Government's Bill of Particulars Re Forfeiture Allegations — United States v. Budamala (Document 23)

Summary

Government's Bill of Particulars Re Forfeiture Allegations in United States v. Raghavender Reddy Budamala, No. CR 2:22-00077-ODW, filed April 13, 2022 as Document 23. Under the forfeiture allegations in the Indictment, the government gives notice that it intends to seek criminal forfeiture of specific property including $1,892,706.33 in bank funds and $27,930.22 in bank funds seized under federal seizure warrants, along with other seized funds. It also lists real property in Irvine, California, and in Los Angeles, California, with legal descriptions.

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     Case 2:22-cr-00077-ODW Document 23 Filed 04/13/22 Page 1 of 4 Page ID #:77



1    TRACY L. WILKINSON
     United States Attorney
2    SCOTT M. GARRINGER
     Assistant United States Attorney
3    Chief, Criminal Division
     JONATHAN GALATZAN
4    Assistant United States Attorney
     Chief, Asset Forfeiture Section
5    MAXWELL COLL (Cal. Bar No. 312651)
6    Assistant United States Attorney
     Asset Forfeiture Section
7         1400 United States Courthouse
          312 North Spring Street
8         Los Angeles, California 90012
          Telephone: (213) 894-1785
9         Facsimile: (213) 894-0142
          E-mail: Maxwell.Coll@usdoj.gov
10
     Attorneys for Plaintiff
11   UNITED STATES OF AMERICA
12                          UNITED STATES DISTRICT COURT
13                    FOR THE CENTRAL DISTRICT OF CALIFORNIA
14   UNITED STATES OF AMERICA,               No. CR 2:22-00077-ODW
15             Plaintiff,                    GOVERNMENT’S BILL OF PARTICULARS
16                                           RE FORFEITURE ALLEGATIONS
                     v.
17
     RAGHAVENDER REDDY BUDAMALA,
18     aka “Reddy Raghav Budamala,”

19             Defendant.

20
21
22
23        Notice is hereby given that the government, pursuant to the

24   forfeiture allegations set out in the Indictment (Dkt. 14), intends

25   to seek the criminal forfeiture of the following specific property,

26   including but not limited to the following:

27
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     Case 2:22-cr-00077-ODW Document 23 Filed 04/13/22 Page 2 of 4 Page ID #:78



1         a.   $1,892,706.33 in in bank funds seized pursuant to a federal
2    seizure warrant executed on or about February 23, 2022, from TMD
3    Ameritrade account ending in ‘8743 in the name of Budamala.
4         b.   $819.028.07 in bank funds seized pursuant to a federal
5    seizure warrant executed on or about February 22, 2022, from Citibank
6
     account ending in ‘6558 in the name of Hayventure LLC.
7
          c.   $27,930.22 in bank funds seized pursuant to a federal
8
     seizure warrant executed on or about February 22, 2022, from Bank of
9
     America account number ending in ‘8343 in the name of Reddy Budamala;
10
          d.   Real Property located in Irvine, California, more
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     particularly described as follows:
12
               DESCRIPTION:
13
               THE LAND REFERRED TO HEREIN IS SITUATED IN THE CITY OF
14
          IRVINE, COUNTY OF ORANGE, STATE OF CALIFORNIA, AND IS DESCRIBED
15
16        AS FOLLOWS:

17             PARCEL 1:

18             LOT 27 OF SAID TRACT EXCEPTING THEREFROM A NON-EXCLUSIVE

19        EASEMENT OVER THE NORTHERLY 5.00 FEET OF SAID LOT FOR THE

20        BENEFIT OF LOT C OF SAID TRACT, AS THE SAME IS SHOWN ON EXHIBIT
21        “A” AND FOR THE PURPOSES SET FORTH THEREIN IN THAT CERTAIN
22        DECLARATION OF ESTABLISHMENT OF EASEMENT RECORDED JUNE 14, 1974
23        IN BOOK 11171, PAGE 1166 OF OFFICIAL RECORDS OF SAID COUNTY.
24             PARCEL 2:
25             A NON-EXCLUSIVE EASEMENT OVER THE NORTHERLY 5.00 FEET OF
26
          LOT 28 OF SAID TRACT, AS THE SAME IS SHOWN ON EXHIBIT “A” AND
27
          FOR THE PURPOSES SET FORTH THEREIN THAT CERTAIN DECLARATION OF
28



                                            2
     Case 2:22-cr-00077-ODW Document 23 Filed 04/13/22 Page 3 of 4 Page ID #:79



1         ESTABLISHMENT OF EASEMENT RECORDED JUNE 14, 1974 IN BOOK 11171,
2         PAGE 1166 OF OFFICIAL RECORDS OF SAID COUNTY.
3               APN: 453-142-27
4         e.    Real Property located in Los Angeles, California, more
5    particularly described as follows:
6
          DESCRIPTION:
7
          THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE CITY OF LOS
8
     ANGELES, COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AND IS DESCRIBED
9
     AS FOLLOWS:
10
          LOT 11, OF TRACT NO. 8602 IN THE CITY OF LOS ANGELES, COUNTY OF
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     LOS ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 107
12
     PAGE(S) 84 OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER OF SAID
13
     COUNTY.
14
          APN: 5479-018-017
15
16        f.    Real Property located in Malibu, California, more

17   particularly described as follows:

18        DESCRIPTION:

19        REAL PROPERTY IN THE UNINCORPORATED AREA OF THE COUNTY OF LOS

20   ANGELES, STATE OF CALIFORNIA, DESCRIBED AS FOLLOWS:
21        THE EAST HALF OF THE NORTHWEST QUARTER OF THE NORTHWEST QUARTER
22   OF THE NORTHWEST QUARTER OF SECTION 17, TOWNSHIP 1 SOUTH, RANGE 18
23   WEST, SAN BERNADINO MERIDIAN, IN THE COUNTY OF LOS ANGELES, STATE OF
24   CALIFORNIA.
25        SAID LAND IS SHOWN ON THE CERTIFICATE OF COMPLIANCE NO. 03-447
26
     RECORDED JANUARY 16, 2004 AS INSTRUMENT NO. 04-0118361 OF OFFICIAL
27
     RECORDS.
28
          APN: 4464-022-021



                                            3
     Case 2:22-cr-00077-ODW Document 23 Filed 04/13/22 Page 4 of 4 Page ID #:80



1         g.   $970,000.00 in funds invested in CMB Infrastructure
2    Investment Group 75 LP.
3         h.   $250,000.00 in funds invested in NHK Mansfield LP.
4         i.   $150,000.00 in funds invested in 529 Investment Plan.
5         j.   $9,998.00 in cryptocurrency invested on the Gemini Trust
6
     cryptocurrency exchange.
7
     Dated: April 13, 2022               Respectfully submitted,
8
                                         TRACY L. WILKISON
9                                        United States Attorney

10                                       SCOTT M. GARRINGER
                                         Assistant United States Attorney
11                                       Chief, Criminal Division
12
                                               /s/ Maxwell Coll
13                                       MAXWELL COLL
                                         Assistant United States Attorney
14                                       Asset Forfeiture Section
15                                       Attorney for Plaintiff
16                                       UNITED STATES OF AMERICA

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