, Sherrills Ford Holdings, Trinvest Partners, Sky Combat Blue, Sky
Combat Red, Polaris Aviation, TR East Point Real Estate, TR Interactive
Technologies, Sterling Funder, SR Equipment Leasing, and TAR Revocable Trust.
49. Similarly, J.Shaw and C.Shaw own Curtis Creek directly and through Valley
Trust. In addition, J.Shaw has or had an interest in or some degree of control over
JS Real Estate Investments, Primestone Properties, SR Equipment Leasing LLC,
Wingover Capital LLC, Northwest Capital LLC, Broadway Trader 4Z, Springlake
Trading, Sterling Funder, and Alys Beach Fund.
50. Bell manages the daily affairs of the Sterling entities as the Chief Operating
Officer and through his company, Whistlejacket. In addition, Bell has at one point
had an interest in or some degree of control over “J-Brem.”
B. Tracing the Tainted Funds
51. Sterling has used at least nine known bank accounts to receive currency
purchase money from investors.
52. As detailed in Exhibits A, B, C, D, and E to this Complaint, proceeds from
sales of currency to consumers were received in the nine accounts listed below, and
gross deposits into each account during the range specified appear below:
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39
Brem, Therrell Farms Estates, Zonolite Holdings, Sustainability Solutions, Gvest
Holdings, Gvest Partners, Gvest Capital, 200 West Land DST, Primestone Feifco
Realty Fund, Preferred Capital, Reclaim Group, Wingover Ranch, Shaw Capital &
Guaranty, Shaw Irrevocable Trust, Shaw Alys Beach, Trinvest Partners, GID
Associates and/or assets owned by those business entities.
54. The purposes behind some of those financial transactions included remitting
proceeds to conspirators, facilitating the operation of the underlying scheme, and
concealing and disguising the nature, source, location, ownership, and control of
fraud proceeds.
55. Additionally, by moving the tainted funds out of receiving accounts and into
“downstream” accounts, conspirators engaged in unlawful monetary transactions
involving more than $10,000 in tainted funds.
56. Finally, acts promoting the schemes to defraud and launder money were
committed at the Valley Road, Heather Drive, and Brookhaven Properties.
57. Consequently, the United States is entitled to forfeiture of the Defendant
Properties as proceeds traceable directly and indirectly to schemes and artifices to
defraud and properties involved in money laundering offenses.
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 39 of 48
40
IV. Conclusion
WHEREFORE, the United States prays:
That the Court forfeit the Defendant Properties to the United States of
America;
That the Court award the Plaintiff the costs of this action; and
That the Court grant such other relief as the Court deems just and proper.
Respectfully submitted this 5th day of June, 2015.
Respectfully submitted,
JOHN A. HORN
Acting United States Attorney
600 U.S. Courthouse
75 Spring Street SW
Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
/s/THOMAS J. KREPP
Assistant United States Attorney
Georgia Bar No. 346781
/s/JENNY R. TURNER
Assistant United States Attorney
Georgia Bar No. 719439
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 40 of 48
41
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERCIA,
v.
THE REAL PROPERTY LOCATED AT
225 VALLEY ROAD, N.W., ATLANTA,
FULTON COUNTY, GEORGIA; 1418
DRESDEN DRIVE, N.E., NUMBER
A310, ATLANTA, DEKALB COUNTY,
GEORGIA; 3464 PACES PLACE, N,W.,
ATLANTA, FULTON COUNTY,
GEORGIA; 4536 EAST BROOKHAVEN
DRIVE, ATLANTA, FULTON AND
DEKALB COUNTIES, GEORGIA;
2385 HEATHER DRIVE, DECATUR,
DEKALB COUNTY, GEORGIA; 48
SHINBONE COURT, PANAMA CITY
BEACH, WALTON COUNTY,
FLORIDA, 7 LA GARZA COURT,
PANAMA CITY BEACH, WALTON
COUNTY, FLORIDA; THE 2006
CESSNA CITATION XLS,
MANUFACTURER'S SERIAL NUMBER
560-5623, BEARING REGISTRATION
NUMBER N562VP; THE GIPPS AERO
PARTY LIMITED MODEL GA8TC-320
BEARING TAIL NUMBER N68GA
AND SERIAL NUMBER GA8-TC-320-
12-187; THE EXTRA
FLUGZEUGPRODUKTIONS UND
MODEL EA300/LT BEARING TAIL
NUMBER N330TY AND SERIAL
Civil Action No.
1:15-CV-
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 41 of 48
42
NUMBER LT020; THE BLACK 2012
MERCEDES BENZ GL550 BEARING
VEHICLE IDENTIFICATION NUMBER
4JGBF8GE5CA785200 AND GEORGIA
TAG NUMBER PAK5506; THE SILVER
2012 SILVER MERCEDES BENZ SLS
AMG BEARING VEHICLE
IDENTIFICATION NUMBER
WDDRJ7HA1CA008056 AND
GEORGIA TAG NUMBER BXY3941;
THE BLACK 2013 AUDI SS QUATRO
BEARING VEHICLE IDENTIFICATION
NUMBER WAUD2AFD2DN020235
AND GEORGIA TAG NUMBER
PMC8546; AND ALL RIGHT, TITLE
AND INTEREST OF STERLING
CURRENCY GROUP, LLC, STERLING
ONLINE PROCESSING SERVICES,
LLC, GID PARTNERS, LLC, ALEX
CAPITAL HOLDINGS LLC,
LULLWATER HOLDINGS LLC,
CURTIS CREEK HOLDINGS, LLC,
VALLEY TRUST, LULLWATER TRUST,
TYSON RHAME, JAMES SHAW,
CAROLE LAURETTE SHAW,
AND/OR FRANK BELL IN ALEX
CAPITAL HOLDINGS LLC; STERLING
CURRENCY GROUP LLC, STERLING
ONLINE PROCESSING SERVICES
LLC, GID PARTNERS LLC, CURTIS
CREEK HOLDINGS LLC, LULLWATER
HOLDINGS LLC, VALLEY TRUST,
LULLWATER TRUST, SPRINGLAKE
TRADING, LLC, JS REAL ESTATE
INVESTMENTS, LLC, SR EQUIPMENT
LEASING, LLC, PRIMESTONE
PROPERTIES LLC, WINGOVER
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 42 of 48
43
CAPITAL LLC, NORTHWEST
CAPITAL LLC, THE TAR REVOCABLE
TRUST, BROADWAY TRADER 4Z,
LLC, YARDS AT NODA, LLC,
SHERRILLS FORD HOLDINGS LLC,
SCOTCH COVE, LLC, RG CLASSICS
LLC, ISOLVEIT.COM LLC,
STERLINGFUNDER LLC, TRINVEST
LLC, SKY COMBAT BLUE LLC, TR
EAST POINT REAL ESTATE LLC, TR
INTERACTIVE TECHNOLOGIES LLC,
POLARIS AVIATION LLC, SKY
COMBAT RED LLC, CASCADES AT
REA, LLC, ARROWOOD STATION
HOLDINGS LLC , ARROWHEAD
STATION HOLDINGS LLC, MIRACLE
CHARTERS, LLC, TR REAL ESTATE
LLC, WHISTLEJACKET, INC., J-BREM
LLC, THERRELL FARMS ESTATES
LLC, ZONOLITE HOLDINGS LLC,
SUSTAINABILITY SOLUTIONS LLC,
GVEST HOLDINGS LLC, GVEST
PARTNERS LLC, GVEST CAPITAL
LLC, 200WEST LAND DST,
PRIMESTONE FIFECO REALTY FUND
LLC, PREFERRED CAPITAL LLC,
RECLAIM GROUP LLC, WINGOVER
RANCH, LLC, SHAW CAPITAL &
GUARANTY, LLC, SHAW
IRREVOCABLE TRUST, SHAW ALYS
BEACH LLC, TRINVEST PARTNERS,
LLC, AND GID ASSOCIATES LLC.
VERIFICATION
I, W. Scott Baucom, of the Federal Bureau of Investigation, have read the
Complaint for Forfeiture in this action and state that its contents are true and
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 43 of 48
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 44 of 48
45
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERCIA,
v.
THE REAL PROPERTY LOCATED AT
225 VALLEY ROAD, N.W., ATLANTA,
FULTON COUNTY, GEORGIA; 1418
DRESDEN DRIVE, N.E., NUMBER
A310, ATLANTA, DEKALB COUNTY,
GEORGIA; 3464 PACES PLACE, N,W.,
ATLANTA, FULTON COUNTY,
GEORGIA; 4536 EAST BROOKHAVEN
DRIVE, ATLANTA, FULTON AND
DEKALB COUNTIES, GEORGIA; 2385
HEATHER DRIVE, DECATUR,
DEKALB COUNTY, GEORGIA; 48
SHINBONE COURT, PANAMA CITY
BEACH, WALTON COUNTY,
FLORIDA, 7 LA GARZA COURT,
PANAMA CITY BEACH, WALTON
COUNTY, FLORIDA; THE 2006
CESSNA CITATION XLS,
MANUFACTURER'S SERIAL NUMBER
560-5623, BEARING REGISTRATION
NUMBER N562VP; THE GIPPS AERO
PARTY LIMITED MODEL GA8TC-320
BEARING TAIL NUMBER N68GA
AND SERIAL NUMBER GA8-TC-320-
12-187; THE EXTRA
FLUGZEUGPRODUKTIONS UND
MODEL EA300/LT BEARING TAIL
NUMBER N330TY AND SERIAL
NUMBER LT020; THE BLACK 2012
MERCEDES BENZ GL550 BEARING
Civil Action No.
1:15-CV-
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 45 of 48
46
VEHICLE IDENTIFICATION NUMBER
4JGBF8GE5CA785200 AND GEORGIA
TAG NUMBER PAK5506; THE SILVER
2012 SILVER MERCEDES BENZ SLS
AMG BEARING VEHICLE
IDENTIFICATION NUMBER
WDDRJ7HA1CA008056 AND
GEORGIA TAG NUMBER BXY3941;
THE BLACK 2013 AUDI SS QUATRO
BEARING VEHICLE IDENTIFICATION
NUMBER WAUD2AFD2DN020235
AND GEORGIA TAG NUMBER
PMC8546; AND ALL RIGHT, TITLE
AND INTEREST OF STERLING
CURRENCY GROUP, LLC, STERLING
ONLINE PROCESSING SERVICES,
LLC, GID PARTNERS, LLC, ALEX
CAPITAL HOLDINGS LLC,
LULLWATER HOLDINGS LLC,
CURTIS CREEK HOLDINGS, LLC,
VALLEY TRUST, LULLWATER TRUST,
TYSON RHAME, JAMES SHAW,
CAROLE LAURETTE SHAW,
AND/OR FRANK BELL IN ALEX
CAPITAL HOLDINGS LLC; STERLING
CURRENCY GROUP LLC, STERLING
ONLINE PROCESSING SERVICES
LLC, GID PARTNERS LLC, CURTIS
CREEK HOLDINGS LLC, LULLWATER
HOLDINGS LLC, VALLEY TRUST,
LULLWATER TRUST, SPRINGLAKE
TRADING, LLC, JS REAL ESTATE
INVESTMENTS, LLC, SR EQUIPMENT
LEASING, LLC, PRIMESTONE
PROPERTIES LLC, WINGOVER
CAPITAL LLC, NORTHWEST
CAPITAL LLC, THE TAR REVOCABLE
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 46 of 48
47
TRUST, BROADWAY TRADER 4Z,
LLC, YARDS AT NODA, LLC,
SHERRILLS FORD HOLDINGS LLC,
SCOTCH COVE, LLC, RG CLASSICS
LLC, ISOLVEIT.COM LLC,
STERLINGFUNDER LLC, TRINVEST
LLC, SKY COMBAT BLUE LLC, TR
EAST POINT REAL ESTATE LLC, TR
INTERACTIVE TECHNOLOGIES LLC,
POLARIS AVIATION LLC, SKY
COMBAT RED LLC, CASCADES AT
REA, LLC, ARROWOOD STATION
HOLDINGS LLC , ARROWHEAD
STATION HOLDINGS LLC, MIRACLE
CHARTERS, LLC, TR REAL ESTATE
LLC, WHISTLEJACKET, INC., J-BREM
LLC, THERRELL FARMS ESTATES
LLC, ZONOLITE HOLDINGS LLC,
SUSTAINABILITY SOLUTIONS LLC,
GVEST HOLDINGS LLC, GVEST
PARTNERS LLC, GVEST CAPITAL
LLC, 200WEST LAND DST,
PRIMESTONE FIFECO REALTY FUND
LLC, PREFERRED CAPITAL LLC,
RECLAIM GROUP LLC, WINGOVER
RANCH, LLC, SHAW CAPITAL &
GUARANTY, LLC, SHAW
IRREVOCABLE TRUST, SHAW ALYS
BEACH LLC, TRINVEST PARTNERS,
LLC, AND GID ASSOCIATES LLC.
I hereby certify, pursuant to Local Rules 5.1 and 7.1D, that the foregoing Verified
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 47 of 48
48
Complaint for Forfeiture has been prepared using Book Antiqua, 13 point font.
/s/ Thomas J. Krepp
Assistant U.S. Attorney
Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 48 of 48
CM/ECF Mobile - GAND 
   
292 Docket Entries for Case 1:15-cv-02032-LMM
06/05/2015 COMPLAINT FOR FORFEITURE filed by United States of America. (No Fee Required)
(Attachments: # 1 Ex. - A, # 2 Ex. - B, # 3 Ex. - C, # 4 Ex. - D, # 5 Ex. - E, # 6 Ex. - F, # 7 Ex. - G, # 8 Ex. - H,
# 9 Ex - I, # 10 Ex. - J, # 11 Ex. - K, # 12 Civil Cover Sheet)(eop) Please visit our website at
http://www.gand.uscourts.gov/forms to obtain Pretrial Instructions which includes the Consent To Proceed
Before U.S. Magistrate form. Modified text on 6/9/2015 (eop).
06/09/2015 AMENDED COMPLAINT against All Defendants, filed by United States of America. (Attachments:
# 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit
H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Krepp, Thomas) Please visit our website at
http://www.gand.uscourts.gov/forms to obtain Pretrial Instructions which includes the Consent To Proceed
Before U.S. Magistrate form.
06/09/2015 MOTION to File Account Listing Under Seal filed by United States of America. (ddm)
06/09/2015 ORDER granting 3 Motion to File Account Listing Under Seal and directing the Clerk to Maintain
Exhibit Under Seal. Signed by Judge Leigh Martin May on 6/9/15. (ddm)
06/09/2015 (FILED UNDER SEAL) Exhibit A (Unredacted Listing of Accounts) to 1 Complaint and 2 Amended
Complaint filed by United States of America. (ddm) (ddm).
06/10/2015 Remark re 1 Complaint, 2 Amended Complaint, List of "Various Entities": Alex Capital Holdings,
LLC; Sterling Currency Group, LLC; Sterling Online Processing Services, LLC; GID Partners, LLC; Curtis
Creek Holdings, LLC; Lullwater Holdings, LLC; Valley Trust; Lullwater Trust; Springlake Trading, LLC; JS Real
Estate Investments, LLC; SR Equipment Leasing, LLC; Primestone Properties, LLC; Wingover Capital, LLC;
Northwest Capital, LLC; The TAR Revocable Trust; Broadway Trader 4Z, LLC; Yards at Noda, LLC; Sherrills
Ford Holdings, LLC; Scotch Cove, LLC; RG Classics, LLC; Isolveit.com, LLC; Sterlingfunder, LLC; Trinvest,
LLC; Sky Combat Blue, LLC; TR East Point Real Estate, LLC; TR Interactive Technologies, LLC; Polaris
Aviation, LLC; Sky Combat Red, LLC; Cascades at Rea, LLC; Arrowood Station Holdings, LLC; Arrowhead
Station Holdings, LLC, Miracle Charters, LLC; TR Real Estate, LLC; Whistlejacket, Inc.; J-Brem, LLC; Therrell
Farms Estates, LLC; Zonolite Holdings, LLC; Sustainability Solutions, LLC; Gvest Holdings, LLC; Gvest
Partners, LLC; Gvest Capital, LLC; 200 West Land DST; Primestone Fifeco Realty Fund, LLC; Preferred
Capital, LLC; Reclaim Group, LLC; Wingover Ranch, LLC; Shaw Capital & Guaranty, LLC; Shaw Irrevocable
Trust; Shaw Alys Beach, LLC; Trinvest Partners, LLC; and GID Associates, LLC. (mmc)
06/10/2015 WARRANTS OF ARREST IN REM issued as to various defendant properties. (ddm)
06/11/2015 STANDING ORDER Regarding Civil Litigation in cases proceeding before Judge May. Signed by
Judge Leigh Martin May on 6/11/15. (ddm)
06/18/2015 MOTION Ex Parte Application for Arrest Warrants In Rem with attached Proposed Order by United
States of America. (Turner, Jenny)
06/24/2015 Return of Service Executed on 6/22/2015 in re property located at 1418 Dresden Drive, N.E.,
Number A310, Atlanta, Dekalb County, GA. (ddm)
06/24/2015 Return of Service Executed on 6/18/2015 in re property located at 4536 East Brookhaven Drive,
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5
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7
8
9
10
11
Case Number or Last, First
Atlanta, Fulton and Dekalb Counties, Georgia. (ddm)
06/24/2015 Return of Service Executed on 6/18/2015 in re property located at 3464 Paces Place, N.W.,
Atlanta, Fulton County, GA. (ddm)
06/24/2015 Return of Service Executed on 6/22/2015 in re property located at 2385 Heather Drive, Decatur,
Dekalb County, Georgia. (ddm)
06/24/2015 Return of Service Executed on 6/22/2015 in re The Real Property Located at 225 Valley Road,
N.W., Atlanta, Fulton County, GA. (ddm)
06/24/2015 Return of Service Executed on 6/22/2015, notice served upon Carole Laurette Shaw. (ddm)
06/24/2015 Return of Service Executed on 6/22/2015, notice served upon Theresa D. and Frank M. Bell.
(ddm)
06/24/2015 Return of Service Executed on 6/22/2015, notice served upon East Brookhaven Holdings, LLC.
(ddm)
06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon JS Real Estate Investments,
LLC. (ddm)
06/24/2015 Return of Service Executed on 6/22/2015, as notice served upon Trinves LLC and/or Erica Nicole
Leathers. (ddm)
06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon Shaw Alys Beach NN6 LLC
(owner of 7 La Garza Court, Panama City Beach, FL). (ddm)
06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon Shaw Alys Beach NN6 LLC
(owner of 48 Shinbone Court, Panama City Beach, FL). (ddm)
07/07/2015 NOTICE Of Filing letter from non-party, Peter Kem Weber, Jr., dated June 30, 2015, regarding his
transactions with defedant GID Partners, LLC. (ddm)
07/09/2015 Submission of 9 Parte Application for Arrest Warrants In Rem, submitted to District Judge Leigh
Martin May. (ddm)
07/21/2015 CLAIM Verified by James S. Shaw. (Samuel, Donald)
07/21/2015 CLAIM Verified by Laurette Shaw. (Samuel, Donald)
07/21/2015 CLAIM Verified by Valley Trust. (Samuel, Donald)
07/21/2015 CLAIM of Frank Bell (Verified Claim) by 2385 Heather Drive, Decatur, Dekalb County, Georgia, All
Right, Title and Interest of Frank Bell in Various Entities. (Danzig, Aaron)
07/21/2015 CLAIM of Theresa D. Bell (Verified Claim) by 2385 Heather Drive, Decatur, Dekalb County,
Georgia, All Right, Title and Interest of Frank Bell in Various Entities. (Danzig, Aaron)
07/22/2015 CLAIM Verified by James S. Shaw. (Samuel, Donald)
07/22/2015 CLAIM Verified by Laurette Shaw. (Samuel, Donald)
07/23/2015 PROPOSED CONSENT ORDER Restraining Order. (Krepp, Thomas)
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20
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25
26
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28
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07/24/2015 CONSENT RESTRAINING ORDER. Signed by Judge Leigh Martin May on 7/24/15. (ddm)
07/24/2015 ORDER denying as moot 9 Motion for Miscellaneous Relief. Entered by Judge Leigh Martin May
on 07/24/2015. (LMM)
07/27/2015 NOTICE of Appearance by Erich N. Durlacher on behalf of Wells Fargo Bank, National Association
(Durlacher, Erich)
07/27/2015 CLAIM Verified Claim to Contest Forfeiture by Wells Fargo Bank, National Association.
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit
G, # 8 Exhibit H)(Durlacher, Erich)
07/30/2015 CLAIM Verified by Tyson Rhame. (Brown, Michael)
07/30/2015 NOTICE of Appearance by Michael L. Brown on behalf of Tyson Rhame (Brown, Michael)
07/30/2015 NOTICE of Appearance by Ankith Kamaraju on behalf of Tyson Rhame (Kamaraju, Ankith)
08/04/2015 Return of Service Executed on 7/20/2015 as to Defendant Property 48 Shinbone Court, Panama
City, FL. (ddm)
08/04/2015 Return of Service Executed on 7/20/2015 as to Defendant Property 7 La Garza Court, Panama
City, FL. (ddm)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank, NA
(Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Fulton County Tax
Commissioner's Office (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Mortgage Electronic
Registration Systems, Inc. (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to SunTrust Mortgage, Inc.
(Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to DeKalb County Tax
Commissioner's Office (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to 1418 Dresden, LLC
(Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to EBSCO Gulf Coast
Development, Inc. (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Walton County Tax
Collector (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Alys Beach NN6,
LLC (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Trinvest, LLC (Krepp,
Thomas)
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32
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08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Alys Beach, LLC
(Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to JS Real Estate
Investments, LLC (Krepp, Thomas)
08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to East Brookhaven
Holdings, LLC (Krepp, Thomas)
08/07/2015 MOTION to Intervene filed by Alison E. Shimer. (Attachments: # 1 Memorandum, # 2 Proposed
Amended Complaint, # 3 Affidavit, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit 3, # 7 Exhibit 4, # 8 Exhibit 5, # 9
Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12 Exhibit 9, # 13 Exhibit 10, # 14 Exhibit 11, # 15 Certficate of
Service)(ddm)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to SR Equipment Leasing
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sky Combat Blue, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Polaris Aviation, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Currency Group
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Online
Processing Services (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Partners, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Alex Capital Holdings,
LLC (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Lullwater Holdings, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Curtis Creek Holdings
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Springlake Trading, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Primestone Properties,
LLC (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Northwest Capital
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Broadway Trader 4Z
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Yards at Noda, LlC
(Krepp, Thomas)
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96
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08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sherrills Ford Holdings
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Scotch Cove, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to RG Classics, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to iSolveIT.com, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterlingfunder, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR East Point Real
Estate (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR Interactive
Technologies, LLC (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sky Combat Red, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Cascades at Rea, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Arrowood Station
Holdings (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Miracle Charters. LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR Real Estate, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Whistlejacket, Inc.
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to J-Brem, LLC (Krepp,
Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Therrell Farms Estates
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Zonolite Holdings, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sustainability Solutions
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America Gvest Holdings, LLC
(Krepp, Thomas)
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08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Partners, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Capital, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to 200 West Land DST
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Primestone FifeCo
Realty Fund (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Preferred Capital, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Recleim Group, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wingover Ranch (Krepp,
Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Capita &
Guaranty, LLC (Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Trinvest Partners, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Levan Capital, LLC
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Bank of North Carolina
(Krepp, Thomas)
08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sabal Capital 3, LLC
(Krepp, Thomas)
08/10/2015 Consent MOTION for Extension of Time to File Answer re 2 Amended Complaint, with Brief In
Support by Frank Bell. (Attachments: # 1 Text of Proposed Order)(Sullivan, Sean)
08/10/2015 Consent MOTION for Extension of Time to File Answer re 2 Amended Complaint, with Brief In
Support by Theresa D. Bell. (Attachments: # 1 Text of Proposed Order)(Sullivan, Sean)
08/11/2015 MINUTE ORDER granting 97 and 98 Motion for Extensions of Time to Answer. Claimants Frank
and Theresa Bell shall have through and including September 11, 2015 to file a responsive pleading to
Plaintiff's Complaint. Approved by Judge Leigh Martin May on 08/11/2015. (rvb)
08/11/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Brown, Michael)
08/12/2015 Return of Service Executed on 8/6/2015, as $52,195.55 was released to ALTUS GTS, Inc. (ddm)
08/12/2015 Return of Service Executed on 8/6/2015, as $35,723.26 was released to ADP, LLC. (ddm)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Bonnie Champagne
(Krepp, Thomas)
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08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Frank Bell & Theresa D.
Bell (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to James S. Shaw, Carol
Laurette Shaw, Valley Trust, Shaw Irrevocable Trust, & Curtis Creek Holdings, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Tyson Rhame, The TAR
Revocable Trust, Lullwater Trust, and Lullwater Holdings, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Currency Group,
Sterling Online Processing, GID Partners, LLC, and Alex Capital Holdings, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Holdings, LLC,
Gvest Partners, LLC, and Gvest Capital, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Recleim Group, LLC
(Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank,
National Association (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America Wingover Capital
Management, LLC, aka, Wingover Capital, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank,
National Association, via Registered Agent (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Arrowood Station
Holdings, LLC, aka, Arrowhead Station Holdings, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Natixis Real Estate
Capital, LLC (Krepp, Thomas)
08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sun Life Assurance
Company of Canada (Krepp, Thomas)
08/13/2015 Request for Leave of Absence for the following date(s): September 25, 2015; September 28, 2015
through September 29, 2015; and October 15, 2015 through October 16, 2015, by Aaron M. Danzig. (Danzig,
Aaron)
08/13/2015 Letter, dated August 10, 2015, from Robert A. Crystal regarding funds he paid to Sterling Currency
Group. (ddm)
08/14/2015 NOTICE of Appearance by Allen Todd Sprinkle on behalf of Gvest Real Estate LLC, Raymond M
Gee (Sprinkle, Allen)
08/14/2015 NOTICE Of Filing by Gvest Real Estate LLC Verified Claim of Gvest Real Estate LLC (Sprinkle,
Allen)
08/14/2015 NOTICE Of Filing by Raymond M Gee Verified Claim of Raymond M. Gee (Sprinkle, Allen)
08/14/2015 Consent MOTION for Extension of Time to File Answer re 1 Complaint, 2 Amended Complaint, by
Wells Fargo Bank, National Association. (Attachments: # 1 Exhibit A - Proposed Consent Order)(Durlacher,
Erich)
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08/17/2015 ORDER granting 120 Consent Motion for Extension of Time to Answer re 2 Amended Complaint.
Wells Fargo Bank, National Association Answer due 9/11/2015. Signed by Judge Leigh Martin May on
8/17/2015. (bdb)
08/17/2015 CONSENT ORDER for Stipulated Sale of Property that Tyson Rhame's and TR East Point's
interests in Chattahoochee Place be sold by private, arms-length sale for $40,000 pursuant to a contract that
currently exists between BJG Finance, LLC and TR East Point Real Estate, LLC; and it is further ORDERED,
that upon the sale of Tyson Rhame's and TR East Point's interests in Chattahoochee Place, the proceeds of
the sale, minus transactional expenses and fees approved by the United States Attorney's Office, shall be
used (i) to allow TR East Point to pay insurance for TR East Point in the amount of $1,791.75 to Berkshire
Hathaway Homestate Companies and (ii) to reimburse the Operating Partner (Carson Pickens) $6,751 for out-
of-pocket expenses incurred in maintaining the property. Any remaining amounts shall be remitted to the
United States Marshals Service, via wire transfer or via cashier's check mailed in care of the United States
Attorney's Office, ATTN: Thomas J. Krepp, 75 Spring Street, S.W., Suite 600, Atlanta, Georgia 30303, to be
deposited into the United States Marshals Seized Asset Deposit Account, an interest bearing account, and
shall remain in the account pending the outcome of the civil forfeiture action; and it is further ORDERED, that
all parties shall be responsible for their own costs and attorneys' fees incurred to effectuate this sale of Tyson
Rhame's and TR East Point's interests in Chattahoochee Place and the disbursement of any proceeds of this
sale to fund continued operations related to other above- styled assets. Signed by Judge Leigh Martin May on
8/17/2015. (bdb)
08/17/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 122 Order and 121 Order. (bdb)
08/17/2015 Notice for Leave of Absence for the following date(s): September 28, 2015 through and including
October 2, 2015, by Donald Franklin Samuel. (Samuel, Donald)
08/17/2015 Letter from non-party Traci Black regarding business transactions with Sterling Currency Group.
(ddm)
08/18/2015 Notice for Leave of Absence for the following date(s): From November 23, 2015 through and
including November 27, 2015, by Donald Franklin Samuel. (Samuel, Donald)
08/24/2015 PROPOSED CONSENT ORDER for Stipulated Use of Funds. (Krepp, Thomas)
08/24/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Associates, LLC
(Krepp, Thomas)
08/24/2015 Consent Order for Stipulated Use of Funds. Signed by Judge Leigh Martin May on 8/24/15. (ddm)
08/24/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 128 Order. (ddm)
08/24/2015 Certification of Consent to Substitution of Counsel. Dahil Dueno Goss replacing attorney Jenny R.
Turner. (Goss, Dahil)
08/25/2015 Submission of 96 MOTION to Intervene, submitted to District Judge Leigh Martin May. (ddm)
08/26/2015 ANSWER to 1 COMPLAINT Verified Answer of Wells Fargo Bank, National Association to
Amended Complaint for Forfeiture by Wells Fargo Bank, National Association. Discovery ends on 1/25/2016.
(Durlacher, Erich) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
08/27/2015 MOTION for Extension of Time to File Consolidated Response to Various Attempts to Intervene by
United States of America. (Attachments: # 1 Text of Proposed Order)(Goss, Dahil)
08/27/2015 ORDER granting 131 Plaintiff's Motion for Extension of Time, through September 11, 2015, to File
Consolidated Response to Attempts to Intervene. Signed by Judge Leigh Martin May on 8/26/15. (ddm)
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08/27/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 132 Order. (ddm)
08/28/2015 Letter from non-party Marilyn Grever regarding business transactions with Sterling Currency
Group. (ddm)
08/31/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim as to Recleim Group LLC
by Gvest Real Estate LLC. (Sprinkle, Allen)
09/02/2015 NOTICE of Appearance by Meredith Jones Kingsley on behalf of Tyson Rhame (Kingsley,
Meredith)
09/02/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Brown, Michael)
09/03/2015 NOTICE of Appearance by Allen Todd Sprinkle on behalf of Gvest Partners LLC, Gvest Capital
LLC (Sprinkle, Allen)
09/03/2015 Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 9/3/15. (ddm)
09/03/2015 RESPONSE in Opposition re 131 MOTION for Extension of Time to File Consolidated Response
to Various Attempts to Intervene filed by Alison E. Shimer. (ddm)
09/04/2015 SERVICE by Publication filed by United States of America. Last publication date 09/03/2015.
(Goss, Dahil)
09/04/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim as to Therrell Farms
Estates LLC and Zonolite Holdings LLC by Gvest Real Estate LLC. (Sprinkle, Allen)
09/04/2015 ANSWER to 2 Amended Complaint by Gvest Real Estate LLC.(Sprinkle, Allen) Please visit our
website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/04/2015 ANSWER to 2 Amended Complaint by Gvest Capital LLC.(Sprinkle, Allen) Please visit our website
at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/04/2015 ANSWER to 2 Amended Complaint by Gvest Partners LLC.(Sprinkle, Allen) Please visit our
website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/04/2015 ANSWER to 2 Amended Complaint by Raymond M Gee.(Sprinkle, Allen) Please visit our website
at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/08/2015 PROPOSED CONSENT ORDER Permitting Disbursement of Seized Funds. (Samuel, Donald)
09/09/2015 CONSENT ORDER PERMITTING DISBURSEMENT OF SEIZED FUNDS : It is hereby ordered
that the United States release $4,237,500.00 from Merrill Lynch Primestone Properties, LLC account
XXX2391 to Wells Fargo Bank N.A., Account Number XXX720. In consideration for the United States'
agreement to transfer these funds, Claimant Shaw agrees to make good faith efforts to sell one Cessna
Citation XLS airplane (serial number 560-5623), which is currently named as forfeitable property in the first
civil forfeiture action. See 1: 15-CV-2032-LMM (Doc. 2). It is therefore further ordered that Claimant Shaw will
use his good faith efforts to sell this airplane. See Order for additional information. Signed by Judge Leigh
Martin May on 9/9/2015. (anc)
09/09/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 147 Order of Disbursement/Distribution of
Funds (anc)
09/09/2015 CLAIM Verified by James S. Shaw. (Attachments: # 1 Exhibit A)(Samuel, Donald)
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09/10/2015 CLAIM Verified by Laurette Shaw. (Attachments: # 1 Exhibit A)(Samuel, Donald)
09/10/2015 NOTICE of Appearance by David M. Lilenfeld on behalf of All Right, Title and Interest of GID
Partners, LLC in Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various
Entities, All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities (Lilenfeld,
David)
09/10/2015 NOTICE of Appearance by Kaitlyn Anne Dalton on behalf of All Right, Title and Interest of GID
Partners, LLC in Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various
Entities, All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities (Dalton,
Kaitlyn)
09/10/2015 CLAIM by All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities.
(Lilenfeld, David)
09/10/2015 CLAIM by All Right, Title and Interest of GID Partners, LLC in Various Entities. (Lilenfeld, David)
09/10/2015 CLAIM by All Right, Title and Interest of Sterling Online Processing Services, LLC in Various
Entities. (Lilenfeld, David)
09/10/2015 CLAIM Verified by Tyson Rhame. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Brown, Michael)
09/11/2015 ANSWER to 2 Amended Complaint by James S. Shaw, Laurette Shaw.(Samuel, Donald) Please
visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/11/2015 ANSWER to 2 Amended Complaint, filed by Frank Bell. (Danzig, Aaron) Modified on 9/11/2015 to
edit text (ddm).
09/11/2015 ANSWER to 2 Amended Complaint, filed by Theresa D. Bell. (Danzig, Aaron) Modified on
9/11/2015 to edit text (ddm).
09/11/2015 RESPONSE re 96 MOTION to Intervene and Opposition to Correspondence Seeking to Intervene
filed by United States of America. (Krepp, Thomas)
09/11/2015 Verified ANSWER to 2 Amended Complaint by All Right, Title and Interest of GID Partners, LLC in
Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities, All Right,
Title and Interest of Sterling Online Processing Services, LLC in Various Entities.(Lilenfeld, David) Please visit
our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/11/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim with Respect to Sherrills
Ford Holdings LLC by Gvest Real Estate LLC. (Sprinkle, Allen)
09/11/2015 ANSWER to 2 Amended Complaint by Tyson Rhame.(Brown, Michael) Please visit our website at
http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/14/2015 Partial WITHDRAWAL of Claim re 155 Claim with respect to Gvest Holdings LLC, Gvest Partners
LLC, and Gvest Capital LLC by Tyson Rhame. (Brown, Michael)
09/15/2015 CLAIM Verified by Sabal Capital 3, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)
(Stewart, David)
09/15/2015 NOTICE of Appearance by David Mitchell Stewart on behalf of Sabal Capital 3, LLC (Stewart,
David)
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09/15/2015 NOTICE of Appearance by Michael L. Brown on behalf of Ronald Green (Brown, Michael)
09/15/2015 CLAIM Verified by Ronald Green. (Brown, Michael)
09/16/2015 REPLY to Response to Motion re 96 MOTION to Intervene filed by Alison E. Shimer. (ddm)
09/18/2015 NOTICE of Appearance by Sharon Audrey Israel on behalf of Sun Life Assurance Company of
Canada (Israel, Sharon)
09/18/2015 CLAIM (Verified Claim) by Sun Life Assurance Company of Canada. (Israel, Sharon)
09/18/2015 ANSWER to 2 Amended Complaint by Sun Life Assurance Company of Canada.(Israel, Sharon)
Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
09/18/2015 NOTICE Of Filing Certificate of Service Showing Mailing of Plaintiff's Opposition to Attempts to
Intervene to non-party files by United States of America re 159 Response to Motion (Attachments: # 1 Exhibit)
(Krepp, Thomas)
09/18/2015 NOTICE by James S. Shaw re 148 Claim Partial Withdrawal of Verified Claim of GVEST Real
Estate LLC with Respect to Sherrills Ford Holdings LLC (Samuel, Donald)
09/21/2015 NOTICE by James S. Shaw re 148 Claim Amended Notice of Partial Withdrawal of Verified Claim
of James Shaw With Respect To Gvest Capital LLC (Samuel, Donald)
09/21/2015 Letter from non-party Jo Midgley regarding business transactions with Sterling Currency Group.
(ddm)
09/24/2015 NOTICE of Appearance by Erich N. Durlacher on behalf of Wells Fargo Advisors, LLC (Durlacher,
Erich)
09/24/2015 Consent MOTION for Extension of Time to Allow Wells Fargo Advisors, LLC Additional Time to
File Verified Claim and Respond to Plaintiff's Complaint re: 1 Complaint, 2 Amended Complaint, by Wells
Fargo Advisors, LLC. (Attachments: # 1 Text of Proposed Order Proposed Consent Order)(Durlacher, Erich)
09/24/2015 ORDER granting 177 Consent Motion for Extension of Time, through and including October 15,
2015, to Allow Wells Fargo Advisors, LLC Additional Time to File Verified Claim and Respond to Plaintiff's
Complaint 1 Complaint, Amended Complaint 2 . Signed by Judge Leigh Martin May on 9/24/15. (ddm)
09/25/2015 MOTION to Stay Proceedings by United States of America. (Krepp, Thomas)
09/25/2015 Letter from non-party Walter Midgley regarding business transactions with Sterling Currency
Group. (ddm)
09/28/2015 NOTICE Of Filing Certificate of Service for U.S. Opposition to Attempts to Intervene filed on non-
party filers by United States of America re 159 Response to Motion (Krepp, Thomas)
10/05/2015 NOTICE of Appearance by David John Forestner on behalf of Ronald Green (Forestner, David)
10/05/2015 Verified Claim of Ronald G. Green by Ronald Green. (Forestner, David) Modified on 10/5/2015 to
edit docket text to match description of pleading (ryc).
10/05/2015 ANSWER to 2 Amended Complaint by Sabal Capital 3, LLC.(Stewart, David) Please visit our
website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
10/05/2015 Letter from non-party Laurel Buescher regarding business transactions with Sterling Currency
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Group and request for release of non-party's property. (jtj)
10/06/2015 APPLICATION for Admission of Adam P. Schwartz Pro Hac Vice (Application fee $ 150, receipt
number 113E-6081925)by Ronald Green. (Forestner, David)
10/06/2015 ANSWER to 2 Amended Complaint Ronald G. Green's Answer to Plaintiff's Amended Verified
Complaint by Ronald Green.(Forestner, David) Please visit our website at http://www.gand.uscourts.gov to
obtain Pretrial Instructions.
10/07/2015 APPLICATION for Admission of Stephanie E. Ambs Pro Hac Vice (Application fee $ 150, receipt
number 113E-6084956)by Ronald Green. (Forestner, David)
10/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Associates, LLC
(Krepp, Thomas)
10/14/2015 ORDER granting 179 Motion to Stay. The Clerk is DIRECTED to ADMINISTRATIVELY CLOSE
these matters pending the stay. The Government is also DIRECTED to file status reports under seal every 90
days, advising the status of the criminal investigation and whether the stays are still warranted. It is also
ORDERED that these stays do not impact the filing of any future consent orders for stipulated sale or consent
orders for stipulated use of funds that the parties may wish to file in order to preserve or liquidate the assets
listed in the complaints. Signed by Judge Leigh Martin May on 10/14/15. (jpa)
10/14/2015 Civil Case Terminated. (jpa)
10/14/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 190 Order. Notice of street name change for
the Atlanta courthouse included. (jpa)
10/14/2015 ANSWER to 2 , 1 Amended Complaint , ANSWER to 2 , 1 COMPLAINT by SterlingFunder LLC.
(Lilenfeld, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
10/14/2015 CLAIM Verified by SterlingFunder LLC. (Lilenfeld, David)
10/14/2015 NOTICE Of Filing Certificate of Service by United States of America re 159 Response to Motion
Served on Non-Parties (Krepp, Thomas)
10/15/2015 Verified ANSWER to 2 Amended Complaint for Forfeiture by Wells Fargo Advisors, LLC.
(Durlacher, Erich) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
10/21/2015 Return of Service Executed on 10/19/2015, as $28,556.85 was taken custody of and deposited.
(ddm)
10/26/2015 ANSWER to 2 Amended Complaint by "GID Associates".(Lilenfeld, David) Please visit our website
at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
10/28/2015 NOTICE Of Filing Certificate of Service Plaintiff's Opposition to Attempts to Intervene by United
States of America (Krepp, Thomas)
11/02/2015 CLAIM filed by F. Lorenzo Crutchfield, Jr. (kdw)
11/03/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property re: 147 Order of
Disbursement/Distribution of Funds,,,. (Samuel, Donald)
11/03/2015 CLAIM by "GID Associates". (Attachments: # 1 Exhibit A-Tradename Registration)(Lilenfeld, David)
11/03/2015 CONSENT ORDER FOR STIPULATED SALE OF PROPERTY signed by Judge Leigh Martin May
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on 11/3/15. (kdw)
11/04/2015 Clerk's Certificate of Mailing as to Alison E. Shimer re 200 Order. Notice of street name change for
the Atlanta courthouse included. (kdw)
11/09/2015 Letter from non-party Louis Gonzales regarding business transactions with Sterling Currency
Group. (ddm)
11/12/2015 NOTICE Of Filing Amended Complaint for Forfeiture by United States of America to KEYCORP
(Krepp, Thomas)
11/27/2015 NOTICE of Appearance by Kelly Kathleen Connors on behalf of United States of America
(Connors, Kelly)
12/01/2015 Letter from non-party Lorenzo Crutchfield regarding business transactions with Sterling Currency
Group. (ddm)
12/08/2015 NOTICE Of Filing by United States of America re 159 Response to Motion Certificate of Service of
U.S. Response to Opposition to Attempts to Intervene Served on Non-Party Filers (Krepp, Thomas)
12/10/2015 PROPOSED CONSENT ORDER For stipulated sale of property. (Brown, Michael)
12/11/2015 CONSENT ORDER FOR STIPULATED SALE OF PROPERTY signed by Judge Leigh Martin May
on 12/11/15. (kdw)
12/11/2015 Clerk's Certificate of Mailing as to Alison E. Shimer re 208 Order. Notice of street name change for
the Atlanta courthouse included. (kdw)
12/11/2015 Clerk's Certificate of Mailing as to F. Lorenzo Crutchfield, Jr re 208 Order. Notice of street name
change for the Atlanta courthouse included. (kdw)
12/16/2015 Verified ANSWER to 2 Amended Complaint by The Real Property Located at 225 Valley Road,
N.W., Atlanta, Fulton County, GA.(Fox, James) Please visit our website at http://www.gand.uscourts.gov to
obtain Pretrial Instructions.
12/29/2015 CLAIM Verified by Suntrust Mortgage, Inc.. (Attachments: # 1 Exhibit 1 - Note, # 2 Exhibit 2 -
Security Deed)(Davey, Melissa)
12/29/2015 Verified ANSWER to 2 Amended Complaint for Forfeiture by Suntrust Mortgage, Inc..(Davey,
Melissa) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
01/08/2016 Notice for Leave of Absence for the following date(s): February 5, 2016; February 12, 2016;
February 19, 2016; March 2-4, 2016; March 25, 2016; and April 4-8, 2016, by Aaron M. Danzig. (Danzig,
Aaron)
01/14/2016 ---FILED UNDER SEAL PER 179 --- STATUS REPORT filed by United States of America. (kdw)
(kdw).
01/19/2016 NOTICE Of Filing Copy of motion served on non-party filers by United States of America re 159
Response to Motion (Krepp, Thomas)
02/08/2016 NOTICE of Appearance by Robert Daniel Douglass on behalf of Suntrust Mortgage, Inc.
(Douglass, Robert)
02/09/2016 Letter from non-party, Sharon Marie Stahlsmith, regarding business transactions with Sterling
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Currency Group, LLC. (Attachments: # 1 Exhibits A - E) (jtj)
02/22/2016 MOTION to Lift Stay for the Limited Purpose of Filing Amended Complaint , MOTION for Leave to
File Amended Complaint for Forfeiture by United States of America. (Attachments: # 1 Exhibit proposed
Amended Complaint for Forfeiture, # 2 Exhibit A - K to proposed Amended Complaint for Forfeiture)(Connors,
Kelly)
02/24/2016 NOTICE Of Filing by United States of America re 217 MOTION to Lift Stay for the Limited Purpose
of Filing Amended Complaint MOTION for Leave to File Amended Complaint for Forfeiture Served on Non-
ECF Filers (Attachments: # 1 Exhibit List of People Served)(Connors, Kelly)
03/11/2016 Submission of 217 MOTION to Lift Stay for the Limited Purpose of Filing Amended Complaint,
MOTION for Leave to File Amended Complaint for Forfeiture, submitted to District Judge Leigh Martin May.
(ddm)
03/15/2016 ORDER granting 217 Motion to Lift Stay for the Limited Purpose of Filing Amended Complaints;
granting 217 Motion for Leave to File Amended Complaints. Entered by Judge Leigh Martin May on
03/15/2016. (LMM)
03/15/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Kamaraju, Ankith)
03/15/2016 CONSENT ORDER for Stipulated Sale of Property. Signed by Judge Leigh Martin May on
3/15/2016. (tcc)
03/15/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 220 Order. (tcc)
04/08/2016 PROPOSED CONSENT ORDER Modifying Restraining Order. (Kamaraju, Ankith)
04/11/2016 CONSENT ORDER MODIFYING RESTRAINING ORDER. Signed by Judge Leigh Martin May on
4/11/16. (kdw)
04/11/2016 Clerk's Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 222 Order. Notice of street name change for the Atlanta courthouse included. (kdw)
04/13/2016 (FILED UNDER SEAL) STATUS REPORT filed by United States of America. (dfb)
04/25/2016 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo by Tyson
Rhame, James S. Shaw. (Samuel, Donald)
05/09/2016 Unopposed MOTION for Extension of Time To File Government's Response To Claimant's Motion
re: 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo by United States of
America. (Attachments: # 1 Text of Proposed Order)(Connors, Kelly)
05/09/2016 ORDER granting 225 Unopposed Motion for Extension of Time, through May 13, 2016, To File
Government's Response To Claimant's Motion to Apply Seized Funds to Payment of Overdue Payment to
Wells Fargo 224 . Signed by Judge Leigh Martin May on 5/9/16. (ddm)
05/13/2016 RESPONSE re 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells
Fargo filed by United States of America. (Connors, Kelly)
05/26/2016 Consent MOTION for Extension of Time Extension of Time for Claimant to File Reply to
Government's Response to Claimants' Motion to Apply Seized Funds to Payment of Overdue Payment to
Wells Fargo by Tyson Rhame, James S. Shaw. (Samuel, Donald)
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05/27/2016 ORDER GRANTING 228 Motion for Extension of Time For Claimant to File a Reply to
Government's Response to Claimants' Motion to Apply Seized Funds to Payment of Overdue Payment to W
ells Fargo. Signed by Judge Leigh Martin May on 5/27/2016. (jtj)
05/27/2016 Clerk's Certificate of Mailing to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 229 Order. (jtj)
05/31/2016 REPLY to Response to Motion re 224 MOTION to Apply Seized Funds to Payment of Overdue
Payment to Wells Fargo filed by Tyson Rhame, James S. Shaw. (Samuel, Donald)
06/03/2016 Submission of 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells
Fargo , submitted to District Judge Leigh Martin May. (ddm)
06/03/2016 NOTICE of Hearing on Motion re: 224 MOTION to Apply Seized Funds to Payment of Overdue
Payment to Wells Fargo . A Motion Hearing is set for 6/15/2016 at 02:00 PM in ATLA Courtroom 2107 before
Judge Leigh Martin May. (rvb)
06/03/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re Notice of Hearing on Motion. (rvb)
06/14/2016 MOTION for Order of Sale OF CASCADES AT REA PROPERTY with Brief In Support by Sabal
Capital 3, LLC. (Attachments: # 1 Text of Proposed Order)(Stewart, David)
06/22/2016 MINUTE ORDER DIRECTING the Government to file a response by July 1, 2016 to Claimant
Sabal Capital 3, LLC's 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY. Approved by
Judge Leigh Martin May on 06/22/2016. (rvb)
06/23/2016 Notice for Leave of Absence for the following date(s): August 22, 2016 through September 2,
2016, by Kelly Kathleen Connors. (Connors, Kelly)
06/23/2016 Notice for Leave of Absence for the following date(s): July 18, 2016 through August 2, 2016, by
David Mitchell Stewart. (Stewart, David)
06/24/2016 PROPOSED CONSENT ORDER for stipulated sale of property. (Kamaraju, Ankith)
06/24/2016 Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 6/24/16.
(ddm)
06/24/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 235 Order. Notice of street name change for the Atlanta courthouse included. (ddm)
06/28/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property re: 235 Order. (Kamaraju, Ankith)
06/28/2016 Amended Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on
6/28/16. (ddm)
06/28/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 237 Order. Notice of street name change for the Atlanta courthouse included. (ddm)
07/01/2016 RESPONSE re 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY filed by
United States of America. (Connors, Kelly)
07/11/2016 MOTION for Extension of Time File a Response re: 231 MOTION for Order of Sale OF
CASCADES AT REA PROPERTY by Tyson Rhame. (Kamaraju, Ankith)
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07/13/2016 RESPONSE re 239 MOTION for Extension of Time File a Response re: 231 MOTION for Order of
Sale OF CASCADES AT REA PROPERTY filed by Sabal Capital 3, LLC. (Stewart, David)
07/15/2016 ORDER granting 239 Motion for Extension of Time, through and including July 25, 2016, to
respond re 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY. Signed by Judge Leigh
Martin May on 7/15/16. (hfm)
07/20/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property (Amended). (Connors, Kelly)
07/20/2016 AMENDED CONSENT ORDER FOR STIPULATED SALE OF PROPERTY. Signed by Judge
Leigh Martin May on 07/20/2016. (rvb)
07/25/2016 Second MOTION for Extension of Time re: 231 MOTION for Order of Sale OF CASCADES AT
REA PROPERTY by Tyson Rhame. (Kamaraju, Ankith)
07/26/2016 Submission of 231 MOTION for Order of Sale, 244 Second MOTION for Extension of Time re: 231
MOTION for Order of Sale, submitted to District Judge Leigh Martin May. (hfm)
07/26/2016 Notice for Leave of Absence for the following date(s): November 21, 2016 through and including
November 25, 2016, by Donald Franklin Samuel. (Samuel, Donald)
07/29/2016 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by
Tyson Rhame. (Kamaraju, Ankith)
07/29/2016 Withdrawal of Motion 244 Second MOTION for Extension of Time re: 231 MOTION for Order of
Sale OF CASCADES AT REA PROPERTY filed by Tyson Rhame filed by Tyson Rhame. (Kamaraju, Ankith)
08/02/2016 Notice for Leave of Absence for the following date(s): September 21, 2016 through September 23,
2016, by Kelly Kathleen Connors. (Connors, Kelly)
08/10/2016 MOTION for Extension of Time To File Government's Response To Claimant's Motion re: 246
MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by United
States of America. (Attachments: # 1 Text of Proposed Order)(Connors, Kelly)
08/11/2016 ORDER granting 249 Motion for Extension of Time until a date set by the Court at the conclusion
of the pending status conference, re 246 MOTION for Order. Signed by Judge Leigh Martin May on 8/10/16.
(hfm)
08/11/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 250 Order on Motion for Extension of Time. (hfm)
08/11/2016 MOTION for Extension of Time To File Response to Claimant's Motion re: 246 MOTION for Order
to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by Gvest Real Estate LLC.
(Attachments: # 1 Text of Proposed Order Proposed Order)(Sprinkle, Allen)
08/11/2016 MOTION for Extension of Time to File Response re: 246 MOTION for Order to Apply Seized Funds
to Payment of Overdue Note to Sabal Capital 3, LLC by Sabal Capital 3, LLC. (Attachments: # 1 Text of
Proposed Order)(Stewart, David)
08/15/2016 Minute Entry for proceedings held before Judge Leigh Martin May: Telephone Conference held on
8/15/2016. The Court orally GRANTED Gvest Real Estate LLC's and Raymond Gee's 251 Motion to Extend
Time to File Response to Claimant's Motion and GRANTED Sabal Capital 3, LLC's 252 Motion to Extend Time
to File Response to Claimant Rhame's Motion. The United States of America, Sabal Capital 3, LLC, Gvest
Real Estate LLC and Raymond Gee shall have until August 29, 2016 to file a response to Tyson Rhame's 246
Motion to Apply Seized Funds to Satisfy Sabal Capital 3, LLC's Note. In addition to the response, the parties
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shall each file a proposed orders and any objections/concerns with language contained in opposing parties'
proposed orders. Claimant Rhames shall have until noon on Wednesday, August 17, 2016 to file any
additional information in support of his motion. Counsel for the United States of America was DIRECTED to
follow up on a proposed order in the companion case 1:15-cv-2677-LMM regarding the 216 Motion to Apply
Seized Funds to Payment of Overdue Payment to Wells Fargo. (Court Reporter Montrell Vann)(hfm)
08/17/2016 NOTICE Of Filing by Tyson Rhame re 246 MOTION for Order to Apply Seized Funds to Payment
of Overdue Note to Sabal Capital 3, LLC Supplemental Brief in Support (Attachments: # 1 Exhibit 1)
(Kamaraju, Ankith)
08/29/2016 REPLY BRIEF re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to
Sabal Capital 3, LLC filed by Raymond M Gee, Gvest Real Estate LLC. (Attachments: # 1 Text of Proposed
Order Proposed Order)(Sprinkle, Allen)
08/29/2016 RESPONSE in Opposition re 246 MOTION for Order to Apply Seized Funds to Payment of
Overdue Note to Sabal Capital 3, LLC filed by United States of America. (Attachments: # 1 Exhibit A)
(Connors, Kelly)
08/29/2016 RESPONSE re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to
Sabal Capital 3, LLC filed by Sabal Capital 3, LLC. (Attachments: # 1 Text of Proposed Order)(Stewart, David)
08/30/2016 Submission of 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to
Sabal Capital 3, LLC, submitted to District Judge Leigh Martin May. (hfm)
09/15/2016 REPLY BRIEF re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to
Sabal Capital 3, LLC filed by Tyson Rhame. (Kamaraju, Ankith)
09/19/2016 Submission of 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to
Sabal Capital 3, LLC, submitted to District Judge Leigh Martin May. (hfm)
09/21/2016 ORDER granting 231 Motion for Order of Sale; denying 246 Motion for Order. If the parties have
any objections to this language, they must file their objections within seven days of the date of this Order.
Additionally, if the parties have objections to the description of the Cascades at Rea Property in footnote two,
or want the more fully detailed description provided in Sabal'sProposed Order, Dkt. No. [257-1], they must file
their objections within seven days of the date of this Order. Signed by Judge Leigh Martin May on 9/21/16.
(hfm)
09/23/2016 NOTICE of Appearance by Lex M. Erwin on behalf of Cluck Design Collaborative, PLLC (Erwin,
Lex)
09/23/2016 CLAIM Verified by Cluck Design Collaborative, PLLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B)
(Erwin, Lex)
10/04/2016 Submission of 259 Order, submitted to District Judge Leigh Martin May. (hfm)
10/05/2016 ORDER re Sale of Cascades at Rea Property. Signed by Judge Leigh Martin May on 10/4/16.
(hfm)
10/05/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie
Stahlsmith re 262 Order. (hfm)
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Case 1:15-cv-02032-LMM Document 1-12 Filed 06/05/15 Page 1 of 2
Case 1:15-cv-02032-LMM Document 1-12 Filed 06/05/15 Page 2 of 2
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Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
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Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
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Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016
Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016

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Sterling Currency Group Dinar Banker Court Documents Updated 10-16-2016

  • 1. 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA, v. THE REAL PROPERTY LOCATED AT 225 VALLEY ROAD, N.W., ATLANTA, FULTON COUNTY, GEORGIA; 1418 DRESDEN DRIVE, N.E., NUMBER A310, ATLANTA, DEKALB COUNTY, GEORGIA; 3464 PACES PLACE, N,W., ATLANTA, FULTON COUNTY, GEORGIA; 4536 EAST BROOKHAVEN DRIVE, ATLANTA, FULTON AND DEKALB COUNTIES, GEORGIA; 2385 HEATHER DRIVE, DECATUR, DEKALB COUNTY, GEORGIA; 48 SHINBONE COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA, 7 LA GARZA COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA; THE 2006 CESSNA CITATION XLS, MANUFACTURER'S SERIAL NUMBER 560-5623, BEARING REGISTRATION NUMBER N562VP; THE GIPPS AERO PARTY LIMITED MODEL GA8TC-320 BEARING TAIL NUMBER N68GA AND SERIAL NUMBER GA8-TC-320- 12-187; THE EXTRA FLUGZEUGPRODUKTIONS UND MODEL EA300/LT BEARING TAIL NUMBER N330TY AND SERIAL NUMBER LT020; THE BLACK 2012 Civil Action No. 1:15-CV- Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 1 of 48
  • 2. 2 MERCEDES BENZ GL550 BEARING VEHICLE IDENTIFICATION NUMBER 4JGBF8GE5CA785200 AND GEORGIA TAG NUMBER PAK5506; THE SILVER 2012 SILVER MERCEDES BENZ SLS AMG BEARING VEHICLE IDENTIFICATION NUMBER WDDRJ7HA1CA008056 AND GEORGIA TAG NUMBER BXY3941; THE BLACK 2013 AUDI SS QUATRO BEARING VEHICLE IDENTIFICATION NUMBER WAUD2AFD2DN020235 AND GEORGIA TAG NUMBER PMC8546; AND ALL RIGHT, TITLE AND INTEREST OF STERLING CURRENCY GROUP, LLC, STERLING ONLINE PROCESSING SERVICES, LLC, GID PARTNERS, LLC, ALEX CAPITAL HOLDINGS LLC, LULLWATER HOLDINGS LLC, CURTIS CREEK HOLDINGS, LLC, VALLEY TRUST, LULLWATER TRUST, TYSON RHAME, JAMES SHAW, CAROLE LAURETTE SHAW, AND/OR FRANK BELL IN ALEX CAPITAL HOLDINGS LLC; STERLING CURRENCY GROUP LLC, STERLING ONLINE PROCESSING SERVICES LLC, GID PARTNERS LLC, CURTIS CREEK HOLDINGS LLC, LULLWATER HOLDINGS LLC, VALLEY TRUST, LULLWATER TRUST, SPRINGLAKE TRADING, LLC, JS REAL ESTATE INVESTMENTS, LLC, SR EQUIPMENT LEASING, LLC, PRIMESTONE PROPERTIES LLC, WINGOVER CAPITAL LLC, NORTHWEST Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 2 of 48
  • 3. 3 CAPITAL LLC, THE TAR REVOCABLE TRUST, BROADWAY TRADER 4Z, LLC, YARDS AT NODA, LLC, SHERRILLS FORD HOLDINGS LLC, SCOTCH COVE, LLC, RG CLASSICS LLC, ISOLVEIT.COM LLC, STERLINGFUNDER LLC, TRINVEST LLC, SKY COMBAT BLUE LLC, TR EAST POINT REAL ESTATE LLC, TR INTERACTIVE TECHNOLOGIES LLC, POLARIS AVIATION LLC, SKY COMBAT RED LLC, CASCADES AT REA, LLC, ARROWOOD STATION HOLDINGS LLC , ARROWHEAD STATION HOLDINGS LLC, MIRACLE CHARTERS, LLC, TR REAL ESTATE LLC, WHISTLEJACKET, INC., J-BREM LLC, THERRELL FARMS ESTATES LLC, ZONOLITE HOLDINGS LLC, SUSTAINABILITY SOLUTIONS LLC, GVEST HOLDINGS LLC, GVEST PARTNERS LLC, GVEST CAPITAL LLC, 200WEST LAND DST, PRIMESTONE FIFECO REALTY FUND LLC, PREFERRED CAPITAL LLC, RECLAIM GROUP LLC, WINGOVER RANCH, LLC, SHAW CAPITAL & GUARANTY, LLC, SHAW IRREVOCABLE TRUST, SHAW ALYS BEACH LLC, TRINVEST PARTNERS, LLC, AND GID ASSOCIATES LLC. VERIFIED COMPLAINT FOR FORFEITURE COMES NOW, the United States of America, the Plaintiff in this matter, by John A. Horn, Acting United States Attorney the Northern District of Georgia, Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 3 of 48
  • 4. 4 and Thomas J. Krepp and Jenny Turner, Assistant United States Attorneys, and files this Complaint for Forfeiture. In support thereof, the United States shows the following: I. Introduction 1. This Complaint seeks forfeiture of the below-listed properties to the United States as proceeds of specified unlawful activities and properties involved in money laundering offenses of Sterling Currency Group, LLC (“Sterling”); Sterling Online Processing Services, LLC (Sterling Online); GID Partners, LLC (GID); Alex Capital Holdings LLC (Alex); James Shaw (J.Shaw); Carole Laurette Shaw (C.Shaw); Tyson Rhame (Rhame); Frank Bell (Bell), and other entities controlled by these same businesses and individuals that have used the facilities of interstate commerce in a scheme to defraud investors in the Iraqi dinar by publishing and disseminating false information about the viability of that currency as an investment: a. The real property located at 225 Valley Road, N.W., Atlanta, Fulton County, GA 30305, and all buildings and appurtenances thereto (the Valley Road Property), described more particularly as follows: 225 Valley Road, NW, Atlanta, Fulton County, Georgia Tax Parcel ID No.: 17-0116LL0675 ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING IN LAND LOT 116, 17TH DISTRICT, FULTON COUNTY, GEORGIA, BEING LOT 16 AND PART OF LOT 15, Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 4 of 48
  • 5. 5 BLOCK 6, ACCORDING TO THE PLAT FOR TUXEDO PARK CO., AND VALLEY ROAD CO., RECORDED AT PLAT BOOK 17, PAGE 60, FULTON COUNTY, GEORGIA RECORDS AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGIN AT THE INTERSECTION OF THE NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY ROAD (A 50-FOOT RIGHT OF WAY) AND THE NORTHWESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD (A 50-FOOT RIGHT-OF-WAY), SUCH INTERSECTION BEING THE "TRUE POINT OF BEGINNING", FROM SUCH TRUE POINT OF BEGINNING, RUN THENCE ALONG THE NORTHEASTERLY RIGHT-OF- WAY LINE OF VALLEY ROAD NORTH 46 DEGREES 13 MINUTES 13 SECONDS WEST A DISTANCE OF 125.21 FEET TO A POINT ON THE NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY ROAD; RUN THENCE ALONG THE NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY ROAD AND FOLLOWING THE CURVATURE THEREOF AN ARC DISTANCE OF 71.00 FEET TO A 1 INCH CRIMP TOP FOUND ON THE NORTHEASTERLY RIGHT-OF-WAY LINE OF VALLEY ROAD (SUCH ARC BEING SUBTENDED BY A CHORD BEARING NORTH 51 DEGREES 07 MINUTES 43 SECONDS WEST A CHORD DISTANCE OF 70.93 FEET AND HAVING A RADIUS OF 475.48 FEET); RUN THENCE NORTH 24 DEGREES 48 MINUTES 15 SECONDS EAST A DISTANCE OF 504.46 FEET TO A 1 INCH PIPE FOUND; RUN THENCE SOUTH 70 DEGREES 26 MINUTES 36 SECONDS EAST A DISTANCE OF 211.47 FEET TO A ONE INCH PIPE FOUND ON THE WESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD; RUN THENCE ALONG THE WESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD SOUTH O1 DEGREE 31 MINUTES 47 SECONDS WEST A DISTANCE OF 144.55 FEET TO A POINT ON THE WESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD; RUN THENCE ALONG THE NORTHWESTERLY RIGHT OF Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 5 of 48
  • 6. 6 WAY LINE OF TUXEDO ROAD AND FOLLOWING THE CURVATURE THEREOF AN ARC DISTANCE OF 186.75 TO A POINT ON THE NORTHWESTERLY RIGHT-OF-WAY LINE OF TUXEDO ROAD (SUCH ARC BEING SUBTENDED BY A CHORD BEARING SOUTH 21 DEGREES 10 MINUTES 41 SECONDS WEST A CHORD DISTANCE OF 186.51 FEET AND HAVING A RADIUS OF 1,049.76 FEET); RUN THENCE ALONG THE NORTHWESTERLY RIGHT OF WAY LINE OF TUXEDO ROAD AND FOLLOWING THE CURVATURE THEREOF AN ARC DISTANCE OF 284.09 FEET TO THE INTERSECTION OF THE NORTHEASTERLY RIGHT OF WAY LINE OF VALLEY ROAD AND THE NORTHWESTERLY RIGHT OF WAY LINE OF TUXEDO ROAD AND THE TRUE POINT OF BEGINNING (SUCH ARC BEING SUBTENDED BY A CHORD BEARING SOUTH 44 DEGREES 09 MINUTES 02 SECONDS WEST A CHORD DISTANCE OF 278.57 FEET AND HAVING A RADIUS OF 414.81) SUCH PROPERTY IS MORE PARTICULARLY DELINEATED ON THAT CERTAIN BOUNDARY SURVEY (PLAT NO. 99-0470405 R) FOR ROBERT P. GUYTON, JR. AND EMILY W. GUYTON PREPARED BY WILLIAM W. DELOACH GRLS NO. 1711, OF PEARSON & ASSOCIATES, INC., DATED MAY 24, 1999; b. The real property located at 1418 Dresden Drive, N.E., Number A310, Atlanta, DeKalb County, Georgia, and all buildings and appurtenances thereto (the Dresden Property), described more particularly as follows: 1418 Dresden Drive, NE, Unit A310 Atlanta, DeKalb County, Georgia Tax Parcel ID No.: 18-238-18-072 ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING IN LAND LOT 238 OF THE 18TH DISTRICT OF DEKALB COUNTY, GEORGIA, AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 6 of 48
  • 7. 7 CONDOMINIUM UNIT A-310 OF BUILDING A, THE CONDOMINIUMS AT VILLAGE PLACE BROOKHAVEN, A CONDOMINIUM, AS MORE PARTICULARLY DESCRIBED AND DELINEATED IN THE DECLARATION OF CONDOMINIUM FOR THE CONDOMINIUMS AT VILLAGE PLACE BROOKHAVEN, RECORDED IN DEED BOOK 21154, PAGE 494, ET SEQ., DEKALB COUNTY, GEORGIA RECORDS, AS MAY BE AMENDED, TOGETHER WITH ALL RIGHT, TITLE AND INTEREST IN THE COMMON ELEMENTS AS SET FORTH IN SAID DECLARATION. THIS CONVEYANCE IS MADE SUBJECT TO THE DECLARATION AND ALL MATTERS REFERENCED THEREIN, ALL MATTERS SHOWN ON THE PLAT RECORDED IN CONDOMINIUM PLAT BOOK 209, PAGES 80-86, DEKALB COUNTY, GEORGIA RECORDS, AS MAY BE AMENDED, AND THE FLOOR PLANS RECORDED IN CONDOMINIUM FLOOR PLAN BOOK 209, PAGE 87, AFORESAID RECORDS, AS MAY BE AMENDED; c. The real property located at 3464 Paces Place, N,W., Atlanta, Fulton County, Georgia, and all buildings and appurtenances thereto (the Paces Place Property), described more particularly as follows: 3464 Paces Place, NW, Atlanta, Fulton County, Georgia Tax Parcel ID No.: 17-019800030227 ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING IN LAND LOT 198 OF THE 17TH DISTRICT, FULTON COUNTY, GEORGIA, BEING UNIT C-105 OF PACES PLACE CONDOMINIUM AS PER PLAT OF SURVEY MADE BY ERNEST L. BOGGUS, P.E. & L.S., DATED JUNE, 1966, AND SHOWN AS "PROPERTY OF MARGARET P. HITT" RECORDED IN CONDOMINIUM PLAT BOOK 1, Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 7 of 48
  • 8. 8 PAGES 2 AND 3, AND AS REVISED AND RECORDED IN CONDOMINIUM PLAT BOOK 1, PAGE 16, AFORESAID RECORDS, TOGETHER WITH ALL RIGHT, TITLE AND INTEREST CONTAINED IN DECLARATION OF PACES PLACE CONDOMINIUM RECORDED IN DEED BOOK 4461, PAGES 161-226, INCLUSIVE, AND AS AMENDED BY INSTRUMENT RECORDED IN DEED BOOK 4347, PAGE 295, AFORESAID RECORDS, SAID DECLARATION BY THIS REFERENCE BEING INCORPORATED HEREIN AND MADE A PART HEREOF. THE INTEREST HEREIN CONVEYED INCLUDES WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, AN UNDIVIDED 2.776 PERCENT INTEREST IN THE COMMON AREAS AND FACILITIES OF SAID CONDOMINIUM. d. The real property located at 4536 East Brookhaven Drive, Atlanta, Fulton and DeKalb Counties, Georgia, and all buildings and appurtenances thereto (the Brookhaven Property), described more particularly as follows: 4536 East Brookhaven Drive, NE, a/k/a 3060 Mabry Road Atlanta, Fulton and DeKalb Counties, Georgia Fulton County Tax Parcel ID No.: 17-001300020262 DeKalb County Tax Parcel ID No.: 18-275-02-001 ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING IN LAND LOT 13 OF THE 17TH DISTRICT, FULTON COUNTY, GEORGIA, AND LAND LOT 275 OF THE 18TH DISTRICT, DEKALB COUNTY, GEORGIA, BEING LOT 2 OF THE C.H. WATFORD PROPERTY, AS PER PLAT RECORDED IN PLAT BOOK 20, PAGE 107, DEKALB COUNTY RECORDS, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT THE INTERSECTION OF THE NORTH SIDE OF EAST BROOKHAVEN DRIVE WITH THE NORTHWESTERN SIDE OF MABRY DRIVE (ROAD), IF Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 8 of 48
  • 9. 9 SAID STREET LINES WERE EXTENDED TO FORM AN ANGLE INSTEAD OF A CURVE; RUNNING THENCE WESTERLY ALONG THE NORTH SIDE OF EAST BROOKHAVEN DRIVE 94.2 FEET TO AN IRON PIN AT THE SOUTHEAST CORNER OF LOT 1, SAID SUBDIVISION; RUNNING THENCE NORTHWESTERLY ALONG THE LINE DIVIDING LOT 1 AND LOT 2, SAID SUBDIVISION, 206.5 FEET TO LOT 3, SAID SUBDIVISION; RUNNING THENCE SOUTHEASTERLY ALONG THE LINE WHICH DIVIDES LOT 2 AND LOT 3, SAID SUBDIVISION, 220.0 FEET TO THE NORTHWESTERN SIDE OF MABRY DRIVE (ROAD); RUNNING THENCE SOUTHWESTERLY 200.0 FEET TO THE NORTH SIDE OF EAST BROOKHAVEN DRIVE AND THE POINT OF BEGINNING, BEING IMPROVED PROPERTY KNOWN AS 4536 EAST BROOKHAVEN DRIVE, ACCORDING TO THE PRESENT SYSTEM OF NUMBERING HOUSES IN THE CITY OF ATLANTA AND FULTON AND DEKALB COUNTIES; e. The real property located at 2385 Heather Drive, Decatur, DeKalb County, Georgia, and all buildings and appurtenances thereto (the Heather Drive Property), described more particularly as follows: 2385 Heather Drive Decatur, DeKalb County, Georgia 30033-2701 Tax Parcel ID Number: 18 113 09 015 ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING IN LAND LOT 113 OF THE 18TH DISTRICT OF DEKALB COUNTY, GEORGIA, BEING LOT 15, BLOCK G, ADDITION NO. 5 OF LEAFMORE HILLS SUBDIVISION, ACCORDING TO PLAT RECORDED AT PLAT BOOK 25, PAGE 150, DEKALB COUNTY RECORDS, WHICH PLAT IS HEREBY REFERRED TO AND MADE A PART OF THIS DESCRIPTION, BEING KNOWN AS 2385 HEATHER DRIVE, Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 9 of 48
  • 10. 10 ACCORDING TO THE PRESENT SYSTEM OF NUMBERING HOUSES IN DEKALB COUNTY, GEORGIA. f. The real property located at 48 Shinbone Court, Alys Walton Beach, Walton County, Florida, and all buildings and appurtenances thereto (the Shinbone Property), described more particularly as follows: 48 Shinbone Court, Panama City Beach, Walton County, Florida Tax Parcel ID No.: 27-3S-18-16420-0JJ-0150 LOT 15, BLOCK JJ, ALYS BEACH PHASE 2B, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 16, PAGES 81 AND 81A, OF THE PUBLIC RECORDS OF WALTON COUNTY, FLORIDA.; g. The real property located at 7 La Garza Court, Alys Walton Beach, Walton County, Florida, and all buildings and appurtenances thereto (the La Garza Property) described more particularly as follows: 7 La Garza Court, Panama City Beach, Walton County, Florida Tax Parcel ID No.: 27-3S-18-16420-0NN-0060 LOT 6, BLOCK NN, ALYS BEACH PHASE 2B, ACCORDING TO THE MAP OR PLAT THEREOF, AS RECORDED IN PLAT BOOK 16, PAGES 81 AND 81A, OF THE PUBLIC RECORDS OF WALTON COUNTY, FLORIDA; h. The 2006 Cessna Citation XLS, Manufacturer's Serial Number 560-5623, bearing registration number N562VP (the Cessna); Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 10 of 48
  • 11. 11 i. The Gipps Aero Party Limited Model GA8TC-320 bearing tail number N68GA and serial number GA8-TC-320-12-187 (the Gipps Aero); j. The Extra Flugzeugproduktions Und Model EA300/LT bearing tail number N330TY and Serial Number LT020 (the Extra); k. The black 2012 Mercedes Benz GL550 bearing vehicle identification number 4JGBF8GE5CA785200 and Georgia tag number PAK5506(the Black Mercedes); l. The silver 2012 silver Mercedes Benz SLS AMG bearing vehicle identification number WDDRJ7HA1CA008056 and Georgia tag number BXY3941(the Silver Mercedes); m. The black 2013 Audi SS Quatro bearing vehicle identification number WAUD2AFD2DN020235 and Georgia tag number PMC8546 (the Black Audi); n. All right, title and interest of Sterling, Sterling Online, GID, Alex Capital Holdings LLC (Alex); Lullwater Holdings LLC (Lullwater); Curtis Creek Holdings, LLC (Curtis Creek); Valley Trust; Lullwater Trust, Rhame, J.Shaw, C.Shaw, and/or Bell in the following: i. Sterling; ii. Sterling Online; iii. GID; iv. Alex; Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 11 of 48
  • 12. 12 v. Lullwater Holdings; vi. Lullwater Trust; vii. Curtis Creek; viii. Valley Trust; ix. Springlake Trading, LLC (Springlake Trading); x. JS Real Estate Investments, LLC (JS Real Estate Investments); xi. SR Equipment Leasing, LLC (SR Equipment Leasing); xii. Primestone Properties LLC (Primestone Properties); xiii. Wingover Capital LLC (Wingover Capital); xiv. Northwest Capital LLC (Northwest Capital); xv. The TAR Revocable Trust (TAR); xvi. Broadway Trader 4Z, LLC (Broadway Trader); xvii. Yards at Noda, LLC (Yards at Noda); xviii. Sherrills Ford Holdings LLC (Sherrill’s Ford); xix. Scotch Cove, LLC (Scotch Cove); xx. RG Classics LLC (RG Classics); xxi. Isolveit.com LLC (Isolveit); xxii. Sterlingfunder LLC (Sterlingfunder); xxiii. Trinvest LLC (Trinvest); xxiv. Sky Combat Blue LLC (Sky Combat Blue); xxv. TR East Point Real Estate LLC (TR East Point); xxvi. TR Interactive Technologies LLC (TR Interactive Technologies); xxvii. Polaris Aviation LLC (Polaris Aviation); xxviii. Sky Combat Red LLC (Sky Combat Red); xxix. Cascades at Rea, LLC (Cascades at Rea); xxx. Arrowood Station Holdings LLC (Arrowood Station Holdings); xxxi. Arrowhead Station Holdings LLC (Arrowood Station Holdings); xxxii. Miracle Charters, LLC (Miracle Charters) xxxiii. TR Real Estate LLC (TR Real Estate); xxxiv. Whistlejacket, Inc. (Whistlejacket); xxxv. J-Brem LLC (J-Brem); xxxvi. Therrell Farms Estates LLC (Therrell Farms Estates); xxxvii. Zonolite Holdings LLC (Zonolite Holdings); Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 12 of 48
  • 13. 13 xxxviii. Sustainability Solutions LLC (Sustainability Soultions); xxxix. Gvest Holdings LLC (Gvest Holdings); xl. Gvest Partners LLC (Gvest Partners); xli. Gvest Capital LLC (Gvest Capital); xlii. 200West Land DST (200 West Land); xliii. Primestone FifeCo Realty Fund LLC (Primestone-FifeCo); xliv. Preferred Capital LLC (Preferred Capital); xlv. Reclaim Group LLC (Reclaim Group); xlvi. Wingover Ranch, LLC (Wingover Ranch); xlvii. Shaw Capital & Guaranty, LLC (Shaw Capital and Guaranty); xlviii. Shaw Irrevocable Trust (Shaw Irrevocable Trust); xlix. Shaw Alys Beach LLC (Shaw Alys Beach); l. Trinvest Partners, LLC (Trinvest Partners); and li. GID Associates LLC (GID Associates). (collectively the Defendant Properties). 2. Based on the evidence described below, the Defendant Properties are subject to forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) as proceeds of specified unlawful activity traceable directly and indirectly to violations of 18 U.S.C. §§ 1341, 1343, 1349, 1956, and 1957. 3. Additionally, the Defendant Properties are subject to forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(A) as property involved in money laundering offenses in violation of 18 U.S.C. §§ 1956 and 1957. 4. This Court has jurisdiction over this action and the claims raised herein by virtue of 28 U.S.C. §§ 1345 and 1355(a). 5. Venue is proper in the Northern District of Georgia as to the Valley Road Property, the Dresden Property, the Paces Place Property, the Brookhaven Property, the Heather Drive Property, the Black Mercedes, the Silver Mercedes, and Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 13 of 48
  • 14. 14 the Black Audi because those properties are located and remain herein. See 28 U.S.C. §§ 1395(a) and (b). 6. Additionally, venue is proper in the Northern District of Georgia as to all of the Defendant Properties because acts in furtherance of the conspiracies and substantive offenses alleged above occurred herein and because the offenses subjecting that property are properly chargeable in the Northern District of Georgia. See 28 U.S.C. §§ 1355 (b) and 1395(a) and (b). II. Facts Giving Rise to Forfeiture A. The Business of Sterling Currency Group 7. Since at least 2004, Sterling Currency Group, LLC (“Sterling”), an Atlanta, Georgia-based business that also does business under the name Dinar Banker, has become one of the largest sellers of Iraqi dinar in the United States. While Sterling also offers the sale of what its website calls “other exotic currencies,” including the Vietnamese Dong, Indonesian Rupiah, Afghani, and Chinese Yuan, the bulk of Sterling’s business comes from the sale of the Iraqi dinar. 8. Sterling is one of several money service businesses in the United States that purchases the Iraqi dinar abroad for sale to customers in the United States and Canada. 9. Sterling purchases its inventory of dinar notes from exchangers in the Middle East, transports the notes in bulk to the United States via commercial carrier, retrieves the notes from Hartsfield Jackson International Airport, and trucks them Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 14 of 48
  • 15. 15 for storage to a business location in Atlanta, Georgia, where they remain available to fill customer orders placed on its websites (initially at www.dinarbanker.com and now at www.sterlingcurrencygroup.com) and over the telephone. 10. Sterling operates in partnership with Sterling Online Processing (“Sterling Online”), which provides administrative services for Sterling, as well as GID Partners (“GID Partners”), which is an Iraqi dinar exchanger purchased by Sterling. 11. Tyson Rhame (Rhame) and James Shaw (J.Shaw) are the co-owners and co- founders of Sterling. Rhame and Shaw share ownership of Sterling through their respective interests in several corporations, including Alex Capital Holdings (“Alex”), Lullwater Holdings (“Lullwater”), and Curtis Creek Holdings (“Curtis Creek”) as well as the trusts “Valley Trust” and “Lullwater Trust.” 12. Carol Laurette Shaw (C.Shaw) is married to J. Shaw and is also a co-owner of Sterling through her interests in Alex, Curtis Creek, and Valley Trust. As recently as 2011, C.Shaw played an active role in Sterling’s operations. 13. Frank Bell (Bell) began working for Sterling in 2010 and is presently Sterling’s Chief Operating Officer (COO). Bell presently runs the day-to-day affairs of Sterling. 14. Since at least 2010, Rhame, J.Shaw, C.Shaw, and Bell have shared control of Sterling’s operations. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 15 of 48
  • 16. 16 B. Knowledge of the Scam 15. Sterling’s success is at least partially attributable to its use of the facilities of interstate commerce, including wire communications, both directly and indirectly, to disseminate false and misleading information about the possibility of a revaluation of the dinar and to steer customers toward choosing Sterling over its competitors. 16. The revaluation (or simply, “RV”) theory has spread throughout the Internet and is promoted by a variety of internet blogs and individuals who hold themselves out to be currency experts or “dinar gurus.” According to the RV theory, the dinar will experience an abrupt, exponential rise in value against the U.S. dollar and hence yield enormous profits for dinar holders. 17. An individual who worked for Sterling from approximately 2013 to 2015 confirmed that Bell at one point told customer service center representatives in a meeting that there would never be an Iraqi dinar revaluation. Bell instructed the representatives not to tell callers that the revaluation will never occur but to tell the callers to do their own research. 18. Email communications between Rhame, J.Shaw, C.Shaw, and Bell confirm that these individuals know that the concept of the dinar revaluation is a scam. a. For instance, C.Shaw sent an October 20, 2010, email to Rhame that stated, in part, “I cant [sic] watch these folks be so stupid” and then stated “3 orders all for 100,000 at 200 each and 1 order Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 16 of 48
  • 17. 17 for 10 notes at 330 shipping overnight each at 43.00 and to the same address.” b. On November 3, 2010, J.Shaw sent an email to Rhame entitled, “Discussion Point,” an email that he also forwarded to C.Shaw, which read, in part: Ty, The point of my call was not to talk about net worth. We have a business that I valued at $8-10 million in that formula (SCG). Laurette and I do not think about how much is hers and mine as you do in your relationship (like I should give her 99% of profits). We are 50-50 partners on everything and if we ever split up we would divide all assets as such. She has lately been very nervous and was crying last night because she knows we are running an illegal operation. The point is that her [sic] and I have worked way too hard in life for us to risk everything based on your belief (even if I agree with you) that the Iraqi dinar will not RV and it is ok to make millions of dollars in false promises to our customers. Not only are we risking everything we own, we are risking serious jail time as promoters of a ponzi scheme. . . Jim 19. A series of emails sent on November 30, 2010, further shows knowledge and intent. a. On that date, Rhame sent an email to J.Shaw that J.Shaw then forwarded to C.Shaw, which read in part, “Our business is chicken shit and we got CRUSHED in a conference call on Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 17 of 48
  • 18. 18 Sunday night---not because of anything said against us, but because we operate small minded and haven't been growing. We are not a real company. I got beat up in a conference call again last night because of our limited growth.” b. J.Shaw’s response to Rhame, one that he forwarded to C.Shaw, stated, in part, “Laurettes [sic] job is just as important as yours. I am sick of seeing her work most days and nights just to have you pretend to be doing so much more than anyone.” The email also stated, “I am not sure how much bigger this business needs to be until it can be managed properly. We are at risk for lawsuits and other problems. We are not selling Coca Cola.” c. On that same date, another email from J.Shaw to Rhame, one that J.Shaw ultimately forwarded to C.Shaw more than a year later on December 20, 2011, read as follows: Ty, The more I think of your bullshit emails the more it disgusts me. I bankrolled this entire business at its inception by putting up 80% of initial capital (500/630). Throw in Zurich and I bankrolled 95% of all finances. Laurette has done at least 50% of the work and I was instrumental in our website and getting the business growing. Our agreement was that you and Laurette would work the business. How much work has Bonnie done? AS SOON AS THE BUSINESS STARTS TO DO REALLY WELL, YOU START THROWING OUT YOUR CONTROL FREAK EMAILS. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 18 of 48
  • 19. 19 FYI: Laurette and I are concerned about getting letters to you thanking you for helping them with their hospital with their purchase of $20k for a $200k layaway and other similar letters. We are not Charlatans and I do not like making money under false pretenses. I DONOT WANT TO BE ALI. Our life is happy without swindling people.” 20. Additionally, a March 22, 2011, set of emails further shows that Rhame and C.Shaw were aware of Sterling’s wrongdoing. a. Specifically, on that date, Rhame sent C.Shaw an email that copied J.Shaw with the subject, “Comments related to AMENDED Operating Agreement” in which he asserted, “This amendment is complete bullshit written for the purpose of obtaining banking. Jim and Ty are operation [sic] under the original partnership agreement. We are 50% partners and his ass will go to prison if mine does.” b. Thereafter, C.Shaw replied, “and won't your asses have an interesting time there. NOT.” 21. Likewise, on August 6, 2012, J.Shaw sent Bell an email with the subject line, “not great article,” that contained a hyperlink to a news article entitled, “You Can’t Fix Stupid – The Iraqi Dinar Scam Lives.” C. Sterling’s Unlawful Business Practices 22. Sterling’s unlawful business practices fall into at least two categories. First, Sterling unlawfully used at least one revaluation promoter to disseminate false information and steer prospective dinar purchasers toward Sterling. Second, Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 19 of 48
  • 20. 20 Sterling used telephone conversations and its own web site to make false representations and false promises to its customers. i. Sterling’s Use of the RV Promoters’ Web Sites 23. Sterling has knowingly benefitted from false representations made by web sites and blogs, including “The GET Team.” 24. The GET Team, which is led by an individual known as TerryK, runs an internet chat room and weekly conference calls in which information about the Iraqi dinar is discussed. During those chats and conferences, TerryK spreads false information suggesting that the revaluation is about to occur. 25. In a September 13, 2010, email, TerryK introduced himself to Rhame: Ty, My name is TerryK, I own the worlds [sic] largest Dinar web site going….we have currently 7200 members and currently we hold two calls a week with about 1500 on the call and 100’s if not 1,000’s on skype listening in…what I would like to do is open a discussion with you and maybe have you on a call this coming wed night. It starts at 9pm and thought maybe 10- 15 min on how you operate, how to cash in with your firm and then a question and answers session….let me know via email [sic]. terryk. 26. Thereafter, beginning at least as early as 2011, Sterling began making monthly payments in the amount of $4,000 to TerryK. In total, Sterling has paid TerryK more than $150,000 since 2011. 27. Since TerryK’s 2010 email, Sterling employees, including Bell and Rhame, have routinely spoken on the GET Team’s weekly conference calls. For example, on the May 27, 2015, GET Team conference call, Bell stated that Sterling would be Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 20 of 48
  • 21. 21 offering a “fire sale” in early June 2015. During this conference call, TerryK stated that listeners should purchase currency from Sterling, that he trusted his friends “Ty” and “Frank” at Sterling, and that he had so much trust in Bell that he would be comfortable giving Bell his bank account information. 28. In the GET Team chat room and during the weekly conference calls, TerryK also passed along false information purportedly received from sources about the revaluation of the Iraqi dinar and other currencies (such as the Vietnamese dong). a. For example, on the January 8, 2014, conference call, TerryK stated that a source at Wells Fargo said that it would take at most 10 to 15 minutes to process the exchange of Iraqi dinar. b. Additionally, on the March 12, 2014, conference call, TerryK stated that a source at Wells Fargo had told him “it” was supposed to happen but that the time kept changing. c. Likewise, on the April 16, 2014, conference call, TerryK said that he had heard from the “UST,” a reference to the U.S. Department of Treasury, that the rate was good and that everything would be released that week. 29. On June 3, 2015, TerryK acknowledged during an interview with the Federal Bureau of Investigation (FBI) that he had fabricated source information on GET Team online postings and conference calls. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 21 of 48
  • 22. 22 30. In fact, the U.S. Department of Treasury is not preparing and has never prepared for an Iraqi dinar revaluation. 31. Similarly, Wells Fargo does not trade in the Iraqi dinar and also warns its customers not to invest in it. In fact, a publicly available Well Fargo Advisors Memorandum dated March 10, 2014, states that Wells Fargo is not preparing for an Iraqi dinar revaluation and has no plans whatsoever to exchange the Iraqi dinar. 32. Moreover, a November 7, 2011, email exchange between TerryK, Rhame and Bell confirms that TerryK and Sterling have sought to keep the specific nature of their relationship secret. a. On that date, TerryK sent an email to Rhame and Bell that read: “I want to make sure that our arrangement is between us and no one else...As no one else needs to know about our arrangement... Please confirm... Thanks for all you guys do... [sic]” b. Bell’s reply, sent that same day, read, “Absolutely noone [sic] but us [sic].” 33. Although on May 28, 2015, Bell represented to the FBI during an interview that Sterling maintains a “firewall” between itself and revaluation promoters, email records belie his assertions. a. For instance, on May 22, 2012, TerryK sent an email to Rhame and Bell that read as follows: Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 22 of 48
  • 23. 23 You should have gotten a lot of business on the reserves the past week, been pushing it hard on the site bro…..make sure TY is not selling dinar from the middle table that one is mine…..[sic]” Bell’s reply, sent the following day, read, “TK, Will do, thanks for your support.” b. Likewise, on March 11, 2013, TerryK sent Bell an email that read, FYI Received payment today, thanks for following up..What else can I do to help sales for your team? Just let me know buddy, I will be in the room later today to get some things moving as well [sic]. c. Also, on July 22, 2013, TerryK sent Bell an email reading as follows: Frank, please find attached the banner invoice for the month of August 2013, I trust things are going well, as we keep promoting the heck out of Sterling.. [sic] If there is anything you need let me know. 34. On June 3, 2015, Bell acknowledged to FBI agents that Sterling should not have continued to do business with the dinar promoters. ii. False Representations and Promises on Sterling’s Website 35. Sterling’s business practices have included publishing information on its own website that its principals knew to be untrue and disseminating false information over the telephone. 36. For instance, though Sterling’s website now warns customers that “Sterling Currency Group / DinarBanker is not an accredited financial consultant” and that “that the value of the currency may go down or go up depending on circumstances Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 23 of 48
  • 24. 24 beyond our control,” in 2010, Sterling, used its former website, www.dinarbanker.com, to suggest that a revaluation could occur in the near future. 37. Furthermore, on of December 27, 2010, Sterling’s website displayed an article titled “Iraqi Dinar Revaluation” that cited Tyson Rhame as its primary source and that stated, in part:1 To put it simply, the Iraqi Dinar is currently worth less than 1/10th of a US penny (Approximately $1000 US dollars buys 1 million Iraqi Dinar). Historically, the Iraqi Dinar has been worth over 3 US dollars for every Iraqi Dinar (Over $3,000,000 US dollars purchased 1 million Iraqi Dinar). Put another way, 1 million Iraqi Dinar is currently worth a little less that 1000 US dollars and historically 1 million Iraqi Dinar has been worth well over $3,000,000.00 US dollars. So, the question is: Will the Iraqi Dinar increase in value? And if so, how? And when? * * * * The bottom line is that the Iraqi Dinar is currently at an extremely low valuation compared to the US Dollar. The currency has steadily increased in value since inception in late 2003. Iraq is a country with phenomenal wealth potential; and additionally, has the backing and support of the major political and economic powers of the world. There currently seems to be minimal risk that the Iraqi Dinar will decrease in value. The tremendous potential upside return compared to the minimal downside risk seems to make the Iraqi Dinar a compelling investment opportunity worth investigating. * * * In determining when the Iraqi Dinar will increase in value, all indicators point toward something happening in the near future (next 12 months) if not the very near future (next 3 1 All emphases are in the original material. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 24 of 48
  • 25. 25 months). The appreciation of the Iraqi Dinar has been unprecedentedly flat over the past 8 months despite low Iraqi inflation and a weakening US economy and US dollar. The Iraqi economy has been on a continual surge of economic growth for the past couple of years as Iraq has continued to stabilize and rebuild. The news coming out of Iraq from numerous returning military members with various reliable sources indicates a rapid move and increase in valuation occurring prior to, or in conjunction with US troop reductions. Indicators also point to an increase in the Iraqi Dinar exchange rate occurring prior to, or shortly after Iraqi elections. It appears that administratively, the IMF, WTO, and other world financial entities are working in close conjunction with the Iraqi Government to bring Iraq’s financial system online with the rest of the world. The expectation is that the Iraqi Dinar will soon be freely traded through banks worldwide---further accelerating their recovery and economy, and adding to overall stability. * * * To answer the question of ‘How’ and ‘How high?’ the Iraqi Dinar will revaluate, some speculation is in order. Based on historical precedents, an initial sudden significantly (overnight/over weekend) high revaluation seems very possible. This initial move could be anywhere along the entire spectrum of rumored possibilities from $.01 to $1.49. After this initial revaluation, it seems likely there will be numerous significant incremental increases in valuation over a period of time. This continual increase in value after an initial base valuation will prevent an overwhelming surge on the world financial system. By incrementally increasing the value of the dinar, it will limit the number and amount of Iraqi Dinar exchanges as many investors and currency traders will choose to hold their Iraqi Dinar or purchase more as they anticipate further valuation increases. In other words, a steady increase in the value of the Iraqi Dinar will create a free flowing market as some investors cash-out, others hold on, and others purchase Iraqi Dinar for the first time. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 25 of 48
  • 26. 26 38. In contrast, since that time, Bell has told FBI agents that he believes that the Iraqi dinar will never revalue. In a May 28, 2015, interview with the FBI, Bell explained that based upon his education and experience with international finance, he believes that the Iraqi dinar will never be revalued to the extent that dinar promoters commonly claim. Furthermore, in a June 3, 2015, interview with the FBI, Bell used the term “mythology” when discussing the concept of an Iraqi dinar revaluation. 39. In 2010, Sterling’s website also represented that following the revaluation, customers would be able to exchange their Iraqi dinars at kiosks or “remote satellite offices” located at airports around the country. 40. Postings to Sterling’s website are illustrative. a. For instance as of January 3, 2010, Sterling’s website displayed an article titled, “Complete Guide To Exchanging Iraqi Dinar After Revaluation” that stated, in part, Dinar Banker has the ability to set up secure remote satellite offices at numerous airport locations nationwide within 24 hours. They have a long history of transporting and securing currency all over the world through their global operations and are prepared for any exchange needs.2 b. Similarly, as of October 21, 2010, Sterling’s website displayed an article titled, “Iraqi Dinar Exchange Locations” that stated, in part: 2 Emphasis in original. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 26 of 48
  • 27. 27 DinarBanker will have secure remote satellite offices set up at numerous airport locations nationwide as soon as possible in the event of a revaluation. You will not have to go through security in the airport exchange locations – You can simply come in with Dinar in a briefcase or luggage and come to the exchange location set up in the office area of each airport. We will have de la Rue machines to quickly count and verify your Dinar and all equipment needed to perform fast and secure wire transfers. c. That same article then represented that the “Current Exchange Locations” that Sterling planned “in the Event of an RV include[d]:” City, State - Airport Code Atlanta, GA - ATL Boston, MA - BOS Chicago, IL - ORD Cincinnati, OH - CVG Dallas / Forth Worth, TX - DFW Denver, CO - DEN Detroit, MI - DTW Houston, TX - IAH Las Vegas, NV - LAS Los Angeles, CA - LAX Miami, FL - MIA Minneapolis, MN - MSP New Orleans, LA - MSY New York, NY - JFK Phoenix, AZ - PHX Salt Lake City, UT - SLC San Francisco, CA - SFO Seattle, WA - SEA St. Louis, MO - STL Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 27 of 48
  • 28. 28 Tampa, FL - TPA Washington, DC - DCA (Ronald Reagan) Washington, DC - IAD (Dulles) International Locations Calgary, Canada - YYC Vancouver, Canada - CYVR Toronto, Canada - CYXZ San Juan, Puerto Rico 41. In 2010, Rhame told a Sterling customer over the telephone that Sterling would open a kiosk at John F. Kennedy International Airport in New York following the revaluation to exchange Iraqi dinars for U.S. dollars. 42. Despite these representations, a former Sterling employee has confirmed that Sterling never had any arrangements with airports to operate remote satellite offices or kiosks. Furthermore, representatives from three of the above-listed airports have confirmed that Sterling never had arrangements to operate remote satellite offices or kiosks. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 28 of 48
  • 29. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 29 of 48
  • 30. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 30 of 48
  • 31. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 31 of 48
  • 32. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 32 of 48
  • 33. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 33 of 48
  • 34. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 34 of 48
  • 35. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 35 of 48
  • 36. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 36 of 48
  • 37. 37 Isolveit.com, Sherrills Ford Holdings, Trinvest Partners, Sky Combat Blue, Sky Combat Red, Polaris Aviation, TR East Point Real Estate, TR Interactive Technologies, Sterling Funder, SR Equipment Leasing, and TAR Revocable Trust. 49. Similarly, J.Shaw and C.Shaw own Curtis Creek directly and through Valley Trust. In addition, J.Shaw has or had an interest in or some degree of control over JS Real Estate Investments, Primestone Properties, SR Equipment Leasing LLC, Wingover Capital LLC, Northwest Capital LLC, Broadway Trader 4Z, Springlake Trading, Sterling Funder, and Alys Beach Fund. 50. Bell manages the daily affairs of the Sterling entities as the Chief Operating Officer and through his company, Whistlejacket. In addition, Bell has at one point had an interest in or some degree of control over “J-Brem.” B. Tracing the Tainted Funds 51. Sterling has used at least nine known bank accounts to receive currency purchase money from investors. 52. As detailed in Exhibits A, B, C, D, and E to this Complaint, proceeds from sales of currency to consumers were received in the nine accounts listed below, and gross deposits into each account during the range specified appear below: Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 37 of 48
  • 38. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 38 of 48
  • 39. 39 Brem, Therrell Farms Estates, Zonolite Holdings, Sustainability Solutions, Gvest Holdings, Gvest Partners, Gvest Capital, 200 West Land DST, Primestone Feifco Realty Fund, Preferred Capital, Reclaim Group, Wingover Ranch, Shaw Capital & Guaranty, Shaw Irrevocable Trust, Shaw Alys Beach, Trinvest Partners, GID Associates and/or assets owned by those business entities. 54. The purposes behind some of those financial transactions included remitting proceeds to conspirators, facilitating the operation of the underlying scheme, and concealing and disguising the nature, source, location, ownership, and control of fraud proceeds. 55. Additionally, by moving the tainted funds out of receiving accounts and into “downstream” accounts, conspirators engaged in unlawful monetary transactions involving more than $10,000 in tainted funds. 56. Finally, acts promoting the schemes to defraud and launder money were committed at the Valley Road, Heather Drive, and Brookhaven Properties. 57. Consequently, the United States is entitled to forfeiture of the Defendant Properties as proceeds traceable directly and indirectly to schemes and artifices to defraud and properties involved in money laundering offenses. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 39 of 48
  • 40. 40 IV. Conclusion WHEREFORE, the United States prays: That the Court forfeit the Defendant Properties to the United States of America; That the Court award the Plaintiff the costs of this action; and That the Court grant such other relief as the Court deems just and proper. Respectfully submitted this 5th day of June, 2015. Respectfully submitted, JOHN A. HORN Acting United States Attorney 600 U.S. Courthouse 75 Spring Street SW Atlanta, GA 30303 (404) 581-6000 fax (404) 581-6181 /s/THOMAS J. KREPP Assistant United States Attorney Georgia Bar No. 346781 /s/JENNY R. TURNER Assistant United States Attorney Georgia Bar No. 719439 Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 40 of 48
  • 41. 41 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERCIA, v. THE REAL PROPERTY LOCATED AT 225 VALLEY ROAD, N.W., ATLANTA, FULTON COUNTY, GEORGIA; 1418 DRESDEN DRIVE, N.E., NUMBER A310, ATLANTA, DEKALB COUNTY, GEORGIA; 3464 PACES PLACE, N,W., ATLANTA, FULTON COUNTY, GEORGIA; 4536 EAST BROOKHAVEN DRIVE, ATLANTA, FULTON AND DEKALB COUNTIES, GEORGIA; 2385 HEATHER DRIVE, DECATUR, DEKALB COUNTY, GEORGIA; 48 SHINBONE COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA, 7 LA GARZA COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA; THE 2006 CESSNA CITATION XLS, MANUFACTURER'S SERIAL NUMBER 560-5623, BEARING REGISTRATION NUMBER N562VP; THE GIPPS AERO PARTY LIMITED MODEL GA8TC-320 BEARING TAIL NUMBER N68GA AND SERIAL NUMBER GA8-TC-320- 12-187; THE EXTRA FLUGZEUGPRODUKTIONS UND MODEL EA300/LT BEARING TAIL NUMBER N330TY AND SERIAL Civil Action No. 1:15-CV- Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 41 of 48
  • 42. 42 NUMBER LT020; THE BLACK 2012 MERCEDES BENZ GL550 BEARING VEHICLE IDENTIFICATION NUMBER 4JGBF8GE5CA785200 AND GEORGIA TAG NUMBER PAK5506; THE SILVER 2012 SILVER MERCEDES BENZ SLS AMG BEARING VEHICLE IDENTIFICATION NUMBER WDDRJ7HA1CA008056 AND GEORGIA TAG NUMBER BXY3941; THE BLACK 2013 AUDI SS QUATRO BEARING VEHICLE IDENTIFICATION NUMBER WAUD2AFD2DN020235 AND GEORGIA TAG NUMBER PMC8546; AND ALL RIGHT, TITLE AND INTEREST OF STERLING CURRENCY GROUP, LLC, STERLING ONLINE PROCESSING SERVICES, LLC, GID PARTNERS, LLC, ALEX CAPITAL HOLDINGS LLC, LULLWATER HOLDINGS LLC, CURTIS CREEK HOLDINGS, LLC, VALLEY TRUST, LULLWATER TRUST, TYSON RHAME, JAMES SHAW, CAROLE LAURETTE SHAW, AND/OR FRANK BELL IN ALEX CAPITAL HOLDINGS LLC; STERLING CURRENCY GROUP LLC, STERLING ONLINE PROCESSING SERVICES LLC, GID PARTNERS LLC, CURTIS CREEK HOLDINGS LLC, LULLWATER HOLDINGS LLC, VALLEY TRUST, LULLWATER TRUST, SPRINGLAKE TRADING, LLC, JS REAL ESTATE INVESTMENTS, LLC, SR EQUIPMENT LEASING, LLC, PRIMESTONE PROPERTIES LLC, WINGOVER Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 42 of 48
  • 43. 43 CAPITAL LLC, NORTHWEST CAPITAL LLC, THE TAR REVOCABLE TRUST, BROADWAY TRADER 4Z, LLC, YARDS AT NODA, LLC, SHERRILLS FORD HOLDINGS LLC, SCOTCH COVE, LLC, RG CLASSICS LLC, ISOLVEIT.COM LLC, STERLINGFUNDER LLC, TRINVEST LLC, SKY COMBAT BLUE LLC, TR EAST POINT REAL ESTATE LLC, TR INTERACTIVE TECHNOLOGIES LLC, POLARIS AVIATION LLC, SKY COMBAT RED LLC, CASCADES AT REA, LLC, ARROWOOD STATION HOLDINGS LLC , ARROWHEAD STATION HOLDINGS LLC, MIRACLE CHARTERS, LLC, TR REAL ESTATE LLC, WHISTLEJACKET, INC., J-BREM LLC, THERRELL FARMS ESTATES LLC, ZONOLITE HOLDINGS LLC, SUSTAINABILITY SOLUTIONS LLC, GVEST HOLDINGS LLC, GVEST PARTNERS LLC, GVEST CAPITAL LLC, 200WEST LAND DST, PRIMESTONE FIFECO REALTY FUND LLC, PREFERRED CAPITAL LLC, RECLAIM GROUP LLC, WINGOVER RANCH, LLC, SHAW CAPITAL & GUARANTY, LLC, SHAW IRREVOCABLE TRUST, SHAW ALYS BEACH LLC, TRINVEST PARTNERS, LLC, AND GID ASSOCIATES LLC. VERIFICATION I, W. Scott Baucom, of the Federal Bureau of Investigation, have read the Complaint for Forfeiture in this action and state that its contents are true and Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 43 of 48
  • 44. Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 44 of 48
  • 45. 45 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERCIA, v. THE REAL PROPERTY LOCATED AT 225 VALLEY ROAD, N.W., ATLANTA, FULTON COUNTY, GEORGIA; 1418 DRESDEN DRIVE, N.E., NUMBER A310, ATLANTA, DEKALB COUNTY, GEORGIA; 3464 PACES PLACE, N,W., ATLANTA, FULTON COUNTY, GEORGIA; 4536 EAST BROOKHAVEN DRIVE, ATLANTA, FULTON AND DEKALB COUNTIES, GEORGIA; 2385 HEATHER DRIVE, DECATUR, DEKALB COUNTY, GEORGIA; 48 SHINBONE COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA, 7 LA GARZA COURT, PANAMA CITY BEACH, WALTON COUNTY, FLORIDA; THE 2006 CESSNA CITATION XLS, MANUFACTURER'S SERIAL NUMBER 560-5623, BEARING REGISTRATION NUMBER N562VP; THE GIPPS AERO PARTY LIMITED MODEL GA8TC-320 BEARING TAIL NUMBER N68GA AND SERIAL NUMBER GA8-TC-320- 12-187; THE EXTRA FLUGZEUGPRODUKTIONS UND MODEL EA300/LT BEARING TAIL NUMBER N330TY AND SERIAL NUMBER LT020; THE BLACK 2012 MERCEDES BENZ GL550 BEARING Civil Action No. 1:15-CV- Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 45 of 48
  • 46. 46 VEHICLE IDENTIFICATION NUMBER 4JGBF8GE5CA785200 AND GEORGIA TAG NUMBER PAK5506; THE SILVER 2012 SILVER MERCEDES BENZ SLS AMG BEARING VEHICLE IDENTIFICATION NUMBER WDDRJ7HA1CA008056 AND GEORGIA TAG NUMBER BXY3941; THE BLACK 2013 AUDI SS QUATRO BEARING VEHICLE IDENTIFICATION NUMBER WAUD2AFD2DN020235 AND GEORGIA TAG NUMBER PMC8546; AND ALL RIGHT, TITLE AND INTEREST OF STERLING CURRENCY GROUP, LLC, STERLING ONLINE PROCESSING SERVICES, LLC, GID PARTNERS, LLC, ALEX CAPITAL HOLDINGS LLC, LULLWATER HOLDINGS LLC, CURTIS CREEK HOLDINGS, LLC, VALLEY TRUST, LULLWATER TRUST, TYSON RHAME, JAMES SHAW, CAROLE LAURETTE SHAW, AND/OR FRANK BELL IN ALEX CAPITAL HOLDINGS LLC; STERLING CURRENCY GROUP LLC, STERLING ONLINE PROCESSING SERVICES LLC, GID PARTNERS LLC, CURTIS CREEK HOLDINGS LLC, LULLWATER HOLDINGS LLC, VALLEY TRUST, LULLWATER TRUST, SPRINGLAKE TRADING, LLC, JS REAL ESTATE INVESTMENTS, LLC, SR EQUIPMENT LEASING, LLC, PRIMESTONE PROPERTIES LLC, WINGOVER CAPITAL LLC, NORTHWEST CAPITAL LLC, THE TAR REVOCABLE Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 46 of 48
  • 47. 47 TRUST, BROADWAY TRADER 4Z, LLC, YARDS AT NODA, LLC, SHERRILLS FORD HOLDINGS LLC, SCOTCH COVE, LLC, RG CLASSICS LLC, ISOLVEIT.COM LLC, STERLINGFUNDER LLC, TRINVEST LLC, SKY COMBAT BLUE LLC, TR EAST POINT REAL ESTATE LLC, TR INTERACTIVE TECHNOLOGIES LLC, POLARIS AVIATION LLC, SKY COMBAT RED LLC, CASCADES AT REA, LLC, ARROWOOD STATION HOLDINGS LLC , ARROWHEAD STATION HOLDINGS LLC, MIRACLE CHARTERS, LLC, TR REAL ESTATE LLC, WHISTLEJACKET, INC., J-BREM LLC, THERRELL FARMS ESTATES LLC, ZONOLITE HOLDINGS LLC, SUSTAINABILITY SOLUTIONS LLC, GVEST HOLDINGS LLC, GVEST PARTNERS LLC, GVEST CAPITAL LLC, 200WEST LAND DST, PRIMESTONE FIFECO REALTY FUND LLC, PREFERRED CAPITAL LLC, RECLAIM GROUP LLC, WINGOVER RANCH, LLC, SHAW CAPITAL & GUARANTY, LLC, SHAW IRREVOCABLE TRUST, SHAW ALYS BEACH LLC, TRINVEST PARTNERS, LLC, AND GID ASSOCIATES LLC. I hereby certify, pursuant to Local Rules 5.1 and 7.1D, that the foregoing Verified Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 47 of 48
  • 48. 48 Complaint for Forfeiture has been prepared using Book Antiqua, 13 point font. /s/ Thomas J. Krepp Assistant U.S. Attorney Case 1:15-cv-02032-LMM Document 1 Filed 06/05/15 Page 48 of 48
  • 49. CM/ECF Mobile - GAND      292 Docket Entries for Case 1:15-cv-02032-LMM 06/05/2015 COMPLAINT FOR FORFEITURE filed by United States of America. (No Fee Required) (Attachments: # 1 Ex. - A, # 2 Ex. - B, # 3 Ex. - C, # 4 Ex. - D, # 5 Ex. - E, # 6 Ex. - F, # 7 Ex. - G, # 8 Ex. - H, # 9 Ex - I, # 10 Ex. - J, # 11 Ex. - K, # 12 Civil Cover Sheet)(eop) Please visit our website at http://www.gand.uscourts.gov/forms to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form. Modified text on 6/9/2015 (eop). 06/09/2015 AMENDED COMPLAINT against All Defendants, filed by United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Krepp, Thomas) Please visit our website at http://www.gand.uscourts.gov/forms to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form. 06/09/2015 MOTION to File Account Listing Under Seal filed by United States of America. (ddm) 06/09/2015 ORDER granting 3 Motion to File Account Listing Under Seal and directing the Clerk to Maintain Exhibit Under Seal. Signed by Judge Leigh Martin May on 6/9/15. (ddm) 06/09/2015 (FILED UNDER SEAL) Exhibit A (Unredacted Listing of Accounts) to 1 Complaint and 2 Amended Complaint filed by United States of America. (ddm) (ddm). 06/10/2015 Remark re 1 Complaint, 2 Amended Complaint, List of "Various Entities": Alex Capital Holdings, LLC; Sterling Currency Group, LLC; Sterling Online Processing Services, LLC; GID Partners, LLC; Curtis Creek Holdings, LLC; Lullwater Holdings, LLC; Valley Trust; Lullwater Trust; Springlake Trading, LLC; JS Real Estate Investments, LLC; SR Equipment Leasing, LLC; Primestone Properties, LLC; Wingover Capital, LLC; Northwest Capital, LLC; The TAR Revocable Trust; Broadway Trader 4Z, LLC; Yards at Noda, LLC; Sherrills Ford Holdings, LLC; Scotch Cove, LLC; RG Classics, LLC; Isolveit.com, LLC; Sterlingfunder, LLC; Trinvest, LLC; Sky Combat Blue, LLC; TR East Point Real Estate, LLC; TR Interactive Technologies, LLC; Polaris Aviation, LLC; Sky Combat Red, LLC; Cascades at Rea, LLC; Arrowood Station Holdings, LLC; Arrowhead Station Holdings, LLC, Miracle Charters, LLC; TR Real Estate, LLC; Whistlejacket, Inc.; J-Brem, LLC; Therrell Farms Estates, LLC; Zonolite Holdings, LLC; Sustainability Solutions, LLC; Gvest Holdings, LLC; Gvest Partners, LLC; Gvest Capital, LLC; 200 West Land DST; Primestone Fifeco Realty Fund, LLC; Preferred Capital, LLC; Reclaim Group, LLC; Wingover Ranch, LLC; Shaw Capital & Guaranty, LLC; Shaw Irrevocable Trust; Shaw Alys Beach, LLC; Trinvest Partners, LLC; and GID Associates, LLC. (mmc) 06/10/2015 WARRANTS OF ARREST IN REM issued as to various defendant properties. (ddm) 06/11/2015 STANDING ORDER Regarding Civil Litigation in cases proceeding before Judge May. Signed by Judge Leigh Martin May on 6/11/15. (ddm) 06/18/2015 MOTION Ex Parte Application for Arrest Warrants In Rem with attached Proposed Order by United States of America. (Turner, Jenny) 06/24/2015 Return of Service Executed on 6/22/2015 in re property located at 1418 Dresden Drive, N.E., Number A310, Atlanta, Dekalb County, GA. (ddm) 06/24/2015 Return of Service Executed on 6/18/2015 in re property located at 4536 East Brookhaven Drive, 1 2 3 4 5 6 7 8 9 10 11 Case Number or Last, First
  • 50. Atlanta, Fulton and Dekalb Counties, Georgia. (ddm) 06/24/2015 Return of Service Executed on 6/18/2015 in re property located at 3464 Paces Place, N.W., Atlanta, Fulton County, GA. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015 in re property located at 2385 Heather Drive, Decatur, Dekalb County, Georgia. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015 in re The Real Property Located at 225 Valley Road, N.W., Atlanta, Fulton County, GA. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015, notice served upon Carole Laurette Shaw. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015, notice served upon Theresa D. and Frank M. Bell. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015, notice served upon East Brookhaven Holdings, LLC. (ddm) 06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon JS Real Estate Investments, LLC. (ddm) 06/24/2015 Return of Service Executed on 6/22/2015, as notice served upon Trinves LLC and/or Erica Nicole Leathers. (ddm) 06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon Shaw Alys Beach NN6 LLC (owner of 7 La Garza Court, Panama City Beach, FL). (ddm) 06/24/2015 Return of Service Executed on 6/18/2015, as notice served upon Shaw Alys Beach NN6 LLC (owner of 48 Shinbone Court, Panama City Beach, FL). (ddm) 07/07/2015 NOTICE Of Filing letter from non-party, Peter Kem Weber, Jr., dated June 30, 2015, regarding his transactions with defedant GID Partners, LLC. (ddm) 07/09/2015 Submission of 9 Parte Application for Arrest Warrants In Rem, submitted to District Judge Leigh Martin May. (ddm) 07/21/2015 CLAIM Verified by James S. Shaw. (Samuel, Donald) 07/21/2015 CLAIM Verified by Laurette Shaw. (Samuel, Donald) 07/21/2015 CLAIM Verified by Valley Trust. (Samuel, Donald) 07/21/2015 CLAIM of Frank Bell (Verified Claim) by 2385 Heather Drive, Decatur, Dekalb County, Georgia, All Right, Title and Interest of Frank Bell in Various Entities. (Danzig, Aaron) 07/21/2015 CLAIM of Theresa D. Bell (Verified Claim) by 2385 Heather Drive, Decatur, Dekalb County, Georgia, All Right, Title and Interest of Frank Bell in Various Entities. (Danzig, Aaron) 07/22/2015 CLAIM Verified by James S. Shaw. (Samuel, Donald) 07/22/2015 CLAIM Verified by Laurette Shaw. (Samuel, Donald) 07/23/2015 PROPOSED CONSENT ORDER Restraining Order. (Krepp, Thomas) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
  • 51. 07/24/2015 CONSENT RESTRAINING ORDER. Signed by Judge Leigh Martin May on 7/24/15. (ddm) 07/24/2015 ORDER denying as moot 9 Motion for Miscellaneous Relief. Entered by Judge Leigh Martin May on 07/24/2015. (LMM) 07/27/2015 NOTICE of Appearance by Erich N. Durlacher on behalf of Wells Fargo Bank, National Association (Durlacher, Erich) 07/27/2015 CLAIM Verified Claim to Contest Forfeiture by Wells Fargo Bank, National Association. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Durlacher, Erich) 07/30/2015 CLAIM Verified by Tyson Rhame. (Brown, Michael) 07/30/2015 NOTICE of Appearance by Michael L. Brown on behalf of Tyson Rhame (Brown, Michael) 07/30/2015 NOTICE of Appearance by Ankith Kamaraju on behalf of Tyson Rhame (Kamaraju, Ankith) 08/04/2015 Return of Service Executed on 7/20/2015 as to Defendant Property 48 Shinbone Court, Panama City, FL. (ddm) 08/04/2015 Return of Service Executed on 7/20/2015 as to Defendant Property 7 La Garza Court, Panama City, FL. (ddm) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank, NA (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Fulton County Tax Commissioner's Office (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Mortgage Electronic Registration Systems, Inc. (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to SunTrust Mortgage, Inc. (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to DeKalb County Tax Commissioner's Office (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to 1418 Dresden, LLC (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to EBSCO Gulf Coast Development, Inc. (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Walton County Tax Collector (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Alys Beach NN6, LLC (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Trinvest, LLC (Krepp, Thomas) 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48
  • 52. 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Alys Beach, LLC (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to JS Real Estate Investments, LLC (Krepp, Thomas) 08/05/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to East Brookhaven Holdings, LLC (Krepp, Thomas) 08/07/2015 MOTION to Intervene filed by Alison E. Shimer. (Attachments: # 1 Memorandum, # 2 Proposed Amended Complaint, # 3 Affidavit, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit 3, # 7 Exhibit 4, # 8 Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12 Exhibit 9, # 13 Exhibit 10, # 14 Exhibit 11, # 15 Certficate of Service)(ddm) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to SR Equipment Leasing (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sky Combat Blue, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Polaris Aviation, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Currency Group (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Online Processing Services (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Partners, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Alex Capital Holdings, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Lullwater Holdings, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Curtis Creek Holdings (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Springlake Trading, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Primestone Properties, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Northwest Capital (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Broadway Trader 4Z (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Yards at Noda, LlC (Krepp, Thomas) 49 50 51 96 52 53 54 55 56 57 58 59 60 61 62 63 64 65
  • 53. 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sherrills Ford Holdings (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Scotch Cove, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to RG Classics, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to iSolveIT.com, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterlingfunder, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR East Point Real Estate (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR Interactive Technologies, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sky Combat Red, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Cascades at Rea, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Arrowood Station Holdings (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Miracle Charters. LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to TR Real Estate, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Whistlejacket, Inc. (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to J-Brem, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Therrell Farms Estates (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Zonolite Holdings, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sustainability Solutions (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America Gvest Holdings, LLC (Krepp, Thomas) 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83
  • 54. 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Partners, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Capital, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to 200 West Land DST (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Primestone FifeCo Realty Fund (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Preferred Capital, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Recleim Group, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wingover Ranch (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Shaw Capita & Guaranty, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Trinvest Partners, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Levan Capital, LLC (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Bank of North Carolina (Krepp, Thomas) 08/10/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sabal Capital 3, LLC (Krepp, Thomas) 08/10/2015 Consent MOTION for Extension of Time to File Answer re 2 Amended Complaint, with Brief In Support by Frank Bell. (Attachments: # 1 Text of Proposed Order)(Sullivan, Sean) 08/10/2015 Consent MOTION for Extension of Time to File Answer re 2 Amended Complaint, with Brief In Support by Theresa D. Bell. (Attachments: # 1 Text of Proposed Order)(Sullivan, Sean) 08/11/2015 MINUTE ORDER granting 97 and 98 Motion for Extensions of Time to Answer. Claimants Frank and Theresa Bell shall have through and including September 11, 2015 to file a responsive pleading to Plaintiff's Complaint. Approved by Judge Leigh Martin May on 08/11/2015. (rvb) 08/11/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Brown, Michael) 08/12/2015 Return of Service Executed on 8/6/2015, as $52,195.55 was released to ALTUS GTS, Inc. (ddm) 08/12/2015 Return of Service Executed on 8/6/2015, as $35,723.26 was released to ADP, LLC. (ddm) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Bonnie Champagne (Krepp, Thomas) 84 85 86 87 88 89 90 91 92 93 94 95 97 98 99 100 101 102
  • 55. 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Frank Bell & Theresa D. Bell (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to James S. Shaw, Carol Laurette Shaw, Valley Trust, Shaw Irrevocable Trust, & Curtis Creek Holdings, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Tyson Rhame, The TAR Revocable Trust, Lullwater Trust, and Lullwater Holdings, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sterling Currency Group, Sterling Online Processing, GID Partners, LLC, and Alex Capital Holdings, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Gvest Holdings, LLC, Gvest Partners, LLC, and Gvest Capital, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Recleim Group, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank, National Association (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America Wingover Capital Management, LLC, aka, Wingover Capital, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Wells Fargo Bank, National Association, via Registered Agent (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Arrowood Station Holdings, LLC, aka, Arrowhead Station Holdings, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Natixis Real Estate Capital, LLC (Krepp, Thomas) 08/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to Sun Life Assurance Company of Canada (Krepp, Thomas) 08/13/2015 Request for Leave of Absence for the following date(s): September 25, 2015; September 28, 2015 through September 29, 2015; and October 15, 2015 through October 16, 2015, by Aaron M. Danzig. (Danzig, Aaron) 08/13/2015 Letter, dated August 10, 2015, from Robert A. Crystal regarding funds he paid to Sterling Currency Group. (ddm) 08/14/2015 NOTICE of Appearance by Allen Todd Sprinkle on behalf of Gvest Real Estate LLC, Raymond M Gee (Sprinkle, Allen) 08/14/2015 NOTICE Of Filing by Gvest Real Estate LLC Verified Claim of Gvest Real Estate LLC (Sprinkle, Allen) 08/14/2015 NOTICE Of Filing by Raymond M Gee Verified Claim of Raymond M. Gee (Sprinkle, Allen) 08/14/2015 Consent MOTION for Extension of Time to File Answer re 1 Complaint, 2 Amended Complaint, by Wells Fargo Bank, National Association. (Attachments: # 1 Exhibit A - Proposed Consent Order)(Durlacher, Erich) 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120
  • 56. 08/17/2015 ORDER granting 120 Consent Motion for Extension of Time to Answer re 2 Amended Complaint. Wells Fargo Bank, National Association Answer due 9/11/2015. Signed by Judge Leigh Martin May on 8/17/2015. (bdb) 08/17/2015 CONSENT ORDER for Stipulated Sale of Property that Tyson Rhame's and TR East Point's interests in Chattahoochee Place be sold by private, arms-length sale for $40,000 pursuant to a contract that currently exists between BJG Finance, LLC and TR East Point Real Estate, LLC; and it is further ORDERED, that upon the sale of Tyson Rhame's and TR East Point's interests in Chattahoochee Place, the proceeds of the sale, minus transactional expenses and fees approved by the United States Attorney's Office, shall be used (i) to allow TR East Point to pay insurance for TR East Point in the amount of $1,791.75 to Berkshire Hathaway Homestate Companies and (ii) to reimburse the Operating Partner (Carson Pickens) $6,751 for out- of-pocket expenses incurred in maintaining the property. Any remaining amounts shall be remitted to the United States Marshals Service, via wire transfer or via cashier's check mailed in care of the United States Attorney's Office, ATTN: Thomas J. Krepp, 75 Spring Street, S.W., Suite 600, Atlanta, Georgia 30303, to be deposited into the United States Marshals Seized Asset Deposit Account, an interest bearing account, and shall remain in the account pending the outcome of the civil forfeiture action; and it is further ORDERED, that all parties shall be responsible for their own costs and attorneys' fees incurred to effectuate this sale of Tyson Rhame's and TR East Point's interests in Chattahoochee Place and the disbursement of any proceeds of this sale to fund continued operations related to other above- styled assets. Signed by Judge Leigh Martin May on 8/17/2015. (bdb) 08/17/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 122 Order and 121 Order. (bdb) 08/17/2015 Notice for Leave of Absence for the following date(s): September 28, 2015 through and including October 2, 2015, by Donald Franklin Samuel. (Samuel, Donald) 08/17/2015 Letter from non-party Traci Black regarding business transactions with Sterling Currency Group. (ddm) 08/18/2015 Notice for Leave of Absence for the following date(s): From November 23, 2015 through and including November 27, 2015, by Donald Franklin Samuel. (Samuel, Donald) 08/24/2015 PROPOSED CONSENT ORDER for Stipulated Use of Funds. (Krepp, Thomas) 08/24/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Associates, LLC (Krepp, Thomas) 08/24/2015 Consent Order for Stipulated Use of Funds. Signed by Judge Leigh Martin May on 8/24/15. (ddm) 08/24/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 128 Order. (ddm) 08/24/2015 Certification of Consent to Substitution of Counsel. Dahil Dueno Goss replacing attorney Jenny R. Turner. (Goss, Dahil) 08/25/2015 Submission of 96 MOTION to Intervene, submitted to District Judge Leigh Martin May. (ddm) 08/26/2015 ANSWER to 1 COMPLAINT Verified Answer of Wells Fargo Bank, National Association to Amended Complaint for Forfeiture by Wells Fargo Bank, National Association. Discovery ends on 1/25/2016. (Durlacher, Erich) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 08/27/2015 MOTION for Extension of Time to File Consolidated Response to Various Attempts to Intervene by United States of America. (Attachments: # 1 Text of Proposed Order)(Goss, Dahil) 08/27/2015 ORDER granting 131 Plaintiff's Motion for Extension of Time, through September 11, 2015, to File Consolidated Response to Attempts to Intervene. Signed by Judge Leigh Martin May on 8/26/15. (ddm) 121 122 123 124 125 126 127 128 129 130 131 132
  • 57. 08/27/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 132 Order. (ddm) 08/28/2015 Letter from non-party Marilyn Grever regarding business transactions with Sterling Currency Group. (ddm) 08/31/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim as to Recleim Group LLC by Gvest Real Estate LLC. (Sprinkle, Allen) 09/02/2015 NOTICE of Appearance by Meredith Jones Kingsley on behalf of Tyson Rhame (Kingsley, Meredith) 09/02/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Brown, Michael) 09/03/2015 NOTICE of Appearance by Allen Todd Sprinkle on behalf of Gvest Partners LLC, Gvest Capital LLC (Sprinkle, Allen) 09/03/2015 Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 9/3/15. (ddm) 09/03/2015 RESPONSE in Opposition re 131 MOTION for Extension of Time to File Consolidated Response to Various Attempts to Intervene filed by Alison E. Shimer. (ddm) 09/04/2015 SERVICE by Publication filed by United States of America. Last publication date 09/03/2015. (Goss, Dahil) 09/04/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim as to Therrell Farms Estates LLC and Zonolite Holdings LLC by Gvest Real Estate LLC. (Sprinkle, Allen) 09/04/2015 ANSWER to 2 Amended Complaint by Gvest Real Estate LLC.(Sprinkle, Allen) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/04/2015 ANSWER to 2 Amended Complaint by Gvest Capital LLC.(Sprinkle, Allen) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/04/2015 ANSWER to 2 Amended Complaint by Gvest Partners LLC.(Sprinkle, Allen) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/04/2015 ANSWER to 2 Amended Complaint by Raymond M Gee.(Sprinkle, Allen) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/08/2015 PROPOSED CONSENT ORDER Permitting Disbursement of Seized Funds. (Samuel, Donald) 09/09/2015 CONSENT ORDER PERMITTING DISBURSEMENT OF SEIZED FUNDS : It is hereby ordered that the United States release $4,237,500.00 from Merrill Lynch Primestone Properties, LLC account XXX2391 to Wells Fargo Bank N.A., Account Number XXX720. In consideration for the United States' agreement to transfer these funds, Claimant Shaw agrees to make good faith efforts to sell one Cessna Citation XLS airplane (serial number 560-5623), which is currently named as forfeitable property in the first civil forfeiture action. See 1: 15-CV-2032-LMM (Doc. 2). It is therefore further ordered that Claimant Shaw will use his good faith efforts to sell this airplane. See Order for additional information. Signed by Judge Leigh Martin May on 9/9/2015. (anc) 09/09/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 147 Order of Disbursement/Distribution of Funds (anc) 09/09/2015 CLAIM Verified by James S. Shaw. (Attachments: # 1 Exhibit A)(Samuel, Donald) 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148
  • 58. 09/10/2015 CLAIM Verified by Laurette Shaw. (Attachments: # 1 Exhibit A)(Samuel, Donald) 09/10/2015 NOTICE of Appearance by David M. Lilenfeld on behalf of All Right, Title and Interest of GID Partners, LLC in Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities, All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities (Lilenfeld, David) 09/10/2015 NOTICE of Appearance by Kaitlyn Anne Dalton on behalf of All Right, Title and Interest of GID Partners, LLC in Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities, All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities (Dalton, Kaitlyn) 09/10/2015 CLAIM by All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities. (Lilenfeld, David) 09/10/2015 CLAIM by All Right, Title and Interest of GID Partners, LLC in Various Entities. (Lilenfeld, David) 09/10/2015 CLAIM by All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities. (Lilenfeld, David) 09/10/2015 CLAIM Verified by Tyson Rhame. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Brown, Michael) 09/11/2015 ANSWER to 2 Amended Complaint by James S. Shaw, Laurette Shaw.(Samuel, Donald) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/11/2015 ANSWER to 2 Amended Complaint, filed by Frank Bell. (Danzig, Aaron) Modified on 9/11/2015 to edit text (ddm). 09/11/2015 ANSWER to 2 Amended Complaint, filed by Theresa D. Bell. (Danzig, Aaron) Modified on 9/11/2015 to edit text (ddm). 09/11/2015 RESPONSE re 96 MOTION to Intervene and Opposition to Correspondence Seeking to Intervene filed by United States of America. (Krepp, Thomas) 09/11/2015 Verified ANSWER to 2 Amended Complaint by All Right, Title and Interest of GID Partners, LLC in Various Entities, All Right, Title and Interest of Sterling Currency Group, LLC in Various Entities, All Right, Title and Interest of Sterling Online Processing Services, LLC in Various Entities.(Lilenfeld, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/11/2015 PARTIAL WITHDRAWAL of Claim re 118 Notice of Filing Verified Claim with Respect to Sherrills Ford Holdings LLC by Gvest Real Estate LLC. (Sprinkle, Allen) 09/11/2015 ANSWER to 2 Amended Complaint by Tyson Rhame.(Brown, Michael) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/14/2015 Partial WITHDRAWAL of Claim re 155 Claim with respect to Gvest Holdings LLC, Gvest Partners LLC, and Gvest Capital LLC by Tyson Rhame. (Brown, Michael) 09/15/2015 CLAIM Verified by Sabal Capital 3, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C) (Stewart, David) 09/15/2015 NOTICE of Appearance by David Mitchell Stewart on behalf of Sabal Capital 3, LLC (Stewart, David) 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165
  • 59. 09/15/2015 NOTICE of Appearance by Michael L. Brown on behalf of Ronald Green (Brown, Michael) 09/15/2015 CLAIM Verified by Ronald Green. (Brown, Michael) 09/16/2015 REPLY to Response to Motion re 96 MOTION to Intervene filed by Alison E. Shimer. (ddm) 09/18/2015 NOTICE of Appearance by Sharon Audrey Israel on behalf of Sun Life Assurance Company of Canada (Israel, Sharon) 09/18/2015 CLAIM (Verified Claim) by Sun Life Assurance Company of Canada. (Israel, Sharon) 09/18/2015 ANSWER to 2 Amended Complaint by Sun Life Assurance Company of Canada.(Israel, Sharon) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 09/18/2015 NOTICE Of Filing Certificate of Service Showing Mailing of Plaintiff's Opposition to Attempts to Intervene to non-party files by United States of America re 159 Response to Motion (Attachments: # 1 Exhibit) (Krepp, Thomas) 09/18/2015 NOTICE by James S. Shaw re 148 Claim Partial Withdrawal of Verified Claim of GVEST Real Estate LLC with Respect to Sherrills Ford Holdings LLC (Samuel, Donald) 09/21/2015 NOTICE by James S. Shaw re 148 Claim Amended Notice of Partial Withdrawal of Verified Claim of James Shaw With Respect To Gvest Capital LLC (Samuel, Donald) 09/21/2015 Letter from non-party Jo Midgley regarding business transactions with Sterling Currency Group. (ddm) 09/24/2015 NOTICE of Appearance by Erich N. Durlacher on behalf of Wells Fargo Advisors, LLC (Durlacher, Erich) 09/24/2015 Consent MOTION for Extension of Time to Allow Wells Fargo Advisors, LLC Additional Time to File Verified Claim and Respond to Plaintiff's Complaint re: 1 Complaint, 2 Amended Complaint, by Wells Fargo Advisors, LLC. (Attachments: # 1 Text of Proposed Order Proposed Consent Order)(Durlacher, Erich) 09/24/2015 ORDER granting 177 Consent Motion for Extension of Time, through and including October 15, 2015, to Allow Wells Fargo Advisors, LLC Additional Time to File Verified Claim and Respond to Plaintiff's Complaint 1 Complaint, Amended Complaint 2 . Signed by Judge Leigh Martin May on 9/24/15. (ddm) 09/25/2015 MOTION to Stay Proceedings by United States of America. (Krepp, Thomas) 09/25/2015 Letter from non-party Walter Midgley regarding business transactions with Sterling Currency Group. (ddm) 09/28/2015 NOTICE Of Filing Certificate of Service for U.S. Opposition to Attempts to Intervene filed on non- party filers by United States of America re 159 Response to Motion (Krepp, Thomas) 10/05/2015 NOTICE of Appearance by David John Forestner on behalf of Ronald Green (Forestner, David) 10/05/2015 Verified Claim of Ronald G. Green by Ronald Green. (Forestner, David) Modified on 10/5/2015 to edit docket text to match description of pleading (ryc). 10/05/2015 ANSWER to 2 Amended Complaint by Sabal Capital 3, LLC.(Stewart, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 10/05/2015 Letter from non-party Laurel Buescher regarding business transactions with Sterling Currency 166 167 168 169 170 171 172 173 174 175 176 177 178 179 181 180 182 183 184 185
  • 60. Group and request for release of non-party's property. (jtj) 10/06/2015 APPLICATION for Admission of Adam P. Schwartz Pro Hac Vice (Application fee $ 150, receipt number 113E-6081925)by Ronald Green. (Forestner, David) 10/06/2015 ANSWER to 2 Amended Complaint Ronald G. Green's Answer to Plaintiff's Amended Verified Complaint by Ronald Green.(Forestner, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 10/07/2015 APPLICATION for Admission of Stephanie E. Ambs Pro Hac Vice (Application fee $ 150, receipt number 113E-6084956)by Ronald Green. (Forestner, David) 10/13/2015 NOTICE Of Filing Complaint for Forfeiture by United States of America to GID Associates, LLC (Krepp, Thomas) 10/14/2015 ORDER granting 179 Motion to Stay. The Clerk is DIRECTED to ADMINISTRATIVELY CLOSE these matters pending the stay. The Government is also DIRECTED to file status reports under seal every 90 days, advising the status of the criminal investigation and whether the stays are still warranted. It is also ORDERED that these stays do not impact the filing of any future consent orders for stipulated sale or consent orders for stipulated use of funds that the parties may wish to file in order to preserve or liquidate the assets listed in the complaints. Signed by Judge Leigh Martin May on 10/14/15. (jpa) 10/14/2015 Civil Case Terminated. (jpa) 10/14/2015 Clerks Certificate of Mailing as to Alison E. Shimer re 190 Order. Notice of street name change for the Atlanta courthouse included. (jpa) 10/14/2015 ANSWER to 2 , 1 Amended Complaint , ANSWER to 2 , 1 COMPLAINT by SterlingFunder LLC. (Lilenfeld, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 10/14/2015 CLAIM Verified by SterlingFunder LLC. (Lilenfeld, David) 10/14/2015 NOTICE Of Filing Certificate of Service by United States of America re 159 Response to Motion Served on Non-Parties (Krepp, Thomas) 10/15/2015 Verified ANSWER to 2 Amended Complaint for Forfeiture by Wells Fargo Advisors, LLC. (Durlacher, Erich) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 10/21/2015 Return of Service Executed on 10/19/2015, as $28,556.85 was taken custody of and deposited. (ddm) 10/26/2015 ANSWER to 2 Amended Complaint by "GID Associates".(Lilenfeld, David) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 10/28/2015 NOTICE Of Filing Certificate of Service Plaintiff's Opposition to Attempts to Intervene by United States of America (Krepp, Thomas) 11/02/2015 CLAIM filed by F. Lorenzo Crutchfield, Jr. (kdw) 11/03/2015 PROPOSED CONSENT ORDER For Stipulated Sale of Property re: 147 Order of Disbursement/Distribution of Funds,,,. (Samuel, Donald) 11/03/2015 CLAIM by "GID Associates". (Attachments: # 1 Exhibit A-Tradename Registration)(Lilenfeld, David) 11/03/2015 CONSENT ORDER FOR STIPULATED SALE OF PROPERTY signed by Judge Leigh Martin May 186 187 188 189 190 191 192 193 194 195 196 197 201 198 199 200
  • 61. on 11/3/15. (kdw) 11/04/2015 Clerk's Certificate of Mailing as to Alison E. Shimer re 200 Order. Notice of street name change for the Atlanta courthouse included. (kdw) 11/09/2015 Letter from non-party Louis Gonzales regarding business transactions with Sterling Currency Group. (ddm) 11/12/2015 NOTICE Of Filing Amended Complaint for Forfeiture by United States of America to KEYCORP (Krepp, Thomas) 11/27/2015 NOTICE of Appearance by Kelly Kathleen Connors on behalf of United States of America (Connors, Kelly) 12/01/2015 Letter from non-party Lorenzo Crutchfield regarding business transactions with Sterling Currency Group. (ddm) 12/08/2015 NOTICE Of Filing by United States of America re 159 Response to Motion Certificate of Service of U.S. Response to Opposition to Attempts to Intervene Served on Non-Party Filers (Krepp, Thomas) 12/10/2015 PROPOSED CONSENT ORDER For stipulated sale of property. (Brown, Michael) 12/11/2015 CONSENT ORDER FOR STIPULATED SALE OF PROPERTY signed by Judge Leigh Martin May on 12/11/15. (kdw) 12/11/2015 Clerk's Certificate of Mailing as to Alison E. Shimer re 208 Order. Notice of street name change for the Atlanta courthouse included. (kdw) 12/11/2015 Clerk's Certificate of Mailing as to F. Lorenzo Crutchfield, Jr re 208 Order. Notice of street name change for the Atlanta courthouse included. (kdw) 12/16/2015 Verified ANSWER to 2 Amended Complaint by The Real Property Located at 225 Valley Road, N.W., Atlanta, Fulton County, GA.(Fox, James) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 12/29/2015 CLAIM Verified by Suntrust Mortgage, Inc.. (Attachments: # 1 Exhibit 1 - Note, # 2 Exhibit 2 - Security Deed)(Davey, Melissa) 12/29/2015 Verified ANSWER to 2 Amended Complaint for Forfeiture by Suntrust Mortgage, Inc..(Davey, Melissa) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. 01/08/2016 Notice for Leave of Absence for the following date(s): February 5, 2016; February 12, 2016; February 19, 2016; March 2-4, 2016; March 25, 2016; and April 4-8, 2016, by Aaron M. Danzig. (Danzig, Aaron) 01/14/2016 ---FILED UNDER SEAL PER 179 --- STATUS REPORT filed by United States of America. (kdw) (kdw). 01/19/2016 NOTICE Of Filing Copy of motion served on non-party filers by United States of America re 159 Response to Motion (Krepp, Thomas) 02/08/2016 NOTICE of Appearance by Robert Daniel Douglass on behalf of Suntrust Mortgage, Inc. (Douglass, Robert) 02/09/2016 Letter from non-party, Sharon Marie Stahlsmith, regarding business transactions with Sterling 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216
  • 62. Currency Group, LLC. (Attachments: # 1 Exhibits A - E) (jtj) 02/22/2016 MOTION to Lift Stay for the Limited Purpose of Filing Amended Complaint , MOTION for Leave to File Amended Complaint for Forfeiture by United States of America. (Attachments: # 1 Exhibit proposed Amended Complaint for Forfeiture, # 2 Exhibit A - K to proposed Amended Complaint for Forfeiture)(Connors, Kelly) 02/24/2016 NOTICE Of Filing by United States of America re 217 MOTION to Lift Stay for the Limited Purpose of Filing Amended Complaint MOTION for Leave to File Amended Complaint for Forfeiture Served on Non- ECF Filers (Attachments: # 1 Exhibit List of People Served)(Connors, Kelly) 03/11/2016 Submission of 217 MOTION to Lift Stay for the Limited Purpose of Filing Amended Complaint, MOTION for Leave to File Amended Complaint for Forfeiture, submitted to District Judge Leigh Martin May. (ddm) 03/15/2016 ORDER granting 217 Motion to Lift Stay for the Limited Purpose of Filing Amended Complaints; granting 217 Motion for Leave to File Amended Complaints. Entered by Judge Leigh Martin May on 03/15/2016. (LMM) 03/15/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property. (Kamaraju, Ankith) 03/15/2016 CONSENT ORDER for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 3/15/2016. (tcc) 03/15/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 220 Order. (tcc) 04/08/2016 PROPOSED CONSENT ORDER Modifying Restraining Order. (Kamaraju, Ankith) 04/11/2016 CONSENT ORDER MODIFYING RESTRAINING ORDER. Signed by Judge Leigh Martin May on 4/11/16. (kdw) 04/11/2016 Clerk's Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 222 Order. Notice of street name change for the Atlanta courthouse included. (kdw) 04/13/2016 (FILED UNDER SEAL) STATUS REPORT filed by United States of America. (dfb) 04/25/2016 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo by Tyson Rhame, James S. Shaw. (Samuel, Donald) 05/09/2016 Unopposed MOTION for Extension of Time To File Government's Response To Claimant's Motion re: 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo by United States of America. (Attachments: # 1 Text of Proposed Order)(Connors, Kelly) 05/09/2016 ORDER granting 225 Unopposed Motion for Extension of Time, through May 13, 2016, To File Government's Response To Claimant's Motion to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo 224 . Signed by Judge Leigh Martin May on 5/9/16. (ddm) 05/13/2016 RESPONSE re 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo filed by United States of America. (Connors, Kelly) 05/26/2016 Consent MOTION for Extension of Time Extension of Time for Claimant to File Reply to Government's Response to Claimants' Motion to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo by Tyson Rhame, James S. Shaw. (Samuel, Donald) 217 218 219 220 221 222 223 224 225 226 227 228
  • 63. 05/27/2016 ORDER GRANTING 228 Motion for Extension of Time For Claimant to File a Reply to Government's Response to Claimants' Motion to Apply Seized Funds to Payment of Overdue Payment to W ells Fargo. Signed by Judge Leigh Martin May on 5/27/2016. (jtj) 05/27/2016 Clerk's Certificate of Mailing to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 229 Order. (jtj) 05/31/2016 REPLY to Response to Motion re 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo filed by Tyson Rhame, James S. Shaw. (Samuel, Donald) 06/03/2016 Submission of 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo , submitted to District Judge Leigh Martin May. (ddm) 06/03/2016 NOTICE of Hearing on Motion re: 224 MOTION to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo . A Motion Hearing is set for 6/15/2016 at 02:00 PM in ATLA Courtroom 2107 before Judge Leigh Martin May. (rvb) 06/03/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re Notice of Hearing on Motion. (rvb) 06/14/2016 MOTION for Order of Sale OF CASCADES AT REA PROPERTY with Brief In Support by Sabal Capital 3, LLC. (Attachments: # 1 Text of Proposed Order)(Stewart, David) 06/22/2016 MINUTE ORDER DIRECTING the Government to file a response by July 1, 2016 to Claimant Sabal Capital 3, LLC's 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY. Approved by Judge Leigh Martin May on 06/22/2016. (rvb) 06/23/2016 Notice for Leave of Absence for the following date(s): August 22, 2016 through September 2, 2016, by Kelly Kathleen Connors. (Connors, Kelly) 06/23/2016 Notice for Leave of Absence for the following date(s): July 18, 2016 through August 2, 2016, by David Mitchell Stewart. (Stewart, David) 06/24/2016 PROPOSED CONSENT ORDER for stipulated sale of property. (Kamaraju, Ankith) 06/24/2016 Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 6/24/16. (ddm) 06/24/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 235 Order. Notice of street name change for the Atlanta courthouse included. (ddm) 06/28/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property re: 235 Order. (Kamaraju, Ankith) 06/28/2016 Amended Consent Order for Stipulated Sale of Property. Signed by Judge Leigh Martin May on 6/28/16. (ddm) 06/28/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 237 Order. Notice of street name change for the Atlanta courthouse included. (ddm) 07/01/2016 RESPONSE re 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY filed by United States of America. (Connors, Kelly) 07/11/2016 MOTION for Extension of Time File a Response re: 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY by Tyson Rhame. (Kamaraju, Ankith) 229 230 231 232 233 234 235 236 237 238 239
  • 64. 07/13/2016 RESPONSE re 239 MOTION for Extension of Time File a Response re: 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY filed by Sabal Capital 3, LLC. (Stewart, David) 07/15/2016 ORDER granting 239 Motion for Extension of Time, through and including July 25, 2016, to respond re 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY. Signed by Judge Leigh Martin May on 7/15/16. (hfm) 07/20/2016 PROPOSED CONSENT ORDER For Stipulated Sale of Property (Amended). (Connors, Kelly) 07/20/2016 AMENDED CONSENT ORDER FOR STIPULATED SALE OF PROPERTY. Signed by Judge Leigh Martin May on 07/20/2016. (rvb) 07/25/2016 Second MOTION for Extension of Time re: 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY by Tyson Rhame. (Kamaraju, Ankith) 07/26/2016 Submission of 231 MOTION for Order of Sale, 244 Second MOTION for Extension of Time re: 231 MOTION for Order of Sale, submitted to District Judge Leigh Martin May. (hfm) 07/26/2016 Notice for Leave of Absence for the following date(s): November 21, 2016 through and including November 25, 2016, by Donald Franklin Samuel. (Samuel, Donald) 07/29/2016 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by Tyson Rhame. (Kamaraju, Ankith) 07/29/2016 Withdrawal of Motion 244 Second MOTION for Extension of Time re: 231 MOTION for Order of Sale OF CASCADES AT REA PROPERTY filed by Tyson Rhame filed by Tyson Rhame. (Kamaraju, Ankith) 08/02/2016 Notice for Leave of Absence for the following date(s): September 21, 2016 through September 23, 2016, by Kelly Kathleen Connors. (Connors, Kelly) 08/10/2016 MOTION for Extension of Time To File Government's Response To Claimant's Motion re: 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by United States of America. (Attachments: # 1 Text of Proposed Order)(Connors, Kelly) 08/11/2016 ORDER granting 249 Motion for Extension of Time until a date set by the Court at the conclusion of the pending status conference, re 246 MOTION for Order. Signed by Judge Leigh Martin May on 8/10/16. (hfm) 08/11/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 250 Order on Motion for Extension of Time. (hfm) 08/11/2016 MOTION for Extension of Time To File Response to Claimant's Motion re: 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by Gvest Real Estate LLC. (Attachments: # 1 Text of Proposed Order Proposed Order)(Sprinkle, Allen) 08/11/2016 MOTION for Extension of Time to File Response re: 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC by Sabal Capital 3, LLC. (Attachments: # 1 Text of Proposed Order)(Stewart, David) 08/15/2016 Minute Entry for proceedings held before Judge Leigh Martin May: Telephone Conference held on 8/15/2016. The Court orally GRANTED Gvest Real Estate LLC's and Raymond Gee's 251 Motion to Extend Time to File Response to Claimant's Motion and GRANTED Sabal Capital 3, LLC's 252 Motion to Extend Time to File Response to Claimant Rhame's Motion. The United States of America, Sabal Capital 3, LLC, Gvest Real Estate LLC and Raymond Gee shall have until August 29, 2016 to file a response to Tyson Rhame's 246 Motion to Apply Seized Funds to Satisfy Sabal Capital 3, LLC's Note. In addition to the response, the parties 240 241 242 243 244 245 246 247 248 249 250 251 252 253
  • 65. shall each file a proposed orders and any objections/concerns with language contained in opposing parties' proposed orders. Claimant Rhames shall have until noon on Wednesday, August 17, 2016 to file any additional information in support of his motion. Counsel for the United States of America was DIRECTED to follow up on a proposed order in the companion case 1:15-cv-2677-LMM regarding the 216 Motion to Apply Seized Funds to Payment of Overdue Payment to Wells Fargo. (Court Reporter Montrell Vann)(hfm) 08/17/2016 NOTICE Of Filing by Tyson Rhame re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC Supplemental Brief in Support (Attachments: # 1 Exhibit 1) (Kamaraju, Ankith) 08/29/2016 REPLY BRIEF re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC filed by Raymond M Gee, Gvest Real Estate LLC. (Attachments: # 1 Text of Proposed Order Proposed Order)(Sprinkle, Allen) 08/29/2016 RESPONSE in Opposition re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC filed by United States of America. (Attachments: # 1 Exhibit A) (Connors, Kelly) 08/29/2016 RESPONSE re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC filed by Sabal Capital 3, LLC. (Attachments: # 1 Text of Proposed Order)(Stewart, David) 08/30/2016 Submission of 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC, submitted to District Judge Leigh Martin May. (hfm) 09/15/2016 REPLY BRIEF re 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC filed by Tyson Rhame. (Kamaraju, Ankith) 09/19/2016 Submission of 246 MOTION for Order to Apply Seized Funds to Payment of Overdue Note to Sabal Capital 3, LLC, submitted to District Judge Leigh Martin May. (hfm) 09/21/2016 ORDER granting 231 Motion for Order of Sale; denying 246 Motion for Order. If the parties have any objections to this language, they must file their objections within seven days of the date of this Order. Additionally, if the parties have objections to the description of the Cascades at Rea Property in footnote two, or want the more fully detailed description provided in Sabal'sProposed Order, Dkt. No. [257-1], they must file their objections within seven days of the date of this Order. Signed by Judge Leigh Martin May on 9/21/16. (hfm) 09/23/2016 NOTICE of Appearance by Lex M. Erwin on behalf of Cluck Design Collaborative, PLLC (Erwin, Lex) 09/23/2016 CLAIM Verified by Cluck Design Collaborative, PLLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Erwin, Lex) 10/04/2016 Submission of 259 Order, submitted to District Judge Leigh Martin May. (hfm) 10/05/2016 ORDER re Sale of Cascades at Rea Property. Signed by Judge Leigh Martin May on 10/4/16. (hfm) 10/05/2016 Clerks Certificate of Mailing as to F. Lorenzo Crutchfield, Jr, Alison E. Shimer, Sharon Marie Stahlsmith re 262 Order. (hfm) 254 255 256 257 258 259 260 261 262
  • 66. Case 1:15-cv-02032-LMM Document 1-12 Filed 06/05/15 Page 1 of 2
  • 67. Case 1:15-cv-02032-LMM Document 1-12 Filed 06/05/15 Page 2 of 2