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Guru Revaluation Scam - Sterling Currency Group

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Iraqi Dinar Guru TerryK of the Get Team and Sterling Currency Group Court Documents for Case 1:16-cr-00067-SCJ-CMS - Dinar Revaluation News Updates on Scam. Dinar RV News

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Guru Revaluation Scam - Sterling Currency Group

  1. 1. ORIGINAL IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION FILED IN OPEN COURT FEB 1 « 2016 James i. utnin:;,. •.. ici"k U N I T E D S T A T E S OF A M E R I C A IK T Y S O N R H A M E T E R R E N C E K E L L E R , A K A T E R R Y K , j A M E S S H A W F R A N K B E L L Criminal Indictment No. 1:16CR67 UNDER SEAL THE GRAND JURY CHARGES THAT: Count One Conspiracy to Commit Mail Fraud and Wire Fraud (18 U.S.C. § 1349) 1. Beginning in or about 2010, and continuing to on or about June 3, 2015, in the Northern District of Georgia and elsewhere, the defendants, TYSON RHAME, TERRENCE KELLER, also known as TerryK, JAMES SHAW, and FRANK BELL, did knowingly and willfully combine, conspire, confederate, agree and have a tacit understanding with each other and with others, both known and unknown to the Grand Jury, to devise and intend to devise a scheme and artifice to defraud, and to obtain money and property, by means of materially false and fraudulent pretenses, representations, and promises, and by the omissions of material facts, well knowing and having reason to know that said pretenses were and would be false and fraudulent when made and caused to be made and that said omissions were and would be materiaL and, in so Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 1 of 41
  2. 2. doing, caused the United States Postal Service and other interstate carriers to be used, and interstate wire communications to be made, in furtherance of the scheme and artifice to defraud, in violation of Title 18, United States Code, Sections 1341 and 1343. Background It is relevant to this Indictment that during the time period of the conspiracy: 2. Sterling Currency Group, LLC, which also did business as Sterling Online Processing Services, LLC, and Dinar Banker (collectively, "Sterling"), was a Georgia corporation with its principal place of business in Atlanta, Georgia. Sterling sold and exchanged so-called "exotic currencies", including most predominantly the currency for the country of Iraq, the Iraqi dinar. 3. TYSON RHAME and JAMES SHAW were co-owners of Sterling, which began operations in 2004. FRANK BELL began working for Sterling in 2010 and became Sterling's Chief Operating Officer in 2011. 4. During the course of the conspiracy. Sterling grossed over $600 million in revenue from the sale of Iraqi dinar and other currencies. During this time period, RHAME and SHAW received over $180 million in distributions from Sterling. Sterling's sales were primarily derived from three sources: (1) dinar and other currency sales to individual customers, (2) non-refundable and refundable "layaway orders" whereby customers could put a percentage of money down for the full purchase price of the dinar and other currency, and (3) orders from entities that purchased the dinar and other currencies in bulk (who 2 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 2 of 41
  3. 3. were, at various times of the conspiracy, referred to as "high-value customers", "high-risk customers", "resellers", and "agents"). 5. "The GET Team" was the trade name for a group of individuals, led by TERRENCE KELLER, also known as TerryK, who ran a website, an internet chat forum and weekly conference calls in which, among other things, information was disseminated to participants concerning the potential investment value of the Iraqi dinar. KELLER maintained operational control over The GET Team, including its finances and revenue, through a Kentucky corporation named "TCB Group." Manner and Means 6. During the time period of the conspiracy, the Iraqi dinar was touted by some as a potential investment opportunity. For example, in 2010, Sterling's website, which contained videos featuring RHAME and articles written by RHAME, described the potential for the Iraqi dinar to increase in value. Additionally, information publicly available on certain internet websites, blogs, chat rooms, and conference calls fueled the speculation by predicting that a "revaluation" of the Iraqi dinar would occur imminently. A "revaluation" or "RV", in this context, meant a sudden, exponential rise in value of the Iraqi dinar as compared to the U.S. dollar and other relatively stable global currencies. Individuals who owned Iraqi dinar would realize potentially enormous gains if an "RV" ever occurred in this manner. 3 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 3 of 41
  4. 4. 7. TERRENCE KELLER, through The GET Team, was one of the leading internet-based proponents of the "RV" theory. On The GET Team's website, internet chat forum, and on weekly conference calls, KELLER falsely claimed to have information from, and verified by, high-level confidential sources in the United States government, the Iraqi government, international organizations, and major financial institutions, regarding an imminent "RV." 8. Sterling was one of the largest sellers and currency exchangers of the Iraqi dinar in the United States. Beginning at least as early as 2010, Sterling's business revenue was driven in part by the investment advice touted by TERRENCE KELLER and others, both on the internet and on participating conference calls. In fact, TYSON RHAME, JAMES SHAW, and FRANK BELL, through Sterling, began advertising with The GET Team through a web banner placed on The GET Team's website. A Sterling representative also participated in The GET Team's internet forum and on conference calls with followers. At various times, RHAME and BELL personally participated in The GET Team's conference calls. Followers of The GET Team were on occasion offered a discount coupon and sale price to purchase Iraqi dinar from Sterling. 9. TERRENCE KELLER induced followers of The GET Team into believing his claims about the imminent "RV" of the Iraqi dinar, and about his access to high-level confidential sources, by making material misrepresentations and by omissions of material facts. For instance, KELLER did not have information from, or contact with, high-level confidential sources. Additionally, KELLER 4 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 4 of 41
  5. 5. claimed directly and indirectly to followers of The GET Team that he had no financial or other ulterior motive to promote the Iraqi dinar as an investment, but rather, that he was simply disseminating his knowledge and information so that others could benefit from it as well. Religious and patriotic themes were often interwoven into The GET Team's conference calls and internet forums, further solidifying the perception that KELLER was honest, credible and could be trusted. 10. In truth, TERRENCE KELLER had a secret arrangement with TYSON RHAME, JAMES SHAW and FRANK BELL to promote and "pump" the Iraqi dinar in exchange for payments made by Sterling to benefit KELLER. KELLER, RHAME, SHAW, and BELL knew and believed that representations concerning an imminent "RV" of the Iraqi dinar, particularly claims that the information came from one or more supposed high-level confidential sources, would boost sales for Sterling. 11. TERRENCE KELLER affirmatively told his followers that he did not make substantial profits from his dealings with Sterling and other dinar dealers. In actuality, since at least as early as August 2011, Sterling paid KELLER over $160,000. Additionally, since Sterling's partnership with KELLER began in late 2010, KELLER received dinar specials, extensions on layaway sales, and other material benefits from Sterling. Separate from this, KELLER received over $100,000 from at least one other dinar dealer. KELLER consistently downplayed all of these financial benefits to his followers and listeners. 5 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 5 of 41
  6. 6. 12. The correlation between Sterling's increased sales and TERRENCE KELLER'S promotion and "pump" of the Iraqi dinar was further cemented by the presence of a Sterling representative and other dinar dealer representatives, including, at times, TYSON RHAME and FRANK BELL, on The GET Team's conference calls and internet forums. At various times, RHAME, BELL and other Sterling representatives participated in conference calls and internet forums in which KELLER made representations to followers concerning the imminent Iraqi dinar "RV", his access to high-level confidential sources, and claims that he was just trying to be helpful and received no financial benefit for providing this information to others. 13. The presence and participation of TYSON RHAME, FRANK BELL, and other Sterling representatives on The GET Team's conference calls and internet forums provided further validation to followers that KELLER's claims about an imminent "RV" of the Iraqi dinar should be believed. While making no direct representations about the likelihood of an "RV" themselves or offering investment advice to potential investors, RHAME, BELL, and other Sterling representatives assured listeners on The GET Team's conference calls that Sterling was prepared to handle the high volume of Iraqi dinar exchanges that many investors expected would occur immediately after the "RV." 6 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 6 of 41
  7. 7. 14. Since at least as early as 2011, RHAME, SHAW, AND BELL established financial relationships with additional promoters, both known and unknown to the Grand Jury, who promoted the notion of an Iraqi dinar revaluation. 15. TYSON RHAME, JAMES SHAW, and FRANK BELL knew and believed that many of Sterling's customers relied upon information from TERRENCE KELLER and these other promoters when making investment decisions regarding the Iraqi dinar, and that much of the information being disseminated by KELLER and the other promoters was materially false. For one, RHAME, SHAW, and BELL never believed that KELLER or the other dinar promoters had the types of high-level sources they repeatedly claimed to have. Furthermore, at the same time that RHAME, SHAW, and BELL told their employees not to speculate or offer investment advice to customers, they knew that KELLER and the other promoters would continue to spread false information about the dinar. 16. TYSON RHAME, JAMES SHAW, and FRANK BELL knew and believed that the pumping activities of TERRENCE KELLER and other dinar promoters (who were oftentimes called "bloggers") were essential to Sterling's financial success. In November 2010, SHAW told an individual that Sterling was the "second largest in US but have been making ground up as we now have the bloggers singing our praises. Almost a little cult like." In December 2010, RHAME told colleagues that KELLER and the GET Team "push 80% of our business these days." By December 2011, the relationship with KELLER had 7 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 7 of 41
  8. 8. grown so strong that, in an internal Sterling email, BELL referred to The GET Team as Sterling's "largest referrer." RHAME, SHAW, and BELL knew and believed that the relationships with KELLER and the other dinar promoters continued to generate Sterling millions of dollars in dinar and other currency sales throughout the course of the conspiracy. All in violation of Title 18, United States Code, Section 1349. Counts Two Through Seven Mail Fraud (18 U.S.C. §§ 1341 and 2) 17. The Grand Jury re-alleges and incorporates herein by reference the factual allegations set forth in paragraphs 2-16. 18. On or about the dates listed below, within the Northern District of Georgia, the defendants, TYSON RHAME, TERRENCE KELLER, also known as TerryK, JAMES SHAW, and FRANK BELL, aided and abetted by each other and others known and unknown to the Grand Jury, for the purpose of executing and attempting to execute the above-described scheme and artifice to defraud, knowingly and willfully caused to be delivered the following mailings to the Sterling customers identified by initials below, by the Postal Service and by private and commercial interstate carrier: 8 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 8 of 41
  9. 9. Count Date (On or about) Mailing 2 4/29/2011 Money Order for $489.00 mailed from J.H. to Sterling 3 8/22/2011 Money Order for $303.00 mailed from R.G. to Sterling 4 9/29/2011 Money Order for $2,380.00 mailed from K.C. to Sterling 5 5/8/2012 Cashier's check for $2,845.00 mailed from R.W. to Sterling 6 9/4/2012 Cashier's check for $120.00 mailed from L.B. to Sterling 7 10/8/2014 Cashier's check for $1,165.00 mailed from M.G. to Sterling All in violation of Title 18, United States Code, Sections 1341 and 2. Counts Eight Through Eleven Wire Fraud (18 U.S.C. §§ 1343,1349, and 2) 19. The Grand Jury re-alleges and incorporates herein by reference the factual allegations set forth in paragraphs 2-16. 20. On or about the dates listed below, within the Northern District of Georgia, the defendants, TYSON RHAME, TERRENCE KELLER, also known as TerryK, JAMES SHAW, and FRANK BELL, aided and abetted by each other and others known and unknown to the Grand Jury, for the purpose of executing and attempting to execute the above-described scheme and artifice to defraud. 9 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 9 of 41
  10. 10. knowingly and willfully caused the following wire communications to be transmitted in interstate commerce: Count Date Wire Communication 8 7/11/2011 Wire transfer of $1,089.00 from A.L. to Sterling 9 08/11/2011 Wire teansfer of $2,402.00 from L.P. to Sterling 10 1/10/2012 Wire transfer of $11,370 from D.G. to Sterling 11 5/14/2015 Wire transfer of $480 from K.H. to Sterling All in violation of Title 18, United States Code, Sections 1343,1349, and 2. Count Twelve Money Laundering Conspiracy (18 U.S.C. § 1956(h)) 21. The Grand Jury re-alleges and incorporates herein by reference the factual allegations set forth in paragraphs 2-16. 22. Beginning in or about 2010, and continuing to on or about June 3, 2015, in the Northern District of Georgia and elsewhere, the defendants, TYSON RHAME and JAMES SHAW, did knowingly combine, conspire, and agree with each other and with others, both known and unknown to the Grand Jury, to commit offenses against the United States in violation of Title 18, United States Code, Section 1957, to wit: to knowingly engage and attempt to engage in monetary transactions by, through or to a financial institution, affecting interstate and foreign commerce, in criminally derived property of a value 10 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 10 of 41
  11. 11. greater than $10,000, such property having been derived from a specified unlawful activity, to wit: mail fraud, in violation of 18 U.S.C. § 1341, and wire fraud, in violation of Title 18, United States Code, Section 1343; in violation of Title 18, United States Code, Section 1957. All in violation of Title 18, United States Code, Section 1956(h). Counts Thirteen Through Twenty-Four Money Laundering (18 U.S.C. §§ 1957 and 2) 23. The Grand Jury re-alleges and incorporates herein by reference the factual allegations set forth in paragraphs 2-16. 24. On or about the dates listed below, within the Northern District of Georgia and elsewhere, the defendants, TYSON RHAME and JAMES SHAW, aided and abetted by each other and others known and unknown to the Grand Jury, did knowingly engage and attempt to engage in monetary transactions by, through or to a financial institution, affecting interstate commerce, as described below, each such transaction knowingly involving criminally derived property of a value greater than $10,000, such property having been derived from a specified unlawful activity, that is mail fraud, in violation of Title 18, United States Code, Section 1341, and wire fraud, in violation of Title 18, United States Code, Section 1343, each transaction constituting a separate count as set forth below: 11 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 11 of 41
  12. 12. Count Date Monetary Transaction 13 01/24/2011 Transfer in the amount of $150,000 from a PrivateBank account controlled by SHAW, ending in account number 6748, to another Private Bank account controlled by SHAW, ending in account number 4531 14 02/18/2011 Transfer in the amount of $75,000 from a USAA account controlled by RHAME, ending in account number 4327-2, to a financial account in the name of a third party with initials "T.A.G." 15 03/22/2011 Check in the amount of $1,000,000 from a USAA account controlled by RHAME, ending in account number 4327-2, issued to "TYSON RHAME", which was then deposited in a Navy Federal Credit Union Account controlled by RHAME, ending in account number 6340. 16 03/23/2011 Check in the amount of $800,000 from a PrivateBank account controlled by SHAW, ending in account number 4531, issued to a third party with initials "F.F.C." 17 10/25/2012 Transfer in the amount of $700,000 from a Wells Fargo Bank account controlled by RHAME, ending in account number 8032, to a Wells Fargo Advisors account controlled by RHAME, ending in account number 7939. 18 12/31/2012 Transfer in the amount of $5,000,000 from a Merrill Lynch account controlled by SHAW, ending in account number 2089, to another Merrill Lynch account controlled by SHAW, ending in account number 0471. 19 04/04/2013 Transfer in the amount of $500,000 from a Wells Fargo account controlled by RHAME, ending in account number ending in 8032, to a third party with initials "Y.N." 20 06/21/2013 Transfer in the amount of $2,929,000 from a Merrill Lynch account controlled by SHAW, ending in account number 2089, to another Merrill Lynch account controlled by SHAW, ending in account number 2066. 12 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 12 of 41
  13. 13. 21 07/30/2014 Transfer in the amount of $3,000,000 from a Merrill Lynch account controlled by RHAME, ending in account number 2062, to a Wells Fargo account controlled by Rhame, ending in account number 5439. 22 10/27/2014 Transfer in the amount of $2,500,000 from a Merrill Lynch account controlled by SHAW, ending in account number 2089, to a Merrill Lynch account controlled by SHAW, ending in account number 2050. 23 01/07/2015 Transfer in the amount of $750,000 from a Merrill Lynch account controlled by SHAW, ending in account number 2089, to a Merrill Lynch account controlled by SHAW, ending in account number 2050. 24 01/26/2015 Transfer in the amount of $2,500,000 from a Merrill Lynch account controlled by RHAME, ending in account number 2062, to a Wells Fargo account controlled by RHAME, ending in account number 5493. All in violation of Title 18, United States Code, Sections 1957 and 2. Forfeiture Provision 25. Upon conviction of one or more of the offenses alleged in Counts One Through Eleven of the Indictaient, the Defendants, TYSON RHAME, TERRENCE KELLER, JAMES SHAW, and FRANK BELL, shall forfeit to the United States pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and Title 28, United States Code, Section 2461, any property, real or personal, which constitutes or is derived from proceeds traceable to the wire and mail fraud offenses or a conspiracy to commit such offenses including, but not hmited to, the following: • MONEY JUDGMENT: A sum of money in United States currency representing the amount of proceeds obtained as a result of the 13 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 13 of 41
  14. 14. offenses. If more than one defendant is convicted of an offense, the defendants so convicted are jointly and severally liable; and • REAL A N D PERSONAL PROPERTY identified in paragraph 27 below. 26. Upon conviction of one or more of the offenses alleged in Counts Twelve through Twenty-Four of the Indictment, the Defendants, TYSON RHAME and JAMES SHAW, shall forfeit to the United States pursuant to Title 18, United States Code, Section 982(a)(1), any property, real or personal, involved in the money laundering offenses and all property traceable to such property including, but not limited to, the following: • MONEY JUDGMENT: A sum of money in United States currency representing the total amount of money involved in each offense for which the defendant is convicted. If more than one defendant is convicted of an offense, the defendants so convicted are jointly and severally liable; • REAL PROPERTY located at 225 Valley Road, N.W., Atlanta, Fulton County, Georgia 30305, Tax Parcel ID No.: 17-0116LL0675; and • REAL A N D PERSONAL PROPERTY identified in paragraph 27 below. 27. Real and Personal Property Subject to Forfeiture: A. BANK ACCOUNTS: 1) $1,826,973.89 seized from Actors Federal Credit Union account number XXXXOl-75; 14 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 14 of 41
  15. 15. 2) $200,000.00 seized from Actors Federal Credit Union account number XXXXOl-76; 3) $45,183.75 seized from Actors Federal Credit Union account number XXXXOl-99; 4) $6,321.47 seized from Actors Federal Credit Union account number XXXX02-75; 5) $105,193.25 seized from Actors Federal Credit Union account number XXXX02-76; 6) $42,848.25 seized from Actors Federal Credit Union account number XXXX02-99; 7) any and all funds maintained in Goldman Sachs and Co. account number XXX-XX113-9; 8) any and all funds maintained in J.P. Morgan Chase account number XXX-X9613; 9) $760,456.50 seized from Mahopac National Bank account number XXXXXX8418; 10) any and all funds maintained in Merrill Lynch account number XXX-X0471; 11) any and all funds maintained in Merrill Lynch account number XXX-X0478; 12) any and all funds maintained in Merrill Lynch account number XXX-X0479; 13) any and all funds maintained in Merrill Lynch account number XXX-X0480; 14) any and all funds maintained in Merrill Lynch account number XXX-X0488; 15 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 15 of 41
  16. 16. 15) $100,002.56 seized from Merrill Lynch account number XXX- X1015; 16) any and all funds maintained in Merrill Lynch account number XXX-X2048; 17) any and all funds maintained in Merrill Lynch account number XXX-X2049; 18) any and all funds maintained in Merrill Lynch account number XXX-X2050; 19) any and all funds maintained in Merrill Lynch account number XXX-X2062; 20) any and all funds maintained in Merrill Lynch account number XXX-X2065; 21) any and all funds maintained in Merrill Lynch account number XXX-X2066; 22) any and all funds maintained in Merrill Lynch account number XXX-X2072; 23) any and all funds maintained in Merrill Lynch account number XXX-X2087; 24) any and all funds maintained in Merrill Lynch account number XXX-X2089; 25) any and all funds maintained in Merrill Lynch account number XXX-X2386; 26) $5,177,314.90 seized from Merrill Lynch account number XXX- X2391; 16 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 16 of 41
  17. 17. 27) any and all funds maintained in Merrill Lynch account number XXX-X2421; 28) any and all funds maintained in Merrill Lynch account number XXX-X2426; 29) $14,231.03 seized from Regions Bank account number XXXXXX0235; 30) $25,260.98 seized from Regions Bank account number XXXXXX8724; 31) $246.85 seized from SunTrust Bank account number XXXXXXXXX0477; 32) $66,312.33 seized from SunTrust Bank account number XXXXXXXXX7073; 33) $115,774.55 seized from SunTrust Bank account number XXXXXXXXX7380; 34) $2,780,017.79 seized from TD Ameritoade account number XXX- XX3551; 35) any and all funds maintained in TD Ameritrade account number XXX-XX5715; 36) any and all funds maintained in TD Ameritrade account number XXX-XX5720; 37) any and all funds maintained in TD Ameritrade account number XXX-XX7569; 38) $72.61 seized from USAA Federal Savings Bank XXXXX-184-2; 39) $104,336.14 seized from USAA Federal Savings Bank account number XXX-X327-2; 17 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 17 of 41
  18. 18. 40) any and all funds maintained in Wedbush Morgan Securities Inc. account number XXXX4008; 41) any and all funds maintained in Wedbush Morgan Securities Inc. account number XXXX8860; 42) $3,000.00 seized from Wells Fargo account number XXXXXX0124; 43) $36,200.72 seized from Wells Fargo account number XXXXXX0132; 44) $30,843.89 seized from Wells Fargo account number XXXXXX0165; 45) $126.02 seized from Wells Fargo account number XXXXXX0199; 46) $94,635.98 seized from Wells Fargo account number XXXXXX0223; 47) $9,787.45 seized from Wells Fargo account number XXXXXX0231; 48) $1,297.77 seized from Wells Fargo account number XXXXXX0280; 49) $13,961.39 seized from Wells Fargo account number XXXXXX0298; 50) $293,814.26 seized from Wells Fargo account number XXXXXX0371; 51) $9,940.00 seized from Wells Fargo account number XXXXXX0397; 52) $37,878.22 seized from Wells Fargo account number XXXXXX0496; 18 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 18 of 41
  19. 19. 53) $22,797.65 seized from Wells Fargo account number XXXXXX0579; 54) $37,015.37 seized from Wells Fargo account number XXXXXX2673; 55) $99,970.00 seized from Wells Fargo account number XXXXXX2681; 56) $201,572.39 seized from Wells Fargo account number XXXXXX2821; 57) $178,791.99 seized from Wells Fargo account number XXXXXX2839; 58) $85,038.93 seized from Wells Fargo account number XXXXXX2850; 59) $122,487.52 seized from Wells Fargo account number XXXXXXXXX3245; 60) $38,036.83 seized from Wells Fargo account number XXXXXX3808; 61) $1,597,831.09 seized from Wells Fargo account number XXXXXX4675; 62) $77,676.58 seized from Wells Fargo account number XXXXXX4767; 63) $50,048.42 seized from Wells Fargo account number XXXXXX5133; 64) $1,201,546.95 seized from Wells Fargo account number XXXXXX5439; 65) $40,516.12 seized from Wells Fargo account number XXXXXX5536; 19 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 19 of 41
  20. 20. 66) $114,187.52 seized from Wells Fargo account number XXXXXX5551; 67) $43,132.68 seized from Wells Fargo account number XXXXXX6320; 68) $1,611.81 seized from Wells Fargo Advisors account number XXXX-6797; 69) $158,010.36 seized from Wells Fargo account number XXXXXX7400; 70) $8,796.58 seized from Wells Fargo Advisors account number XXXX-7939; 71) $139,577.61 seized from Wells Fargo account number XXXXXX8032; 72) $79,896.51 seized from Wells Fargo account number XXXXXX8575; 73) $16,882.82 seized from Wells Fargo account number XXXXXX8594; 74) $61,854.65 seized from Wells Fargo account number XXXXXX8658; 75) $39,597.41 seized from Wells Fargo account number XXXXXX8674; and 76) $44,405.30 seized from Wells Fargo account number XXXXXX9969; B. CORPORATE AND TRUST ENTITIES: 1) Sterling Currency Group, LLC; 20 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 20 of 41
  21. 21. 2) Sterling Online Processing Services, LLC; 3) GID Partners, LLC; 4) Alex Capital Holdings, LLC; 5) Lullwater Holdings; 6) Lullwater Trust; 7) Curtis Creek; 8) Valley Trust; 9) Springlake Trading, LLC; 10) JS Real Estate Investments, LLC; 11) SR Equipment Leasing, LLC; 12) Primestone Properties, LLC; 13) Wingover Capital, LLC; 14) Northwest Capital, LLC; 15) The TAR Revocable Trust; 16) Broadway Trader 4Z, LLC; 17) Yards at Noda, LLC; 18) Sherrills Ford Holdings, LLC; 19) Scotch Cove, LLC; 20) RG Classics, LLC; 21) Isolveit.com, LLC; 22) Sterlingfunder, LLC; 23) Trinvest, LLC; 21 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 21 of 41
  22. 22. 24) Sky Combat Blue, LLC; 25) TR East Point Real Estate, LLC; 26) TR Interactive Technologies, LLC; 27) Polaris Aviation, LLC; 28) Sky Combat Red, LLC; 29) Cascades at Rea, LLC; 30) Arrowood Station Holdings, LLC; 31) Arrowhead Station Holdings, LLC; 32) Miracle Charters, LLC; 33) TR Real Estate, LLC; 34) Whistlejacket, Inc.; 35) J-Brem, LLC; 36) Therrell Farms Estates, LLC; 37) Zonolite Holdings, LLC; 38) Sustainability Solutions, LLC; 39) 200 West Land DST; 40) 200 West Building, LLC; 41) Primestone FifeCo Realty Fund, LLC; 42) Preferred Capital, LLC; 43) Wingover Ranch, LLC; 44) Shaw Capital & Guaranty, LLC; 45) Shaw Irrevocable Trust; 22 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 22 of 41
  23. 23. 46) Shaw Alys Beach, LLC; 47) GID Associates, LLC; and 48) LeVan Capital, LLC, f / k / a Trinvest Partners, LLC; REAL PROPERTIES: 1) the real property located at 4536 East Brookhaven Drive, N.E., a/k/a 3060 Mabry Road, Atlanta, Fulton and DeKalb Counties, Georgia, Fulton Tax Parcel ID No.: 17-001300020262 and DeKalb Tax Parcel ID No.: 18-275-02-001; 2) the real property located at 1418 Dresden Drive, N.E., Unit A310, Atlanta, DeKalb County, Georgia, Tax Parcel ID No.: 18-238-18- 072; 3) the real property located at 3464 Paces Place, N.W., Atlanta, Fulton County, Georgia, Tax Parcel ID No.: 17-019800030227; 4) the real property located at 48 Shinbone Court, Panama City Beach, Walton County, Florida, Tax Parcel ID No.: 27-3S-18- 16420-0JJ-0150; 5) the real property located at 7 La Garza Court, Panama City Beach, Walton County, Florida, Tax Parcel ID No.: 27-3S-18- 16420-0NN-0060; 6) the real property located at 715 Rollerton Road, Charlotte, Mecklenburg County, North Carolina, Tax Parcel ID No.: 08303142, more particularly described as: Being a portion of that certain parcel of land located in Charlotte, Mecklenburg County, North Carolina formerly having a Parcel ID# of 08303101, recorded in Deed Book 22268, Page 908 of the Mecklenburg County Registry, and being more particularly described as follows: 23 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 23 of 41
  24. 24. BEGINNING at an existing iron pipe, said pipe being the northwest corner of RM 36th Street Investors, LLC (now or formerly) Deed Book 20682, Page 575; thence with the western line of RM 36th Street Investors, LLC, S 26°49'36" E a total distance of 403.52 feet to a point in the center of the Norfolk Southern Railroad right-of-way, passing a new iron pipe at 13.85 feet; thence with the center of the Norfolk Southern Railroad right-of-way, said right-of-way being forty feet (40') in width, the following (3) calls: 1) S 69°25'24"W, a distance of 498.00 feet to a point; thence 2) around a curve to the left having a radius of 1,392.37 feet for an arc distance of 336.98 feet (chord bearing and distance of S 62°29'24" W 336.16 feet) to a point; thence 3) S 55°33'24" W, a distance of 20.06 feet to a point in the center of the right-of-way for a railroad spur line; thence continuing with the center of the railroad spur line right- of-way for six (6) calls and also severing the land of CAR-CHI, LLC, a North Carolina Limited Liability Company (now or formerly) and then continuing for three (3) more calls for a total of nine (9) calls as follows: 1) around a curve to the right having a radius of 1,479.38 feet for an arc distance of 95.75 feet (chord bearing and distance of S 60°03'20" W 95.73 feet) to a point; thence 2) around a curve to the right having a radius of 878.08 feet for an arc distance of 99.84 feet (chord bearing and distance of S 65°10'01" W 99.78 feet) to a point; thence 3) around a curve to the right having a radius of 461.80 feet for an arc distance of 99.76 feet (chord bearing and distance of S 74°36' 47" W 99.57 feet) to a point; thence 24 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 24 of 41
  25. 25. 4) around a curve to the right having a radius of 465.99 feet for an arc distance of 100.70 feet (chord bearing and distance of S 86°59'32" W 100.50 feet) to a point; thence 5) around a curve to the right having a radius of 604.51 feet for an arc distance of 100.88 feet (chord bearing and distance of N 82°02' 11" W 102.55 feet) to a point; thence 6) around a curve to the right having a radius of 1079.86 feet for an arc distance of 43.72 feet (chord bearing and distance of N 76°05'45" W 43.72 feet) to a point; thence 7) N 26°48'25" E, a distance of 215.17 feet to a point; thence leaving the center of the railroad spur line right-of-way and continuing to sever the land of CAR-CHI, LLC 8) around a curve to the right having a radius of 709.79 feet for an arc distance of 503.29 feet (chord bearing and distance of N 47°07' 13" E 492.82 feet) to a point; thence 9) N 67°26'02" E, a distance of 706.87 feet to the POINT OF BEGINNING, containing 10.86 acres, more or less, and shown as "Tract 1" on a Final Subdivision Plat by The John R. McAdams Company, Inc. entitled "THE YARDS AT NODA FINAL SUBDIVISION PLAT- MAP 1," dated June 12, 2008. LESS AND EXCEPT that portion of the above described property consisting of 17,950 square feet, more or less, as described in that Final Judgment recorded in Book 26953, at Page 586, of the Mecklenburg County Public Registry. Note: In the deed filed of record in Book 23948, at Page 734, of the Mecklenburg County Public Registry, the chord distance in call #5 above is stated to be 100.76 feet. However, the Survey referred to above lists the chord distance for that same call as 102.55. See 25 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 25 of 41
  26. 26. the Survey filed of record in Map Book 50, at Page 476, of the Mecklenburg County Public Registry. Being the same property shown and depicted on the survey entitled "ALTA/ACSM Land Title Survey Prepared for YARDS AT NODA, LLC" prepared by C. Clark Neilson, NC PLS No. L- 3212, dated March 8, 2012, last revised February 13, 2013, designated Map File W-1732B, and being more particularly described as: That certain parcel of land, situated, lying and being in the City of Charlotte, Mecklenburg County, North Carolina, and being more particularly described as follows: COMMENCING at NGS Monument " M 045", having NC GRID NAD83 coordinates of N:549,759.58 ft; E: 1,459,955.84 ft; thence N28°52'00" E a horizontal ground distance of 590.55 feet to an existing iron pipe, said point being located at the northwest corner of the RM36th Street Investors, LLC Property as described in Deed Book 20682, Page 575 of the Mecklburg County Registry; Which is POINT OF BEGINNING; thence with the aforesaid RM 36th Sh-eet Investors, LLC Property S 26°49'36" E crossing and existing iron pipe at a distance of 13.52 feet for a total distance of 403.52 feet for a total distance of 403.52 feet to a new iron rod, said point being located in the centerline of the Norfolk Southern Railroad R/W (now or formerly); thence with the centerline of the aforesaid Railroad R / W the following 9 courses and distances: 1) S 69°25'24 W a distance of 498.00 feet to a new iron rod; 2) with the arc of a circular curve turning to the left with a radius of 1,392.37 feet, and an arc length of 336.98 (chord: S 62°29'24" W a distance of 336.16 feet), to an existing nail; 3) S 55°33'24 W a distance of 20.06 feet to an existing nail; 4) with the arc of a circular curve turning to the right a radius of 1,479.38 feet, and an arc length of 95.75, (chord: S 60°03'20"W a distance of 95.73 feet), to and existing iron pipe; 5) with the arc of a circular curve turning to the right with a radius of 878.08 feet, and an arc length of 99.83, (chord: S 65°10'01" W a distance of 99.78 feet), to a new iron rod; 6) with the arc of a circular curve turning to the 26 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 26 of 41
  27. 27. right with a radius of 461.80 feet, and an arc length of 99.76, (chord: S 74°36'47" W a distance of 99.57 feet), to an existing nail; 7) with the arc of a circular curve turning to the right with a radius of 465.99 fee, and an arc length of 100.70, ( S 86°59'32 W a distance of 100.50 feet), to an existing nail; 8) with the arc of a circular curve turning to the right with a radius of 604.51 feet, and an arc length of 100.88, (chord: N 82°02'11" W a distance of 10.76 feet), to a new iron rod; 9) with the arc of a circular curve turning to the right with a radius of 1,079.86 feet, and an arc length of 3.81,(chord: N 77°09'17" W a distance of 3.81 feet), to a new iron rod, said iron rod being located at the southeast corner of the City of Charlotte Property as described in Deed Book 26112, Page 394 and Deed Book 26953, Page 586 of the Mecklenburg County Registry; thence with the aforesaid City of Charlotte Property the following 3 courses and distances: 1) N 26°46'52" E a distance of 200.93 feet to an existing iron rod capped "City Survey"; 2) with the arc of a circular curve turning to the right with a radius of 709.79 feet, and an arc length of 377.86, (chord: N 39°34'13" E a distance of 373.42 feet), to an existing iron rod capped "City Survey", 3) with the arc of a circular curve turning to the left with a radius of the left with a radius of 5629.65 feet, and an arc length of 143.91, (chord: S 60°30'37" W a distance of 143.91 feet), to a new iron rod, said point being located on a common line with Tract 2 of The Yards at Noda Subdivision, Map 1 as described in Map Book 50, Page 476 of the Mecklenburg County Registry; thence with the aforesaid Tract 2 the following 2 courses and distances: 1) with the arc of a circular curve turning to the right with a radius of 709.79 feet, and an arc length of 259.46, (chord: N 56°57'43" E a distance of 258.02 feet), to an existing iron pipe: 2) N 67°26'02" E a distance of 706.87 feet to the POINT OF BEGINNING, Containing 455,016 square feet or 10.4457 acres as shown on a survey by R.B. Pharr and Associates P.A. dated March 8 2012, Last revised February 13, 2013 (Map File W-1732B). 7) 699.115 acres, more or less, in Mountain Creek Township, Catawba County, North Carolina, Tax Parcel ID No.: 461904616962, more particularly described as: 27 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 27 of 41
  28. 28. A TOTAL OF 699.115 ACRES LOCATED I N MOUNTAIN CREEK TOWNSHIP, CATAWBA COUNTY, NORTH CAROLINA, CONSISTING OF THE FOLLOWING THREE (3) TRACTS OF LAND: (A) THAT TRACT OF LAND DESIGNATED AS "SURPLUS TRACT 3424-01, AREA=585.933 ACRES" ON PLAT RECORDED I N PLAT BOOK 63, PAGES 37- 44 I N THE CATAWBA COUNTY REGISTER OF DEEDS ("PLAT"), (B) THAT TRACT OF LAND DESIGNATED AS "AREA=89.447 ACRES" ON THE PLAT, A N D (C) THAT TRACT OF LAND DESIGNATED AS "AREA=23.735 ACRES" ON THE PLAT. TOGETHER WITH SUCH ADDITIONAL PROPERTY AS WAS CONVEYED TO GRANTOR BY DENNIS WINKS AND PAMELA WINKS PURSUANT TO THAT CERTAIN LINE AGREEMENT DATED MAY 7, 2013 A N D RECORDED JULY 18, 2013 I N BOOK 3200, PAGE 176 I N THE CATAWBA COUNTY REGISTER OF DEEDS. LESS AND EXCEPT SUCH PROPERTY AS WAS CONVEYED TO DENNIS WINKS AND PAMELA WINKS BY GRANTOR PURSUANT TO THAT CERTAIN LINE AGREEMENT DATED MAY 7, 2013 AND RECORDED JULY 18, 2013, IN BOOK 3200, PAGE 176 I N THE CATAWBA COUNTY REGISTER OF DEEDS. TOGETHER WITH THE NON-EXCLUSIVE RIGHTS OF ACCESS UNDER THE RIGHT-OF-WAY AGREEMENT FOR RACCOON TRACT DRIVE RECORDED I N BOOK 1718 AT PAGE 403, CATAWBA COUNTY REGISTER OF DEEDS OFFICE, AS SHOWN ON PLAT RECORDED I N PLAT BOOK 53, PAGE 48, AFORESAID COUNTY REGISTRY; the real property located at 200 West Second Street, Winston- Salem, Forsyth County, North Carolina, Tax Parcel ID No.: 6835- 26-1005.00, more particularly described as: 28 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 28 of 41
  29. 29. ALL OF THAT PROPERTY BEING KNOWN AND DESIGNATED AS LOT 1 AS SHOWN ON THE MAP OF TRIAD PARK AS RECORDED I N PLAT BOOK 30, PAGE 40, I N THE OFFICE OF THE REGISTER OF DEEDS OF FORSYTH COUNTY, NORTH CAROLINA, REFERENCE TO WHICH IS HEREBY MADE FOR A MORE PARTICULAR DESCRIPTION. ALSO BEING A PORTION OF PARCEL 16, AS SHOWN ON MAP OF CENTRAL DOWNTOWN PROJ. NO. N.C. R-55, AS RECORDED IN PLAT BOOK 28, PAGE 121, FORSYTH COUNTY REGISTRY. TOGETHER WITH PERMANENT A N D EXCLUSIVE EASEMENT ENTITLED "OFFICE BUILDING LOBBY EXTENSION" A N D IDENTIFIED AS EASEMENT "C" ON THE MAP OF TRIAD PARK RECORDED I N PLAT BOOK 30, AT PAGE 40, FORSYTH COUNTY REGISTRY. TOGETHER WITH THE EASEMENTS A N D PARKING RIGHTS GRANTED BY THE CITY OF WINSTON-SALEM TO DUDLEY WEBB & COMPANIES, A NORTH CAROLINA CORPORATION (THE "DEVELOPER") I N THE DEVELOPMENT AGREEMENT DATED FEBRUARY 12,1985, AS AMENDED, WHICH IS RECORDED IN BOOK 1624, AT PAGES 2191 AND 2295, IN THE OFFICE OF THE REGISTER OF DEEDS OF FORSYTH COUNTY, NORTH CAROLINA, WHICH EASEMENTS AND PARKING RIGHTS WERE ASSIGNED BY THE DEVELOPER TO WEBB/WINSTON-SALEM VENTURES, 100 LIMITED PARTNERSHIP, A NORTH CAROLINA LIMITED PARTNERSHIP, BY INSTRUMENT DATED SEPTEMBER 30, 1987, AND RECORDED I N BOOK 1624, AT PAGE 4003, I N THE OFFICE OF THE REGISTER OF DEEDS OF FORSYTH COUNTY, NORTH CAROLINA; 9) approximately 46.866 acres on England Street, Mecklenburg County, North Carolina, Tax Parcel ID Nos.: 205-173-19, 205-173- 18, 205-173-17, 205-173-16, 205-173-15, 205-173-14, 205-173-13, 205-173-12, 205-173-11, 205-173-02, 205-173-22, 205-173-20, and 205-173-21, more particularly described as: 29 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 29 of 41
  30. 30. All that certain lot or parcel of land situated in the City of Charlotte, Mecklenburg County, North Carolina, and more particularly described as follows: Tract 1 - Mecklenburg County Tax Parcel No. 205-173-02: Beginning at a found iron in the most Southwestern corner of property owned by the City of Charlotte as recorded in Deed Book 17540, Page 337 of the Mecklenburg County Registry, said iron being located S 5°26'38" E 635.53' from a found iron in the line of City of Charlotte as described above; from the POINT OF BEGINNING thence with a bearing of S 70°57'43" E and a total distance of 519.76' (passing an iron at 425.68' and 469.53'), to a point near the centerline of the (Now or Formerly) Norfolk Southern Railway as shown in Map Book 40, Page 693; thence leaving the margin of the centerline with a bearing of S 12°55'13" E and a distance of 224.62', to a point; thence with a bearing of S 2°58'17" Wand a distance of 250.00', to a point; thence with a bearing of S 68°30'46" W and a distance of 8.16', to a point near the centerline of the (Now or Formerly) Norfolk Southern Railway as referenced above; thence with the margin of centerline of said track an Arc to the Right having a Radius of 1671.44' and a Length of 462.30' and being Chorded by a bearing of S 12°51'29" W with a distance of 460.83' to a point near the centerline of said track; thence with an Arc to the Right having a Radius of 3278.14' and a Length of 239.85' and being Chorded by a bearing of S 22°52'40" W with a distance of 239.80' to a point near the centerline of said track; thence with a bearing of S 24°58'23" Wand a distance of 262.08', to a point also near the centerline of said track; thence leaving the said Railway with the common line of the (Now or Formerly) City of Charlotte, as recorded in Deed Book 4147, Page 370 of said registry a -bearing of N 70°42'34" Wand a total distance of 294.39', to a found iron rod (passing irons at 65.32' and at 1 04.54'); thence with the common line of the (Now or Formerly) City of Charlotte, as recorded in Deed Book 4147, Page 370 of said registry with a bearing of N 12°46'34" Wand a distance of 553.51', to a found concrete monument; thence with the common line of The City of 30 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 30 of 41
  31. 31. Charlotte, as recorded in deed book 4147, page 370 of said registry a bearing of S 69°04'50" Wand a distance of 657.69', to a found iron pipe; thence with the common line of (Now or Formerly) Crown Atlantic Company as recorded in Deed Book 10478, Page 356 of said registry a bearing of N 33°07'05" W and a distance of 175.49', to a found iron pipe; thence with the common line of the (Now or Formerly) CW Holdings of Charlotte, LLC as recorded in Deed Book 17644, Page 302 of said registry a bearing of N 32°29'~4" W and a distance of 320.60', to a found iron; thence with the common line of the (Now or Formerly) Reagents, Inc., as recorded in Deed Book 3982, Page 796 of said registry a bearing of N 23°09'06" E and a distance of 99.74', to a found iron; thence with the Reagents, Inc. line a bearing of N 79°38'15" Wand a distance of 221.70', to a found iron on the Eastern edge of the 60' Right of Way of England Street as shown on Map Book 23, Page 809 of said registry; thence with said Right of Way a bearing of N 25° 11'32" E and a distance of 118.51', to a found iron; thence leaving said Right of Way with the common line of Lemarc Inc. as recorded in Deed Book 8717, Page 986 of said registry with a bearing of S 80°01'01" E and a distance of 280.06', to a set rebar; thence with a Lemarc line a bearing of N 25°11'32" E and a distance of 248.70', to a found iron; thence with the Lemarc line a bearing of N 80°00'30" Wand a distance of 280.05', to a found iron in the Eastern edge of the 60' Right of Way of England Street as described above; thence with said right of way a bearing of N 25°11'32" E and a distance of 714.79', to a set rebar; thence leaving said Right of Way with the common line of the (Now or Formerly) City of Charlotte as recorded in Deed Book 20204, Page 51 of said registry a bearing of N 71°24'05" E and a distance of 39.53', to a set rebar; thence with City of Charlotte line for (4) courses: (1) a bearing of S 64°54'04" E and a distance of 76.46', to a set rebar; (2) thence with an Arc to the Left having a Radius of 315.49' and a Length of 206.12' and being Chorded by a bearing of S 83°37'04" E and a distance of 202.47', to a set rebar; (3) thence with a bearing of N 77°39'59" E and a distance of 379.7 4', to a set rebar; (4) thence with a bearing of S 56°07'20" E and a distance of 86.86', to a set rebar, said rebar being located S 47"45'52" W 2365.07' (ground distance) from NGS monument "M-082"; thence 31 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 31 of 41
  32. 32. with the common hne of the (Now or Formerly) City of Charlotte as recorded in Deed Book 17540, Page 337 of the Mecklenburg County Registry a bearing of S 5°26'38" E and a distance of 373.44' to the POINT OF BEGINNING, and containing 46.866 Acres as shown on survey by Carolina Surveyors, Inc., last revised luly 24, 2007. LESS AND EXCEPT that certain property described as follows: Being all of Parcel l A , Parcel 1 B, Parcel 2A, Parcel 3A, Parcel 3B, Parcel 11 A, Parcel 11 B, Parcel 11 C, Alley 1, Alley 2, Alley 3, Alley 11 and all streets dedicated as Public Right of Way, all as shown on that certain survey entitled "A Plat Showing liadley Subdivision Map 1" dated February 4, 2009, prepared by Thomas E. White, North Carolina Professional Land Surveyor L-4689 of Carolina Surveyors, Inc. and recorded in Map Book 51, Page 367, Mecklenburg County Public Registry. Tract n - Mecklenburg County Tax Parcel Nos. 205-173-11, 205- 173-12, 205-173-13, 205-173-14, 205-173-15, 205-173-16, 205-173-17, 205-173-18, 205-173-19, 205-173-20, 205-173-21 and 205-173-22: Being all of Parcel l A , Parcel IB, Parcel 2A, Parcel 3A, Parcel 3B, Parcel H A , Parcel IIB, Parcel I I C , Alley 1, Alley 2, Alley 3 and Alley 11 as shown on that certain survey entitled "A Plat Showing Hadley Subdivision Map 1" dated February 4, 2009, prepared by Thomas E. White, North Carolina Professional Land Surveyor L-4689 of Carolina Surveyors, Inc. and recorded in Map Book 51, Page 367, Mecklenburg County Public Registry. Tracts I and II being portions of that certain property conveyed from Brian B. Helms and wife Debra C. Helms and Jerry N. Helms and wife. Sue Lemmond Helms to Arrowood Station, LLC by deed recorded August 29, 2007 in Book 22742, Page 593, Mecklenburg County Public Registry. 10) the real property located at 2294 Fernwood Drive, East Point, Fulton County, Georgia, Tax Parcel ID No.: 14-016600021379; 32 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 32 of 41
  33. 33. 11) the real property located at 1891 Connally Drive, East Point, Fulton County, Georgia, Tax Parcel ID No.: 14-016600021361; 12) the real property located at 1901 Connally Drive, East Point, Fulton County, Georgia, Tax Parcel ID No.: 14-016600021353; 13) the real property located at 2095 Newnan Avenue, East Point, Fulton County, Georgia, Tax Parcel ID No.: 14-013400020644; 14) the real property located at 2225 Dodson Drive, East Point, Fulton County, Georgia, Tax Parcel ID No.: 14-019800070014; 15) the real property located at 1202/1216 Zonolite Road, N.E., Atlanta, DeKalb County, Georgia, Tax Parcel ID No.: 18-107-14- 036; 16) the real property located at 1750 Briarwood Road, Atlanta, DeKalb County, Georgia, Tax Parcel ID No.: 18-197-02-006; 17) the real property located at 1808 Therrell Farms Road, Sandy Ridge, Union County, North Carolina, Tax Parcel ID Nos.: 06183026, 06183029, 06183030, and 06183058, more particularly described as: Tract 1: Being all of Lots 1 and 33 of Therrell Farms, Map 1 as same is shown on map thereof recorded in Plat Cabinet H, at File 757, in the Union County Public Registry, North Carolina; reference to which is hereby made for a more particular description thereof. Tract 2: Being all of Lots 4 and 5 of Therrell Farms, Map 2, as same is shown on map thereof recorded in Plat Cabinet H, at File 759, in the Union County Public Registry, North Carolina; reference to which is hereby made for a more particular description thereof; 33 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 33 of 41
  34. 34. 18) the real property specifically identified as: 4237 Rea Road, 7903 Rea View Court, 7907 Rea View Court, 7911 Rea View Court, 7915 Rea View Court, 7919 Rea View Court, 7920 Rea View Court, 7916 Rea View Court, 7912 Rea View Court, 7908 Rea View Court, 7904 Rea View Court, 0.14 acres on Rea View Court, 0.141 acres on Rea View Court, 0.052 acres on Rea View Court, and 0.107 acres on Rea View Court, Charlotte, Mecklenburg County, North Carolina, Tax Parcel ID Nos.: 21159314, 21159318, 21159319, 21159320, 21159321, 21159322, 21159323, 21159324, 21159325, 21159326, 21159327, 21159328, 21159329, 21159330, and 21159331, more particularly described as: SITUATED in the City of Charlotte, Mecklenburg County, North Carolina, and being more particularly described as follows: BEGINNING at the iron survey stake, having North Carolina (NAD 83) grid coordinates of N = 498,776.23 feet and E = 1,460,301.57 feet located at the northwest corner of the property of 2728 Holding Corporation, as described in Deed Book 8736, Page 810 in the Mecklenburg County Public Registry (hereinafter the "Registry"); thence from the point of beginning, with and along the boundary line of said property of 2728 Holding Corporation, S. 14-28-47 E. 12.46 feet to an iron survey stake located at the northwest corner of the property of Madina M. Riley, as described in Deed Book 21469, Page 777, in the Registry; thence with and along the boundary line of said property of Madina M. Riley, S. 14-28-47 E. 326.72 feet to a misc. deciduous tree; thence S. 41-19-05 W. 100.45 feet to an iron pipe lying in the northeast corner of the property of Jane Rea Clute, et al., as described in Deed Book 5562, Page 243, of the Registry; thence with and along the boundary line of said property of Jane Rea Clute, et al, N . 49-17-05 W. 293.77 feet to an iron pipe having North Carolina (NAD 83) grid coordinates of N = 498,776.23 feet and E = 1,460,301.57 feet, lying southeast of the right-of-way of Rea Road; thence the following three (3) courses and distances: (1) with the arc of a circular curve to the left, having a radius of 2,473.08 feet, a chord bearing and distance of N. 43-55-16 E. 85.28 feet and an arc length of 85.29 feet to a point; (2) N . 43-45-15 E. 34 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 34 of 41
  35. 35. 60.35 feet to a point; (3) N . 43-56-00 E. 148.87 feet to an iron survey stake, the place of beginning, all as shown on that certain Topographic Survey for Insite Residential, LLC, dated December 31, 2007, and prepared by A.G. Zoutewelle, P.A. ADDITIONAL DESCRIBED AS FOLLOWS: SITUATED in the City of Charlotte, Mecklenburg County, North Carolina, and being more particularly described as follows: BEGINNING at the iron survey stake, having North Carolina (NAD 83) grid coordinates of N = 498,776.23 feet and E = 1,460,301.57 feet located at the northwest corner of the property of 2728 Holding Corporation, as described in Deed Book 8736, Page 810, in the Mecklenburg County Public Registry (hereinafter the "Registry"); thence from the point of beginning, with and along the boundary line of said property of 2728 Holding Corporation, S. 14-28-47 E. 12.46 feet to an iron survey stake located at the northwest corner of the property of Madina M. Riley, as described in Deed Book 21469, Page 777, in the Registry; thence with and along the boundary line of said property of Madina M. Riley, S. 14-28-47 E. 326.72 feet to a misc. deciduous tree; thence S. 41-19-05 W. 100.45 feet to an iron pipe lying in the northeast corner of the property of Jane Rea Clute et al, as described in Deed Book 5562, Page 243 of the Registry; thence with and along the boundary line of said property of Jane Rea Clute et al, N. 49-17-05 W. 293.77 feet to an iron pipe having North Carolina (NAD 83) grid coordinates of N = 498,573.69 feet and E = 1,460,087.84 feet, lying southeast of the right-of-way of Rea Road; thence the following three (3) courses and distances: (1) with the arc of a circular curve to the left, having a radius of 2,473.08 feet, a chord bearing and distance of N. 43-55-16 E. 85.28 feet and an arc length of 85.29 feet to a point; (2) N. 43-45-15 E. 60.35 feet to a point; (3) N. 43-56-00 E. 148.87 feet to an iron survey stake, the place of beginning, all as shown on that certain Topographic Survey for Insite Residential, LLC, dated December 31,2007, and prepared by A.G. Zoutewelle, P.A.; and 35 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 35 of 41
  36. 36. 19) the real property located at 2553 340* Street, Keokuk, and adjoining 377 acres in Montrose Township, Lee County, Iowa, Tax Parcel ID Nos.: 042318341000070; 042318342000020; 042318343000050; 042318344000010; 042318344000020; 042318344000040; 042318342000040; 042318344000030; 042318342000010; and 042318342000030, more particularly described as: Three Hundred and Seventy Seven (377) acres off the East side of Section Thirty Four (34), in Township Sixty Six (66) North, Range Five (5) West of the Fifth Principal Meridian, in Lee County, Iowa. Subject, however, to conveyances to Lee County, Iowa, for the purposes and for use as public highways of parcels recorded at Microfiche 98S-44 E2, Microfiche 99S-10 C7, and Book 05S, Page 494, at the Office of the Recorder of Lee County, Iowa, and subject to other easements and licenses of record; PERSONAL PROPERTY: 1) 2006 Cessna Citation XLS aircraft. Manufacturer's Serial Number 560-5623, bearing registration number N562VP; 2) Gipps Aero Party Limited Model GA8TC-320 aircraft bearing tail number N68GA and serial number GA8-TC-320-12-187; 3) Extra Flugzeugproduktions Und Model EA300/LT aircraft bearing tail number N330TY and serial number LT020; 4) 2012 Mercedes Benz GL550 bearing vehicle identification number 4JGBF8GE5CA785200; 5) 2012 Mercedes Benz SLS AMG bearing vehicle identification number WDDRJ7HA1CA008056; and 6) 2013 Audi SS Quatro bearing vehicle identification number WAUD2AFD2DN020235; 36 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 36 of 41
  37. 37. CURRENCY AND MONETARY INSTRUMENTS: 1) a total of approximately 8,671,456,050 in Iraqi dinar seized from 2751 Buford Highway, #403, Atlanta, Georgia on June 3, 2015; 2) a total of approximately 13,317,698,200 in Vietnamese Dong seized from 2751 Buford Highway, #403, Atlanta, Georgia on June 3, 2015; 3) a total of approximately 2,100 in Afghanis seized from 2751 Buford Highway, #403, Adanta, Georgia on June 3, 2015; 4) a total of approximately 100 in Chinese Yuan seized from 2751 Buford Highway, #403, Atlanta, Georgia on June 3, 2015; 5) a total of approximately 1,600,000 in Indonesian Rupiahs seized from 2751 Buford Highway, #403, Atlanta, Georgia on June 3, 2015; 6) approximately 29 silver coins seized from 2751 Buford Highway, #403, Atlanta, Georgia on June 3, 2015; 7) a total of approximately 14,396,403 in Iraqi dinar seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 8) a total of approximately 20,000 in Vietnamese Dong seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 9) a total of approximately 150,000 in Bank of Mozambique notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 10) a total of approximately 23,200 in Bank of Egypt notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 37 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 37 of 41
  38. 38. 11) a total of approximately 1,000 in Union of Burma bank notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 12) a total of approximately 1,000,000 in Republic of Iran bank notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 13) a total of approximately 9,799 in Chinese Yuan seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 14) a total of approximately 1,502,600 in Afghanis seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 15) a total of approximately 2,450 in Bank of Surtname notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 16) a total of approximately 9,300 in Bank of Yugoslavia notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 17) a total of approximately 155,000 in Cambodian Bank notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 18) a total of approximately 500 in Brazilian currency seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 19) a total of approximately 1,000 in Bank of Sudan notes seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 20) approximately 182 gold coins seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; 21) approximately 49 silver coins seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015; and 38 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 38 of 41
  39. 39. 22) approximately $48,718.00 in United States currency seized from 4536 East Brookhaven Drive, Atlanta, Georgia on June 3, 2015. 28. If, as a result of any act or omission of TYSON RHAME, JAMES SHAW, FRANK BELL, OR TERRENCE KELLER, any property subject to forfeiture: a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third person; c. has been placed beyond the jurisdiction of the Court; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be subdivided without difficulty; the United States intends, pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b)(1); or Title 28, United States Code, Section 2461(c), to seek forfeiture of any other 39 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 39 of 41
  40. 40. property of said defendants up to the value of the forfeitable property. A FOREPERSON J O H N A . H O R N United States Attorney T H O M A S J. K R E P P Assistant United States Attorney GeorgiaJBaiiMx346Z&j^ S T E V E N D . d p i M B E R G Assistant United States Attorney Georgia Bar No. 312144 A J ^ M I E L. M I C K E L S O N Assistant United States Attorney Georgia Bar No. 591094 600 U.S. Courthouse 75 Spring Street, S.W. Atianta, GA 30303 404-581-6000; Fax: 404-581-6181 40 Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 40 of 41
  41. 41. C R I M I N A L C H A R G E S FILED Today's Date: February 9, 2016 Date Charges Filed: February 10, 2016 U S A O #: 2014R00956 Caption: Tyson Rhame, et al. Under Seal? Yes Court Number: P S N Case: No FILED IN OPFNC Charge Type: Indictment District/Magistrate Judge: Felony FEB 1 § 2016 James V, , . 1 B y „ ' ' '""^ Defendant Information: Deputy Cici k Tyson Rhame Praecipe Charge: Count: 18§1349 1 Charge: Count: 18§1341 and 2 Charge: Count: 18§1343,1349, and 2 ••Li;::.::;y,v8-li - , Charge: Count: 18§1956(h) Charge: Count: 18§1957 and 2 •Vxy^;^-,,:y'yl3-24 L,''V' Terrence Keller Praecipe Charge: Count: 18§1349 Charge: Count: 18§1341 and 2 Charge: Count: 18§1343,1349, and 2 James Shaw Praecipe Charge: Count: 18§1349 Charge: Count: 18§1341 and 2 •Y2-7:y •••••• y,L,,^ Charge: Count: 18§1343,1349, and 2 •••;-''Cvyv:://;-:';84i^y •••-y^v Charge: Count: 18§1956(h) ••^•^12/L:v''vLL, Charge: Count: 18§1957and2 : ••••:13-24y; Frank Bell Praecipe Charge: Count: 18§1349 [IF O C D E T F Case= Yes Then REMINDER: Fonvard copy of indictment and this form to OCDETF Assistant Case 1:16-cr-00067-SCJ-CMS Document 1 Filed 02/10/16 Page 41 of 41
  42. 42. FEB 1 0 2016 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA Criminal Action No. V. 4 TYSON RHAME, et. al. UNDER SEAL Motion to Seal Indictment The United States of America, by John A. Horn, United States Attorney, and Thomas J. Krepp, Assistant United States Attorney for the Northern District of Georgia, respectfully requests that the attached Indictment, motion to seal and order be sealed for the following reasons: The Federal Bureau of Investigation (FBI) plans to arrest the defendant, Terrence Keller, aka Terryk. Atlanta-based FBI agents are currently coordinating with Kentucky-based FBI agents as it is beUeved Keller lives in Kentucky. Premature disclosure of these charges could hamper the agents' ability to safely arrest Keller. WHEREFORE, the United States of America respectfully requests that this motion, the Indictment and ensuing order be sealed. Case 1:16-cr-00067-SCJ-CMS Document 2 Filed 02/10/16 Page 1 of 2
  43. 43. Submitted this 10* day of February 2016. Respectfully submitted, J O H N A . FIORN United States Attorney /s/Thomas J. Krepp Assistant United States Attorney Georgia Bar No. 346781 Thomas.Krepp@usdoj.gov 2 Case 1:16-cr-00067-SCJ-CMS Document 2 Filed 02/10/16 Page 2 of 2
  44. 44. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION FEB 1 » 2016 UNITED STATES OF AMERICA V. TYSON RHAME, et. al. Criminal Action No. UNDER SEAL Order Having read and considered the government's Motion to Seal Indictment and application and for good cause shown, It is hereby ORDERED that the Indictment and application be sealed. SO ORDERED this lO^ day of h , 20 f L R U S S E L L G. V I N E Y A R D UNITED ST ATES M A G I ^ A T E JUDGE Presented by: Thomas J. Krepp, Assistant United States Attorney Case 1:16-cr-00067-SCJ-CMS Document 3 Filed 02/10/16 Page 1 of 1
  45. 45. U.S. Department of Justice United States Attorney IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA Division; Atlanta (USAO: 2014R00956) DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION FILED IN OPEN COURT I J K n (• FEB 1« 2016 James .. I icrk C O U N T Y N A M E ; Fulton X Indictnient DATE: Februaiy 10, 2016 Infonnation DATE: UNITED STATES O F AMERICA vs. T Y S O N R H A M E GREATER OFFENSE CHARGED: X Felony Misdemeanor D I S T R I C T C O U R T N O . l : 1 6 C H 6 7 Z UNDER SEAL M A G I S T R A T E C A S E N O . Magisti'ate's Complaint DATE: SUPERSEDING INDICTMENT Prior Case Number: Date Ffled: Defendant Information: Is the defendant in custody? Yes X No Will the defendant be arrested pending outcome of this proceeding? X Yes No Is the defendant a fugitive? Yes X No Has the defendant been released on bond? Yes X No Will the defendant require an interpreter? Yes X No District Judge: Attorney: Thomas J. Krepp Defense Attorney: Case 1:16-cr-00067-SCJ-CMS Document 4 Filed 02/10/16 Page 1 of 1
  46. 46. U.S. Department of Justice United States Attorney IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA Division: Atlanta (USAO: 2014R00956) DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION C O U N T Y N A M E : Fulton X Indiciment Ii-iformation DATE: February 10, 2016 DATE: UNITED STATES O F AMERICA vs. T E R R E N C E K E L L E R , A/ByA T E R R Y K GREATER OFFENSE CHARGED; X Felony Misdemeanor Defendant Information: Is the defendant in custody? Yes X No Will the defendant be arrested pending outcome of this proceeding? X Yes No Is the defendant a fugitive? Yes X No Has the defendant been released on bond? Yes X No Will the defendant require an interpreter? Yes X No FEB 1 © 2016 1:16 CRG7D I S T R I C T C O U R T N O . UNDER SEAL M A G I S T R A T E C A S E N O . Magistrate's Complaint DATE: SUPERSEDING INDICTMENT Prior Case Number; Date Filed: District Judge: Attorney: Thomas J. Krepp Defense Attorney: Case 1:16-cr-00067-SCJ-CMS Document 5 Filed 02/10/16 Page 1 of 1
  47. 47. U.S. Department of Justice United States Attorney IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA Division; Atlanta (USAO: 2014R00956) DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION FEB James i By: » 201£ C O U N T Y N A M E : Fulton X Indictment DATE: Februai7lO,2016 Information DATE: UNITED STATES O F AJVIERICA vs. J A M E S S H A W GREATER OFFENSE CHARGED: X Felony Misdemeanor D I S T R I C T C O U R T N O . 1:1 6 CR6 7 UNDER SEAL M A G I S T R A T E C A S E N O . Magistrate's Complaint DATE: SUPERSEDING INDICTMENT Prior Case Number: Date Filed: Defendant Information: Is the defendant in custody? Yes X No Will the defendant be arrested pending outcome of this proceeding? X Yes No Is the defendant a fugitive? Yes X No Has the defendant been released on bond? Yes X No Will the defendant require an interpreter? Yes X No District Judge: Attorney: Thomas J. Krepp Defense Attorney: Case 1:16-cr-00067-SCJ-CMS Document 6 Filed 02/10/16 Page 1 of 1
  48. 48. U.S. Department of Justice United States Attorney FILED IN OPEN COURT IN THE UNITED STATES DISTRICT COURT ^ ^J) c A ! FOR THE NORTHERN DISTRICT OF G E O R G I A Division: Atlanta (USAO: 2014R00956) DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION FEB 1 0 2016 C O U N T Y N A M E : Fulton D I S T R I C T C O U R T N O . M A G I S T R A T E C A S E N O . 1!16CR67 UNDER SEAL X Indictment DATE: Februaiy 10, 2016 Information DATE: UNITED STATES O F AMERICA V8. F R A N K B E L L GREATER OFFENSE CHARGED: X Felony Misdemeanor Magistrate's Complaint DATE: SUPERSEDING INDICTMENT Prior Case Number: Date Filed: Defendant Information: Is the defendant in custody? Yes X No Will the defendant be arrested pending outcome of this proceeding? X Yes No Is the defendant a fugitive? Yes X No Has the defendant been released on bond? Yes X No Will the defendant require an interpreter? Yes X No District Judge: Attorney: Thomas J. Krepp Defense Attorney: Case 1:16-cr-00067-SCJ-CMS Document 7 Filed 02/10/16 Page 1 of 1
  49. 49. FILED IN OPEN COURTU.S. Department of Justice ! I Q 1^ f ' United Slates Attorney ^ ' ' t-hB 10 2016 I N THE U N I T E D S T A T E S D I S T R I C T C O U R T James N- y2>WHJ:k FOR THE NORTHERN DISTRICT OF GEORGIA D e p i ^ l e r l c U N ITED STATES OF AMERICA Indictment/ Information l : 1 6 C H 6 7 J Tyson Rhame UNDER SEAL Agent to Arrest T A si o ' * • '• ' ' PRAECIPE - The Clerk is hereby directed to issue a warrant for arrest, certified copy (copies) of indictment attached, returnable instanter, in the above-stated case. Thomas J. Krepf Assistant United States Attorney Filed In Clerk's Office, this day of , 20 Clerk By ^ Deputy Clerk Form No, USA-19-8 (Rev. 08/06/87) N.D.G,), 08/26/94 Case 1:16-cr-00067-SCJ-CMS Document 8 Filed 02/10/16 Page 1 of 1
  50. 50. FILED mOPF.N COURT ] I Q n C' , L , . - > U.S. Department of Justice UnIted 5tates Attorney ^fl 7 QiJiF James '^''"^ I N T H E U N I T E D S T A T E S D I S T R I C T C O U R T %• De^^IyCi^k FOR THE NORTHERN DISTRICT OF GEORGIA U N ITED STATES OF AMERICA Indictment/ Information 1 : 1 6 C R 6 7 i Terrence Keller, a/k/a TerryK UNDER SEAL • 'ISSUED AMD n^^r.^^nEO Agent to Arrest TO U.S. MAkapAL ^ I / I L l k — ^ DEPUTY CLERK PRAECIPE ' The Clerk is hereby directed to issue a warrant for arrest, certified copy (copies) of indictment attached, returnable instanter, in the above-stated case. Thomas J. K/epp Assistant United'States Attorney Filed In Clerk's Office, this day of , 20 Clerk By _ Deputy Clerk Form No, USA-19-8 {Rev, 08/06/87) N.D,G,i, 08/26/94 Case 1:16-cr-00067-SCJ-CMS Document 9 Filed 02/10/16 Page 1 of 1
  51. 51. FILED IN OPEN COURT U.S. Departmenl of Justice FCD | ft ^ f l J C United suites AHorney ' ^ ^ ^.0 10 James .. s ^ . Deputy'Clerk I N T H E U N I T E D S T A T E S D I S T R I C T C O U R T FOR THE NORTHERN DISTRICT OF G E O R G I A UNITED STATES OF AMERICA Indictment/ Information 1 : 1 6 C 1 6 7 ^ James Shaw UNDER SEAL |ce! fcrr) ANO nr.LfVEP.HD Agent to Arrest TO U.S. ^lAFiSl-iAL PRAECIPE _ DEPUTYCLEW The Clerk is hereby directed to issue a warrant for arrest, certified copy (copies) of indictment attached, returnable instanter, in the above-stated case. fhomas J. Krepjy Assistant United States Attorney Filed In Clerk's Office, this _^ day of , 20 . Clerk By Deputy Clerk Form No, USA-19-8 (Rev, 08/06/87) N,D,Ga, 08/26/94 Case 1:16-cr-00067-SCJ-CMS Document 10 Filed 02/10/16 Page 1 of 1
  52. 52. FILED m OPEN COURT U.S. Department of Justice United States Attorney FEB 1 II 2016 IN T H E U N I T E D S T A T E S D I S T R I C T C O U R T D e W o ^ FOR THE NORTHERN DISTRICT OF GEORGIA UNITED STATES OF AMERICA Indictment/ Information , l : 1 6 C l 8 f 4 Frank Bell UNDER SEAL Agent to Arrest ' ISSUED AND OEUVEPED TO U,.S. MARSHAL BEPyW CLERK P R A E C I P E The Clerk is hereby directed to issue a warrant for arrest, certified copy (copies) of indictment attached, returnable instanter, in the above-stated case. Thomas J. Krep' Assistant United States Attorney Filed In Clerk's Office, tliis _ _ _ _ _ day of , 20 . . Clerk By Deputy Clerk Form No. US.Vig-S {Rev, 08/06/87) N.D.Cl, 08/26/94 Case 1:16-cr-00067-SCJ-CMS Document 11 Filed 02/10/16 Page 1 of 1
  53. 53. " . ORIGINAL FILEDINCHAMBERS FEB .WO!�_ ,_/) U.S. MAGlsTRAlCTLJDQ'E ND. GEORGIAIN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA Criminal Action No. 1:16:CR-67 v. TYSON RHAME, et. al. Motion to Unseal Indictment, Motion to Seal, and Order to Seal The United States of America, by John A. Horn, United States Attorney, and Thomas J. Krepp, Assistant United States Attorney for the Northern District of Georgia, moves this court to unseal the above-referenced Indictment, Motion to Seal, and Order to Seal, and in support thereof shows that each of the named defendants are believed to be self-surrendering this morning. Accordingly, there is no longer a need for this indictment to remain under seal. The government requests the unsealing of this indictment so that it may be provided during the defendants' anticipated initial appearances. WHEREFORE, the United States of America respectfully requests that the above-referenced Indictment, Motion to Seal, and Order to Seal be unsealed. Case 1:16-cr-00067-SCJ-CMS Document 12 Filed 02/22/16 Page 1 of 2
  54. 54. ·- . Submitted this 22nd day of February 2016. Respectfully submitted, JOHN A. HORN United States Attorney �#;///sffhomas J. Krepp Assistant United States Attorney Georgia Bar No. 346781 Thomas.Krepp@usdoj.gov 2 Case 1:16-cr-00067-SCJ-CMS Document 12 Filed 02/22/16 Page 2 of 2
  55. 55. ORIGINAL IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION FILED INCHAMBERS FE�.J'J �16 ,p, U.S.MA�E ND. GEORGIA UNITED STATES OF AMERICA Criminal Action No. 1:16:CR-67 v. TYSON RHAME, et. al. Order It is hereby ordered that the Indictment, Motion to Seal, and Order to Seal listed above be unsealed this 1-2J day of ff.ibfvv,,cj , 2016. AJ3ALAN J. BAVERMAN UNITED STATES MAGISTRATE JUDGE Presented by: Thomas J. Krepp, Assistant United States Attorney Case 1:16-cr-00067-SCJ-CMS Document 13 Filed 02/22/16 Page 1 of 1
  56. 56. hflAGISTRATE'S CRIMINAL MINUTES ARRAIGNMENT PLEA AND SENTENCE Filed in Open Court: Date: 2/22/16 Magistrate (presiding):ALAN J. BAVERMAN Time in Court: 1 Hrs 36 Mins Time: 1:39 pm Tape: FTR Deputy Clerk: Lisa Enix CASE NO.. AUSA: USPO/PTR: 1:16-CR-0067-1 Thomas Krepp, Steven Grimberg & Jamie Mickelson Defendant's Name: Tyson Rhame Defendant's Atty: Michael Brown Antwan Walker Type Counsel: Retained ARREST DATE: INTERPRETER: INITIAL APPEARANCE HEARING. ( ) IN THIS DISTRICT Dft in custody? ( ) Yes ( ) No Defendant advised of right to counsel. ( ) WAIVER OF COUNSEL FILED. ORDER appointing Federal Defender Program as counsel. ( ) INITIAL APPEARANCE ONLY. ORDER appointing as counsel. ORDER giving defendant days to employ counsel. Dft to pay attorney fees as follows: INFORMATION/COMPLAINT FILED. Copy indictment given to dft? (X ) Yes () No WAIVER OF INDICTMENT FILED, Read to dft? ( ) Yes ( ) No (X) Prior to Hrg CONSENT TO TRIAL BEFORE MAGISTRATE (Misd / Petty) offense filed. ARRAIGNMENT HELD. ( ) Superseding indictment ( ) Dft's WAIVER of appearance filed. Arraignment continued to at Request of ( ) Govt ( ) Dft Dft failed to appear for arraignment. Bench warrant issued Dft enters PLEA OF NOT GUILTY. ( ) Dft stood mute; plea of NOT GUILTY entered. ( ) Waiver of appearance. MOTION TO CHANGE PLEA, and order allowing same. PLEA OF GUILTY / NOLO as to counts Petition to enter PLEA OF GUILTY / NOLO filed. NEGOTIATED PLEA between Government and defendant filed. Assigned To Judge JONES for ( X ) trial ( ) arraignment/sentence. Assigned to Magistrate SALINAS for pretrial proceedings. Estimated trial time: days. ( ) SHORT ( ) MEDIUM (X) LONG Case 1:16-cr-00067-SCJ-CMS Document 14 Filed 02/22/16 Page 1 of 3
  57. 57. ARRAIGNMENT - Pg. 2 CASE NO: l:16-CR-0067-l-SCJ-CMS CONSENT TO PRE-SENTENCE INVESTIGATION filed. Referred to USPO for PSI and continued until at for sentencing. GOVERNMENT MOTION FOR DETENTION FILED. Hearing set at TEMPORARY COMMITMENT ISSUED. DFT REMANDED TO CUSTODY OF US MARSHALS SERVICE. BOND/PRETRIAL DETENTION HEARING J ( BOND / PRETRIAL DETENTION HEARING HELD. BOND HEARING HELD. GOVERNMENT MOTION FOR DETENTION ( ) GRANTED ( ) DENIED ( ) WITHDRAWN WRITTEN ORDER TO FOLLOW. HEARING HELD on motion for reduction / modification of bond. MOTION FOR REDUCTION OF BOND / MODIFICATION OF BOND ( ) GRANTED ( ) DENIED. WRITTEN ORDER TO FOLLOW. _X BOND SET at $1,000,000 (one million) _K NON-SURETY SURETY ( )CASE ( )PROPERTY ( )CORPORATE SURETY J ( SPECIAL CONDITIONS: Post $1 million cash with Registry of Court 48 hours before U.S. Virgins trip and defendant shall have money refunded when he returns from the trip. Nationwide travel for business with 48 hours notice to Pretrial Services; on upcoming trip may not visit British Virgin Islands, See attachment about No Contact Order. X BOND FILED; DEFENDANT RELEASE. BOND NOT EXECUTED. DEFENDANT TO REMAIN IN MARSHAL'S CUSTODY. WITNESSES: SENTENCE: Case 1:16-cr-00067-SCJ-CMS Document 14 Filed 02/22/16 Page 2 of 3
  58. 58. U.S. Department of Justice United States Attorney FILED IN OPEN COURT i I n o. Atlanta ^r.^ FEB 2 2 Zaj6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF G E O R G I A JAMBS Ni. HA I : B y : " ^ - ^ . t y P L E A ( W i t h C o u n s e l ) CRIMINAL NO. l:16-CR-67 C T y s o n R h a m e , d e f e n d a n t , h a v i n g r e c e i v e d a c o p y o f t h e w i t h i n I n d i c t m e n t , a n d h a v i n g b e e n a r r a i g n e d p l e a d N o t G u i l t y t h e r e t o t o c o u n t s 1 t h r o u g h 2 4 t h e r e o f . I n O p e n C o u r t t h i s 2 2 n d d a y o f F e b r u a r y , 2 0 1 6 . 1 ^ • ^ / S I G N A T U R E ( D e f e n s e A t t o r n e y ) ^ ^ ^ N A T U R E ( D e f e n d a n t ) ^ ^ s o n R h a m e I N F O R M A T I O N B E L O W M U S T B E T Y P E D O R P R I N T E D P h o n e : - B a r N u m b e r : P h o n e : ^iM M 91 7 ^ 7 F i l e d i n O p e n C o u r t b y : ( S i g n a t u r e ) D a t e Form No. USA-40-;l9-B N.D. Ga. 11/8/12 Case 1:16-cr-00067-SCJ-CMS Document 14 Filed 02/22/16 Page 3 of 3
  59. 59. AO 98 (Rev. 12/11) Appearance Bond Page 1 hILbU INUPhlMUiJlHU UNITED STATES DISTRICT COUES+S.D.G. A t l a n t a FEB 2 2 2016 M E S N ^ A T T m L C DepufyCIerk Case No. 1:16-CR-0067-l-SCJ-CMS for the Northern District of Georgia United States of America V. TYSON RHAME Defendant JAI By: APPEARANCE BOND Defendant's Agreement I, TYSON RHAME (defendant), agree to follow every order of this court, or any court that considers this case, and I further agree that this bond may be forfeited if I fail: ( X ) to appear for court proceedings; ( X ) if convicted, to surrender to serve a sentence that the court may impose; or ( X ) to comply with all conditions set forth in the Order Setting Conditions of Release. Type of Bond ( ) (1) This is a personal recognizance bond. ( X ) (2) This is an unsecured bond of $ 1,000,000 (one million) ( ) (3) This is a secured bond of $ , secured by: ( ) (a) $ , in cash deposited with the court. ( ) (b) the agreement of the defendant and each surety to forfeit the following cash or other property (describe the cash or other property, including claims on it — such as a lien, mortgage, or loan — and attach proof of ownership and value): If this bond is secured by real property, documents to protect the secured interest may be filed of record. ( ) (c) a bail bond with a solvent surety (attach a copy of the bail bond, or describe it and identify the surety): Forfeiture or Release of the Bond Forfeiture of the Bond. This appearance bond may be forfeited if the defendant does not comply with the above agreement. The court may immediately order the amount of the bond surrendered to the United States, including the security for the bond, if the defendant does not comply with the agreement. At the request of the United States, the court may order a judgment of forfeiture against the defendant and each surety for the entire amount of the bond, including interest and costs. Release ofthe Bond. The court may order this appearance bond ended at any time. This bond will be satisfied and the security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to serve a sentence. Case 1:16-cr-00067-SCJ-CMS Document 15 Filed 02/22/16 Page 1 of 3
  60. 60. AO 9iS (Rev. 12/11) Appearance Bond Page 2 Declarations Ownership of the Property. I, the defendant - and each surety - declare under penalty of perjury that: (1) all owners of the property securing this appearance bond are included on the bond; (2) the property is not subject to claims, except as described above; and (3) I will not sell the property, allow further claims to be made against it, or do anything to reduce its value while this appearance bond is in effect. Acceptance. I, the defendant - and each surety - have read this appearance bond and have either read all the conditions of release set by the court or had them explained to me. I agree to this Appearance Bond. I, the defendant - and each surety - declare under penalty of perjury that this information is true. (See 28 U.S.C. § 1746.) Date: 2/22/16 X Defendant's signature (1) Surety/property owner-printed name (1) Surety/property owner — signature and date (1) Surety/property owner's address (1) Surety/property owner's city/state/zip (2) Surety/property owner -printed t (2) Surety/property owner — signature and date (2) Surety/property owner's address (2) Surety/property owner's city/state/zip (3) Surety/property owner - printed name (3) Surety/property owner — signature and date (3) Surety/property owner's address (3) Surety/property owner's city/state/zip CLERK OF COURT Date: Signature of Clerk or Deputy Clerk APPROVED Date: Alan J. Bavermcm, United States Magistrate Judge Case 1:16-cr-00067-SCJ-CMS Document 15 Filed 02/22/16 Page 2 of 3
  61. 61. No Contact Order No contact with any individual that the defendant has direct knowledge is: (1) A current or former Sterling customer except as is necessary to wind down Sterling business operations. The govemment must be notified i f and when customers are contacted for this purpose. (2) A former Sterling employee or contractor unless the contact relates to separate business transactions between the defendant and that individual. Under no circumstances may the defendant discuss the facts of this case with these individuals. (3) A current or former Sterling agent or reseller. (4) A follower, member or administrator of The GET Team and/or People's Talk Radio. *For purposes of these restrictions, "Sterling" refers to "Sterling Currency Group," "Sterling Online Processing Services," and "Dinar Banker." Case 1:16-cr-00067-SCJ-CMS Document 15 Filed 02/22/16 Page 3 of 3
  62. 62. A0 199A(Rev. 12/11) Order Setting Conditions of Release Page 1 of 3 Pages V. TYSON RHAME Defendant Case No.: l:16-CR-0067-01 UNITED STATES DISTRICT COIM^PJN OPEN COURT for the U.S.D.C. Atlanta Northern District of Georgia i FEB 2 ^ 2018 ; JAMES H •flATpKCMc UNITED STATES OF AMERICA ) [ Depuftte* ' _ O R D E R S E T T I N G CONDITIONS O F R E L E A S E IT IS ORDERED that the defendant's release is subject to these conditions: (1) The defendant must not violate federal, state, or local law while on release. (2) The defendant must cooperate in the collection of a DNA sample if it is authorized by 42 U.S.C. § 14135a. (3) The defendant must advise the court or the pretrial services office or supervising officer in writing before making any change of residence or telephone number. (4) The defendant must appear in court as required and, if convicted, must surrender as directed to serve a sentence that the court may impose. The defendant must appear at: Place on Date and Time If blank, defendant will be notified of next appearance. (5) The defendant must sign an Appearance Bond, if ordered. Case 1:16-cr-00067-SCJ-CMS Document 16 Filed 02/22/16 Page 1 of 3
  63. 63. AO 199B (Rev. 12/11) Additional Conditions of Release Page j _ of j _ Pages ADDITIONAL CONDITIONS OF R E L E A S E IT IS FURTHER ORDERED that the defendant's release is subject to the conditions marked below: ( ) (6) The defendant is placed in the custody of Person or organization Address (only if above is an organization) City and state Tel. No. i^uy ariu siaie . -— ; ,. , - who agrees to (a) supervise the defendant, (b) use every effort to assure the defendant's appearance at all court proceedings, and (c) notify the court immediately if the defendant violates a condition of release or is no longer in the custodian's custody. Signed: Custodian Date ( X ) (7) The defendant must: submit to supervision by and report for supervision ( X ) (a) to the ( x) U.S. Pretrial Services ( ) U.S. Probation Office lO LllC y ^ -V/ telephone number 404-215-1950 , ( ) No later than y ^ B e f o r e leaving courthouse, jOT ( X ) (b) maintain or actively seek lawful and verifiable employment. ( ) (c) continue or start an education program. ( X ) (d) surrender any passport to your supervising officer bv : i h ' t U ^ , and do not obtain nor possess a passport or other international travel document, not obtain or possess a passport or other international travel document in your name, another name or on behalf of a third party, including minor children. ( X ) (e) abide by the following restrictions on personal association, residence, or travel: J^ide^address_piwided t o j ^ ^ and do not change your address or telephone number w/o written PTS pre^approyaj ( X ) (f) avoidallcontact, directly or indirectly, with any person who is or may be a victim or witness in the investigation or prosecution, including: any and all co-defendants and/or unindicted co-conspirators ^ j t^^l|)i4>r^_i_iJ|a:^.^ri-4 j I,)taJj^-^m^ - T ( ) (g) get medical or psychiatric treatment: ( ) as directed by your supervising officers ( ) ( ) (h) maintain residence at a halfway house or community cortcctions center, as the pretrial services office or supervising officer considers necessary. ( X ) (i) not possess a firearm, destructive device, other weapon, or ammunition, in your home, vehicle or place of employment, or upon your person. ( X ) (j) not use alcohol ( ) at all ( x ) excessively. ( X ) (k) not use or unlawfully possess a narcotic drug or other controlled substances defined in 21 U.S.C. § 802, unless law&lly prescribed by a licensed medical practitioner. . • t, ( ) (1) submit to testing for a prohibited substance if required by the pretrial services office or supervising officer. Testing may be used with random frequency and may include urine testing, the wearing of a sweat patch, a remote alcohol testing system, and/or any form of prohibited substance screening or testing. The defendant must not obstruct, attempt to obstruct, or tamper with the efficiency and accuracy of prohibited substance screening or testing. ( ) (m) participate in a program of inpatient or outpatient substance abuse therapy and counseling i f directed by the pretrial services office or supervising officer. ( ) (n) participate in one ofthe following location restriction programs and comply with its requirements as directed. ( ) (i) Curfew. You are restricted to your residence every day ( ) from to , or ( ) as directed by the pretrial services office or supervising officer; or ( ) (ii) Home Detention. You are restricted to your residence at all times except for employment; education; religious services; medical, substance abuse, or mental health treatment; attorney visits; court appearances; court-ordered obligations; or other activities approved in advance by the pretrial services office or supervising officer; or ( ) (iii) Home Incarceration. You are restricted to 24-hour-a-day lock-down at your residence except for medical necessities and court appearances or other activities specifically approved by the court. ( ) (o) submit to location monitoring as directed by the pretrial services office or supervising officer and compfy with all of the program requirements and instructions provided. . , . ( ) You must pay all or part of the cost of the program based on your ability to pay as determined by the pretrial services office or supervising officer. ( X ) (p) report within 72 hours to the pretrial services office or supervising officer, every contact with law enforcement personnel, including arrests, questioning, or traffic stops. ( X ) (p) restrict travel to the Northern District of Georgia unless the supervising officer has approved travel m advance. ( (s) J ^ . H i i « i t t i M _ ^ ^ ' ' » J _ 4 ^ ^ V j L _ ' £ ^ ^ (X ) (t) ^ ' ^ ^ ^ • ' L ^ - Z ^ . i M i ^ K i Case 1:16-cr-00067-SCJ-CMS Document 16 Filed 02/22/16 Page 2 of 3
  64. 64. <sa;AO 199C (Rev. 12/03) Advice of Penalties Advice of Penalties and Sanctions TO THE DEFENDANT: YOU ARE ADVISED OF THE FOLLOWING PENALTIES AND SANCTIONS: Violatine any ofthe foregoing conditions of release may result in the immediate issuance of a warrant for your arrest a revocalrn S e a s e , an order of deLtion, a forfeimre of any bond, and a prosecution for contempt of court and could result m a term ° ' " ^ ' ^ m r o l l e t : : " y o t o m m l t a federal felony offense, the punishment is an additional pnson term of not more than ten years; if^ou comr^it a federal misdemeanor offense, the punishment is an additional prison term of not more than one year. Thts sentence will be consecutive (/.a, in addition to) any other sentence you receive. , h is a crime puni hable by up to ten years of imprisomnent and a $250,000 fme or both to: obstruct a crimmal investi a on ta^p^^^^ h a wimes's, victim' or informant; or intimidate or attempt to intimidate a witness, victim, juror mfonnant or X e ; olthe court The penalties for tampering, retaliation, or intimidation are significantly more serious if they mvolve a kilhng or attempted kiUing^ you knowingly fail to appear as required by the conditions of release, or to surrender for vou mav be nrosecuted for failing to appear or surrender and additional punishment may be imposed. If you are convicted of you j^^^P™-;^fp^;^ I X life imprisomnent, or imprisonment for a term of fifteen years or more, you shall be fined not more than $250,000 or imprisoned for not more than 10 years, or both; (2) an offense punishable by imprisomnent for a term of five years or more, but less than fifteen years, you shall be fined not more than $250,000 or imprisoned for not more than five years, or both; (3) any other felony, you shall be fined not more than $250,000 or imprisoned not more than two years, or both, 4 a misdemeanor, you shall be fmed not more than $100,000 or imprisoned not more than one year, or both. A term of imprisonment imposed for failure to appear or surrender shall be in addition to the sentence for any other offense. In addition, a failure to appear or surrender may result in the forfeitttre of any bond posted. Acknowledgment of Defendant I acknowledge that I am the defendant in this case and that I am aware ofthe conditions of release. I promise to obey all conditions of relea", to appe^^^^^^^^^^ and to surrender for service of any sentence imposed. I am aware of the^^enalties and sanctions set forth above. Signature of Defendant Address City and State Telephone Directions to United States Marshal ; X "tS: ' ^ ^ ^ ^ " t Z f ^ ^ T ^ ^ ^ ' ^ ^ - " -tody - i , notified *e de,. or .ud.e .ha, .he defend™. < * S s pos«d b o „ ? L " complied wid, all o.her IdKlons for release. If s.ill i . cus.ody. .he defendan. mus. be produced before the appropriate judge at the time and place specified. ! D^^^- " ^ i . ' ' " i ' ' fsignature of Judicial Officer Al .AN .1. BAVERMAN . U. S. MAGISTRATE JUDGE Name and Title of Judicial Officer DISTRIBUTION: COURT DEFENDANT PRETRIAL SERVICE U.S. ATTORNEY U.S. MARSHAL Case 1:16-cr-00067-SCJ-CMS Document 16 Filed 02/22/16 Page 3 of 3
  65. 65. ILED IN CHAMBER? IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA TYSON RHAME, U.S. MA( N D. GEORGIA CRIMINAL ACTION NO. l:16-CR-0067-01-SCJ-CMS ORDER The sum of $1,000,000 (one million dollars) is to be paid into the registry of this Court by Tyson Rhame 48 (forty-eight) hours before his travels to the Virgin Islands. This cash bond is only posted to secured the defendant retum from a one-week trip to the Virgin Islands. After the defendant returns from his trip, the money shall be refunded to him. It is hereby O R D E R E D , that the Clerk of Court is hereby directed to deposit the sum of $1,000,000 (one million dollars) into the registry ofthe Court. IT IS SO ORDERED this 22nd day of February, 2016. A L A N J. B A V E R M A N UNITED STATES MAGISTRATE JUDGE Case 1:16-cr-00067-SCJ-CMS Document 17 Filed 02/22/16 Page 1 of 1
  66. 66. MAGISTRATE'S CRIMINAL MINUTES ARRAIGNMENT PLEA AND SENTENCE Filed in Open Court: Date: 2/22/16 Magistrate (presidinaVALAN J. BAVERMAN 1:16-CR-0067-2 Time in Court: J Hrs 36 Mins Time: 1:39 pm Tape: FTR Deputy Clerk: Lisa Enix CASE NO.. AUSA: USPO/PTR: Thomas Krepp, Steven Grimberg & Jamie Mickelson Defendant's Name: Terrence Keller Defendant's Atty: Tom Hawker Matthew Lawrimore Type Counsel: FDP ARREST DATE: INTERPRETER: INITIAL APPEARANCE HEARING. ( ) IN THIS DISTRICT Dft in custody? { ) Yes ( ) No Defendant advised of right to counsel. ( ) WAIVER OF COUNSEL FILED. ORDER appointing Federal Defender Program as counsel. ( ) INITIAL APPEARANCE ONLY. ORDER appointing as counsel. ORDER giving defendant days to employ counsel. X Dft to pay attorney fees as follows: $1,000 into the Registry of the Court the 1°' of every month. INFORMATION/COMPLAINT FILED. Copy indictment given to dft? (X ) Yes ( ) No WAIVER OF INDICTMENT FILED. Read to dft? ( ) Yes ( ) No (X ) Prior to Hrg CONSENT TO TRIAL BEFORE MAGISTRATE (Misd / Petty) offense filed. ARRAIGNMENT HELD. ( ) Superseding indictment ( ) Dft's WAIVER of appearance filed. Arraignment continued to at Request of ( ) Govt ( ) Dft Dft failed to appear for arraignment. Bench warrant issued Dft enters PLEA OF NOT GUILTY. ( ) Dft stood mute; plea of NOT GUILTY entered. ( ) Waiver of appearance. MOTION TO CHANGE PLEA, and order allowing same. PLEA OF GUILTY/NOLO as to counts Petition to enter PLEA OF GUILTY / NOLO filed. NEGOTIATED PLEA between Government and defendant filed. Assigned To Judge JONES for ( X ) trial ( ) arraignment/sentence Assigned to Magistrate SALINAS Estimated trial time: days. for pretrial proceedings. ( ) SHORT 0 MEDIUM (X)LONG Case 1:16-cr-00067-SCJ-CMS Document 18 Filed 02/22/16 Page 1 of 3
  67. 67. ARRAIGNMENT - Pg. 2 CASE NO: l:16-CR-0067-2-SCJ-CMS CONSENT TO PRE-SENTENCE INVESTIGATION filed. Referred to USPO for PSI and continued until at for sentencing. GOVERNMENT MOTION FOR DETENTION FILED. Hearing set at TEMPORARY COMMITMENT ISSUED. DFT REMANDED TO CUSTODY OF US MARSHALS SERVICE. BOND/PRETRIAL DETENTION HEARING X BOND / PRETRIAL DETENTION HEARING HELD. BOND HEARING HELD. GOVERNMENT MOTION FOR DETENTION ( ) GRANTED ( ) DENIED ( ) WITHDRAWN WRITTEN ORDER TO FOLLOW. HEARING HELD on motion for reduction / modification of bond. MOTION FOR REDUCTION OF BOND / MODIFICATION OF BOND ( ) GRANTED ( ) DENIED. WRITTEN ORDER TO FOLLOW. X BOND SET at $ 100,000 X NON-SURETY SURETY ( )CASE ( )PROPERTY ( )CORPORATE SURETY X Special Conditions: No publicly posting or discussing or publishing information regarding Iragi dinar or other foreign currency on the Internet, conference calls or other media. May travel for work with notice to pretrial sen/ices; see attachment No Contact Order. X BOND FILED; DEFENDANT RELEASE. BOND NOT EXECUTED. DEFENDANT TO REMAIN IN MARSHAL'S CUSTODY. WITNESSES: SENTENCE: Case 1:16-cr-00067-SCJ-CMS Document 18 Filed 02/22/16 Page 2 of 3
  68. 68. U.S. Departiiient of justice United States Attorney U.S.D.C. Atlanta IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF G E O R G M '"E-B 2 ^ Z016 J A _ M ^ ; H M T E N , fej^rk P L E A (With Counsel) CRIMINAL NO. f :16-CR-67 I, Terrence Keller, defendant, having received a copy of the within Indictinent, and having been arraigned plead Not Guilty thereto to counts 1 through 11 thereof. In Open Court this 27.j^& day of February, 2016. S K N A T U ^ ^ ' Attorney) INFORMATION BELOW MUST BE TYPED OR PRINTED Phone: ^ O^l^^X 'l^^^Q^ Bar Number: Phone: iolet ipeps^ouff 5ignatit/e)— Date Form No. USA-40-19-B N,D. Ga. ri/8/12 Case 1:16-cr-00067-SCJ-CMS Document 18 Filed 02/22/16 Page 3 of 3
  69. 69. FILED IN OPEN COURT U.S.D.C. Atlanta . UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA I ATLANTA DIVISION ? UNITED STATES OF AMERICA, Plaintiff, vs. CASE NO. 1:16-CR-67-2 TERRENCE KELLER Defendant. ORDER APPOINTING COUNSEL TOM HAWKER The above-named defendant has testified under oath or has filed with the Court an affidavit of financial status and hereby satisfied this Court that he or she is financially unable to employ counsel. Accordingly, the FEDERAL DEFENDER PROGRAM, INC., is hereby appointed to represent this defendant in the above-captioned case unless relieved by an Order of this Court or by Order of the Court of Appeals. Dated at Atlanta, Georgia this 22nd day of February, 2016. UNITED STATE'% MAGISTRATE JUDGE Case 1:16-cr-00067-SCJ-CMS Document 19 Filed 02/22/16 Page 1 of 1
  70. 70. ^CJA7 ("Rev. 9/05) . ^ ^ , , LOCATION CODE FILED IN OPEN COURT U.S.D.C. Atlanta , . . . |. F E B 2 2|Q16 ' • rX?*, Docket No. L16-CR-0067-2-SCJ ^^/^'^^^'DeputyCpc Oia)ER TERMINATING ^ APPOINTMENT OF COUNSEL • USA vs. TERRENCE KELLER and/or Check A U T H O R I Z A T I O N F O R one or D I S T R I B U T I O N O F both A V A I L A B L E P R I V A T E X FUNDS WHEREAS, TOM HAWKER was appointed as counsel for the above df^fendant/petitioner. on the 22^° dav of February , 20 _16_; and WHEREAS, the court finds that funds are available from or on behalf of the above named defendant/petitioner for payment of compensation and expenses of court-appointed counsel and/or for other services necessary for adequate representation, and thatthe above defendant/petitioner is therefore financially able to obtain counsel or to make partial payment for representation, and/or for other services necessary for adequate representation; IT IS THEREFORE: Check • ORDERED that the appointment of said counsel is hereby terminated, one or both X AUTHORIZED/DIRECTED that such fiinds in the amount of $ 1,000 be paid by said defendant/petitioner or by as follows: (enter specific terms of repayment, i.e., date due if lump-sum payment; schedule and amounts of each payment if installment payment.) The defendant is qualified for court appoint counsel, the Defendant is order to pay $1,000.00 into the Registry of the Court on the 1"^ day of every month. The first payment shall be due on March 1, 2016. Dated this 22nd dayof February ,20 16 . UnitedStates Judge/Magistrate DISTRIBUTION: COURT'S F I L E COURT APPOINTED COUNSEL PERSON REPRESENTED C L E R K ' S F I L E Case 1:16-cr-00067-SCJ-CMS Document 20 Filed 02/22/16 Page 1 of 1
  71. 71. lev. 12/11) Appearance Bond Page 1 UNITED STATES DISTRICT COURT^^^-^-^" ^^^^"^^ for the FEB 2 2 2|16 Northern District of Georgia United States of America V. TERRENCE KELLER Defendant Case No. l:16-CR-0067-2 APPEARANCE BOND Defendant's Agreement I TERRENCE KELLER (ye/e«(^an<;, agree to follow every order of this court, or any c'ourtthat considers this case, and Ifiirther agree that this bond may be forfeited if I fail: ( X ) to appear for court proceedings; ( X ) if convicted, to surrender to serve a sentence that the court may impose; or ( X ) to comply with all conditions set forth in the Order Setting Conditions of Release. Type of Bond ( ) (1) This is a personal recognizance bond. ( X ) (2) This is an unsecured bond of $ 100,000 ( ) (3) This is a secured bond of $ , secured by: ( ) (a) $ J in cash deposited with the court. ( ) (b) the agreement ofthe defendant and each surety to forfeit the following cash or other property (describe the cash or other property, including claims on it-such as a lien, mortgage, or loan - and attach proof of ownership and value); I f t h i s bondirsecuredby^reafproperty^o^mentstol^rotect the secured interest may be filed of record. ( ) (c) a bail bond with a solvent surety (attach a copy of the bail bond or describe it and identify the surety): Forfeiture or Release of the Bond Forfeiture ofthe Bond. This appearance bond may be forfeited if the defendant does not comply with the above agreement. The court may immediately order the amount ofthe bond surrendered to the United States, including the security for the bond, if the defendant does not comply with the agreement. At the request of the United States, the court may order a judgment of forfeiture against the defendant and each surety for the entire amount ofthe bond, includmg interest and costs. ^- r- . J Release ofthe Bond The court may order this appearance bond ended at any time. This bond will be satisfied and the security will be released when either: (1) the defendant is found not guilty on all charges, or (2) the defendant reports to serve a sentence. Case 1:16-cr-00067-SCJ-CMS Document 21 Filed 02/22/16 Page 1 of 2

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