Guru Revaluation Scam - Sterling Currency Group

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

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
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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.
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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
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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.
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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."
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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
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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:
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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)
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.
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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))
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

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)
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:
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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
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
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."
2089, to another Merrill Lynch account controlled by
SHAW, ending in account number 2066.
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2062, to a Wells Fargo account controlled by Rhame,
ending in account number 5439.
2089, to a Merrill Lynch account controlled by SHAW,
23 01/07/2015 Transfer in the amount of $750,000 from a Merrill Lynch
2089, to a Merrill Lynch account controlled by SHAW,
2062, to a Wells Fargo account controlled by RHAME,
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
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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;
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2) $200,000.00 seized from Actors Federal Credit Union account
number XXXXOl-76;
number XXXXOl-99;
number XXXX02-75;
number XXXX02-76;
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;
XXX-X0478;
XXX-X0479;
XXX-X0480;
XXX-X0488;
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15) $100,002.56 seized from Merrill Lynch account number XXX-
X1015;
XXX-X2048;
XXX-X2049;
XXX-X2050;
XXX-X2062;
XXX-X2065;
XXX-X2066;
XXX-X2072;
XXX-X2087;
XXX-X2089;
XXX-X2386;
26) $5,177,314.90 seized from Merrill Lynch account number XXX-
X2391;
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XXX-X2421;
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;
XXX-XX5720;
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;
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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;
XXXXXX0132;
XXXXXX0165;
45) $126.02 seized from Wells Fargo account number XXXXXX0199;
XXXXXX0223;
XXXXXX0231;
XXXXXX0280;
XXXXXX0298;
XXXXXX0371;
XXXXXX0397;
XXXXXX0496;
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XXXXXX0579;
XXXXXX2673;
XXXXXX2681;
XXXXXX2821;
XXXXXX2839;
XXXXXX2850;
XXXXXXXXX3245;
XXXXXX3808;
61) $1,597,831.09 seized from Wells Fargo account number
XXXXXX4675;
XXXXXX4767;
XXXXXX5133;
64) $1,201,546.95 seized from Wells Fargo account number
XXXXXX5439;
XXXXXX5536;
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XXXXXX5551;
XXXXXX6320;
68) $1,611.81 seized from Wells Fargo Advisors account number
XXXX-6797;
XXXXXX7400;
70) $8,796.58 seized from Wells Fargo Advisors account number
XXXX-7939;
XXXXXX8032;
XXXXXX8575;
XXXXXX8594;
XXXXXX8658;
XXXXXX8674; and
XXXXXX9969;
B. CORPORATE AND TRUST ENTITIES:
1) Sterling Currency Group, LLC;
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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;
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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;
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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:
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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
2) around a curve to the right having a radius of 878.08 feet for
74°36' 47" W 99.57 feet) to a point; thence
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an arc distance of 100.88 feet (chord bearing and distance of N
82°02' 11" W 102.55 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
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
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the Survey filed of record in Map Book 50, at Page 476, of the
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

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.:
27

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

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
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
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

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

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

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,
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,
10) the real property located at 2294 Fernwood Drive, East Point,
32

11) the real property located at 1891 Connally Drive, East Point,
12) the real property located at 1901 Connally Drive, East Point,
13) the real property located at 2095 Newnan Avenue, East Point,
14) the real property located at 2225 Dodson Drive, East Point,
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

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
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

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

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

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
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

11) a total of approximately 1,000 in Union of Burma bank notes
June 3, 2015;
12) a total of approximately 1,000,000 in Republic of Iran bank notes
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
2015;
16) a total of approximately 9,300 in Bank of Yugoslavia notes seized
2015;
17) a total of approximately 155,000 in Cambodian Bank notes seized
2015;
18) a total of approximately 500 in Brazilian currency seized from
19) a total of approximately 1,000 in Bank of Sudan notes seized
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

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

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
Georgia Bar No. 312144
A
J ^ M I E L. M I C K E L S O N
600 U.S. Courthouse
75 Spring Street, S.W.
Atianta, GA 30303
404-581-6000; Fax: 404-581-6181
40

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

FEB 1 0 2016
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.

Submitted this 10* day of February 2016.
Respectfully submitted,
J O H N A . FIORN
/s/Thomas J. Krepp
Thomas.Krepp@usdoj.gov
2

ATLANTA DIVISION
FEB 1 » 2016
V.
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

U.S. Department of Justice
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:
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:

Division: Atlanta
(USAO: 2014R00956)
C O U N T Y N A M E : Fulton
X Indiciment Ii-iformation
DATE: February 10, 2016 DATE:
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
FEB 1 © 2016
1:16 CRG7D I S T R I C T C O U R T N O .
UNDER SEAL
Magistrate's Complaint
DATE:
Prior Case Number;
Date Filed:
District Judge:
Defense Attorney:

Division; Atlanta
(USAO: 2014R00956)
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
D I S T R I C T C O U R T N O . 1:1 6 CR6 7
UNDER SEAL
DATE:
Prior Case Number:
Date Filed:
District Judge:
Defense 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)
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 .
1!16CR67
UNDER SEAL
X Indictment
DATE: Februaiy 10, 2016
Information
DATE:
V8.
F R A N K B E L L
DATE:
Prior Case Number:
Date Filed:
District Judge:
Defense Attorney:

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
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

FILED mOPF.N COURT
] I Q n C' , L , . - >
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
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 '
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

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
fhomas J. Krepjy
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

FILED m OPEN COURT
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 ^
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
Thomas J. Krep'
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

" .
ORIGINAL
FILEDINCHAMBERS
FEB .WO!�_ ,_/)
U.S. MAGlsTRAlCTLJDQ'E
ND. GEORGIAIN THE UNITED STATES DISTRICT COURT
ATLANTA DIVISION
Criminal Action No. 1:16:CR-67
v.
Motion to Unseal Indictment, Motion to Seal, and Order to Seal
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.

·- .
Submitted this 22nd day of February 2016.
JOHN A. HORN
�#;///sffhomas J. Krepp
2

ORIGINAL
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.
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:

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

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.
_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:

FILED IN OPEN COURT
i I n o. Atlanta
^r.^ FEB 2 2 Zaj6
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

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.

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
(3) Surety/property owner - printed name (3) Surety/property owner — signature and date
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
APPROVED
Date:
Alan J. Bavermcm, United States Magistrate Judge

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."

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.

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.
iûy 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: Jîdeâddress_piwided t o j ^ ^
and do not change your address or telephone number w/o written PTS preâpproyaj
( 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
( 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

<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; ifôu comrît 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^ênalties 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

ILED IN CHAMBER?
ATLANTA DIVISION
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

MAGISTRATE'S CRIMINAL MINUTES
ARRAIGNMENT
PLEA AND
SENTENCE
Magistrate (presidinaVALAN J. BAVERMAN
1:16-CR-0067-2
Time in Court: J Hrs 36 Mins
CASE NO..
AUSA:
USPO/PTR:
& 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
X Dft to pay attorney fees as follows: $1,000 into the Registry of the Court the 1°' of every month.
Copy indictment given to dft? (X ) Yes ( ) No
WAIVER OF INDICTMENT FILED.
Read to dft? ( ) Yes ( ) No (X ) Prior to Hrg
PLEA OF GUILTY/NOLO as to counts
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

ARRAIGNMENT - Pg. 2 CASE NO: l:16-CR-0067-2-SCJ-CMS
X BOND / PRETRIAL DETENTION HEARING HELD.
BOND HEARING HELD.
X BOND SET at $ 100,000
X NON-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.
WITNESSES:
SENTENCE:

U.S. Departiiient of justice
U.S.D.C. Atlanta
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

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

^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

lev. 12/11) Appearance Bond
Page 1
UNITED STATES DISTRICT COURT^^^-^-^" ^^^^"^^
for the FEB 2 2 2|16
V.
TERRENCE KELLER
Defendant
Case No. l:16-CR-0067-2
APPEARANCE BOND
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:
Type of Bond
( X ) (2) This is an unsecured bond of $ 100,000
( ) (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 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
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
serve a sentence.

I 98 (Rev. 12/11) Appearance Bond —-—-—--===:=================================
Declarations
Ownership ofthe Property. I, the defendant - and each surety - declare under penalty of perjury that:
(1) aJ owners ofthe property securing this appearance bond are included on the bond;
(2) the prcoerty is not subject to claims, except as described above; and
(3) I will not seii the property, allow further claims to be made against it, or do anything to reduce its value
surety - declare under penalty of perjury that this information is hue. (See 28 U.S.C. § 1746.)
Date: 2/22/16 , , , ^ . , . ,
• < ^ r Mature
(1) Surety/property owner-printed name " ' " (1) Surety/property owner - signature and date
^i^rety/property owner S address 0) Surety/properly owner S city/state/zip
' (2) Surety/property owner- printed name ' (2) Surety/property owner - signature and date
'ftTSuretyfroperty owner S address " 0 Surety/property owner's eity/state/zip
(3) Surety/property owner - printed name
(3) Surety/property owner's address
(3) Surety/property owner — signature and date
(3) Surety/property owner's city/state/zip
CLERK OF COURT
Date:

AO 199A (Rev. 12/11) Order Setting Conditions of Release Page 1 of — 3 Pages
^^^I^ED IN OPEN COURT
UNITED STATES DISTRICT COURTU.S.D.C. Atlanta
for the
i FEB 2 2 Z016
Northern District of Georgia ; „ |
; By. Deputy CteriT/
V.
TERRENCE KELLER
Defendant
Case No.: 1:16-CR-0067-02
The defendant must appear at: _ _ _ _
Place
on
Date and Time

AO 199B (Rev. 12/11) Additional Conditions of Release ^ Page _7^_ of 3_ Pages
" ADDITIONAL CONDITIONS OF R E L E A S E
( ) (6) The defendant is placed in the custody of:
organization)
City and state Tel. No.
who agrees to (a) supervise the^d'efendant, (b) use every effort to assure the defendant's appearance at all court proceedings, and (c) notiiy the court immediately
Signed:
Custodian Date
x ) (a) to the ( x) U.S. Pretrial Services ( ) U.S. Probation Office
telephone number 404-215-1950 , ( ) No later than M Before leaving courthouse, OIL
) (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 by : i ^ i A f & f and do not obtain nor possess a passport or other mtemational
travel document, not obtain or possess a passport or other intemational travel document in your name, another name or on behall ol a
third party, including minor children. „ , • , c •
(e) abide by the following restrictions on personal association, residence, or travel: Reside at address provided_toPretna[Services
and do not change your address or telephone number w/o written PTS pre^^EroyaL
( X )
( X ) (f)
( ) (g)
( ) (h)
a i l U UU ilUL L-Iiailg,C- ^yULtl^ a . u t a i v j j yji i.-.^y^^^^^^^^ ^..^^^^^^^^^^ - ~
avoid all contact, 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-eonspirators m J ^ i i ^ ^ i L y > > t ^ _ ^
gM^-CL_-«<y 1 r ^
get medical or psychiatric treatment: ( ) as directed by your supervising officers ( )
( X ) (i)
( X ) G)
( X ) (k)
maintain residence at a hallway house or community corrections center, as the pretrial services office or supervising officer considers
necessary.
not possess a firearm, destructive device, other weapon, or ammunition, in your home, vehicle or place of employment, or upon your
person.
( x ) Ci) not use alcohol ( ) at all ( x ) excessively.
not use or unlawfaUy possess a narcotic drug or other controlled substances defmed in 21 U.S.C. § 802, unless lawfully prescribed by a
licensed medical practitioner. _ j -tu „A^^
( ) (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 forat of prohibited
( ) (m) participate in a program of inpatient or outpatient substance abuse therapy and counseling i f directed by the pretrial services olfiee or
( ) (n) participate in one ofthe following location restriction programs and comply with its requirements as directed.
substance abuse, or mental health tteatment; attorney visits; court appearances; court-ordered obligations; or other activtties
( ) (o) submit to location monitoring as directed by the prettial services office or supervising officer and comply with all ofthe program
requirements and instructions provided. . ^, • „r
( ) You must pay all or part ofthe cost ofthe program based on your ability to pay as determined by the pretrial services oftice or
arrests, questioning, or traffic stops. , • .
( X ) (p) restrict travel to the Northern District of Georgia unless the supervising officer has approved tt-avelm advance. .
( X )

%.A0 199C (Rev.12/03) Advice of Penalties
Page 3 of 3 Pages
TO THE DEFENDANT:
Violating any ofthe foregoing conditions of release may resuh in the immediate issuance of a warrant for your arrest, a
revocation of release, an order of detention, a forfeihire of any bond, and a prosecution for contempt of court and could result m a term
of imprisonment, a fme, or both. *
While on release if you commit a federal felony offense, the punishment is an additional pnson term of not more than ten
years; if you commit a federal misdemeanor offense, the punishment is an additional prison tenn of not more than one year. This sentence
will be consecutive (/. e., in addition to) any other sentence you receive.
It is a crime punishable by up to ten years of imprisonment and a $250,000 fine or both to: obstruct a crimmal
investigation' tamper with a witness, victim or infonnant; or intimidate or attempt to intimidate a witaess, victim, juror informant, or
officer ofthe court. The penahies for tampering, retaliation, or intimidation are significantly more serious if they involve a killing or
attempted kilhng^^^^^ you knowingly fail to appear as required by the conditions of release, or to sunender for the service of sentence,
vou may be prosecuted for failing to appear or sunender and additional punishment may be imposed. If you are convicted ot.
(1) an offense punishable by death, life imprisomnent, or imprisonment for a tenn of fifteen years or more, you shall be fmed
not more than $250,000 or imprisoned for not more than 10 years, or both; u „ u ^ *
(2) an offense punishable by imprisonment for a tenn of five years or more, but less than fifteen years, you shall be fined not
(3) any other felony, you shall be fmed 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 imprisomnent imposed for failure to appear or sunender shall be in addition to the sentence for any other offense. In
addition, a failure to appear or sunender may result in the forfeiftire of any bond posted.
I acknowledge that I am the defendant in this case and that I am aware ofthe condifions of release. I promise to obey all conditions
of release, to appear as directed, and to sunender for service of any sentence imposed. l am a w a i : ^ 4 h ^ h i e s and sanctions set forth
above. ^''""^'''^^^^^..^ )
Signahiree-fdefendant
Address
ofty and State / Telephone
( ) The defendant is ORDERED released after processing. ,u , ,u ^ fo„H.nt
f The United States marshal is ORDERED to keep the defendant in custody until notified by the clerk or judge that the defendant
^ ^ has posted bond and/or complied with all other conditions for release. If still in custody, the defendant must be produced before
the appropriate judge at the time and place specified.
Date: , 1 -
» Signature of Judicial Officer
ALAN J. BAVERMAN . U. S. MAGISTRATE JUDGE

No Contact Order
operations. The govemment must be notified if and when customers are contacted for this
purpose.

MAGirYftATE'S CRIMINAL MINUTES
ARRAIGNMENT
PLEA AND
SENTENCE
Filed In Open Court: Date: 2/22/16
Magistrate (presldinq):ALAN J. BAVERMAN
Time In Court: 1 Hrs 36 MIns
CASE NO..
AUSA:
USPO/PTR:
1:16-CR-0067-3
& Jamie Mickelson
Defendant's Name: James Shaw
Defendant's Atty: Donald Samuel
Lisa Moore Type Counsel: Retanled
ARREST DATE:
INTERPRETER:
Copy Indictment given to dft? (X ) Yes ( ) No
Assigned To Judge JONES f o r ( X ) trial ( ) arraignment/sentence.
Assigned to Magistrate SALINAS for pretrial proceedings.
Estimated trial time: days. ( ) SHORT ( ) MEDIUM (X) LONG

ARRAIGNMENT - Pg. 2 CASE NO: 1:16-CR-0067-3-SCJ-CMS
CONSENT TO PRE-SENTENCE INVESTIGATION filed, Referred to USPO for PSI and continued
BOND HEARING HELD.
X BOND SET at $ 100,000,000.00
_X NON-SURETY
X Special Conditions Post $2,000,000 (two million) into thie Registry of tiie Court 48 hours before travel to the
Bahamas and the defendant shall have money refunded when he returns from his trip; nationwide travel for
business permitted within 48 hrs notice to pretrial services, allow to travel for child's college interviews; see
attachment about no contact order, etc.
WITNESSES:
SENTENCE:

FILED IN OPEN COURT
IN THE UNITED STATES DISTRICT C G l M f D.C. Atlanta
FEB 2 2 2016
P L E A ( W i t h C o u n s e l ) ^ ^ ^ M e p u t y ^
CRIMINAL NO. f :16-CR-67
I, James Shaw, defendant, having received a copy of the within Indictment,
and having been arraigned plead Not Guilty thereto to counts 1 through 24
thereof.
In Open Court this 22nd day of February, 2016.
SIGNATURE (Defense'Attorneyj SICmTURE (Defendant)
Jarges Shaw
Phone; V / ^ ^ ' Z ^ Z - 2 2 2 < r
Bar Number: ^l¥¥7<' Phone: ^fOf- YOh O/^'^
Filed in Open Court by:
(Signature) Date
N.D. Ga. 11/8/12

AO , 12/11) Appearance Bond
FILED IMOPFM cnimp '^
U.S.D.C. Atlanta
for the ' FEB 2 2 2016
V.
Case No. 1:16-CR-0067-3-SCJ-CMS
JAMES SHAW
Defendant
L ^ ' Deputy Cleric ,
I,
APPEARANCE BOND
JAMES SHAW
- — (defendant), agree to follow every order of this court, or any. |...c.yl-.^..^l..,.^y, u.g,i VV IKJ lUllUW CV
( X ) if convicted, to surrender to serve a sentence that the court may impose' or
Type of Bond
( X ) (2) This is an unsecured bond of $ lJ)00,OOO^onejTiiflionl _
( ) (3) This is a secured bond of $ ^ secured by:
^ ) (^) $ , in cash deposited with the court.
(describe the cash or other property, including claims on it - such as a lien, mortgage, or loan - and attach proof of
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 ofthe bail bond, or describe it and identify the suretyf
Forfeiture or Release ofthe Bond
agreement. The court may immediately order the amount ofthe bond surrendered to the United States, including the
security for the bond, ,f the defendant does not comply with the agreement. At the request ofthe Unit d States L court
h t l T t t d ' f o s t r " ' '''''' '""^ «f ^he bond,tcluding
s r e ? s : L : e ^ ' ' ^ ^ ^ ' ' ' ' ' ' ^ ^ - - ^ ^ - " ^ °" - d e t e n d a X o r t s to

Declarations
(1) all owners ofthe property securing this appearance bond are included on the bond;
surety - declare under penalty of perjury that this information is true. (See 28 U.S.C. § 1746.)
Date: 2/22/16
Dfjl'lfiant's signature
(1) Surety/property owner -printed name (1) Surety/property owner — signature and date
(2) Surety/property owner - printed name (2) Surety/property owner — signature and date
CLERK OF COURT
Date:
Date:
APPROVED
Alan J. Baverman, tlnited States Magistrate Judge

AO 199A (Rev. 12/11) Order Setting Conditions of Release Page 1 of 3 Pages
I!GIHAIL ^^^^ ^^"^^^^ DISTRICT Couffu^^ô^c^Âti^rrta ""^
V.
JAMES SHAW
Defendant
Northern District of Georgia FEB 2 2 2^16
jAiÊswm
, , By. ^©eûty Clerk
Case No.: 1:16-CR-0067-03
The defendant must appear at:
Place
on
Date and Time

AO 199B (Rev. 12/11) Additional Conditions of Release Page J _ of J3_ Pages
ADDITIONAL CONDITIONS OF RELEASE
( ) (6) The defendant is placed in the custody of:
organization)
City and state
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
Signed:
Tel. No.
Custodian Date
( X ) (a) to the ( x) U.S. Pretrial Services ( ) U.S. Probation Office
telephone number 404-215-1950 , ( ) No later than M Before leaving courthouse, ox
(b) maintain or actively seek lawful and verifiable employment. ^
(c) continue or start an education program.
(d) surrender any passport to your supervising officer by : /h.^tw^«C and do not obtain nor possess a passport or other intemational
travel document, not obtain or possess a passport or other intemational travel document in your name, another name or on behalf of a
third party, including minor children.
(e) abide by the following restrictions on personal association, residence, or travel: Reside at address provided to Pretrial Services
and do not change your address or telephone number w/o written PTS pre- approval
(f) avoid all contact, 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 y; K(, iv-«i| SC ape / j "^4*^1 b J
(g) get medical or psychiatric treatment: ( ) as directed by your supervising officers ( )
(h) maintain residence at a halfway house or community corrections center, as the pretrial services office or supervising officer considers
necessary.
(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 defmed in 21 U.S.C. § 802, unless lawfully prescribed by a
licensed medical practitioner.
(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
(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,
( ) (o) submit to location monitoring as directed by the pretrial services office or supervising officer and comply with all ofthe program
requirements and instructions provided.
( ) You must pay all or part ofthe cost of the program based on your ability to pay as determined by the pretrial services office or
arrests, questioning, or traffic stops.
( X ) (p) resti-ict travel to the Northern District of Georgia unless the supervising officer has aroroved travel in advance. ^ ,
( X ) |>e»-i I IjOaojOoo ^otxij K o - ^ i k t t f e ^ ^rMe4, Emh^insy " L*^ P K > J . ir%,h Kcyfffh
( ) (s) °LAMS^ ^ ^
( y ) (t) % rf^nv.'-^ pwqftif IH i i r ^ 0 f c < t . ^ J ^ _ . 4 a l ^ ^ A « » A i p _ . . J l J I ^ ttMtm rTl
On t-tt |lA>v-i»o f A ^ f y ^ • 'l

%.A0 199C (Rev.12/03) Advice of Penalties Page 3 of 3 Pages
TO THE DEFENDANT:
YOU ARE ADVISED OF THE FOLLOWrNG PENALTIES AND SANCTIONS:
Violating any ofthe foregoing conditions of release may result in the immediate issuance of a warrant for your arrest, a
revocation of release, an order of detention, a forfeitare of any bond, and a prosecution for contempt of court and could result in a term
of imprisonment, a tine, or both.
While on release, if you commit a federal felony offense, the punishment is an additional prison term of not more than ten
years; if you commit a federal misdemeanor offense, the punishment is an additional prison term of not more than one year. This sentence
will be consecutive {i.e., in addition to) any other sentence you receive.
It is a crime punishable by up to ten years of imprisonment and a $250,000 fine or both to: obstruct a criminal
investigation; tamper with a witness, victim or informant; or intimidate or attempt to intimidate a witness, victim, juror, informant, or
officer of the court. The penalties for tampering, retaliation, or intimidation are significantly more serious if they involve a killing or
attempted killing.
If after release, you knowingly fail to appear as required by the conditions of release, or to surrender for the service of sentence,
you may be prosecuted for failing to appear or surrender and additional punishment may be imposed. If you are convicted of:
(1) an offense punishable by death, life imprisonment, or imprisonment for a term of fifteen years or more, you shall be fined
(2) an offense punishable by imprisonment for a term of five years or more, but less than fifteen years, you shall be fined not
(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 forfeiture of any bond posted.
I acknowledge that I am the defendant in this case and that I am aware of the conditions of release. I promise to obey all condidons
of release, to appear as directed, and to surrender for service of any sentence imposed. I am aware of the penalties and sanctions set forth
above.
Signature of Defendant
i/^lt^ Address
City and State Telephone
(A ) The defendant is ORDERED released after processing.
^ ) The United States marshal is ORDERED to keep the defendant in custody until notified by the clerk or judge that the defendant
has posted bond and/or complied with all other conditions for release. If still in custody, the defendant must be produced before
the appropriate judge at the time and place specified.
Date; f j ^ [ H -
Signa^re of Judicial Officer
ALAN J. BAVERMAN , U. S. MAGISTRATE JUDGE
DISTRIBUTION; COURT DEFENDANT PRETRIAL SERVICE U.S. ATTORNEY U.S, MARSHAL

No Contact Order
purpose.

ILED IN CHAMBEF
A T L A N T A DIVISION
V.
JAMES SHAW,
FEB
U.S. MAGISTRAyL
n D. GEORGIA
CRIMINAL ACTION NO.
1:16-CR-0067-02-SCJ-CMS
ORDER
The sum of $2,000,000 (two million dollars) is to be paid into the registry of this Court by
James Shaw 48 (forty-eight) hours before his travels to the Bahamas. This cash bond is only
posted to secured the defendant retum from a one-week trip to the Bahamas. After the defendant
returns from his trip, the money shall be reflinded 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
$2,000,000 (two 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

MAGISTRATE'S CRIMINAL MINUTES
ARRAIGNMENT
PLEA AND
SENTENCE
Magistrate (presidinaVALAN J. BAVERMAN
Time in Court: J Hrs 36 Mins
CASE NO..
AUSA
1:16-CR-0067-4
Ttiomas Krepp, Steven Grimberg
& Jamie Mickelson
Defendant's Name: Frank Bell
Defendant's Atty: Aaron Danzig
USPO/PTR: Antwan Walker Type Counsel: Retained
ARREST DATE:
INTERPRETER:
ORDER giving defendant
Copy indictment given to dft? (X) Yes ( ) No
days to employ counsel.
X
NEGOTIATED PLEA between Government and defendant filed
Assigned To Judge JONES for ( X ) trial
Assigned to Magistrate SALINAS
Estimated trial time: days.
;) arraignment/sentence,
for pretrial proceedings.
( ) SHORT ( ) MEDIUM (X) LONG

ARRAIGNMENT - Pg. 2 CASE NO: 1:16-CR-0067-4-SCI-CMS
BOND HEARING HELD.
X BOND SET at $ 200,000
X NON-SURETY
SURETY ( )CASE ( ) PROPERTY ( ) CORPORATE SURETY
X SPECIAL CONDITIONS: Post mottier's home as security for Virgins Island trip 48 hours before trip. Travel
permitted for work with pretrial services notification; Do not travel to the British Virgins Island during permitted
trip; see attached No contact order.
WITNESSES:
SENTENCE:

U.S, Department of Justice
United States Attorney Pii m IN OPEN COURT
U.S.U.U. Atlanta
IN THE UNITED STATES DISTRICT COURT o 2 ?016 ^
FOR THE NORTHERN DISTRICT OF GEORGIi^ ^ |
I • / ^ ^ " o e ^ Clerk
P L E A (With Counsel)
CRIMINAL NO. l:16-CR-67
I, Frank Bell, defendant, having received a copy of the within Indictment, and
having been arraigned plead Not Guilty thereto to counts 1 through 11 thereof.
In Open Court this 22nd day of February, 2016.
0 ^
SIGNATURE ( D ^ n s e Attorney) SIGNATURE (Defendant)
Frank Bell
Phone: HoH. feii^-C^a^-f ' : • i- - ^ ^ • /
Bar Number: ^ ^ Phone: .
Filed in Open Court by:
(Signature) Date
N.D. Ga. 11/8/12

AO 98 (Rev. 12/11) Appearance Bond
Page 1
^ ^ F l i E D IN OF'EN COURT
UNITED STATES DISTRICT CouRr U.S.D.C. Atlanta
V.
FRANK BELL
for tiie
Nortliem District of Georgia
Case No.
Defendant
FEB ?. 2 2816
JAMES^Aff£,N,C|
; '""^ 'DBpirty Clerk
l:16-CR-0067-4-SCJ-CMS
APPEARANCE BOND
FRANK BELL (defendant), agree to follow every order of this court, or any
Type of Bond
( X ) (2) This is an unsecured bond of $ 200,000.00
( ) (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
Ifthis 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):
may order a judgment of forfeiture against the defendant and each surety for the entire amount ofthe 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
serve a sentence.

AO 98 (Rev. 12/11) Appearance Bond
Page 2
Declarations
(1) all owners of the property securing this appearance bond are included on the bond;
surety - declare under penally of perjury that this information is true. (See 28 U.S.C. § 1746.)
Date: 2/22/16
f Defendant's signature
/
CLERK OF COURT
Date:
Date: ^ 1 * ^ I k
APPROVED / ,
Date:
i 1 f «^ Alan J. Baverman, United States Magistrate Judge

AO 199A (Rev. 12/11) Order Setting Conditions of Release Page 1 of 3 Pages
U N I T E D STATES DISTRICT CoufttEo IN OPEN COURT
for the U.S.D.C. Atlanta
Northern District of Georgia f£Q '% 2 ?0I6
JAME^r^ATTJ
UNITED STATES OF AMERICA ) ^f5%
V. )
) Case No.: 1:16-CR-0067-04
_ FRANK BELL )
Defendant )
The defendant must appear al: —
Place
on
Date and Time

AO 199B (Rev. 12/11) Additional Conditions of Release Page 2_ of Pages
~ ADDITIONAL CONDITIONS OF R E L E A S E
( ) (6) The defendant is placed in the custody of
organization)
City and state Tel. No,
who agrees to (a) supervise the defendant:(b)ê every effort to assure the defendant's appearance at all court proceedings, and (c) notify the court immediately
Signed:
Custodian Date
( X ) (a) to the ( U.S. Pretrial Services ( ) U.S. Probation Office
telephone number ^04:215^95^ , ( ) No later than ^ B e f o r e leaving courthouse, j)r
( X ) (b) mamtain or actively seetclawM and verifiable employment.
( ) (c) continue or start an education program. .
( X ) (d) surrender any passport to your supervising officer by : j ^ v r K ^ v T i n d do not obtain nor possess a passport or other intemational
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. r, ^ • i o
( X ) (e) abide by the following restrictions on personal association, residence, or travel: M_ealaddre_s^pjwide^^
and do not change your address or telephone number w/o written PTS pre- approval
( X ) (ID ^void all contact, directly or indirectly, with any person who is or may be a victim or witness in the investigation or pr|ecîon,
including: any and all co-defendants and/or unindicted co-conspirators j i^KihAAi..Lylll£^..'î'^ ^^'^ f # ^ - f e | g l ^ , r M ^
( ) (g) ''^^^&t^^d^cXQmnQnX: ( ) as directed by your supervising officers ( )
( ) (h) mlmrtahêsidene7at7halfwVh'ous^ 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 ) (i) not use alcohol ( ) at all ( x ) excessively.
( X ) (k) not use or unlawfuUy possess a narcotic drug or other controlled substances defined in 21 U.S.C. § 802, unless lawfuUy prescribed by a
{ ) (1) Lta'tt teftinj fât^^^^^ substance if required by the pretrial services office or supervising officer. Testing may be used with randoin
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 obstmet, or tamper with the efficiency and accuracy of prohibited
( ) (m) participate in a program of inpatient or outpatient substance abuse therapy and counseling if directed by the pretrial services office or
( ) (n) participate in one of the following location restriction programs and comply with its requirements as directed.
( ) (i) Curfew. You are restricted to your residence every day ( ) from to , or ( j as
directed by the pretrial services office or supervising officer; or ,. . • j • ,
i ) (ii) Home Detention. You are restricted to your residence at all times except for employment; education; religious services; medical,
approved in advance by the pretrial services office or supervising officer; or , . • ^
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 comply with all ofthe program
requirements and instructions provided. . ,, , , • , •
( ) You must pay all or part ofthe cost ofthe program based on your ability to pay as determined by the pretrial services office oi
arrests, questioning, or traffic stops. ^ , • j „
( X ) (p) restrict travel to the Northem District of Georgia unless the supervisingofficer has approvedjravel m advancê. .
( / ) (r) _ r j ^ _ ^ _ 1 ^ ^ A J : ^ ^^^îL^^^—±^^^--^^P,^*^^
( X ) (s) ^ 4 ^ M t l ^ i 5 ^ . M l L l ^ ^ T i ^ Z ^ ^ - ^ ^ ^ -i—j^ ^—^l4i^t—V—^
(X) (t) _^^.^^>^'A%^M-^—^fl-K-^'^k^---^^^-^f

%>A0 199C {Rev.12/03) Advice of Penalties Page 3 of 3 Pages
TO THE DEFENDANT:
Violating any ofthe foregoing conditions of release may result in the immediate issuance of a warrant for your arrest, a
revocation of release, an order of detention, a forfeiture of any bond, and a prosecution for contempt of court and could result in a term
of imprisonment, a fine, or both.
While on release, if you commit a federal felony offense, the punishment is an additional prison term of not more than ten
years; if you commit a federal misdemeanor offense, the punishment is an additional prison term of not more than one year. This sentence
will be consecutive {i.e., in addition to) any other sentence you receive.
It is a crime punishable by up to ten years of imprisonment and a $250,000 fme or both to: obstruct a criminal
investigation; tamper with a witaess, victim or informant; or intimidate or attempt to intimidate a witaess, victim, juror, informant, or
officer of the court. The penalties for tampering, retaliation, or intimidation are significantly more serious if they involve a kilhng or
attempted killing. . , • f ^
If after release, you knowingly fail to appear as required by tae conditions of release, or to surrender for the service of sentence,
you may be prosecuted for failing to appear or surrender and additional punishment may be imposed. If you are convicted of
(1) an offense punishable by death, life imprisonment, or imprisonment for a term of fifteen years or more, you shall be fined
(2) an offense punishable by miprisonment for a term of five years or more, but less taan fifteen years, you shall be fmed not
(3) any other felony, you shall be fmed not more than $250,000 or imprisoned not more than two years, or both;
(4) a misdemeanor, you shall be fined not more than $100,000 or imprisoned not more taan one year, or both.
A term of imprisonment imposed for failure to appear or surrender shall be in addition to tae sentence for any otaer offense. In
addition, a failure to appear or surrender may result in the forfeiture of any bond posted.
I acknowledge taat I am tae defendant in tais case and taat I am aware of tae conditions of release. I promise to obey all conditions
of release, to appear as directed, and to surrender for service of any sentence imposed. I am aware rftae penalties and sanctions set forth
above. , " /
/ ' Signature of Defendant
Address
( f ) The defendant is ORDERED released after processing. , , . ^
A ^ The United States marshal is ORDERED to keep tae defendant in custody until notified by tae clerk or judge that tae defendant
has posted bond and/or complied wita all otaer conditions for release. If still jn custody, tae defendant must be produced before
the appropriatejudge at the time and place specified.
Date: fe- t
1 f'*~^ ~ * * Signatare of Judicial Officer
ALAN J. BAVERMAN , U. S. MAGISTRATE JUDGE

-"^ No Contact Order
purpose.

Richard Russell Federal Building Telephone: (404) 581-6000
75 Spring Street S.W., Suite 600 Fax: (404) 581-6181
Atlanta, Georgia 30303
February 26, 2016
Courtroom Deputies
U.S. Courthouse
75 Ted Turner Dr., S.W.
Re: U.S. v. Tyson Rhame, et al. (1:16-CR-67-SCJ-CMS)
U.S. v. Kwabena Otchere (1:14-CR-265-MHC-CMS)
U.S. v. Cheryl Singleton (1:15-CR-443-SCJ-JFK)
U.S. v. Qadir Shabazz (1:13-CR-441-TCB-CMS)
U.S. v. Reginald Byrd (1:15-CR-267-LMM)
U.S. v. Rodney Byrd (1:15-CR-266-LMM)
Dear Courtroom Deputies:
Pursuant to Local Criminal Rule 57.1(E)(4), I write to notify the Court that I
will be out of the office from March 17, 2016 through March 18, 2016 and June 10,
2016 through June 30, 2016. I request that the Court not schedule any court
appearances in the above-referenced matters for those dates.
Sincerely,
JOHN A. HORN
/s/Thomas J. Krepp
THOMAS J. KREPP
cc: Counsel for Defendant (via ECF)

8592309v1
Atlanta Office
171 17th Street NW, Suite 2100
Atlanta, GA 30363-1031
Direct phone: 404.873.8504
Direct fax: 404.873.8505
E-mail: aaron.danzig@agg.com
Atlanta • Washington, D.C.
February 29, 2016
Mr. James N. Hatten, Clerk of Court
United States District Court
Northern Division of Georgia, Atlanta Division
Richard B. Russell Federal Building
75 Ted Turner Dr., SW
Re: United States of America v. Tyson Rhame, et al.; Northern District of
Georgia, Atlanta Division, Criminal Action No. 1:16-cr-00067-SCJ-
CMS
Dear Mr. Hatten:
I hereby respectfully notify the Court and all opposing counsel pursuant to
Local Rule 57.1E (4), that I will either be out of state on vacation or business on
the following dates:
 March 2, 2016 through March 4, 2016;
 March 25, 2016;
 April 4, 2016 through April 8, 2016;
 May 13, 2016;
 June 2-3, 2016; and
 June 5, 2016.
Please accept this request that the court not schedule any appearances in
this matter during the aforementioned period of absence. The Court’s
consideration in this regard is appreciated.

Mr. James N. Hatten, Clerk of Court
February 29, 2016
Page 2
8592309v1
If the Court has any questions, comments or concerns, please do not
hesitate to contact me.
By the e-filing of this letter, I have notified counsel of my correspondence
with the court.
Sincerely,
ARNALL GOLDEN GREGORY LLP
/s/ Aaron M. Danzig
Aaron M. Danzig
AMD:ies
cc: All Counsel of Record (via CM/ECF System)

ATLANTA DIVISION
UNITED STATES OF AMERICA :
:
:
v. : CRIMINAL ACTION NO.
: 1:16-CR-0067-03-SCJ-CMS
JAMES SHAW, :
:
:
‘
AMENDED ORDER
The sum of $2,000,000 (two million dollars) is to be paid into the registry of this Court by
James Shaw 48 (forty-eight) hours before his travels to the Bahamas. This cash bond is only
posted to secured the defendant return from a one-week trip to the Bahamas. After the defendant
returns from his trip, the money shall be refunded to him.
It is hereby ORDERED, that the Clerk of Court is hereby directed to deposit the sum of
$2,000,000 (two million dollars) into the registry of the Court.
IT IS SO ORDERED this 29th day of February, 2016.

ATLANTA DIVISION
v.
TYSON RHAME,
TERRENCE KELLER,
JAMES SHAW,
FRANK BELL
Criminal Action No.
1:16-CR-67-SCJ-CMS
ORDER
WHEREAS the discovery materials provided and otherwise made available to
the defendants by the United States in this case are voluminous, and contain
sensitive information pertaining to individuals and companies, some of whom
are not parties to the litigation, as well as sensitive information that might be
subject to the provisions of the Bank Secrecy Act; and
WHEREAS redaction of all potential sensitive information in this voluminous
production would be unduly burdensome, and would be subject to error given
the volume of documentation involved in this production;
THEREFORE, IT IS HEREBY ORDERED pursuant to Rule 16(d) of the Federal
Rules of Criminal Procedure that:
1. Any and all materials and information provided by the United States to the
defendants (hereinafter referred to in this order as “discovery”) are to be used by
the defendants and their counsel solely for the purpose of allowing the
defendants to prepare their defense, and that none of the defendants, defense
Case 1:16-cr-00067-SCJ-CMS Document 33-1 Filed 03/01/16 Page 1 of 4

counsel, nor members of any defense team will disseminate, disclose, or provide
discovery materials containing the sensitive information identified herein, to
anyone who is not necessary to the preparation of the defense.
2. All discovery materials provided by the United States, regardless of
whether such materials and information have already been produced or will be
produced in the future, and regardless of whether such materials and
information have or will be produced pursuant to Rule 16 or otherwise, shall not
be further disseminated by the defendants or their counsel to any individual,
organization, or other entity, other than: (1) members of the defense team, i.e., co-
counsel, paralegals, investigators, litigation support personnel, the defendants,
and secretarial staff; (2) any experts or consultants retained to assist in the
preparation of the defense; and (3) the Court, unless the sensitive information
identified herein is redacted from such materials and information. Upon any
dissemination of the materials and information containing the sensitive
information identified herein, defense counsel will inform the recipient of this
Protective Order and the requirement to maintain the confidentiality of the
information conveyed.
3. Defense counsel, any co-counsel, and any investigators may display copies
of any discovery containing the sensitive information identified herein, to non-
expert witnesses, if it is determined that it is necessary to do so for the purpose of
preparing the defense of the case, and may do so without any notice to the
United States. Defense counsel may also provide copies of discovery documents
to witnesses in advance of meeting with them, so long as the witnesses agree that

they would not disseminate the documents, and so long as defense counsel
retrieves all copies of the documents from the witness subsequent to meeting
with them.
4. If a defendant’s counsel desires to disclose any discovery or make available
or communicate the content of such discovery containing the sensitive
information identified herein, to any other person not described in this Order,
Government’s counsel must first be so advised and seek to reach an informal
resolution of or agreement on the matter. If an agreement cannot be reached,
Defendant’s counsel shall apply to the Court for relief from this Order.
5. If a defendant’s counsel desires to file any discovery as attachments to
motions and it appears that the discovery contains information subject to this
Order, the discovery must be filed under seal so as not to reveal sensitive
information on the public docket.
5. This ORDER solely governs the defendants and defense teams use of
documents produced in this action from the United States. This ORDER does not
limit the defendants and defense teams use of documents that they might
already possess prior to receiving discovery, or might obtain through other
means.

6. This ORDER shall survive the final termination of this action, and that
upon termination of this action and, upon the termination of any appeal, counsel
for each defendant shall return all copies of the discovery to the Government, or
shall certify that said documents have been destroyed.
SO ORDERED THIS __________ day of ______________________, 2016.
CATHERINE M. SALINAS
Prepared by
(404) 581- 4647

1
ATLANTA DIVISION
v.
TYSON RHAME,
TERRENCE KELLER,
JAMES SHAW, AND
FRANK BELL
Criminal Action No.
1:16-CR-67-JFK-CMS
Government’s Motion for Protective Order for Discovery Material
Thomas J. Krepp, Steven D. Grimberg, and Jamie L. Mickelson, Assistant United
States Attorneys for the Northern District of Georgia, hereby moves pursuant to
Fed. R. Crim P. 16(d), for a protective order that limits the defendants use and
dissemination of information provided in discovery to that which is reasonably
necessary to prepare their defense.
Specifically, the Government requests an order providing that any
discovery materials and all information included in discovery materials (referred
to in this order as Adiscovery@), regardless of whether such materials and
information are defined as discovery under Rule 16 or already have been

2
produced, that are provided by the United States to the defendants shall not be
further disseminated by any defendant or his counsel to any individuals,
organizations, or other entities, other than: (1) members of the defense team
(co-counsel, paralegals, investigators, litigation support personnel, Defendant,
and secretarial staff); and (2) any experts or consultants retained to assist in the
preparation of the defense. The Government further requests an order stating
that each defendant, his counsel, and any investigator may show but not provide
copies of any discovery to witnesses if it is determined that it is necessary to do
so for the purpose of preparing the defense of the case. The Government further
requests that all discovery is to be provided and used by each defendant and his
counsel solely for the purpose of allowing each defendant to prepare his defense,
and that each defendant, defense counsel, or members of the defense teams will
not disseminate, disclose, or provide the discovery produced by the United
States to anyone who is not necessary to the preparation of the defense.
In support of this motion, the Government states that the discovery
material in this case is voluminous. Many of these documents contain financial
records, including information subject to the Bank Secrecy Act and similar laws,
as well as financial and personal information of third parties, including former
customers of Sterling Currency Group and followers of the GET Team, which are

3
both further described in the Indictment. Finally, the discovery contains bank
account and personal identifying information of the co-defendants as well as
third parties who are not named defendants in this case.
Thus, the Government submits that protective measures are necessary to
guard against dissemination of confidential business, financial, and other
personal information. A protective order is the most reasonable way of
balancing the defendants’ need for access to these materials, with the rights of
individuals whose information may be reflected in this discovery as well as
sensitive Bank Secrecy Act information.
The defendants’ respective attorneys have been consulted regarding the
Government’s motion and they oppose portions of the attached proposed order.

4
WHEREFORE, the United States of America respectfully requests that the
Court issue the protective order presented to the Court.
JOHN A. HORN
/s/THOMAS J. KREPP
/s/STEVEN D. GRIMBERG
Steven.Grimberg@usdoj.gov
/s/JAMIE L. MICKELSON
Jamie.Mickelson@usdoj.gov

Certificate of Service
The United States Attorney’s Office served this document today by filing it using
the Court’s CM/ECF system, which automatically notifies the parties and counsel
of record.
Counsel for Tyson Rhame;
Counsel for Terrence Keller;
Counsel for James Shaw;
Counsel for Frank Bell
March 1, 2016
/s/ THOMAS J. KREPP
THOMAS J. KREPP

AO 442 (12/85) Warrant for Arrest 1 0 0 0
NORTHERN DISTRICT OF GEORGIA
UNITED STATES OF AMERICA, WARRANT FOR ARREST
vs.
CASE NO.: 1:16-CR-67-1
TYSON RHAME
AGENT TO ARREST ' X ^ ^ H P ^
To: The United States Marshal
and any Authorized United States Officer ,:2
YOU ARE HEREBY COMMANDED to arrest TYSON RHAME and bring him or her
forthwith to the nearest magistrate to answer a(n)
X Indictment D Information D Complaint D Order of Court D Violation Notice D Probation Violation Petltion'i::.
Charging him or her with (brief description of offense): Mail Fraud and Wire Fraud
in violation of Title 18, United States Code, 1349 Section(s)
JAMES N. HATTEN Clerk. U.S. District Court
Name of Issuing Officer Title of Issuing Officer
'jl February 11. 2016 at Atlanta, Georgia
Signature of Issuing Officer Date and Location
AUSA: Thomas J. Krepp
RLE 1"'^"^' "^^-'CE
Bail Fixed at $ By:
Name of Judicial Officer - 1
RETURN . - f ^
{ /
This warrant was received and executed with the arrest ofthe above-named defendant at:
1 6 ^
Date Received: 9^ ^ ^ I i p ^ • f - y - ^ ' U ^ k j
Name and Title of Ar/esting Officer y
Date of Arrest: ^ ^ ^ 2 - J j . J p % M m S j r y . ^ . I j S f j S J s / t
Sigri^t/ire of Arresting Officer ' /

AO 442 {I'SBSJ Warrant for Atrast / 0 0 0 ^ H p l
UNITED STATES DISTRICT C O U R T
N O R T H E R N DISTRICT OF G E O R G I A
UNITED STATES OF AMERICA. WARRANT FOR ARREST
vs.
CASE NO.; 1:16-CR-67-1
TYSON RHAME
AGENT TO ARREST
and any Authorized United States Officer
YOU ARE HEREBY COMMANDED to arrest TYSON RHAME and bring him or her
forthwith to the nearest magistrate to answer a(n)
X Indictment • Information • Complaint • Order of Court • Violation Notice • Probation Violation Petition ,
JAMES.N. HATTEN Clerk, U.S. District Court
Name of Issuing Officer Title of issuing Officer
^ - - February 11. 2016 at Atlanta. Georgia
Signatureof Issuing Officer Date and Location
AUSA; Thomas J. Krepp
Bail Fixed at , By;
Name of Judicial Officer R L L L ' 11 ' ^ , i
U.S.D.C. ..Aii.i,i;a
RETURN
This warrant was received and executed with the arrest ofthe above-named%'efendani ^^<^..J^
Date Received: _ A / I L I ^ ^ ( . ^ o ^ j t f j ^ . . ^ . ^ ^ „
Name and Title ofArresting Officer '
Dateof Arrest: ^ _ / 2 x / ^ ^ u . - .

AO 442 (12/85) Warrant for Arrest
vs.
CASE NO.: 1:16-CR-67-2- C f 4 i
TERRENCE KELLER,
A/K/A TerryK
AGENT TO ARREST
YOU ARE HEREBY COMMANDED to arrest TERRENCE KELLER, a/k/a TerryK and bring::"
him or her forthwith to the nearest magistrate to answer a(n) g
X Indictment •information •complaint • Order of Court • Violation Notice • Probation Violation Petitiong
I - . : . .
Charging him or her with (brief description of offense): Mail Fraud and Wire Fraud ••':!
i::r;i
JAMES N. HATTEN Clerk. U.S. District Court ^
February 11, 2016 at Atlanta. Georgia
Bail Fixed at $. By:.
Name of Judicial Officer pi[Lulii( ' T ' ''~r r|';
RETURN
This warrant was received and executed with the arrest of the above-named defendarit at;
Date Received: ' ^ ^ - I jj?
Name and Title of Arr/sting Officer
m i
Date of Arrest:
SlgnafJre of Arresting Officer /

AO 442 f,i2i85S Warranl (cr Arrest /ODD 4^13 7
N O R T H E R N DiSTRICT OF G E O R G I A
VS,
CASE NO,: 1;16-CR-67^2
TERRENCE KELLER,
A/K/A TerryK ^ •
AGENT TO ARREST p
YOU ARE HEREBY COMMANDED to arrest TERRENCE KELLER, a/k/a TerryK and bring ,
him or her forthwith to the nearest magistrate to answer a(n)
i
X Indictment •information • Complaint • Order of Court • Violation Notice • Probation Violation Petition
1...
I-
in violation of Titie 18, United States Code, 1349 Section(s)
JAMES N. HATTEN Clerk, U.S. District Court . _
Title of Issuing Officer
February 11. 2016 at Atlanta, Georgia
Bai! Fixed at $ By: , FILED IN CLERK'S OFFICE^
Name of Judicial Officer u.S.lj.C. - AH.inla
— " — ~ — — , „ , ^
RETURN 1 ! _ ' inrk
'->y- "fep^ily Clerk
This warrant was received and executed with the arrest of the above-named defendant at '
Date Received: .
n lo 7 I,.
Date of Arrest:

AO 442 (12/85) Warrant for Arrest / O O P ^ 1 o
vs.
CASE NO.: 1:16-0R-67-3 - C f A i
JAMES SHAW
AGENT TO ARREST ^ : : ' !
To: The United States Marshal !"•;;
YOU ARE HEREBY COMMANDED to arrest JAMES SHAW and bring him or her forthwith';
to the nearest magistrate to answer a(n)
iT-i
:i:~:
X Indictment CU Information CU Complaint CU Order of Court CD Violation Notice CU Probation Violation Petition;?:-
!;.7":i
JAMES N. HATTEN Clerk, U.S. District Court
' /J / L ^ L ^ ^ ^ ~ ^ ^ February 11. 2016 at Atlanta, Georgia
AUSA: Thomas J, Krepp
Bail Fixed at $ By: FILED 'N Ci ^P'^'S 0 - F I C E
Name of Judicial Officer (j g p Q _ Aiiania
' 'I ' ' i'l
ll II V :;i I., ' - II' I'
RETURN iipi ^1 ,(-'erk
This warrant was received and executed with the arrest ofthe above-named def^nddnt at:
Date Received: ^ -11' I L • ^ f ^ - ^ ^ y s l ^ O s t l
Name and Title qf Arrestirfg Officer
Date of Arrest: ^ ' f t - D ^ ' l l ^ I n . M i D u - ( J S m S M a -
Signawre of Arresting Officer

AO 442 (12/aSj. WarranltorArrest /
N O R T H E R N DISTRICT OF G E O R G i A
vs.
CASE NO.: 1:16-CR-67-3
JAMES SHAW
AGENT TO ARREST
YOU ARE HEREBY COMMANDED to arrest JAMES SHAW and bnng him or her forthw/ith'
to the nearest magistrate to answer a(n)
X Indictment • Infomiation • Complaint • Order of Court • Violation Notice • Probation Violation Petition
Charging him or her with {brief description of offense): . Mai! Fraud and Wire Fraud
JAMES N. HATTEN Clerk, U.S._District Court _____
February 11, 2016 at Atlanta. Georgia
AUSA; Thomas J, Krepp
Bail Fixed at $ By;
Name of Judicial OfficeiFILED IN CLERICS OFFICE
U.S.U.I;. -/vii.iiiia
RETURN t ^
JPML ,' , L 1 i k
This warrant was received and executed with the arrest ofthe above-name^defendan^at^^,^,^^
Date Received: Z-J h f i l hDate of Arrest;

AO 442 (12/85) Warrant for Arrest
vs.
CASE NO.: 1:16-CR-67-4CfA, £
FRANK BELL ^MSSSUt
AGENT TO ARREST ^ j S ^ ^ ^ r '
To: The United States Marshal ,::n
and any Authorized United States Officer g
YOU ARE HEREBY COMMANDED to arrest FRANK BELL and bring him or her forthwith ^
the nearest magistrate to answer a(n)
(.S.I
X Indictment • Information • Complaint • Order of Court • Violation Notice • Probation Violation Petitiorf...
JAMES N. HATTEN Clerk, U.S^District Court
Name of issuing Officer Title of Issuing Officer
( ? ^ ^ 7 ' ^ / ^ ^ - ^ - Februarv 11, 2016 at Atlanta. Georgia
Signature of issuing Officer and Location
r, •, rr- ^ . <t Bv R L E D IN CLERICS OFFICE
Bail Fixed at $ ^V-— . LLs.tj.c-AHaniaName of Judicial Officer
RETURN ^ ' y . ^ t
111' _ierK
This warrant was received and executed with the arrest of the above-named d e f i a n t at:
f 6 f
Date Received: ^ ' I h I .„d T»,. o, Ar^.rt. o t i c
Date Of Arrest: 3 ' 9 - ^ ' l i p / % • A j ^ ' / S j k , l ^ 6 > l l ^ ^ | f e / P

AO 442 (12/85) Warrani tor Arrest
N O R T H E R N DISTRICT OF G E O R G I A
vs.
CASE NO,: 1:16-CR-67-4
FRANK BELL j f c "
AGENT TO ARREST ' ' T ^ ^ ^ f e f
YOU ARE HEREBY COWMANDED to arrest FRANK BELL and bring him or her forthwith to
the nearest magistrate to answer a(n)
X Indictment • Information • Complaint • Order of Court • Violation Notice • Probation Violation Petitiori
Charging him or her with (brief description of offense): Wail Fraud and Wire Fraud
in violation of Title 18, United States Code,, 1349 Sectlon(s).
JAMES N. HATTEN Clerk. U.S. District Court
( / : > ^ ' 7 ' / ^ ^ - x ^ ^ ~ February 11. 2016 at Atlanta. Georgia
Bail Fixed at $ By: BiMLlilIllJZ-ALUL£^
Name of Judicial Officer
= = = = — f • —
RETURN m , . ^ i I r!(
> ^ . u . y :ierk
This warrant was received and executed with the arrest of the above-named defendant at:
Date Received: _^
Date of Arrest: J

AO 100 (2/86) Agreement to Forfeit Property FILED IN CHAiBERS
vs.
FRANK BELL CASENO. 1:16-CR-0067-5-SCJ-CMS
We, the undersigned, acknowledge pursuant to 18 U.S.C. §3142(c)(B)(xii) in consideration ofthe defendant
that we and our personal representatives jointly and severally agree to forfeit to the United States of America all that
property known as 105 Scarborough Court, S E located in Marietta, Georgia, as more particularly described in the
warranty deed attached hereto, which has been provided to the court as indicia of ownership of said property;
The conditions of this agreement are that the defendant is to appear before this court and at such other places
as the defendant may be required to appear, in accordance with any and all orders and directions relating to the
defendant's appearance in this case, including appearance for violation of a condition of defendant's release as may be
ordered or notified by this court or any other United States Court to which the defendant may be held to answer or the
cause transferred. The defendant is to abide by any judgment entered in such matter by surrendering to serve any
sentence imposed and obeying any order or direction in connection with such judgment.
It is agreed and understood that this is a continuing agreement (including any proceedings on appeal or review)
which shall continue until such time as the undersigned are exonerated.
If the defendant appears as ordered or notified and othenwise obeys and performs the foregoing conditions of
this agreement, then this agreement is to be void, but if the defendant fails to obey or perform any of these conditions,
the property described in this agreement shall immediately be forfeited to the United States, Forfeiture under
this agreement for any breach of its conditions may be declared by any United States District Court having cognizance
of the above entitled matter at the time of such breach, and if the property is forfeited and if the forfeiture is not set aside
or remitted, judgment may be entered upon motion in such United States District Court against each debtor jointly and
severally for forfeiture of the property together with interest and costs, and execution may be issued and the property
secured as provided by the Federal Rules of Criminal Procedure and any other laws of the United States of America.
This agreement is signed on March 1, 2016, at the U.S. Courthouse in Atlanta, Georgia.
Address: 2385 Heather Drive, Decatur, Georgia 30033
Owners/Sureties:
'A I Address: 105 Scarborough Court, SE, Marietta, Georgia 30067
ALICE FRASER
Approved:

ma
DRIVER'S LfCEJVS^
065694454
( I A S S C
Al ICE DUKE
FRASER
DOB 08/01/1937
EXP 08/01/2016
105 SCARBOROUGH CT SE
MARIETTA GA 30067^4931
Kt. I I I lion B bnd NONE
I 01 06'2012
acx F Tyi s BRO >
Hut 5-08 V 'Jl 145
•n 124^1 <vmt 6
J

CARLA JACKSON
CHELLY MCDUFFIE
Phone: {
Fax:
COBB COUNTY PROPERTY TAX BILL 2015
Pay online at www.cobbtax.org or 1-866-729-2622
See the back of this bill for more payment Information
TAX COMMISSIONER
CHIEF DEPUTY
7 7 0 - 5 2 8 - 8 6 0 0
7 7 0 - 5 2 8 - 8 6 7 9
B E L L A L I C E D
105 S C A R B O R O U G H C T
Y O U R P A Y M E N T I S D U E O C T O B E R 1 5 , 2 0 1 5 Late Fees apply October 16, 2015
P a r c e Fair M a r k e t V a l u e A s s e s s e d V a l u e A c r e a g e T a x Distr 5
161Z5200670 4 8 7 , 3 8 0 1 9 4 , 9 5 2 0 . 0 0 Unincorporated Cobb Yes; Age 55, Basic, School
A s s e s s e d Value
1 9 4 , 9 5 2 1 9 4 , 9 5 2
Net A s s e s s m e n t
0
Mlllage R a t e = T a x e s D u e
0 . 0 0 0 0 5 0
T a x i n g Authority
S t a t e
Levied by the State of Georgia representing approximately O.OOo/o of your taxes due.
The Governor and General Assembly passed a tax relief, lowering your state property taxes each year until they are eliminated.
S c h o o l G e n e r a l 1 9 4 , 9 5 2 - 1 9 4 , 9 5 2 = O x 0 . 0 1 8 9 0 0 =
Levied by the Cobb County Board of Education representing approximately O.OQo/o of your taxes due.
C o u n t y
Levied by the Board of Commissioners representing approximately 100.00<>/o of your taxes due.
Taxpayer Reassessment Relief Act: You received an increased exemption of $ 52,063.00 because your property's value was reassessed.
C o u n t y G e n e r a l
C o u n t y B o n d
C o u n t y Fire
1 9 4 , 9 5 2
1 9 4 , 9 5 2
1 9 4 , 9 5 2
6 2 , 0 6 3
0
0
1 3 2 , 8 8 9
1 9 4 , 9 5 2
1 9 4 , 9 5 2
0 . 0 0 7 1 2 0 =
0 . 0 0 0 3 3 0 =
0 . 0 0 3 0 6 0 =
$ 0 . 0 0
$ 0 . 0 0
$ 9 4 6 . 1 7
$ 6 4 . 3 3
$ 5 9 6 . 5 5
2 0 1 5 1 6 1 2 5 2 0 0 6 7 0 1 0 / 1 5 / 2 0 1 5 Pay: N/A
ital T a x e s D u e
$1,607.05

When Recorded Retum To:
ALICE D FRASER
105 SCARBOROUGH CT SE
MARIETTA, GA 30067
BK: 1 5 0 7 a PG: & 0 3 7
Filed and Recorded 3iil--12-2613 il!35:e7ft!1
DOC«: D E 0 1 3 - - 0 & 9 i e i
REBECCft KEftTOH
CLERK OF SUPERIOR COORT Cobb Cty. Gfl.
Loan #: 0027168129
CANCELLATION OF DEED TO SECURE DEBT
(Cancellation of Security Deed)
STATE OF GEORGIA
COUNTY OF COBB
The indebtedness referred to in that certain Deed to Secure Debt from A^^^^^^^
M O R T G A G E , I N C . dated 07/09/2003, and recorded in Deed Book 13822, Page 3885 in toe ottice ot tlie ^êrK oi
W r i o r C o u r t of C O M ^ Georgia, having been paid in full and the undersigned bemg the present owner
orsucrsecured Lt^^^ of bling the original grantee or the heir, assign, transferee, or devisee of the
orirind grartfe, te clerk^^^^^^^^^ courtIs auliorized and directed to cancel that deed of record as
provided in Code Section 44-14-4 of the O.C.G.A. for other Mortgage cancellations.
Property is commonly^nown as: 105 SCARBOROUGH COURT SE, MARIETTA, GA 30067-4331.
Dated on ( / ^ IQW /2013 ( M M / D D / Y Y Y Y ) .
S U N T R U S ™ O R T G A G E , I N C .
Belinda Aguirre ASSff. CORPORATE SECRETARY
Signed and deliveredoDJiie-dateLabove shown.
NCE MOSS Witness
J i m (MM/DD/YYYY), by
DANIELLE KENNEDY Witness
/
STATE OF FLORIDA COUNTY OF PINELLAS
The foregoing instrument was acknowledged before me on - • . ATF ÎPPRFTARY
ASHLEY BRABAND and Belinda Aguirre as VICE PRESIDENT and A^^^^^ f o R ^ j R A T E
respectively focÛNTRUST MORTGAGE, INC., who, as such VICE PRESIDENT and ASST. CORI ORATE
SECRETARSspectively being authorized to do so, executed the foregoing instrument for the purposes therein
contained ffi/she/they is (are)^personally known to me. gizal)eth /V Wustad
* Notary Publlo State of Florida
% My Commission* EE 088429
Expires August 27,2015
ElizaMth A. Mustard ' Bonded Thru Notary PublicUndewriters
NefS^ Public - State of FLORIDA
Commission expires: 08/27/2015
Document Prepared By: E.Lance/NTC, 2100 Alt. 19 North, Palm Harbor, F L 34683 (800)346-9152
SMRCN 20792937 _@ HARD FILE CJ5147251 T2613060210 [C] F0RM1RCNGA5

GANEK, VvniGHT & DOBKIN
4aOO Aahlurt.' Dunwuody Htl., S u . 260
Atlinw, Q«orgl» 30338
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WARRANTY DEED
to
STATE OF GEORGIA COUNTY OF DEKALB
THIS INDENTURE, made the 28th day of September, 1998, between
WILLIAM B. WESTBROOK and MARLYN M. WESTBROCK,
as party or parties ot the first part, hereinafter called Grantor, and
ALICE D. BELL
as party or parties ot the second part, hereinafter called Grantee (the words, "Grantor" and "Grantee"
include their respective heirs, successors and asslans where the context requires or permits),
WITNESSETH that! Grantor, for and in consideration of the sum of TEN AND NO/100 AND
OTHER GOOD AND VALUABLE CONSIDERATION («10.00) DOLLARS in hand paid at and before
the sealing and delivery of these presents, the receipt whereof is hereby acknowledged, has granted,
bargained, sold, aliened, conveyed and confirmed, and by these presents does grant, bargain, sell, alien,
convey and confirm unto tha said Grantee,
ALL THAT TRACT OR PARCEL OF LAND LYING AND BEING LAND LOT 1252 OF THE 16TH DISTRICT,
2ND SECTION, COBB COUNTY, GEORGIA AND BEING LOT 12 OF OLDE IVY GATE SUBDIVISION F/K/A
SCARBOROUGH SUBDIVISION, AS SHOWN AND DESIGNATED ON A PLAT THEREOF RECORDED AT
PLAT BOOK 156, PAGE 80, IN THE CLERK'S OFFICE FOR THE SUPERIOR COURT OF COBB COUNTY,
GEORGIA TO WHICH PLAT REFERENCE IS HEREBY MADE FOR A MORE COMPLETE AND ACCURATE
DESCRIPTION AS TO THE METES, BOUNDS AND LOCATION OF SAID PROPERTY.
This conveyance is made subject to the following:
1. Slate and county ad valorem reai property taxes and assessments for 1998 not yet due and
payable and subsequent years.
2. All easements and restrictions of record.
TO HAVE AND TO HOLD the said tract or parcel of land, with all and singular rights, members
and appurtenances thereof, to the same being, belonging, or in anywise appertaining, to the only property
use, benefit and behoof ot the said Grantee forever in FEE SIMPLE.
AND THE SAID Grantor will warrant and forever defend the right and title to the above described
properly unto the said Grantee against the claims of all persons whomsoever.
IN WITNESS WHEREOF, the Grantor has signed and sealed this deed, the day and year above
written.
Signed, sealed and delivered
this 28th day of September,
1998, in thajBE
fiiimit
WILLIAM B. WESTBROCK
(Seal)
wrnnmtr (Seal)

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 """-ED IN CHAMBERS
tlOsii,-''' """" MAROlZOft'ii V
Northern District of Georgia , .. v v
, as. MAGISTRW-OODGE r
United States ot America ) ^ ^ G E O R G I A
V. )
) CaseNo. l:16-CR-0067-4-SCJ-CMS
FRANK BELL )
Defendant )
A P P E A R A N C E BOND
I, FRANK BELL (defendant), agree to follow every order of this court, or any
court that considers this case, and 1 further agree that this bond may be forfeited i f I fail:
( X ) i f convicted, to surrender to serve a sentence that the court may impose; or
Type of Bond
( ) (2) This is an unsecured bond of $
( X ) (3) This is a secured bond of $ 200,000 , secured by:
(describe tiie casii or otiier property, including claims on it — such as a lien, mortgage, or loan — and attach proof of
Post Alice Eraser's home as security for Virgin Islands trip 48 hours before trip
Ifthis 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 of tiie Bond. This appearance bond may be forfeited if the defendant does not comply with the above
security for the bond, i f the defendant does not comply with the agreement. A t the request of the United States, the court
may order a judgment of forfeiture against the defendant and each surety for the entire amount o f the bond, including
interest and costs.
serve a sentence.

Declarations
(1) all owners ofthe property securing this appearance bond are included on the bond;
Acceptance. I , the defendant - and each surety - have read this appearance bond and have either read all the conditions
surety - declare under penalty of perjury that this information is tt-ue. (See 28 U.S.C. § 1746.)
Date: _____ 2/2aZJ6
Alice Fraser
(1) Surety/property owner-printed name { (]) Surety/property owner - signature and date
105 Scarborough Court, S E Marietta, GA 30067-4331
(2) Surety/property owner -printed name
(3) Surety/property owner -printed name
CLERK OF COURT
Date: '02/-29m. ' U
Date: 2I2m6_
- - d
Signature of Cterli or Deputy Clerli
APPROVED
Alan J. Baverman, United States Magistrate Judge

A072A
(Rev.8/8
2)
ATLANTA DIVISION
v.
JAMES SHAW,
Defendant.
CRIMINAL ACTION FILE NO.
1: 16-CR-0067-3-SCJ-AJB
O R D E R
On February 22, 2016, Defendant James Shaw was released on a bond and
ordered by the Court to surrender his passport to Pretrial Services. As a special
condition of release, the Court is allowing Defendant to travel to the Bahamas only,
and as a result, is permitting his passport to be returned to him temporarily for this trip.
IT IS HEREBY ORDERED that U.S. Pretrial Services return Defendant's
passport to him twenty-four (24) hours before his trip the Bahamas. Defendant shall
return his passport to the probation officer by 11:00 a.m. on the next business day after
he returns from the Bahamas. All other conditions of pretrial release remain in full
force and effect.
IT IS SO ORDERED, this the 2nct day of March, 2016.
ALAN J. BA ERMAN

LEGAL02/36216567v1
ATLANTA DIVISION
UNITED STATES OF AMERICA )
)
v. ) Criminal Case No. 1:16-CR-00067
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
NOTICE OF APPEARANCE
Pursuant to Local Rule 83.1, Ankith Kamaraju of the firm Alston & Bird
LLP hereby notices his appearance as counsel of record for Defendant Tyson
Rhame in the above-captioned proceeding.
Respectfully submitted, this 3rd day of March, 2016.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar No. 667989
ALSTON & BIRD LLP
One Atlantic Center
1201 West Peachtree Street
Tel: 404-881-7000
Fax: 404-881-7777
E-mail: ankith.kamaraju@alston.com
Attorney for Defendant Tyson Rhame

LEGAL02/36216567v1
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
CERTIFICATE OF SERVICE
I hereby certify that on March 3, 2016, I electronically filed the foregoing
NOTICE OF APPEARANCE with the Clerk of Court using the CM/ECF system,
which will automatically send e-mail notification to the attorneys of record.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

1
IN THE UNITD STATES DISTRICT COURT
ATLANTA DIVISION
UNITED STATES OF AMERICA CRIMINAL INDICTMENT
v. NO. 1:16-CR-067-SCJ-CMS
TYSON RHAME
TERRENCE KELLER
JAMES SHAW
FRANK BELL
Defendant, [REVISED 02/17/2010]
O R D E R
I. A pretrial conference shall be held in this case on March 11, 2016 at 9:45
a.m., before the undersigned Magistrate Judge in Courtroom 1810, 18th Floor,
United States Courthouse, 75 Ted Turner Drive, S.W., Atlanta, Georgia 30303.
Counsel who will actually handle the trial of the case must be present. The
defendant need not be present. N.D. Ga. CrR. 17.1.
Please note that it shall be the responsibility of Defendant’s counsel to notify
the office of the undersigned and counsel for the Government if no pretrial motions
shall be filed and/or no pretrial conference is required.
II. Prior to the above-scheduled conference, the following shall occur:

2
A. The parties shall confer regarding the probable disposition of the
case, scheduling problems, resolution of issues related to discovery production and
the mechanics thereof, possible motions, and possible stipulations of law and fact,
pursuant to N.D. Ga. CrR. 12.1D.
B. Upon the defendant’s request, the government shall permit the
defendant to inspect and copy discoverable matter, including but not limited to, all
Rule 16 materials, all search warrants and affidavits, consent forms for any searches
that the defendant arguably has standing to challenge, Miranda rights and waiver of
Miranda rights forms, and photographs from which identification of the defendant
was made. If the government has discoverable materials not immediately available
locally, it shall advise the defendant of the existence and nature of the items.
N.D. Ga. CrR. 16.1.
In accordance with FED. R. CRIM. P. 12(b)(4), the government shall enumerate
and describe with particularity the existence and nature of all items seized during any
search that the defendant arguably has standing to challenge, including specifying
where such items were seized during said search.1
Where reciprocal discovery is
1
Pursuant to N.D. Ga. CrR. 16.1, at arraignment the government is required to
provide the defendant with an inventory of all items seized from the defendant by
law enforcement officials which the government expects to introduce at trial.
The government SHALL furnish the affected defendant with such an inventory.

3
requested by the government, the attorney for the defendant shall personally advise
the defendant of the request, the defendant’s obligations thereto, and the possibility
of sanctions, including exclusion of any such evidence from trial, for failure to
comply with the Rule. See FED. R. CRIM. P. 16(b) and (d); N.D. Ga. CrR. 16.1.
C. A party desiring to inspect and copy any materials which were not
available initially shall be permitted to do so in accordance with the Local Rules.
N.D. Ga. CrR. 16.1.
D. All discovery of materials known by the parties or their agents to exist
shall be completed within the times contemplated by this order unless a modifying
order is entered upon motion made under N.D. Ga. CrR. 16.1 or FED. R. CRIM. P.
16(d). The parties shall document, independent of their personal recollection,
compliance with requests and orders for discovery.
III. Filing Pretrial Motions
The parties are reminded that pretrial disclosure in criminal cases generally is
governed by FED. R. CRIM. P. 16 or pursuant to case law, such as Brady v. Maryland,
373 U.S. 83 (1963), and that the government ordinarily has no basis upon which to
object. The local rules require any party seeking relief through a motion to confer
with opposing counsel in an attempt to resolve disputed matters prior to the filing of

4
motions related thereto. N.D. Ga. CrR. 12.1.D. Moreover, FED. R. CRIM. P. 16
directs that the government must produce discoverable material upon only a
“request” of the defendant.
Therefore, counsel are DIRECTED to NOT file any motion for materials or
information or other relief that: (1) the opposing party has agreed to provide, or
(2) the party is entitled to inspect and copy under applicable criminal rules and case
law, UNLESS the attorney certifies to the court in writing that: (1) the materials
have been requested from the opposing party or the motion for other relief has been
discussed with the counsel for the opposing party, and (2) the opposing counsel
declines to provide the materials/information/relief requested. If counsel believes it
is necessary to document what is requested from, or agreed to by, the government, he
or she may do so by letter to opposing counsel, without filing or copying such letter
with the Court. Counsel also may re-label his or her standard motions as “Requests”
and serve them on opposing counsel, but NOT file them with the Clerk’s Office or
the Court. Or, counsel may file with the Clerk a certification that the defendant had
served the government with a discovery request, and keep the original discovery
request in his or her file, to be filed with the Clerk only upon the need to use the
request in court, similar to the practice in civil cases. See N.D. Ga. R. 5.4 and 26.3.

5
The Court WILL discuss any such requests at the pretrial conference. The requests,
certificates or letters may later be used to support a motion for sanctions or to
compel, if the opposing party fails to comply with his or her legal obligations or
agreements. See FED. R. CRIM. P. 16(d)(2).
If, after consultation and failure to reach an agreement with opposing counsel,
counsel files a motion for materials or information outside the scope of
FED. R. CRIM. P. 16 and relevant case law, he or she shall do so ONLY by making a
particularized showing that relates to the facts of this case.
IV. Standard Rulings
The following rulings are made in this case and are intended only to obviate
the need for standard, non-particularized motions on these subjects. Any party
who disagrees with these standard rulings may file, within the time allowed for filing
motions, see N.D. Ga. CrR. 12.1(B), a particularized motion for relief therefrom,
including a motion to compel or for a protective order.
A. Discovery Materials: Upon request of the defendant, the government is
directed to provide to the defendant all materials and information falling within the
scope of FED. R. CRIM. P. 16 and N.D. Ga. CrR. 16.1, including but not limited to an
inventory of all items seized from the defendant by law enforcement officials which

6
the government intends to introduce at trial. The government has a continuing duty
to disclose any evidence that is subject to discovery or inspection. United States v.
Jordan, 316 F.3d 1215, 1249 (11th
Cir. 2003); FED. R. CRIM. P. 16(c).
B. Discovery and Disclosure of Evidence Arguably Subject to Suppression
and of Evidence Which is Exculpatory and/or Impeaching: Upon request of the
defendant, the government is directed to comply with FED. RS. CRIM. P. 12 and 16,
by providing notice as specified in section II.B, supra. The government also is
directed to provide all materials and information that are arguably favorable to the
defendant in compliance with its obligations under Brady v. Maryland, 373 U.S. 83
(1963); Giglio v. United States, 405 U.S. 150 (1972); and their progeny.
Exculpatory material as defined in Brady and Kyles v. Whitley, 514 U.S. 419, 434
(1995), shall be provided sufficiently in advance of trial to allow a defendant to use it
effectively. Impeachment material must be provided no later than production of the
Jencks Act statements.
C. Rule 404(b): Upon request of the defendant, the government is directed to
provide to the defense a summary of any evidence it intends to offer of other crimes,
wrongs or acts pursuant to FED. R. EVID. 404(b). The 404(b) evidence shall be
provided to the defense as soon as practicable after the government has

7
determined to use such evidence, subject to the following deadlines: If the
404(b) evidence pertains to acts or conduct of the defendant which is alleged to have
occurred within the Northern District of Georgia, the summary required to be
provided under this heading and the rule shall be provided no later than fourteen
(14) days before trial. If the acts or conduct is alleged to have occurred outside the
Northern District of Georgia, the summary required to be provided under this
heading shall be provided no later than twenty-one (21) days before trial.
D. Preservation of Evidence and Handwritten Notes of Agents:
The government is directed to preserve all evidence and handwritten notes of law
enforcement officers pertaining to this case and the defendant. Notwithstanding this
provision, if the government wishes to destroy contraband drug evidence in
conformance with the procedures set forth in 28 C.F.R. § 50.21, the government
must first give each affected defendant notice in writing of the intended contraband
destruction. Said notice shall not be given earlier than fourteen (14) days after the
entry of this Order. Any defendant shall have fourteen (14) days after the date of
the notice to file a written objection to the proposed contraband destruction. If no
objections are filed and the government otherwise has complied with any applicable

8
protocol under 28 C.F.R. § 50.21, the government may destroy the excess
contraband.2
E. Examination and Testing of Physical Evidence: The defendant shall be
allowed to examine and test physical evidence under reasonable conditions which
maintain the integrity of the evidence.
F. Monitored Phone Calls of an In-Custody and All Electronic Recordings
of Defendant: The government shall disclose to the defendant if it has heard, used,
or intends to use, any monitored phone calls made by the defendant while in custody,
and shall disclose to defendant all electronic monitoring of the defendant in
accordance with FED. R. CRIM. P. 16 and 18 U.S.C. § 2500, et seq. (Title III).
A defendant is not entitled to the recorded conversations of co-defendants or others
to which he/she was not a party, unless required to be produced by Rule 16, the
Jencks Act, or Brady and/or Giglio.
G. Identification Materials: The government shall disclose to the defense the
circumstances under which any photographic or lineup identification of the
2
The government is reminded that the provisions of this Order apply only to
parties presently before the Court and not to defendants who have not been
apprehended or who are subsequently charged in this case.

9
defendant was made and shall provide the defendant with copies of any photographs
used to make any identification.
H. Charts and Summaries: The government shall produce any charts or
summaries to be used in its opening statement or presentation of its case-in-chief at
trial no later than three (3) business days before trial. The defendant shall produce
any charts and summaries to be used in his or her opening statement no later than
three (3) business days before trial. All other charts and summaries shall be
produced to the other party at least one (1) business day prior to their use. As used
in this paragraph, the term “summaries” excludes summaries of expert testimony
which must be disclosed upon request under FED. R. CRIM. P. 16(a)(1)(G); expert
summaries are due to be disclosed in the time provided for discovery.
I. Jencks Act (18 U.S.C. § 3500): The Court has no authority to order the
government to provide Jencks Act material at any time prior to the completion of
direct examination of the government witness at issue. Jordan, 316 F.3d at 1227
n.17, 1251 & n.78. The Court strongly encourages the government to disclose
Jencks Act material before the pretrial hearing or trial at which the witness will be
called to testify. Any agreement between the parties to provide early Jencks Act

10
material may be memorialized orally at the pretrial conference or by letter agreement
between the parties. The government is ORDERED to comply with the Jencks Act.
J. Names of Unindicted Co-Conspirators: If there is a conspiracy count in
the indictment or if the government intends to rely on FED. R. EVID. 801(d)(2)(E) to
introduce co-conspirator statements, the government is directed to provide the
defendant with the names of unindicted co-conspirators known to the government,
but not with statements made by co-conspirators or with their address or other
identifying information, unless required by the Jencks Act, Brady and/or Giglio.
K. Identification of Government Witnesses: Upon request of the defendant,
the government is required to provide the names of all expert witnesses, along with
other information and materials required by FED. R. CRIM. P. 16(a)(1)(F) and (G) and
FED. RS. EVID. 702, 703, and 705.
No party is required to provide a list of its other witnesses in advance of trial
unless otherwise compelled by law. The Court will entertain a motion for a witness
list only if it is particularized to the facts of this case.
L. Bruton Issues: The government shall disclose to the defendant and the
Court whether it anticipates introduction at trial of a co-defendant’s statement that
inculpates the defendant, within the meaning of Bruton v. United States, 391 U.S.

11
123 (1968). At the pretrial conference, the government shall be prepared to
announce whether, if both defendants opted to go to trial, they could not be tried
jointly since the co-defendant’s statements could not be properly redacted to comply
with the Supreme Court’s directive in Gray v. Maryland, 523 U.S. 185 (1998).
M. Motions to Sever Defendants Under FED. R. CRIM. P. 14(a) Due to
Prejudicial Overspill: Severance under FED. R. CRIM. P. 14 where there is an
allegation of undue prejudice from a joint trial due to prejudicial “overspill” is
warranted only when a defendant demonstrates that a joint trial will result in
“specific and compelling prejudice” to his or her defense. Compelling prejudice
occurs when the jury is unable, even after proper instruction from the trial court, “to
separately appraise the evidence as to each defendant and render a fair and impartial
verdict.” United States v. Liss, 265 F.3d 1220, 1228 (11th
Cir. 2001). The trial court
is empowered to sever defendants or counts after the commencement of the trial
under Rule 14 if manifest necessity so requires. United States v. Butler, 41 F.3d
1435, 1441 (11th
Cir. 1995). Therefore, any motion for severance on grounds of
prejudicial overspill should not be filed unless it sets out specific, individualized
grounds as to why the defendant is unduly prejudiced by a joint trial with others.

12
N. Reserving Right to File Additional or Out-of-Time Motions: Motions
for an extension of time to file pretrial motions are not granted as a matter of right,
but must be based on good cause shown. Any motion to file additional or out-of-
time motions must contain a particularized statement of the existence of good cause
to file such a motion, must identify the specific motion or motions that may be filed,
a statement of the position of opposing counsel, and be accompanied by a proposed
order which includes appropriate language excluding any delay under the Speedy
Trial Act, 18 U.S.C. § 3161, et seq.
O. Motion to Adopt Motions of Co-Defendants: No motion to adopt one or
more motions of a co-defendant shall be filed unless it is accompanied by a
statement specifically demonstrating the standing of the adopting party to seek the
relief requested in each motion sought to be adopted. A motion to adopt shall only
seek to adopt a single motion of a co-defendant; moving to adopt multiple motions,
even of the same co-defendant, requires the filing of a separate motion to adopt as to
each motion. As to any motion sought to be adopted, the adopting defendant must
either (1) specifically identify the motion sought to be adopted by its docket number
in CM/ECF (preferred); or (2) include as an attachment to the motion to adopt a copy
of at least the front page of the motion sought to be adopted. The motion must

13
otherwise comply with the requirements of N.D. Ga. CrR. 12.1.C. Any motions to
adopt not filed in compliance with this paragraph shall be denied.
P. Motion for Reciprocal Discovery: If the defendant has requested
discovery, upon request of the government following its compliance with its
FED. R. CRIM. P. 16(a)(1)(E) obligations, the defendant is required to provide
discovery materials and information in accordance with FED. R. CRIM. P. 16(b) and
N.D. Ga. CrR. 16.1.
Subject to the above instructions:
(1) Unless otherwise extended by the undersigned or the District Judge
to whom this case is assigned for trial, the parties shall file with the Clerk within (14)
fourteen days after arraignment any necessary pretrial motions pursuant to
N.D. Ga. CrR. 12.1A and B and 16.1 and N.D. Ga. R. 5.1.A, 7, 10 and 11.
(2) Each motion other than a motion to adopt shall contain a
certification that counsel conferred with opposing counsel concerning the
subject matter of the motion but was unable to reach agreement on the
resolution of the issue therein. N.D. Ga. CrR. 12.1D.
V. Procedure at Pretrial Conference
A. Government counsel shall be prepared to discuss:
1. The circumstances surrounding any arrest of the defendant;

14
2. The circumstances surrounding any identifications made of the
defendant;
3. The circumstances surrounding any statements made by the
defendant to law enforcement or other government
agents; and
4. The circumstances surrounding any searches or seizures that
resulted in evidence that the Government intends to
use against the defendant.
5. Whether it intends to introduce any evidence pursuant to FED. R.
EVID. 404(b).
6. Whether it intends to introduce any expert testimony.
B. Where possible, the undersigned will rule orally on any motions that
have been filed. The rulings will be noted on the docket sheets and the docket of the
case.
C. Evidentiary hearings will be scheduled.
D. Counsel also shall be prepared to discuss the following:
1. Evidentiary and other legal issues they anticipate may arise at
trial;
2. Probability of disposition of the case without trial;
3. Problems relating to the scheduling of trial; and
4. Whether any facts can be stipulated.
E. Failure to respond to a motion after being directed to do so within
fourteen (14) days thereafter or at such time as set by the Magistrate Judge may be
considered as indicating there is no opposition to the motion. N.D. Ga. R.7.1.B;
N.D. Ga. CrR. 12.1.B.

15
F. Failure by a party to raise defenses or objections or make motions as
specified in FED. R. CRIM. P. 12(b)(3)(A)-(D) shall constitute a waiver thereof,
unless good cause for such failure is shown.3
G. When a party fails to supplement or perfect a motion within the time
afforded after having requested or been given an opportunity to supplement or
perfect said motion, the Court may deem the original motion abandoned or
withdrawn.
VI. Rescheduling of the Pretrial Conference
The pretrial conference may be continued only by order of the Court. A party
seeking to continue a pretrial conference must first confer with all other counsel
representing parties in this case to determine whether all parties consent to the
continuance. If all parties consent to the rescheduling of the pretrial conference, the
party seeking the continuance should then contact the undersigned Magistrate
Judge’s Courtroom Deputy Clerk to request to reschedule the pretrial conference,
and if said request is granted, to set a new date and time for the conference.
3
A motion is not necessary to protect a party’s right to Rule 16 discovery
materials and information so long as the party seeking protection complies with the
procedure set forth in this Order. See FED. R. CRIM. P. 12(b)(3)(E).

16
If a party seeking to continue a pretrial conference cannot obtain the
consent of all parties in this case, a written motion specifying the reasons for
the continuance must be filed with the Clerk and a courtesy copy served on
the undersigned at least one (1) business day prior to the pretrial conference.
Any consent continuance or motion to continue the pretrial conference shall be
accompanied by a proposed order which includes the following: (1) a place for
the entry of any rescheduled date and time to hold the pretrial conference, and
(2) the following language for the Court’s consideration:
( ) The delay between the original and rescheduled pretrial
conferences shall be excluded from Speedy Trial Act calculations
because the Court finds that the reason for the delay was for good
cause and the interests of justice in granting the continuance outweigh
the public’s and the defendant’s rights to a speedy trial. 18 U.S.C.
§ 3161, et seq.
( ) The delay between the original and rescheduled pretrial
conferences shall not be excluded for Speedy Trial Act purposes.
18 U.S.C. § 3161, et seq.
( ) The Court finds that due to the extensive discovery in this case, it
was necessary to extend the time for the defendants to file pretrial
motions, and accordingly, postpone the holding of the initial pretrial
conference. The Court finds that the interests of justice in continuing
the pretrial motions deadline and in holding the pretrial conference
substantially outweigh the interests of the public and defendants in the
speedy resolution of this matter, and thus the Clerk is directed to
count as excludable any delay occurring in extending the motions
deadline and the holding of the pretrial conference. 18 U.S.C. § 3161,
et seq.

17
IT IS SO ORDERED, this the 3rd day of March 2016.
CATHERINE M. SALINAS

LEGAL02/36233078v1
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
ORDER
Defendant Tyson Rhame and the United States have consented to
modification of this Court’s February 22nd, 2016 Order Setting Conditions of
Release and Order requiring a $1,000,000 bond to allow Rhame to travel to the US
Virgin Islands. The Parties have agreed that these Orders should be modified to
allow Rhame to travel to Colorado or Wyoming instead of the US Virgin Islands
conditioned on: (i) the $1,000,000 cash bond already paid to the Court and (ii)
approval of these travel plans by Rhame’s probation officer.
Accordingly, it is hereby:
1. ORDERED, that this Court’s February 22nd, 2016 Order Setting Conditions
of Release and Order requiring a $1,000,000 bond to allow Rhame to travel

2
LEGAL02/36233078v1
to the US Virgin Islands be modified to allow Rhame to travel to Colorado
or Wyoming instead of the US Virgin Islands conditioned on (i) the
$1,000,000 cash bond already paid to the Court; and (ii) approval of these
travel plans by Rhame’s probation officer.
2. ORDERED, that upon his return to the Northern District of Georgia Rhame
will file a Motion pursuant to Local Rule 67 requesting this Court to direct
the Clerk to refund the $1,000,000 cash bond to Rhame.
SO ORDERED THIS ______ day of March, 2016
________________________________
ALAN J. BAVERMAN
Prepared by:
Ankith Kamaraju, Counsel for Tyson Rhame

LEGAL02/36216567v1
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
Motion to Amend Order Setting Conditions of Release
On February 22, 2016 this Court entered an order Setting Conditions of
Release as to Tyson Rhame. On the same day this Court approved travel by Tyson
Rhame to the US Virgin Islands conditioned on a payment of a $1,000,000 cash
bond paid into the Court registry. Rhame paid this $1,000,000 cash bond on
March 1, 2016. Confirmation of this payment was docketed with this Court on
March 2, 2016.
Because of mechanical problems with the boat Rhame was planning on
using in the US Virgin Islands, Rhame would like to modify the Order Setting
Conditions of Release and the Court’s order allowing Rhame to travel to the US
Virgin Islands to allow Rhame travel to Colorado or Wyoming instead.

2
LEGAL02/36216567v1
Accommodations are still being made at this time for the travel. The United States
has consented to this modification. Rhame’s probation officer requested a Court
order allowing Rhame to travel to either Colorado or Wyoming.
WHEREFORE, Rhame requests that this Court:
1. Modify its Order Setting Conditions of Release and Order requiring a
$1,000,000 bond to be paid to allow Rhame to travel to Colorado or
Wyoming instead of the US Virgin Islands conditioned on (i) the
$1,000,000 cash bond already paid to the Court; and (ii) approval of
these travel plans by Rhame’s probation officer;
2. Enter an Order directing the Clerk to refund the $1,000,000 cash bond
to Rhame upon his return to the Northern District of Georgia and upon
motion by Rhame pursuant to Local Rule 67.
Respectfully submitted, this 3rd day of March, 2016.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

LEGAL02/36216567v1
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
I hereby certify that on March 3, 2016, I electronically filed the foregoing
Motion to Amend Order Setting Conditions of Release with the Clerk of Court
using the CM/ECF system, which will automatically send e-mail notification to the
attorneys of record.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

600 U.S. Courthouse 75 Ted Turner Drive SW Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
1
ATLANTA DIVISION
v.
TYSON RHAME, ET AL.
Criminal Action No.
1:16-CR-67-SCJ-CMS
NOTICE OF ENTRY OF APPEARANCE
Dahil D. Goss, Assistant United States Attorney for the Northern District of
Georgia, files this Notice of Entry of Appearance and respectfully requests that
she be added as an additional counsel of record for the United States of America
for asset forfeiture issues.
JOHN A. HORN
/s/Dahil D. Goss
Dahil.Goss@usdoj.gov

I served this document today by filing it using the Court’s CM/ECF system,
which automatically notifies the parties and counsel of record.
March 4, 2016
/s/Dahil D. Goss
Dahil D. Goss

600 U.S. Courthouse 75 Ted Turner Drive SW Atlanta, GA 30303
(404) 581-6000 fax (404) 581-6181
1
ATLANTA DIVISION
v.
TYSON RHAME, ET AL.
Criminal Action No.
1:16-CR-67-SCJ-CMS
NOTICE OF ENTRY OF APPEARANCE
Kelly K. Connors, Assistant United States Attorney for the Northern District of
Georgia, files this Notice of Entry of Appearance and respectfully requests that
she be added as an additional counsel of record for the United States of America
for asset forfeiture issues.
JOHN A. HORN
/s/Kelly K. Connors
kelly.connors@usdoj.gov

I served this document today by filing it using the Court’s CM/ECF system,
which automatically notifies the parties and counsel of record.
March 4, 2016
/s/Kelly K. Connors
Kelly K. Connors

ATLANTA DIVISION
v.
TYSON RHAME,
)
)
) Criminal Case No. 1:16-CR-067-1-SCJ-CMS
)
)
)
)
ORDER
modification of this Court's February 22nd, 2016 Order Setting Conditions of
Release and Order requiring a $1,000,000 bond to allow Rhame to travel to the US
Virgin Islands. The Parties have agreed that these Orders should be modified to
allow Rhame to travel to Colorado or Wyoming instead of the US Virgin Islands
conditioned on: (i) the $1,000,000 cash bond already paid to the Court and (ii)
approval of these travel plans by Rhame's probation officer.
1. ORDERED, that this Court's February 22nd, 2016 Order Setting Conditions
of Release and Order requiring a $1,000,000 bond to allow Rhame to travel
LEGAL02/36233078v I

to the US Virgin Islands be modified to allow Rhame to travel to Colorado
or Wyoming instead of the US Virgin Islands conditioned on (i) the
prin
$1,000,000 cash bond already paid to the Court; and (ii) approval of these
-et<1� Sy<,�t.l� "
travel plans by Rhame's�officer.
2. ORDERED, that upon his return to the Northern District of Georgia Rhame
will file a Motion pursuant to Local Rule 67 requesting this Court to direct
the Clerk to refund the $1,000,000 cash bond to Rhame.
SO ORDERED THIS 4th day of March, 2016
Prepared by:
ALAN J. BAVERMAN
2
LEGAL02/36233078v I

75 Ted Turner Dr., S.W.,
Suite 600
Fax: (404) 581-6181
March 7, 2016
Courtroom Deputies
U.S. Courthouse
75 Ted Turner Drive, S.W.
Atlanta, GA 30303
Re: U.S. v. Rhame, et al (1:16-CR-067-SCJ-CMS)
This letter is to notify the Court pursuant to LCrR 57.1E(4), NDGa, that I will be
out of the office on May 2, 2016 through May 6, 2016 and July 5, 2016 through July 15,
2016. I request that the Court not schedule any court appearances in the above-
referenced matters for those dates.
Sincerely,
JOHN A. HORN
/S/ STEVEN D. GRIMBERG
cc via ECF: Defense Counsel of record

IN THE UNITED STATES DISTRICT COUR
ATLANTA DIVISION
UNITED STATES )
)
V. ) Criminal No. 1:16-CR-67-SCJ-CMS
)
TYSON RHAME, )
TERRENCE KELLER, )
JAMES SHAW, and )
FRANK BELL )
ORDER
Upon Defendants’ joint, unopposed motion and for good cause shown, the
Defendants’ motion for an extension of time for filing pretrial motions and to
continue the pretrial conference is GRANTED. It is hereby ORDERED that the
pretrial conference and motions deadline will set for March 28, 2016 with the
understanding that the parties may request additional time for motions due to the
volume of discovery, the timing of production, and the need for review.
It is also hereby ORDERED that the Clerk shall exclude the delay between
the current motions deadline, March 7, 2016, and the newly scheduled pretrial
conference, March 28, 2016, from the Speedy Trial Act calculations because the
Court finds that the reason for the delay was for good cause and the interests of
justice in granting the continuance outweigh the public’s and the defendants’ rights
to a speedy trial insofar as the failure to grant such continuance would deny counsel

for the defendants the reasonable time necessary for preparation. 18 U.S.C. § 3161,
et seq.
SO ORDERED this _______ day of March, 2016.
___________________________________
HON. CATHERINE M. SALINAS
PRESENTED BY:
Thomas L. Hawker
Georgia State Bar Number: 338670
Federal Defender Program, Inc.
Suite 1500, Centennial Tower
101 Marietta Street, NW
Thomas_hawker@fd.org

1
IN THE UNITED STATES DISTRICT COUR
ATLANTA DIVISION
UNITED STATES )
)
V. ) Criminal No. 1:16-CR-67-SCJ-CMS
)
TYSON RHAME, )
TERRENCE KELLER, )
JAMES SHAW, and )
FRANK BELL )
UNOPPOSED JOINT MOTION TO CONTINUE
PRETRIAL CONFERENCE AND MOTIONS DEADLINE
Defendants, though counsel, hereby file this joint motion to continue the
pretrial conference currently set for March 11, 2016 and the pretrial motions
deadline set for March 7, 2016 as follows:
1.
On February 10, 2016, the defendants were indicted on mail and wire fraud
charges as well as on charges of money laundering.
2.
On February 22, 2016, the defendants were arraigned and released on bond.
At arraignment, the government provided partial discovery consisting of 4 discs
entitled:
• “E-MAIL-SW-000001 to 001113;; INTV – DEFENDANT-0001 to
0020; and SW-000001 to 002468”

2
• “Rhame Interview 6-3-15”
• “Frank Bell Interview May 28, 2015”
• “Frank Bell Interview June 3, 2015”
3.
In its discovery letter, the government indicated that discovery is voluminous
and that defendants each needed to provide five 3-terabyte hard drives and one 1-
terabyte hard drive for the remaining discovery material. These hard drives have
been provided to the government. The government is in the process of transferring
the discovery data to the drives for production to defense counsel.
4.
The government also proposed a protective Order governing the treatment of
the discovery. The parties are currently working to resolve the language of the Order
which will govern potentially sensitive data.
5.
In addition, the defendants are currently determining the best way to copy,
store, and manage the volume of discovery. For example, the volume of discovery
in this case exceeds the entire office storage capacity of Federal Defender Program,
Inc. by two and one-half times. Defense counsel is actively discussing with the
government and each other the best ways to coordinate and eliminate duplication
and the logistics of storing and reviewing the data once turned over.

3
6.
The deadline for pretrial motions pursuant to Rule 12 of the Federal Rules of
Criminal Procedure and Order of this Court is March 7, 2016, with the pretrial
conference set for March 11, 2016.
7.
Through undersigned counsel, the parties respectfully request that the Court
continue the pretrial motions deadline and continue the date for the pretrial
conference. Specifically, the parties request that the motions deadline and pretrial
conference be reset to March 28, 2016, with the understanding that, at the
conference, the parties will propose a motions deadline, update the court on the
discovery production, and raise any other issues of concern. This extension will
hopefully allow for the resolution of the protective Order, the production of some (if
not all) of the voluminous discovery, and the ability for defense counsel to better
assess a realistic motions deadline. Counsel for Mr. Keller has conferred with
counsel for each co-defendant and is authorized to report that they join this motion.
8.
Undersigned counsel is authorized to report that the Government does not
oppose this motion.

4
9.
Under 18 U.S.C. § 3161(h)(7)(A), because the interests of justice in granting
the continuance outweigh the public’s interest in a speedy trial, the time between the
date of this filing, March 7, 2016, and March 28, 2016 should be excluded from
speedy trial calculations.
WHEREFORE, the undersigned, on behalf of the defendants, respectfully
moves this Court to grant the motion to continue the pretrial conference and to
extend the pretrial motions deadline. A proposed Order is attached.
Dated: This 7th day of March, 2016.
/s/ Thomas L. Hawker
THOMAS L. HAWKER
Attorney for Terrence Keller
FEDERAL DEFENDER PROGRAM, INC.
Suite 1500, Centennial Tower
101 Marietta Street, N.W.
Atlanta, GA 30303
(404) 688-7530/Fax (404) 688-0768
Thomas_Hawker@fd.org

5
I hereby certify that the foregoing has been formatted in Times Roman 14 pt.,
in accordance with Local Rule 5.1B, and was filed by ECF this day with the Clerk
of Court with a copy served by ECF notice upon counsel of record as follows:
Thomas J. Krepp
600 Richard B. Russell Building
Dated: This 7th day of March, 2016.
/s/ Thomas L. Hawker
THOMAS L. HAWKER
Attorney for Terrence Keller

75 Spring Street S.W., Suite 600 Fax: (404) 581-6181
March 8, 2016
Courtroom Deputies
U.S. Courthouse
75 Ted Turner Dr., S.W.
Re: U.S. v. Tyson Rhame, et al. (1:16-CR-67-SCJ-CMS)
U.S. v. Kwabena Otchere (1:14-CR-265-MHC-CMS)
U.S. v. Cheryl Singleton (1:15-CR-443-SCJ-JFK)
U.S. v. Qadir Shabazz (1:13-CR-441-TCB-CMS)
U.S. v. Reginald Byrd (1:15-CR-267-LMM)
U.S. v. Rodney Byrd (1:15-CR-266-LMM)
Pursuant to Local Criminal Rule 57.1(E)(4), I write to notify the Court that I
will be out of the office May 12, 2016, May 13, 2016, and May 16, 2016. I request
that the Court not schedule any court appearances in the above-referenced
matters for those dates.
Sincerely,
JOHN A. HORN
/s/Thomas J. Krepp
THOMAS J. KREPP
cc: Counsel for Defendant (via ECF)

March 8, 2016
Courtroom Deputy
US Courthouse
Atlanta, GA 30303
Re: United States of America v. Tyson Rhame, et al; 1:16-cr-00067
Dear Courtroom Deputy:
I hereby respectfully notify the Court and all opposing counsel pursuant to Local
Criminal Rule 57.1(E)(4) that I will be out of the office from March 31, 2016 through April
10, 2016. Please accept this request that the Court not schedule any appearances in this
matter during the aforementioned period of absence. The Court’s consideration in this
regard is appreciated. By e-filing this letter I have notified counsel of my correspondence
with the Court.
Sincerely,
/s/ Mike Brown
Michael L. Brown
cc: All counsel of record (via CM/ECF system)
LEGAL02/36239752v1

8629617v1
ATLANTA DIVISION
Plaintiff,
v.
TYSON RHAME,
TERRENCE KELLER, aka TERRYK,
JAMES SHAW, and FRANK BELL,
Defendants.
CRIMINAL ACTION
NO. 1:16-cr-00067-SCJ-CMS
NOTICE OF APPEARANCE
Notice is hereby given, pursuant to Northern District of Georgia Local Rule
83.1(D), that Sean T. Sullivan of the law firm Arnall Golden Gregory LLP hereby
enters his appearance as counsel for Defendant Frank Bell requesting that any
notices, pleadings, and other materials be sent to:
Sean Sullivan, Esq.
Georgia State Bar No. 558105
171 17th Street, N.W., Suite 2100
Atlanta, Georgia 30363-1031
sean.sullivan@agg.com
Phone: 404-873-8510
Fax: 404-873-8511

8629617v1 2
Respectfully submitted this 11th day of March, 2016.
/s/ Sean T. Sullivan
Sean T. Sullivan
sean.sullivan@agg.com
171 17th Street, N.W., Suite 2100
Telephone: 404-873-8510
Facsimile: 404-873-8511
Counsel for Defendant Frank Bell

8629617v1 3
I hereby certify that I have this day served the foregoing NOTICE OF
APPERANCE on all counsel of record by causing a copy of the same to be filed
electronically through the Court’s ECF system which will automatically send
email notification to all Counsel of Record.
This 11th day of March, 2016.
/s/ Sean T. Sullivan
Sean T. Sullivan

ATLANTA DIVISION
UNITED STATES OF AMERICA, :
:
Plaintiff, :
: CRIMINAL ACTION NO.
v. :
: 1:16-CR-0067-03-SCJ-CMS
JAMES SHAW, :
:
Defendant. :
MOTION TO DIRECT CLERK TO
RETURN $2 MILLION BOND
On February 29, 2016, Magistrate Judge Baverman entered an Order (Doc.
32), directing the Clerk to accept into the registry of the court a $2 million cash
bond from James Shaw, which was posted as security in connection with his one-
week trip to the Bahamas.
On March 5, 2016 Mr. Shaw went to the Bahamas and he returned on March
12, 2016. Mr. Shaw has returned his passport to the Pretrial Services Officer, Gail
Broadwater.
Pursuant to the terms of the February 29, 2016 Order (Doc. 32), Shaw
requests that the court issue an Order to direct the Clerk to refund the $2 million to
the trust account of Garland, Samuel & Loeb, P.C.

RESPECTFULLY SUBMITTED,
GARLAND, SAMUEL & LOEB, P.C.
/s/ Donald F. Samuel
DONALD F. SAMUEL
Attorney for Defendant
3151 Maple Drive, N.E.
(404) 262-2225
dfs@gsllaw.com

ATLANTA DIVISION
UNITED STATES OF AMERICA, :
:
Plaintiff, :
: CRIMINAL ACTION NO.
v. :
: 1:16-CR-0067-03-SCJ-CMS
JAMES SHAW, :
:
Defendant. :
I hereby certify that I have this date served the within and foregoing
MOTION TO DIRECT CLERK TO RETURN $2 MILLION BOND with the
Clerk of Court using the CM/ECF system which will automatically send email
notification of such filing to the attorneys of record.
This the 17th day of March, 2016.
/s/ Donald F. Samuel
DONALD F. SAMUEL
Attorney for Defendant

4
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
PROPOSED ORDER FOR DISBURSEMENT OF CASH BOND
Defendant Tyson Rhame was permitted to travel outside of Georgia pursuant
to this Court’s February 22nd, 2016, Order Setting Conditions of Release and its
March 4th, 2016, Order requiring payment of a $1,000,000 cash bond to allow such
travel. Defendant Rhame returned to the Northern District of Georgia on March 12,
2016, and notified his Pretrial Services Officer of the same on March 14, 2016.
Defendant Rhame subsequently filed a Motion pursuant to this Court’s March 4th,
2016, Order and Local Rule 67.1 requesting disbursement of the $1,000,000.00 cash
bond that he tendered to the Court’s registry on March 1st, 2016. Defendant Rhame
and the United States have consented to disbursement of said funds.
Accordingly, it is hereby ORDERED, that the Clerk is authorized and directed
to draw a check on the funds on deposit in the registry of this Court in the principal

5
amount of $1,000,000.00 plus all accrued interest, minus any statutory users fees,
payable to Tyson Rhame, and mail or deliver the check to Tyson Rhame.
________________________________
ALAN J. BAVERMAN
Prepared by:

ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
Consent Motion for Disbursement of Cash Bond
On February 22nd, 2016, this Court entered an order Setting Conditions of
Release as to Tyson Rhame. (Doc. 16.) On the same day, this Court approved Mr.
Rhame’s travel plans to the U.S. Virgin Islands contingent upon deposit of a
$1,000,000.00 cash bond into the Court’s registry. (Doc. 17.) That order was
modified on March 4th, 2016, to allow Mr. Rhame to travel to Colorado or Wyoming
rather than the U.S. Virgin Islands. (Doc. 45.) The same March 4th, 2016, Order
also directed Mr. Rhame to file a Motion upon his return to the Northern District of
Georgia pursuant to Local Rule 67.1, requesting this Court to direct the Clerk to
refund the $1,000,000.00 cash bond to Mr. Rhame. (Doc. 45.) On March 1st, 2016,
Mr. Rhame deposited the initial principal sum of $1,000,000.00 into the Court’s
registry. (CQ 16461900096.) Mr. Rhame returned to the Northern District of

2
Georgia on March 12, 2016, and notified his Pretrial Services Officer of his return
on March 14, 2016. He now requests disbursement of the aforementioned
$1,000,000.00 cash bond. The United States has consented to such disbursement.
WHEREFORE, Mr. Rhame requests this Court, pursuant to its March 4th,
2016, Order and Local Rule 67.1, to enter an Order directing the Clerk to disburse
the aforementioned $1,000,000.00 cash bond in the form of a check payable to Mr.
Rhame.
Respectfully submitted, this 17th day of March, 2016.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar. No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777
E-Mail: ankith.kamaraju@alston.com

3
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
I hereby certify that on March 17th, 2016, I electronically filed the
foregoing Motion for Disbursement of Cash Bond with the Clerk of Court using
the CM/ECF system, which will automatically send e-mail notification to the
attorneys of record.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar. No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

ATLANTA DIVISION
)
)
TYSON RHAME, )
PROPOSED ORDER FOR DISBURSEMENT OF CASH BOND
Defendant Tyson Rhame was permitted to travel outside of Georgia pursuant
to this Court's February 22nd, 2016, Order Setting Conditions of Release and its
March 4th, 2016, Order requiring payment of a $1,000,000 cash bond to allow such
travel. Defendant Rhame returned to the Northern District of Georgia on March 12,
2016, and notified his Pretrial Services Officer of the same on March 14, 2016.
Defendant Rhame subsequently filed a Motion pursuant to this Court's March 4th,
bond that he tendered to the Court's registry on March 1st, 2016. Defendant Rhame
and the United States have consented to disbursement ofsaid funds.
Accordingly, it is hereby ORDERED, that the Clerk is authorized and directed
4

payable to Tyson Rhame, and mail or deliver the check to Tyson Rhame.
SO ORDERED THIS f )''day of March, 2016
Prepared by:
ALAN J. BAVERMAN
--
5

LEGAL02/36259415v1
ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
ORDER
modification of this Court’s February 22nd, 2016 Order Setting Conditions of
Release to allow Rhame to travel to Houston, Texas on March 20th, 2016 to visit an
acquaintance having surgery. The parties agree that Rhame will return to the
Northern District of Georgia on March 24th, 2016. The parties have also agreed that
Rhame should be allowed to travel to St. Simons, Georgia on March 28th, 2016 to
visit a family member having surgery. The parties agree that Rhame will return to
the Northern District of Georgia on March 30th, 2016. All travel must be
preapproved by Rhame’s Pretrial Services Officer.

2
LEGAL02/36259415v1
1. ORDERED, that this Court’s February 22nd, 2016 Order Setting Conditions
of Release be modified to allow Rhame, upon approval of these travel plans
by Rhame’s Pretrial Services Officer, to travel to Houston, Texas on March
20th, 2016. Rhame is to return to the Northern District of Georgia on March
24th, 2016. This Court’s February 22nd Order Setting Conditions of
Release is also modified to allow Rhame, upon approval of these travel plans
by Rhame’s Pretrial Services Officer, to travel to St. Simon’s Georgia on
March 28th, 2016. Rhame is to return to the Northern District of Georgia on
March 30th, 2016.
________________________________
ALAN J. BAVERMAN
Prepared by:

ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
Motion to Amend Order Setting Conditions of Release
On February 22, 2016 this Court entered an order Setting Conditions of
Release as to Tyson Rhame. Rhame would like to travel to Houston, Texas on
March 20th, 2016 to visit an acquaintance having surgery. Rhame will return to
the Northern District of Georgia on March 24th, 2016. Rhame would also like to
travel to St. Simons, Georgia on March 28th, 2016 to visit a family member having
surgery. Rhame will return to the Northern District of Georgia on March 30th,
2016. The United States has consented to this modification. Rhame’s Pretrial
Services Officer will preapprove each of these trips but has requested a Court order
allowing Rhame to travel on the planned trips.
WHEREFORE, Rhame requests that this Court:

1. Modify its Order Setting Conditions of Release to allow Rhame, upon
approval of these travel plans by Rhame’s Pretrial Services Officer, to
travel to Houston, Texas on March 20th, 2016. Rhame will return to the
Northern District of Georgia on March 24th, 2016. This Court’s Order
Setting Conditions of Release is also modified to allow Rhame, upon
approval of these travel plans by Rhame’s Pretrial Services Officer, to
travel to St. Simon’s Georgia on March 28th, 2016. Rhame is to return to
the Northern District of Georgia on March 30th, 2016.
Respectfully submitted, this 18th day of March, 2016.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar. No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

ATLANTA DIVISION
)
)
TYSON RHAME, )
TERRANCE KELLER, )
JAMES SHAW, )
FRANK BELL )
I hereby certify that on March 18th, 2016, I electronically filed the
foregoing Motion to Amend Order Setting Conditions of Release with the Clerk
of Court using the CM/ECF system, which will automatically send e-mail
notification to the attorneys of record.
/s/ Ankith Kamaraju
Ankith Kamaraju
Ga. Bar. No. 667989
ALSTON & BIRD LLP
One Atlantic Center
Tel: 404-881-7000
Fax: 404-881-7777

ATLANTA DIVISION
v.
TYSON RHAME,
TERRANCE KELLER,
JAMES SHAW,
FRANK BELL
)
)
) Criminal Case No. 1:16-CR-00067
)
)
)
)
)
ORDER
modification of this Court's February 22nd, 2016 Order Setting Conditions of
Release to allow Rhame to travel to Houston, Texas on March 20th, 2016 to visit an
acquaintance having surgery. The parties agree that Rhame will return to the
Northern District of Georgia on March 24th, 2016. The parties have also agreed that
Rhame should be allowed to travel to St. Simons, Georgia on March 28th, 2016 to
visit a family member having surgery. The parties agree that Rhame will return to
the Northern District of Georgia on March 30th, 2016. All travel must be
preapproved by Rhame's Pretrial Services Officer.
LEGAL02/362594I 5vI

1. ORDERED, that this Court's February 22nd, 2016 Order Setting Conditions
of Release be modified to allow Rhame, upon approval of these travel plans
by Rhame's Pretrial Services Officer, to travel to Houston, Texas on March
20th, 2016. Rhame is to return to the Northern District of Georgia on March
24th, 2016. This Court's February 22nd Order Setting Conditions of
Release is also modified to allow Rhame, upon approval of these travel plans
by Rhame's Pretrial Services Officer, to travel to St. Simon's Georgia on
March 28th, 2016. Rhame is to return to the Northern District of Georgia on
March 30th, 2016.
SO ORDERED THIS l�y of March, 2016
Prepared by:
ALAN J. BAVERMAN
2
LEGAL02/36259415vl

8653288v1
UNITED STATESDISTRICT COURT
FORTHENORTHERNDISTRICT OF G EORG IA
ATLANTA DIVISION
U NITED STATESOF AM ERICA,
Pla intiff,
v.
TYSONRHAM E,
TERRENCEK ELLER,a k a TERRYK ,
JAM ESSHAW ,a nd FRANK BELL,
Defend a nts.
CRIM INALACTION
NO. 1:16-cr-00067-SCJ-CM S
PROPOSED ORDERFORRELEASEOF BOND
Defend a ntFra nk Bellw a s perm itted to tra velou tsid eofG eorg ia pu rsu a ntto
this Cou rt’s Febru ary 22,2016 Ord er setting Cond itions of Relea se. OnM a rch 1,
2016,Fra nk Bella nd his m other,Alice Fraser,posted a secu red bond of $200,000,
w ith a M s. Fra ser’s hom ea t105 Scarborou g h Cou rt,SE,M a rietta ,G A 30067-4331 as
secu rity. Defend a ntBellretu rned to theNorthernDistrict ofG eorg ia onM a rch 12,
2016,a nd notified his Pretria lServices Officerofhis retu rn. M r. Bellsu bsequ ently
filed a M otionpu rsu a nt to the Febru a ry 22,2016 Order and the M a rch 1,2016
Appea ra nce Bond ,requ esting sa tisfa ctionof the bond a nd relea se of the su rety
a g a instM s. Fra ser’s hom e. Defend antBella nd theU nited Sta tes ha veconsented to
su ch a relea se.

8653288v1 2
Accord ing ly, it is hereby ORDERED, tha t the secu red bond a nd su rety
a g a inst M s. Fra ser’s hom e a s d escribed inthe M arch 1,2016 Appea ra nce Bond ,is
hereby SATISFIED and RELEASED.
SO ORDERED THIS______d a y ofM a rch,2016,
____________________________________
ALANJ. BAVERM AN
U NITED STATESM AG ISTRATEJU DG E
Prepa red by:
Sea nT. Su lliva n,Cou nselforFra nk Bell

8653288v1
UNITED STATESDISTRICT COURT
FORTHENORTHERNDISTRICT OF G EORG IA
ATLANTA DIVISION
U NITED STATESOF AM ERICA,
Pla intiff,
v.
TYSONRHAM E,
TERRENCEK ELLER,a k a TERRYK ,
JAM ESSHAW ,a nd FRANK BELL,
Defend a nts.
CRIM INALACTION
NO. 1:16-cr-00067-SCJ-CM S
CONSENT M OTIONFORRELEASEOF BOND
OnFebru a ry 22,2016,this Cou rt entered a nOrder Setting Cond itions of
Relea serela ted to Frank Bell. (Doc. 29.) As a na d d itiona lcond itionofrelea se,this
Cou rt a pproved M r. Bell’s tra velpla ns to the U .S. Virg inIsla nd s conting ent u pon
posting his m other’s hom ea s secu rity a tlea st48 hou rs beforethetrip. OnM a rch 1,
2016, M r. Bell a nd his m other, Alice Fra ser, posted a n Appea ra nce Bond of
$200,000,w ith a M s. Fra ser’s hom e a t 105 Sca rborou g h Cou rt,SE,M a rietta ,G A
30067-4331 a s secu rity. (Doc. 38.) OnM a rch 3,2016,M r. Bell,throu g h cou nsel,
notified the Pretria l Services Officer tha t M r. Bell’s trip w ou ld instea d be to
Colora d o. M r. Bellretu rned to theNorthernDistrictofG eorg ia onM a rch 12,2016,
a nd notified his Pretria lServices Officerof his retu rn. He now requ ests relea se of

8653288v1 2
the a forem entioned bond secu red by M s. Fra ser’s hom e. The U nited Sta tes ha s
consented to su ch a relea se.
W HEREFORE,M r.Bellrequ ests tha tthis Cou rt,pu rsu a ntto theFebru ary 22,
2016 Ord era nd theM a rch 1,2016 Appeara nceBond ,enteranOrd ertha t thebond
is sa tisfied a nd thesu rety a g a instM s.Fraser’s hom eis relea sed.
Respectfu lly su bm itted this 18th d a y ofM a rch,2016.
/ s/ Sea nT. Su lliva n
Sea nT. Su lliva n
G eorg ia Ba rNo. 558105
sea n.su lliva n@ a g g .com
ARNALLG OLDEN G REG ORY LLP
171 17th Street,N.W .,Su ite2100
Atla nta ,G eorg ia 30363
Telephone:404-873-8510
Fa csim ile:404-873-8511
Counsel for Defendant Frank Bell

8653288v1 3
CERTIFICATEOF SERVICE
Ihereby certify tha t Iha ve this d a y served the foreg oing CONSENT
M OTIONFORRELEASEOF BOND ona llcou nselofrecord by ca u sing a copy of
the sa m e to be filed electronica lly throu g h the Cou rt’s ECF system w hich w ill
a u tom a tica lly send em a ilnotifica tionto a llCou nselofRecord .
This 18th d a y ofM a rch,2016.
/ s/ Sea nT. Su lliva n
Sea nT. Su lliva n
G eorg ia Ba rNo. 558105

ATLANTA DIVISION
v. CRIMINAL ACTION FILE
NO. 1:16-CR-0067-3-SCJ-CMS
JAMES SHAW,
Defendant.
ORDER FOR DISBURSEMENT OF CASE BOND
Defendant James Shaw was permitted to travel outside of Georgia pursuant
to this Court's February 22°d, 2016, Order Setting Conditions of Release and its
February 29th, 2016, Order requiring payment of a $2,000,000 case bond to allow
such travel. DefendantShaw returned to the Northern District of Georgia on March
12, 2016, and returned his passport to the Pretrial Services Officer, Gail Broadwater.
Defendant Shaw subsequentlyfiled a Motion pursuant to this Court's February 29th,
bond that he tendered to the Court's registry on March 3rd, 2016. Defendant Shaw
and the United States have consented to disbursement of said funds.
Accordingly, it ishereby ORDERED, thatthe Clerk is authorized and directed

payable to the trust account of Garland, Samuel & Loeb, P.C.
IT IS SO ORDERED, this the �Y.y of March, 2016.
ALANJ�AN
UNITEDSTATES MAGISTRATEJUDGE

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