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Settlement Agreement
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SCOTT ERIK ASPHAUG, OSB #833674
Acting United States Attorney
District of Oregon
GAVIN W. BRUCE, OSB #113384
Assistant United States Attorney
Gavin.Bruce@usdoj.gov
405 East 8th Avenue, Suite 2400
Eugene, Oregon 97401
Telephone: (541) 465-6771
Attorneys for the United States of America
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
UNITED STATES OF AMERICA,
v.
ANDREW AARON LLOYD,
Defendant.
6:21-cr-00198-MC
SETTLEMENT AGREEMENT
The United States and claimant Charles Schwab & Co., Inc., (“Schwab”) and its
authorized counsel, Brad S. Daniels, have agreed to settle its claim to the funds held in Charles
Schwab Account xx4724, in accord with the following terms.
IT IS AGREED by and between the undersigned parties as follows:
This agreement has no effect on any claims that any other department or agency of the
United States may have against defendant Andrew Lloyd or Charles Schwab & Co., Inc.
The United States agrees to return to Charles Schwab & Co., Inc. $1,789,592.47, which
includes interest.
Claimant Schwab hereby agrees to release and to hold the United States, and any agents,
servants, and employees of the United States, or any state or local law enforcement agency,
acting in their individual or official capacities, harmless from any claim, whether presently or
Settlement Agreement
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hereinafter known, made by themselves arising from and on account of the seizure of the above-
described assets.
The parties will each bear their own costs and their own attorney's fees in this matter.
The parties agree, pursuant to 28 U.S.C. ' 2465(a)(2), there was reasonable cause for the
seizure and arrest of the property and neither the persons who made the seizure or arrest nor the
prosecutors shall be liable to suit or judgment on account of such suit or prosecution, nor shall
the claimant be entitled to costs.
All persons signing this agreement have read and understand each and every provision
herein. This Settlement Agreement is entered into freely and voluntarily. By signing this
Settlement Agreement, the parties merely intend to settle the claims made in this litigation. Each
person signing this Settlement Agreement is fully authorized to do so, whether on his or her own
behalf or as representative for or on behalf of any other party or claimant herein.
This Court shall retain jurisdiction in this cause for the purpose of enforcing the terms of
this agreement.
_____________________________
_____________________
Greg Scanlon, Managing Director
DATE
Claimant Charles Schwab & Co., Inc.
_____________________________
_____________________
Brad S. Daniels,
DATE
Attorney for claimant Schwab
__________________________
_____________________
Gavin W. Bruce
DATE
Assistant United States Attorney
Attorney for the United States of America
/s/ Gregory M. Scanlon
December 29, 2021
/s/ Brad S. Daniels
December 29, 2021
January 3, 2022
s/