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Home Court filings USA v. Thomas et al USA v. Thomas et al — Darrell Thomas judgment, N.D. Ga. Motion for Final Order of Forfeiture by USA as to Darrell Thomas — USA v. Thomas et al. (Dkt. 647, N.D. Ga.)

Court filing

Motion for Final Order of Forfeiture by USA as to Darrell Thomas — USA v. Thomas et al. (Dkt. 647, N.D. Ga.)

Filed March 8, 2023 in USA v. Thomas et al.; one of 58 filings from this case.

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2023-03-08

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 647 · 2023-03-08 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
DARRELL THOMAS 
 
Criminal Action No. 
1:20-cr-00296-JPB-AJB 
MOTION FOR FINAL ORDER OF FORFEITURE 
COMES NOW the United States of America (United States), pursuant to Rule 
32.2(c) of the Federal Rules of Criminal Procedure, and moves the Court for a final 
order of forfeiture.  In support thereof, the United States shows the following:  
Defendant Darrell Thomas pleaded guilty to Counts One and Eighteen of the 
Criminal Indictment, pursuant to a written plea agreement, in which he agreed to, 
among other things, forfeit certain property to the United States.  The Consent 
Preliminary Order of Forfeiture was entered on August 4, 2021 [Doc. 265], 
forfeiting 
the 
following 
property 
to 
the 
United 
States 
pursuant 
to                       
18 U.S.C. §§ 982(a)(1) and (2): 
a. $341,151.47 in funds seized from Bank of America account number 
XXXXXX3940 held in the name of Bellator Phront Group, LLC. 
b. $1,113,113.97 in funds seized from Bank of America account number 
XXXXXX4823 held in the name of Elite Executive Services, Inc. 
c. $536,875.00 in funds seized from Bank of America account number 
XXXXXX8102 held in the name of Bellator Phront Group, Inc. 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 1 of 6

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d. $131,610.00 in United States Currency. 
e. 2018 Land Rover Range Rover Autobiography, VIN 
SALGW2SE2JA503793. 
f. 2018 Mercedes Benz S-Class S65 AMG, VIN WDDUG7KB5JA408046. 
g. 2017 Acura NSX, VIN 19UNC1B08HY000536. 
h. Men’s yellow gold Rolex with diamond bezel and dial. 
i. 18K yellow gold Cuban link necklace with diamonds in clasp.  
j. 18K yellow gold Cuban link bracelet with diamonds in clasp. 
A Supplemental Consent Preliminary Order of Forfeiture was entered on May 
9, 2022, [Doc. 468], forfeiting the following additional property to the United 
States: 
a. $151,395.22 in funds seized from MetaBank account number 
XXXXXXXX6687 held in the name Rapid Pay Card for Bellator 
Phront Group, LLC. 
Pursuant to 21 U.S.C. § 853(n)(1), as incorporated by 28 U.S.C. § 2461(c), the 
United States is required to publish notice of the preliminary order of forfeiture 
and “may also, to the extent practicable, provide direct written notice to any 
person known to have alleged an interest in the” subject property. Here, the 
United States posted notice of the forfeiture action on the official government 
internet site forfeiture.gov for at least thirty consecutive days beginning on August 
12, 2021, and ending on September 10, 2021 [Doc. 398].  The United States posted 
supplemental notices beginning October 27, 2021, and ending on November 25, 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 2 of 6

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2021 [Doc. 399], and beginning May 13, 2022, and ending on June 11, 2022 [Doc. 
501]. 
The United States also sent notice of the forfeiture to all known third parties 
who may have an interest in the assets. Specifically, notice of the forfeiture was 
sent to the following entities and individuals: 
• On June 3, 2022, notice of this forfeiture was delivered to Auto Pawn of 
Daytona, which had an alleged ownership interest in the 2017 Acura 
NSX, VIN 19UNC1B08HY000536 
• On June 9, 2022, notice of this forfeiture was delivered to Laytanya 
Chennet Tarver, who had an alleged ownership interest in the 2017 
Acura NSX, VIN 19UNC1B08HY000536 
• On or about May 31, 2022, the United States sent notice of this forfeiture 
action to Nathalie Ferreir Concepcion, who had an alleged ownership 
interest in the 2017 Acura NSX, VIN 19UNC1B08HY000536. According 
to the United States Postal Service tracking system, the certified-mailed 
notice is still in transit, but the notice mailed via regular U.S. has not been 
returned.  
The Government is not aware of any other person who has an ownership 
interest in the property to whom direct written notice may have been provided. 
Unless excused, anyone claiming an interest in the property must file a petition 
with the Court requesting a hearing to adjudicate that interest.  Such a petition 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 3 of 6

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must be filed “within thirty days of the final publication of notice or his receipt of 
notice…whichever is earlier”.  21 U.S.C. § 853(n)(2).   
On July 1, 2022, Attorney Gregory Snell filed a petition on behalf of William 
Shaffer d/b/a Daytona Beach Imports Inc d/b/a Auto Pawn of Daytona as to the 
2017 Acura NSX, VIN 19UNC1B08HY000536. [Doc 510]. On December 16, 2022, 
the United States entered into a Stipulated Settlement Agreement as to Daytona 
Beach Imports Inc d/b/a Auto Pawn of Daytona (“Claimant”). (Doc. 644). The 
United States agreed that, upon entry of a Final Order of Forfeiture of the 2017 
Acura NSX, VIN 19UNC1B08HY000536, and the sale of the vehicle, the United 
States will pay Claimant $50,000.00 in full settlement and satisfaction of any and 
all claims by Claimant to this vehicle. (Doc. 644 ¶ 3).  
No one else has filed a petition in this criminal ancillary proceeding and the 
time to do so has expired. Thus, the property should be forfeited to the United 
States pursuant to Fed. R. Crim. P. 32.2(c)(2), and 18 U.S.C. § 982(a)(1) and (2). 
WHEREFORE, the United States respectfully requests that this Court enter a 
final order of forfeiture allowing the United States to dispose of the assets 
according to law: 
a. $341,151.47 in funds seized from Bank of America account number 
XXXXXX3940 held in the name of Bellator Phront Group, LLC. 
b. $1,113,113.97 in funds seized from Bank of America account number 
XXXXXX4823 held in the name of Elite Executive Services, Inc. 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 4 of 6

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c. $536,875.00 in funds seized from Bank of America account number 
XXXXXX8102 held in the name of Bellator Phront Group, Inc. 
d. $131,610.00 in United States Currency. 
e. 2018 Land Rover Range Rover Autobiography, VIN 
SALGW2SE2JA503793. 
f. 2018 Mercedes Benz S-Class S65 AMG, VIN WDDUG7KB5JA408046. 
g. 2017 Acura NSX, VIN 19UNC1B08HY000536. 
h. Men’s yellow gold Rolex with diamond bezel and dial. 
i. 18K yellow gold Cuban link necklace with diamonds in clasp.  
j. 18K yellow gold Cuban link bracelet with diamonds in clasp. 
k. $151,395.22 in funds seized from MetaBank account number 
XXXXXXXX6687 held in the name Rapid Pay Card for Bellator Phront 
Group, LLC. 
                                                               Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RYAN K. BUCHANAN 
United States Attorney 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Radka T. Nations  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RADKA T. NATIONS 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assistant United States Attorney 
Georgia Bar No. 618248 
600 U.S. Courthouse 
75 Ted Turner Drive, S.W. 
Atlanta, Georgia 30303 
Telephone: (404) 581-6000 
Radka.nations2@usdoj.gov 
 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 5 of 6

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Certificate of Service 
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 7, 2023 
 
/s/ RADKA T. NATIONS 
 
 
RADKA T. NATIONS 
 
Assistant United States Attorney 
 
Case 1:20-cr-00296-JPB-CMS     Document 647     Filed 03/08/23     Page 6 of 6

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  1. Stipulation of Settlement Agreement as to Darrell Thomas — USA v. Thomas et al. (Dkt. 644, N.D. Ga.)same docket · 2023-03-03
  2. Final Order and Judgment of Orfeiture as to Darrell Thomas — USA v. Thomas et al. (Dkt. 655, N.D. Ga.)same docket · 2023-03-28
  3. TRANSCRIPT of Proceedings as to Darrell Thomas held on 06/16/2022, before Judge JP… — USA v. Thomas et al (Dkt. 604)same docket · 2022-11-21
  4. TRANSCRIPT of Proceedings as to Darrell Thomas held on 05/09/2022, before Judge JP… — USA v. Thomas et al (Dkt. 603)same docket · 2022-11-21
  5. MOTION to Amend Final Order of Forfeiture with Brief In Support by USA as to Darrell… — USA v. Thomas et al (Dkt. 668)same docket · 2023-04-20
  6. Amended Judgment and Commitment as to Darrell Thomas — USA v. Thomas et al. (Dkt. 475, N.D. Ga.)same docket · 2022-05-23
  7. Judgment and Commitment as to Darrell Thomas (1), Cbop — USA v. Thomas et al. (Dkt. 473, N.D. Ga.)same docket · 2022-05-18
  8. Sentencing Memorandum as to Darrell Thomas filed by USA — USA v. Thomas et al. (Dkt. 464, N.D. Ga.)same docket · 2022-05-04
  9. Sentencing Memorandum as to Darrell Thomas filed by Darrell Thomas — USA v. Thomas et al (Dkt. 462)same case · 2022-04-29
  10. Transcript of Proceedings as to Darrell Thomas held on 3/17/21 — USA v. Thomas et al. (Dkt. 113, N.D. Ga.)same case · 2021-04-19
  11. Order as to Darrell Thomas granting the Government's Motion — USA v. Thomas et al. (Dkt. 106, N.D. Ga.)same case · 2021-03-17

Part of: USA v. Thomas et al — Darrell Thomas judgment, N.D. Ga. · U.S. District Court for the Northern District of Georgia · Paycheck Protection Program (PPP) · Criminal prosecutions · Orders and opinions · 2023 · Court filings

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