Order Approving Stipulation for Entry of Order of Forfeiture as to Eldorado Third Community Association

Summary

This is an order approving a stipulation for entry of an order of forfeiture between the United States and Eldorado Third Community Association, represented by Ryan W. Reed, in the case against Meelad Dezfooli. The stipulation states that the jury found Dezfooli guilty of Counts One through Ten and that the Association filed a Notice of Claim on October 24, 2024. The Association agrees to forfeit a Bentley, a Tesla and real property, to withdraw its claims, and to waive notice and a hearing. After the Final Forfeiture Order is entered and the property is sold, the United States agrees to pay the Association $1,882.90 and $1,000 in attorney's fees. The order states that the parties' stipulation (ECF No. 313) is approved, dated December 27, 2024, over the name of Cristina D. Silva, United States District Judge.

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“Order Approving Stipulation for Entry of Order of Forfeiture as to Eldorado Third Community Association.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-plaintiff-v-meelad-dezfooli-dkt-314-49318645ae/, SHA-256 b1aefd63c126dbfaf751e5fd43b5b9267347b89516455c3b14f84418e65e1107.

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Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 1 of 8

1 JASON M. FRIERSON
United States Attorney
2 Nevada Bar No. 7709
DANIEL D. HOLLINGSWORTH
3 Assistant United States Attorney
Nevada Bar No. 1925
4 501 Las Vegas Boulevard South, Suite 1100
Las Vegas, Nevada 89101
5 (702) 388-6336
Daniel.Hollingsworth@usdoj.gov
6 Attorneys for the United States

7
UNITED STATES DISTRICT COURT
8 DISTRICT OF NEVADA

9 UNITED STATES OF AMERICA, Case No. 2:22-cr-00142-CDS-DJA

10 Plaintiff Order Approving Stipulation for
Entry of Order of Forfeiture as to
11 v. Eldorado Third Community
Association
12 MEELAD DEZFOOLI,
[ECF No. 313]
13 Defendant

14 The United States of America and Eldorado Third Community Association, and its
15 counsel, Ryan W. Reed of LEACH KERN GRUCHOW SONG, agree as follows:
16 1. The Grand Jury sitting in Las Vegas, Nevada, returned a Ten-Count
17 Superseding Criminal Indictment against Meelad Dezfooli charging him in Counts One
18 through Three with bank fraud in violation of 18 U.S.C. § 1344(2); in Counts Four through
19 Six with concealment money laundering in violation of 18 U.S.C. § 1956(a)(1)(B)(i); and in
20 Counts Seven through Ten with monetary transactions in criminally derived property in
21 violation of 18 U.S.C. § 1957. Superseding Criminal Indictment, ECF No. 97.
22 2. The jury found Meelad Dezfooli guilty of Counts One through Ten of a Ten-
23 Count Superseding Criminal Indictment, and the jury found, and the Court ordered,
24 forfeiture of property set forth in the Forfeiture Allegations of the Superseding Criminal
25 Indictment. Superseding Criminal Indictment, ECF No. 97; Minutes of Jury Trial Day 7,
26 ECF No. 239; Minutes of Jury Trial Day 8, ECF No. 240; Jury Verdict, ECF No. 243;
27 Forfeiture Jury Instructions and Special Verdict Forms, ECF No. 246; Preliminary Order of
28 Forfeiture, ECF No. 251.
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 2 of 8

1 3. On October 24, 2024, Eldorado Third Community Association filed a Notice

2 of Claim and Declarations in Support of their Claim for the real property located at 1829

3 La Calera, North Las Vegas, Nevada 89084, ECF No. 281.

4 4. Eldorado Third Community Association knowingly and voluntarily agrees to

5 the civil administrative forfeiture, the civil judicial forfeiture, or the criminal forfeiture of

6 the following property:

7 1. 2021 Bentley Flying Spur W12 (VIN SCBBB6ZG5MC084930);

8 2. 2021 Tesla Model 3 (VIN 5YJ3E1EA7MF019125);

9 3. Real property located at 6116 Chinook Way, Las Vegas, Nevada 89108, more

10 particularly described as:

11 LOT TWENTY-FOUR (24) IN BLOCK C OF LEWIS HOMES RAINBOW VISTA
UNIT NO. 1, AS SHOWN BY MAP THEREOF ON FILE IN BOOK 30 OF PLATS,
12 PAGE 41 AND AS AMENDED BY A CERTIFICATE OF AMENDMENT
RECORDED AUGUST 2, 1985 IN BOOK 2159 AS DOCUMENT NO. 2118935, IN
13 THE OFFICE OF THE COUNTY RECORDER OF CLARK COUNTY, NEVADA.
(APN:138-26-615-070);
14

15 4. Real property located at 1829 La Calera Ave., North Las Vegas, Nevada 89084,

16 more particularly described as:

17 LOT FIFTY-FIVE (55) OF ELDORADO R1 – 60 NO. 13 TM NO. 21, AS SHOWN BY
MAP THEREOF ON FILE IN BOOK 123 OF PLATS, PAGE 42 IN THE OFFICE OF
18 THE COUNTY RECORDER OF CLARK COUNTY, NEVADA. (APN:124-21-314-055);
19 5. Real property located at 6033 Watermelon Street, North Las Vegas, Nevada

20 89081, more particularly described as:

21 LOT TWENTY-SIX (26) OF FINAL MAP OF TROPICAL / WALNUT – UNIT 1 (A
COMMON INTEREST COMMUNITY) AS SHOWN BY MAP THEREOF ON FILE
22 IN BOOK 121 OF PLATS, PAGE 53, IN THE OFFICE OF THE COUNTY
RECORDER, CLARK COUNTY, NEVADA. (APN: 123-30-610-026);
23

24 6. Real property located at 176 Glen Falls Ave, Henderson, Nevada 89002, more

25 particularly described as:

26 LOT 17 IN BLOCK “C” OF PARADISE HILLS NO. 16, AS SHOWN BY MAP
THEREOF ON FILE IN BOOK 97 OF PLATS, PAGE 8, IN THE OFFICE OF THE
27 COUNTY RECORDER OF CLARK COUNTY, NEVADA. EXCEPTING
THEREFROM ALL MINERALS, OIL, GAS PETROLEUM, OTHER
28

2
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 3 of 8

1 HYDROCARBON SUBSTANCES AND ALL GEOTHERMAL ENERGY SOURCES
IN OR UNDER OR WHICH MAY BE PRODUCED FROM THE
2 WITHINDESCRIBED LAND WHICH LIE BELOW A PLANE PARALLEL TO AND
FIVE HUNDRED (500) FEET BELOW THE SURFACE OF THE WITHIN-
3 DESCRIBED LAND, FOR THE PURPOSE OF PROSPECTING, EXPLORATION,
DEVELOPMENT, PRODUCTION, OR EXTRACTION OF SAID SUBSTANCES BY
4 MEANS OF MINES, WELLS, DERRICKS, AND/OR OTHER EQUIPMENT;
PROVIDED, HOWEVER, THAT THE OWNER OF SAID SUBSTANCES SHALL
5 HAVE NO RIGHT TO ENTER THE SURFACE OF THE WITHIN-DESCRIBED
LAND NOR TO USE SAID LAND ABOVE SAID PLANE PARALLEL TO AND
6 FIVE HUNDRED (500) FEET BELOW THE SURFACE OF SUCH LAND. (APN:
179-31-212- 022); and
7

8 7. Real property located at 890 Harbor Ave., Henderson, Nevada, 89002, more

9 particularly described as:

10 LOT 374 OF PEARL CREEK – UNIT NO. 2, AS SHOWN BY MAP THEREOF ON
FILE IN BOOK 149 OF PLATS, PAGE 4, IN THE OFFICE OF THE COUNTY
11 RECORDER OF CLARK, COUNTY, NEVADA. (APN: 179-28-814-060)
12 (all of which constitutes property).

13 5. Eldorado Third Community Association knowingly and voluntarily agrees

14 to forfeit the property to the United States.

15 6. Eldorado Third Community Association knowingly and voluntarily agrees

16 to relinquish all possessory rights, ownership rights, and all rights, titles, and interests in the

17 property.

18 7. Eldorado Third Community Association knowingly and voluntarily agrees

19 to waive its right to any civil administrative forfeiture proceedings, any civil judicial

20 forfeiture proceedings, or any criminal forfeiture proceedings (all of which constitutes

21 proceedings) of the property.

22 8. Eldorado Third Community Association knowingly and voluntarily agrees

23 to waive service of process of any and all documents filed in this action or any proceedings

24 concerning the forfeiture of the property arising from the facts and circumstances of this

25 case.

26 9. Eldorado Third Community Association knowingly and voluntarily agrees

27 to waive any further notice to it, its agents, or its attorneys regarding the forfeiture and

28 disposition of the property.

3
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 4 of 8

1 10. Eldorado Third Community Association knowingly and voluntarily agrees not
2 to file any claim, third-party petition, or other documents in any proceedings concerning the
3 property; and agrees not to contest, and agrees not to assist any other person and entity to
4 contest, the forfeiture.
5 11. Eldorado Third Community Association knowingly and voluntarily agrees to
6 withdraw any claims, third-party petitions, or other documents it filed in any proceedings
7 concerning the property.
8 12. Eldorado Third Community Association knowingly and voluntarily agrees to
9 waive the statute of limitations, the CAFRA requirements, Fed. R. Crim. P. 7, 11, and 32.2,
10 the constitutional requirements, and the constitutional due process requirements of any
11 forfeiture proceedings concerning the property.
12 13. Eldorado Third Community Association knowingly and voluntarily agrees to
13 waive its right to a hearing on the forfeiture of the property.
14 14. Eldorado Third Community Association knowingly and voluntarily agrees to
15 waive all constitutional, statutory, legal, equitable rights, defenses, and claims regarding the
16 property in any proceedings, including, but not limited to any constitutional or statutory
17 double jeopardy defense or claim.
18 15. Eldorado Third Community Association knowingly and voluntarily agrees to
19 waive any and all constitutional, statutory, legal, equitable rights, defenses, and claims
20 regarding the property in any proceedings, including, but not limited to, the Excessive Fines
21 Clause and the Cruel and Unusual Punishments Clause of the Eighth Amendment to the
22 United States Constitution
23 16. Eldorado Third Community Association knowingly and voluntarily agrees to
24 the entry of the Final Forfeiture Order of the property to the United States.
25 17. Eldorado Third Community Association understands the forfeiture of the
26 property shall not be treated as satisfaction of any assessment, restitution, fine, cost of
27 imprisonment or any other penalty that may be imposed in addition to forfeiture.
28 ///

4
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 5 of 8

1 18. Eldorado Third Community Association knowingly and voluntarily agrees to

2 the conditions set forth in this Stipulation for Entry of Order of Forfeiture as to Eldorado

3 Third Community Association and Order (Stipulation).

4 19. Eldorado Third Community Association knowingly and voluntarily agrees to

5 hold harmless the United States, the United States Department of Justice, the United States

6 Attorney’s Office for the District of Nevada, the United States Department of the Treasury,

7 the United States Internal Revenue Service, their agencies, their agents, and their employees

8 from any claim made by it or any third party arising from the facts and circumstances of this

9 case.

10 20. Eldorado Third Community Association knowingly and voluntarily releases

11 and forever discharges the United States, the United States Department of Justice, the

12 United States Attorney’s Office for the District of Nevada, the United States Department of

13 the Treasury, the United States Internal Revenue Service, their agencies, their agents, and

14 their employees from any and all claims, rights, or causes of action of any kind that

15 Eldorado Third Community Association now has or may hereafter have on account of, or in

16 any way growing out of, the seizures and the forfeitures of the property in the civil

17 administrative forfeitures, the civil judicial forfeitures, and the criminal forfeitures.

18 21. Each party acknowledges and warrants that its execution of this Stipulation is

19 free and is voluntary.

20 22. This Stipulation contains the entire agreement between the parties.

21 23. Except as expressly stated in this Stipulation, no party, officer, agent,

22 employee, representative, or attorney has made any statement or representation to any other

23 party, person, or entity regarding any fact relied upon in entering into this Stipulation, and

24 no party, officer, agent, employee, representative, or attorney relies on such statement or

25 representation in executing this Stipulation.

26 24. After the United States District Court has signed and entered the Final

27 Forfeiture Order and this Stipulation, after the United States sells the property, and after

28 payment of outstanding taxes, expenses of custody, and sale costs incurred by Internal

5
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 6 of 8

1 Revenue Service, within a practicable time thereafter for the United States, the United

2 States knowingly and voluntarily agrees Eldorado Third Community Association will

3 receive payment from the sale proceeds of the property. When the conditions in this

4 paragraph are met and the property is sold, the United States will transfer to Eldorado Third

5 Community Association through Ryan W. Reed:

6 A. $1,882.90 and
7 B. $1,000 in attorney’s fees.
8 25. Eldorado Third Community Association knowingly and voluntarily agrees to

9 fill out the United States Department of the Treasury Automated Clearing House (ACH)

10 form accurately and correctly and submit it to the United States Attorney’s Office so the

11 payment will be disbursed by electronic fund transfer to Counsel’s IOLTA account for

12 payment to Eldorado Third Community Association.

13 26. If, for any reason, the total to be paid to Eldorado Third Community

14 Association and any other third-party petitioners equals or exceeds the fair market value of

15 the property, this Stipulation shall be null and void, and the United States may allow

16 Eldorado Third Community Association and other parties to foreclose on the property.

17 27. The persons signing this Stipulation warrant and represent that they have full

18 authority to execute this Stipulation and to bind the entities, on whose behalf they are

19 signing, to the terms of this Stipulation.

20 28. This Stipulation shall be construed and interpreted according to federal

21 forfeiture law and federal common law. The jurisdiction and the venue for any dispute

22 related to, and/or arising from, this Stipulation is the unofficial Southern Division of the

23 United States District Court for the District of Nevada, located in Las Vegas, Nevada.

24 29. This Stipulation shall not be construed more strictly against one party than

25 against the other merely by virtue of the fact that it may have been prepared primarily by

26 counsel for one of the parties; it being recognized that both parties have contributed

27 substantially and materially to the preparation of this Stipulation.

28 ///

6
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 7 of 8
Case 2:22-cr-00142-CDS-DJA Document 314 Filed 12/27/24 Page 8 of 8

1 IT IS HEREBY CERTIFIED, under 28 U.S.C. § 2465(a)(2), that there was

2 reasonable cause for the seizure and forfeiture of the property.

4 DATED: DATED: December 20, 2024

5 LEACH KERN GRUCHOW SONG JASON M. FRIERSON
United States Attorney
6

7 /s/ Daniel D. Hollingsworth
RYAN W. REED ASSET FORFEITURE ATTORNEY
8 Counsel for ELDORADO THIRD Assistant United States Attorney
COMMUNITY ASSOCIATION
9
DATED:
10

12 ELDORADO THIRD
COMMUNITY ASSOCATION
13

15 It is hereby ordered that the parties’ stipulation [ECF No. 313] is

16 approved.

18
CRISTINA D. SILVA
19 UNITED STATES DISTRICT JUDGE

20 DATED: December 27, 2024
21

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