United States of America’s Unopposed Motion to Approve Sale Price and Sale Terms for Real Property Located at 3726 South Las Vegas Boulevard, Unit 1803, Las Vegas, Clark County, Nevada — United States v. Abramovs (Dkt. 96, D. Nev.)

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The United States of America's Unopposed Motion to Approve Sale Price and Sale Terms for a Veer Towers condominium unit in Las Vegas, Clark County, Nevada, 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, dated June 9, 2022. The government asks the Court to approve the sale of the forfeited unit for $495,000. It states that neither the buyers nor anyone who will be on the title after the sale is a felon and that the sale is an arms-length transaction. District Judge Richard F. Boulware signed the order line on June 11, 2022.

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Case 2:21-cr-00027-RFB-DJA Document 96 Filed 06/11/22 Page 1 of 3



 1 JASON M. FRIERSON
   United States Attorney
 2 Nevada Bar Number 7709
   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
                              UNITED STATES DISTRICT COURT
 8                                 DISTRICT OF NEVADA

 9 UNITED STATES OF AMERICA,                     2:21-CR-027-RFB-DJA

10               Plaintiff,                      United States of America’s Unopposed
                                                 Motion to Approve Sale Price and Sale
11         v.                                    Terms for Real Property Located at 3726
                                                 South Las Vegas Boulevard, Unit 1803,
12 JORGE ABRAMOVS,                               Las Vegas, Clark County, Nevada

13               Defendant.

14         The United States moves this Court to approve a sale of 3726 South Las Vegas

15 Boulevard, Unit 1803, Las Vegas, Clark County, Nevada (property) 1 for $495,000.

16
    MORE PARTICULARLY DESCRIBED AS:
     1

17 PARCEL I:
   UNIT ONE THOUSAND EIGHT HUNDRED THREE (1803) IN BUILDING “W” IN
18 VEER TOWERS, AS SHOWN ON THAT CERTAIN FINAL MAP OF THE VEER
   TOWERS, A RESORT CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF
19
   PLATS, PAGE 42 (THE “MAP”) AND AS SET FORTH IN THE DECLARATION OF
20 COVENANTS, CONDITIONS AND RESTRICTIONS AND RESERVATION OF
   EASEMENTS FOR VEER TOWERS (THE “DECLARATION”), RECORDED MAY
21 03, 2010 IN BOOK 20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE
   OF THE COUNTY RECORDER, CLARK COUNTY, NEVADA (THE “OFFICIAL
22 RECORDS”).

23 PARCEL II:
   AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE COMMON
24 ELEMENTS OF VEER TOWERS (INCLUDING ANY ANNEXATIONS
   THEREOF)AS SHOWN BY THE MAP AND AS SET FORTH IN THE DECLARTION.
25 PARCEL III:
   AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS ONE (1) AND TWO
26 (2) DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS LIMITED

27 COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS ONE (1) AND TWO
   (2) IN THE DECLARATION AND AD SHOWN AND DELINEATED UPON THE
28 MAP REFFERED TO ABOVE.

            Case 2:21-cr-00027-RFB-DJA Document 96 Filed 06/11/22 Page 2 of 3



 1          The reasons for this request are (1) Jorge Abramovs agreed to the sale of the property

 2   at $495,000, (2) to authorize Doug Sawyer to sell the property for $495,000 under the Court-

 3   ordered interlocutory sale, (3) to stop the accruing of taxes and fees, and (4) to avoid

 4   accidents and liability accruing against the property.

 5          This Motion is made and is based on the papers and pleadings on file herein and the

 6   attached Memorandum of Points and Authorities.

 7                          Motion and Memorandum of Points and Authorities

 8          This Court authorized the Interlocutory Sale of the property. 2 Mr. Sawyer listed the

 9   price for $480,000. Anthony Chun and Shao Hua Chang offered $495,000 to purchase the

10   property. If this Court does not approve the sale, the buyers will receive their earnest money

11   deposit.

12

13
     PARCEL IV:
14   NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
     OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
15   CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
16   DECEMBER 01, 2009 AND RECORDED DECEMBER 1, 2009 IN BOOK 20091201 AS
     INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS AMENDED BY
17   THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF CENTRAL PLANT
     EASEMENTS, DATED JANUARY 7, 2010 AND RECORDED JANUARY 7, 2010 IN
18   BOOK 20100107 AS INSTRUMENT NO. 0000577 OF OFFICIAL RECORDS; (B)
     PARKING AND ACCESS AGREEMENT, DATED APRIL 28, 2010 AND
19   RECORDED MAY 3, 2010 IN BOOK 20100503 AS INSTRMENT NO. 0000515 OF
20   OFFICIAL RECORDS; (C) DECLARATION OF SUPPORT AND ENCROACHMENT
     EASEMENTS, DATED DECEMBER 1, 2009 AND RECORDED DECEMBER 1, 2009
21   IN BOOK 20091201 AS INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND
     AS AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF
22   SUPPORT AND ENCROACHMENT EASEMENTS, DATED JANUARY 7, 2010 AND
     RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO. 0000578
23
     OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY SYSTEMS
24   EASEMENTS, DATED DECEMBER 1, 2009 AND RECORDED DECEMBER 1, 2009
     IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF OFFICIAL RECORDS, AND
25   AS AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF
     LIFE SAFETY SYSTEM EASEMENTS DATED JANUARY 7, 2010 AND
26   RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
     0000579, AND ALL IMPROVEMENTS AND APPURTENANCES THEREON, APN:
27
     162-20-714-153.
     2
28     Order granting 54 Motion for an Interlocutory Order of Sale of 3726 South Las Vegas
     Boulevard, Unit 1803, ECF No. 56.
                                                    2

              Case 2:21-cr-00027-RFB-DJA Document 96 Filed 06/11/22 Page 3 of 3



 1            If this Court approves the sale price and sale terms, the proceeds will be accounted

 2   for and distributed according to the terms set forth herein. The escrow payments are

 3   approximately (1) $5,207.20 to the Clark County Treasurer pursuant to the signed

 4   Stipulation; 3 (2) $12,782.99 for HOA fees; (3) $5,110 for title transfer and escrow costs; (4)

 5   the broker commission at a rate of 6% of the purchase price; (5) $720 for the Common

 6   Interest Community fees; and (6) the remaining proceeds to the government to be held in an

 7   interest-bearing account by the United States Marshals Service, which will constitute the

 8   amount to be retained by the Court as a substitute res under Fed. R. Crim. P. 32.2(b)(7) and

 9   Supp. R. G(7)(b)(iii) and (iv).

10            The government has determined that (1) neither the buyers nor any individual who

11   will be on the title after the completion of the sale is a felon; and (2) this sale represents an

12   arms-length transaction.

13            Dated: June 9, 2022.
                                                          JASON M. FRIERSON
14                                                        United States Attorney
15                                                        /s/ James A. Blum
                                                          JAMES A. BLUM
16                                                        Assistant United States Attorney
17

18                                                        IT IS SO ORDERED:
19

20                                                        RICHARD F. BOULWARE
                                                          UNITED STATES DISTRICT JUDGE
21
                                                          DATED: June 11, 2022
22

23

24

25

26

27

28
     3
         Stipulation, ECF No. 76.
                                                      3

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