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Home Court filings Full Docket Kao Hawaii 1 21 Cr 00061 MOTION for Forfeiture of Property Motion for Entry of a Forfeiture Money Judgment and P…

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MOTION for Forfeiture of Property Motion for Entry of a Forfeiture Money Judgment and Preliminary Order of… (Dkt. 107)

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CourtU.S. District Court for the District of Hawaii
Filed2023-08-15

U.S. District Court for the District of Hawaii · No. 1:21-cr-00061-LEK · Doc. 107 · 2023-08-15 · Docket on CourtListener

Summary

A motion by the United States for a forfeiture money judgment and preliminary order of forfeiture in United States v. Martin Kao, No. 1:21-cr-00061-LEK, in the U.S. District Court for the District of Hawaii, filed August 15, 2023 (Doc. 107). Under Fed. R. Crim. P. 32.2(b), it asks for a money judgment of $12,841,490.00, the total PPP funds it says were fraudulently obtained, and forfeiture of four sums seized on or about September 30, 2020: $693,986.72, $8,000,000.00, $2,000,000.00 and $20,200.00. It states that Kao pled guilty on September 7, 2022 to three wire fraud counts and five money laundering counts without a plea agreement. The motion traces the seized funds to the Navatek LLC account that received the PPP funds and to transfers from it. It is signed by Assistant U.S. Attorney Sydney Spector.

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CLARE E. CONNORS #7936  
      GLENN S. LEON 
United States Attorney 
 
 
      Chief, Fraud Section 
District of Hawaii  
 
 
      Criminal Div., U.S. Dept. of Justice 
 
CRAIG S. NOLAN 
 
 
       
SYDNEY SPECTOR #11232  
      JENNIFER BILINKAS 
 
Assistant U.S. Attorney  
 
      Trial Attorney 
Room 6100, PJKK Federal Building       U.S. Dept. of Justice  
300 Ala Moana Blvd. 
 
 
      Criminal Division, Fraud Section 
Honolulu, Hawaii  96850  
 
      1400 New York Avenue, N.W. 
Telephone:  (808) 541-2850 
 
      Washington, D.C. 20005 
Facsimile:  (808) 541-2958 
 
      Telephone:  (202) 305-3928 
Email: Craig.Nolan@usdoj.gov     
      Email: Jennifer.Bilinkas@usdoj.gov 
 
 Sydney.Spector@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
IN THE UNITED STATES DISTRICT COURT 
 
 
FOR THE DISTRICT OF HAWAII 
 
 
UNITED STATES OF AMERICA, 
 
 
 
 
Plaintiff, 
 
 
v. 
 
MARTIN KAO,          
 
 
 
 
Defendant. 
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Crim. No. 21-00061 LEK 
 
UNITED STATES’ MOTION FOR 
ENTRY OF A FORFEITURE MONEY 
JUDGMENT AND PRELIMINARY 
ORDER OF FORFEITURE AS TO 
SPECIFIC PROPERTY; PROPOSED 
ORDER OF FORFEITURE (MONEY 
JUDGMENT) AND PRELIMINARY 
ORDER OF FORFEITURE (SPECIFIC 
PROPERTY); CERTIFICATE OF 
SERVICE   
 
 
 
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UNITED STATES’ MOTION FOR ENTRY 
OF A PRELIMINARY ORDER OF FORFEITURE 
 
Pursuant to Fed. R. Crim. P. 32.2(b), the United States of America, by and 
through its undersigned attorneys, moves this Court for the entry of a forfeiture 
money judgment against defendant Martin Kao in the amount of $12,841,490.00 
and preliminary order of forfeiture as to the following property seized on or about 
September 30, 2020:  
i. 
$693,986.72 seized from defendant’s business operating 
account Central Pacific Bank (“CPB”) Account No. 
xxxxxx9145; 
ii. 
$8,000,000.00 seized from defendant’s business investment 
account Merrill Lynch Account No. xxx-x3506; 
iii. 
$2,000,000.00 seized from defendant’s personal investment 
account Merrill Lynch Account No. xxx-x2641; and 
iv. 
$20,200.00 from defendant’s personal checking account First 
Hawaiian Bank (“FHB”) Account No. xx-xx1787 
(collectively, the “Specific Forfeitable Property”). 
 
BACKGROUND 
 
On May 6, 2021, a multi-count Indictment was filed charging defendant 
Martin Kao with three counts of wire fraud, in violation of 18 U.S.C. § 1343 
(Counts 1 through 3) and five counts of money laundering, in violation of 18 U.S.C 
§ 1957 (Counts 4 through 8), and providing notice that, upon conviction, the 
government would seek forfeiture.   
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On September 7, 2022, defendant Martin Kao pled guilty to all Counts, 
without a plea agreement.  In advance of the change of plea, the Government 
submitted a letter to the Court, dated September 6, 2022, outlining the factual basis 
for each of the counts.  ECF No. 102.   During the change of plea hearing, 
defendant Martin Kao agreed that the following facts (the facts relevant to the 
forfeiture sought herein) were accurate.  Sept. 7, 2022 Tr. (“Tr.”) 33:10-38:18: 
 During the period of March 2020 through July 2020, Defendant 
owned 99% of Navatek LLC and served as its Chief Executive 
Officer.  ECF No. 102, Factual Basis at ¶ 1. 
 From approximately March 2020 through July 2020, Defendant 
knowingly submitted and caused to submitted false and fraudulent 
applications for Paycheck Protection Program (“PPP”) loans to Bank 
1 and Bank 2, which resulted in Defendant fraudulently obtaining 
$12,841,490.00 in PPP funds, to which he was not entitled.   The 
funds were deposited into Navatek LLC’s CPB account ending in 
9145.  Id. at ECF No 102 at ¶¶ 3-12, 14-23; see also Tr. at 21:8-26:17, 
39:20-23.  
 Defendant made the following transactions from the Navatek LLC 
CPB bank account ending in 9145 that received the $12,841,490 in 
fraudulently-obtained PPP funds.  Each transaction contained more 
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than $10,000 of the proceeds of the wire fraud to which defendant 
pled guilty: 
Date of 
Transaction 
Description of Transaction 
  
Disposition of Funds 
 
Transaction 
Amount 
04/21/2020 
 
 
  
Check no. 31029 payable to 
NAVATEK, LLC 
 
  
Deposited into 
Navatek’s Merrill 
Lynch account no. 
XXX-X3506 
 
$2,000,000 
 
 
  
04/22/2020 
 
 
 
  
Check no. 30986 payable to 
MARTIN KAO 
 
 
  
Deposited into 
Defendant’s Personal 
Merrill Lynch 
account no. XXX-
X2641 
 $2,000,000 
 
 
 
  
04/29/2020 
 
 
  
Check no. 31124 payable to 
NAVATEK, LLC 
 
  
Deposited into 
Navatek’s Merrill 
Lynch account no. 
XXX-X3506 
 $3,000,000 
 
 
  
05/07/2020 
 
 
  
Check no. 31127 payable to 
NAVATEK, LLC 
 
  
Deposited into 
Navatek’s Merrill 
Lynch account no. 
XXX-X3506 
 $3,000,000 
 
 
  
05/18/2020 
 
 
 
  
Check no. 31249 payable to 
MARTIN KAO 
 
  
Deposited into 
Defendant’s Personal 
FHB account no. XX-
XX1787 
  
 $20,200 
 
 
 
  
 
 
TOTAL 
$10,020,200 
 
Id. at ¶ 36; see also Tr. 31:6-32:13.   
 
On or about September 30, 2020, the government seized certain funds (the 
Specific Forfeitable Property) held in the CPB account that received the 
fraudulently-obtained PPP funds, and from the Merrill Lynch and FHB Accounts 
to which Defendant subsequently transferred the illegal proceeds.  
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The government now seeks a forfeiture money judgment in the amount of 
$12,841,490.00 (the total amount of fraudulently-obtained PPP funds) and entry of 
a Preliminary Order of Forfeiture as to the Specific Forfeitable Property.     
ARGUMENT 
 
Rule 32.2 of the Federal Rules of Criminal Procedure provides, in pertinent 
part: 
As soon as practicable after . . . a plea of guilty . . . is 
accepted, on any count in an indictment or information 
regarding which criminal forfeiture is sought, the court 
must determine what property is subject to forfeiture 
under the applicable statute.  If the government seeks 
forfeiture of specific property, the court must determine 
whether the government has established the requisite 
nexus between the property and the offense. If the 
government seeks a personal money judgment, the court 
must determine the amount of money that the defendant 
will be ordered to pay. 
 
Fed. R. Crim. P. 32.2(b)(1)(A).  The court’s determination as to the requisite nexus 
and the amount of a money judgment “may be based on evidence already in the 
record . . . and any additional evidence or information submitted by the parties and 
accepted by the court as relevant or reliable.”  Fed. R. Crim. P. 32.2(b)(1)(B); see 
also United States v. Creighton, 52 Fed. Appx. 31, 36 (9th Cir. 2002) (hearsay 
evidence permissible in determining forfeiture).  If forfeiture is contested, either 
party may request a hearing.  Fed. R. Crim. P. 32.2(b)(1)(B).  The court “must 
promptly enter a preliminary order of forfeiture setting forth the amount of any 
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money judgment [or] directing the forfeiture of specific property . . . .”  Fed. R. 
Crim. P. 32.2(b)(2)(A).  Unless doing so is impractical, such order must be entered 
sufficiently in advance of sentencing to allow the parties to suggest revisions or 
modifications before the order becomes final.  Fed. R. Crim. P. 32.2(b)(2)(B). 
 
The only question before the Court is whether the evidence before the Court 
is enough to establish, by a preponderance of the evidence, that the requisite nexus 
exists between the forfeitable property and the offenses to which the defendant has 
pled guilty.1  See Rule 32.2(b)(1); see also United States v. Shryock, 342 F.3d 948, 
991 (9th Cir. 2003) (standard of proof regarding the forfeitability of property in a 
criminal case is preponderance of the evidence).  Where the statutory prerequisites 
are met, forfeiture is mandatory.  See United States v. Depue, 585 Fed. Appx. 388, 
388-89 (9th Cir. 2014) (“Because the Government included notice of forfeiture in 
its criminal information, entry of a forfeiture judgment against [defendant] is 
mandatory . . . , and the district court erred in refusing to enter such a judgment at 
the Government’s request.”). 
 
1 The existence or extent of third-party interests in the specific property is 
determined after the entry of the preliminary order.  See United States v. 
Lazarenko, 476 F.3d 642, 648 (9th Cir. 2007).   
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A. 
The Court Should Enter a Forfeiture Money Judgment in the 
Amount of $12,841,490.00 
 
 
 Pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461, a person 
convicted of wire fraud in violation of 18 U.S.C. § 13432, shall forfeit to the United 
States any property, real or personal, which constitutes or is derived from proceeds 
traceable to that offense. 18 U.S.C. § 981(a)(1)(C); 28 U.S.C. § 2461.  “Proceeds” 
is “property of any kind obtained directly or indirectly, as the result of the 
commission of the offense giving rise to forfeiture, and any property traceable 
thereto, and is not limited to the net gain or profit realized from the offense.”  18 
U.S.C. § 981(a)(2)(A).  The amount of the forfeiture is not what the defendant 
earned, but what was “obtained” as a result of the commission of the offense.  
United States v. Lo, 839 F.3d 777, 793 (9th Cir. 2016); United States v. Prasad, 18 
F.4th 313, 319 (9th Cir. 2021).  Additionally, because a wire fraud offense 
necessarily includes a fraudulent scheme as a whole, “the proceeds of the crime of 
conviction consist of the funds involved in that fraudulent scheme, including 
additional executions of the scheme that were not specifically charged or on which 
the defendant was acquitted.”  Lo, 839 F.3d at 793. 
 
Here, Defendant obtained $12,841,490.00, which constitutes proceeds of the 
wire fraud offenses in Counts 1 and 2 to which Defendant pled guilty.  
 
2 Wire fraud is a specified unlawful activity as defined in 18 U.S.C. § 1956(c)(7). 
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Specifically, as a result of Defendant’s false statements to Bank 1 in Navatek 
LLC’s PPP loan application, Defendant obtained $10,000,000 on April 18, 2020.  
ECF No. 106, Factual Basis at ¶ 12.  As a result of Defendant’s false statements to 
Bank 2 in connection with a Navatek subsidiary’s PPP loan application, Defendant 
obtained $2,841,490 on May 6, 2020.  Id. at ¶ 22.  Although the fraudulently-
obtained PPP funds were deposited into an account in the name of Navatek LLC, 
Defendant was 99% owner of Navatek LLC and had control of the account.  Id. at 
¶¶ 1, 36.   
Additionally, pursuant to 18 U.S.C. § 982(a)(1), a person convicted of a 
violation of 18 U.S.C. § 1957 shall forfeit any property, real or personal, involved 
in such violation and property traceable to such violation.  18 U.S.C. § 982(a)(1). 
Here, defendant pled guilty in Counts 4 through 8 to violating 18 U.S.C. 
§ 1957 by engaging in monetary transactions that contained over $10,000 in 
criminally derived property (here, the fraudulently-obtained PPP loans).   Id. at 
¶ 36.  The total funds involved in such § 1957 violations, and thus subject to 
forfeiture, is $10,020,000.  Because at least some of the funds involved in each 
§ 1957 transaction (over $10,000 of each transaction) is included in calculation of 
the forfeiture money judgment amount based on a proceeds theory, the 
Government takes a conservative approach, and does not seek a forfeiture money 
judgment greater than the $12,841,490.   
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Accordingly, the government is entitled to a forfeiture money judgment in 
the amount of $12,841,490.00 (the “Forfeiture Money Judgment”), pursuant to 18 
U.S.C. § 981(a)(1)(C) and 28 U.S.C. §2461, as proceeds of the wire fraud. Further, 
$10,020,000 of the Forfeiture Money Judgment is subject to forfeiture, pursuant to 
18 U.S.C. § 982(a)(1), as property involved in a violation of 18 U.S.C. § 1957 
(Counts 4 through 8). 
B. 
The Court Should Enter a Preliminary Order of Forfeiture as to 
the Specific Forfeitable Property 
 
In addition to the entry of the Forfeiture Money Judgment, the Government 
requests that the Court enter a preliminary order of forfeiture as to the Specific 
Forfeitable Property, namely: 
i. 
$693,986.72 seized from defendant’s business operating 
account CPB Account No. xxxxxx9145; 
ii. 
$8,000,000.00 seized from defendant’s business investment 
account Merrill Lynch Account No. xxx-x3506; 
iii. 
$2,000,000.00 seized from defendant’s personal investment 
account Merrill Lynch Account No. xxx-x2641; and 
iv. 
$20,200.00 from defendant’s personal checking account FHB 
Account No. xx-xx1787. 
Here, Defendant’s fraudulently-obtained PPP funds were deposited into CPB 
account ending in 9145.  ECF No. 106, Factual Basis at ¶¶ 12, 22.  Various 
transactions were then made (totaling $10,020,200) from that CPB account to 
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Merrill Lynch accounts ending in 3506 and 2641, and an FHB account ending in 
1787.  Id. ¶ 36.   
The $693,986.72 seized from CPB Account No. xxxxxx9145 constitutes 
proceeds of the wire fraud to which Defendant pled guilty and is forfeitable 
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461.  The other Specific 
Forfeitable Property (the property seized from the Merrill Lynch and FHB 
accounts) is property involved in the 18 U.S.C. § 1957 violations to which 
Defendant pled guilty, and is subject to forfeiture pursuant 18 U.S.C. § 982(a)(1).   
Upon final forfeiture of the Specific Forfeitable Property, Defendant will be 
entitled to a credit against the amount remaining due on the forfeiture money 
judgment, in the net amount of the Specific Forfeitable Property that is forfeited.   
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CONCLUSION 
 
As the government has proven the requisite basis for forfeiture, the 
requirements of Rule 32.2(b) have been met and the proposed Order of Forfeiture 
(Money Judgment) and Preliminary Order of Forfeiture (Specific Property) should 
be entered. 
DATED:  Honolulu, Hawaii, August 15, 2023. 
 
Respectfully submitted, 
 
CLARE E. CONNORS 
United States Attorney 
District of Hawaii 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Sydney Spector 
By  
 
 
 
 
 
               SYDNEY SPECTOR 
     Assistant U.S. Attorney
Case 1:21-cr-00061-LEK     Document 107     Filed 08/15/23     Page 11 of 12  PageID.946

CERTIFICATE OF SERVICE 
 
I hereby certify that, on the date noted below, a true and correct copy of the 
foregoing was served on counsel of record using the Court’s CM/ECF electronic 
filing system. 
 
DATED:  August 15, 2023, at Honolulu, Hawaii. 
 
 
 
/s/ Sydney Spector  
 
 
 
 
 
 
 
 
 
U.S. Attorney’s Office 
 
Case 1:21-cr-00061-LEK     Document 107     Filed 08/15/23     Page 12 of 12  PageID.947

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