United States of America’s Motion to Approve Listing Price for Real Property Located at 3726 South Las Vegas Boulevard, Unit 509, Las Vegas, Nevada — United States v. Abramovs (Dkt. 83, D. Nev.)

Summary

The United States of America's Motion to Approve Listing Price for a second Veer Towers condominium unit in Las Vegas in United States of America v. Jorge Abramovs, No. 2:21-CR-027-RFB-DJA, in the U.S. District Court for the District of Nevada. The government, through Assistant United States Attorney James A. Blum, asks the Court to approve a listing sale price of $325,000 for the unit and sets out its legal description. It states that on April 12, 2022 the defendant agreed to the sale price through his counsel, Maggie Lambrose, and relies on a valuation from Douglas Sawyer and recent comparable sales. The order line was signed by District Judge Richard F. Boulware, II on April 29, 2022.

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Case 2:21-cr-00027-RFB-DJA Document 83 Filed 04/29/22 Page 1 of 3



 1 CHRISTOPHER CHIOU
   Acting United States Attorney
 2 Nevada Bar Number 14853
   JAMES A. BLUM
 3 Assistant United States Attorney
   501 Las Vegas Boulevard South, Suite 1100
 4 Las Vegas, Nevada 89101
   (702) 388-6336
 5 james.blum@usdoj.gov
   Attorneys for the United States
 6

 7

 8                             UNITED STATES DISTRICT COURT
                                    DISTRICT OF NEVADA
 9
10 UNITED STATES OF AMERICA,                      2:21-CR-027-RFB-DJA

11                Plaintiff,                      United States of America’s Motion to
                                                  Approve Listing Price for Real Property
12         v.                                     Located at 3726 South Las Vegas
                                                  Boulevard, Unit 509, Las Vegas, Nevada
13 JORGE ABRAMOVS,

14                Defendant.

15                         Motion and Memorandum of Points and Authorities

16         The United States of America (United States) moves this Court to approve a listing

17 sale price of $325,000 for Real Property Located at 3726 South Las Vegas Boulevard, Unit

18 509, Las Vegas, Clark County, (Unit 509):

19         MORE PARTICULARLY DESCRIBED AS:
20         PARCEL 1:
21         UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON
           THAT CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT
22         CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF PLATS,
           PAGE 42 AND AS SET FORTH IN THE DECLARATION OF
23         COVENANTS, CONDITIONS AND RESTRICTIONS AND
           RESERVATION OF EASEMENTS FOR VEER TOWERS RECORDED
24         MAY 03, 2010 IN BOOK 20100503 AS INSTRUMENT NO. 0002036,
           BOTH IN THE OFFICE OF THE COUNTY RECORDER, CLARK
25         COUNTY, NEVADA.
26         PARCEL 2:
27         AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE
           COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
28

           Case 2:21-cr-00027-RFB-DJA Document 83 Filed 04/29/22 Page 2 of 3



 1          ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
            FORTH IN THE DECLARTION.
 2
            PARCEL 3:
 3
            AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS 1 AND 2
 4          DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS
            LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO
 5          PARCELS 1 AND 2 IN THE DECLARATION AND AS SHOWN AND
            DELINEATED UPON THE MAP REFFERED TO ABOVE.
 6
            PARCEL 4:
 7
            NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS,
 8          USE AND OTHER PURPOSES ALL DESCRIBED IN THE
            DECLARATION AND IN THAT CERTAIN (A) DECLARTION OF
 9          CENTRAL PLANT EASEMENTS, DATED DECEMBER 01, 2009 AND
            RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
10          INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
            AMENDED BY THAT CERTAIN FIRST AMENDMENT TO
11          DECLARATION OF CENTRAL PLANT EASEMENTS, DATED
            JANUARY 07, 2010 AND RECORDED JANUARY 07, 2010 IN BOOK
12          20100107 AS INSTRUMENT NO. 0000577 OF OFFICIAL RECORDS; (B)
            PARKING AND ACCESS AGREEMENT, DATED APRIL 28, 2010 AND
13          RECORDED MAY 03, 2010 IN BOOK 20100503 AS INSTRMENT NO.
            0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF SUPPORT
14          AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01, 2009
            AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
15          INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS
            AMENDED BY THAT CERTAIN FIRST AMENDMENT TO
16          DECLARATION OF SUPPORT AND ENCROACHMENT
            EASEMENTS, DATED JANUARY 07, 2010 AND RECORDED
17          JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO. 0000578
            OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
18          SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND
            RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
19          INSTRUMENT NO. 0002886 OF OFFICIAL RECORDS, AND AS
            AMENDED BY THAT CERTAIN FIRST AMENDMENT TO
20          DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS DATED
            JANUARY 07, 2010 AND RECORDED JANUARY 07, 2010 IN BOOK
21          20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS,
            AND ALL IMPROVEMENTS AND APPURTENANCES THEREON,
22          APN: 162-20-714-020.

23          On November 12, 2021, this Court authorized the Interlocutory Sale of Unit 509.

24   Order Approving Interlocutory Sale, ECF No. 56. The Interlocutory Sale was not opposed

25   by Defendant. ECF No. 56. Following the Court’s Order, Douglas Sawyer (the Court-

26   approved broker) appraised the property and, based on recent sales, adjustments to the

27   recent sales to account for differences between the property and comparable properties, the

28   condition of the property, and the prevailing real estate market, opined that the property


                                                   2

            Case 2:21-cr-00027-RFB-DJA Document 83 Filed 04/29/22 Page 3 of 3



 1   was worth between $320,000 and $325,000. Mr. Sawyer has recommended a listing price of

 2   $325,000. 1

 3          The United States recommends that this Court approve the recommended listing

 4   price of $325,000. The United States views this listing price as fair and reasonable based on

 5   the information received from Douglas Sawyer and the most recent comparable sales.

 6          Respectfully submitted this 13th day of April 2022.

 7                                                     CHRISTOPHER CHIOU
                                                       Acting United States Attorney
 8
                                                       /s/ James A. Blum
 9                                                     JAMES A. BLUM
                                                       Assistant United States Attorney
10

11

12
                                                IT IS SO ORDERED:
13

14
                                                RICHARD F. BOULWARE, II
15                                              UNITED STATES DISTRICT JUDGE
16                                              DATED:      April 29, 2022

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28   On April 12, 2022, the Defendant agreed to the sale price of $325,000 through his counsel,
     1

     Maggie Lambrose.
                                                   3

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