Court filing — United States v. SCHLEIDER (Dkt. 9, D.N.J.)

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Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 1 of 11 PagelD: 48

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA Hon. Michael A. Shipp, U.S.D.J.
v. Crim. No. 23-5l6 (MAS)
ALEXANDER SCHLEIDER, ; CONSENT JUDGMENT AND
ORDER OF FORFEITURE
Defendant. ; (MONEY JUDGMENT) AND

PRELIMINARY ORDER OF
FORFEITURE AS TO SPECIFIC
PROPERTY (FINAL AS TO THE
DEFENDANT)

WHEREAS, on or about June 29, 2023, defendant Alexander Schleider
pleaded guilty pursuant to a plea agreement with the United States to a two-
count Information, which charged him with (1) conspiring to commit health care
fraud, contrary to 18 U.S.C. § 1347, in violation of 18 U.S.C. § 1349 (Count One);
and (ii) wire fraud, in violation of 18 U.S.C. § 1343 (Count Two). In the plea
agreement, the defendant agreed to forfeit to the United States (a) pursuant to
18 U.S.C. § 982(a)(7), all property, real or personal, the defendant obtained that
constitutes or is derived, directly and indirectly, from gross proceeds traceable
to the federal health care fraud offense charged in Count One of the Information,
which the defendant agreed was approximately $21,399,439.02; and (b)
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), all property, real
or personal, that constitutes or is derived from proceeds the defendant obtained

that are traceable to the wire fraud offense charged in Count Two of the
Case 3:23-cr-00516-MAS Document 9 Filed 06/29/23 Page 2 of 11 PagelD: 49

Information, which the defendant agreed was approximately $322,237.29. In
the plea agreement, the defendant further acknowledged that one or more of the
conditions set forth in 21 U.S.C. § 853(p) exists, and that the United States is
therefore entitled to forfeit substitute assets in an amount not to exceed
$21,721,676.31 (the “Money Judgment’).

The defendant further agreed to forfeit to the United States all of his right,
title, and interest in the the property listed on the attached Exhibit A, which the
defendant admits has the requisite nexus to the offenses charged in the
Information.

In the plea agreement, the defendant further waived the requirements of
Rules 32.2 and 43(a) of the Federal Rules of Criminal Procedure regarding notice
of the forfeiture in the charging instrument, announcement of the forfeiture at
sentencing, and incorporation of the forfeiture in the judgment; acknowledged
he understood that the imposition of the Money Judgment is part of the sentence
that may be imposed in this case; waived any failure by the court to advise him
of this pursuant to Rule 11(b)(1)(J) of the Federal Rules of Criminal Procedure at
the guilty plea proceeding; and waived any and all claims that the forfeiture
constitutes an excessive fine and agreed that the forfeiture does not violate the
Eighth Amendment. The defendant further acknowledged that any forfeiture of
his assets shall not be treated as satisfaction of any fine, restitution, cost of
imprisonment, or any other penalty the Court may impose upon his in addition

to forfeiture.
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 3 of 11 PagelD: 50

Having considered the plea agreement, the record as a whole, and the
applicable law, it is hereby ORDERED, ADJUDGED, AND DECREED as follows:

Money Judqment

1. All property, real or personal, that constitutes or is derived from
proceeds obtained by the defendant that are traceable to the commission of the
healthcare fraud conspiracy and wire fraud offenses charged in the Information,
to which the defendant has pleaded guilty, is forfeited to the United States,
pursuant to 18 U.S.C. § 982(a)(7), and 18 U.S.C. § 981 (a)(1)(C) and 28 U.S.C.
§ 2461(c).

2. The defendant having conceded that one or more of the conditions
set forth in 21 U.S.C. § 853(p) exists, the United States is entitled to forfeit
proceeds and/or substitute assets equal to the value of the proceeds the
defendant obtained, which was $21,721,676.31. A money judgment in the
amount of $21,721,676.31 (the “Money Judgment”) is hereby entered against the
defendant, pursuant to 18 U.S.C. § 982(a)(7), 18 U.S.C. § 981(a)(1)(C) and 28
U.S.C. § 2461(c), 21 U.S.C. § 853(p), and Federal Rule of Criminal Procedure
32.2(b).

3. All payments on the Money Judgment shall be made by (i) electronic
funds transfer, as directed by the United States Attorney’s Office; or (11) postal
money order, bank or certified check, made payable, in this instance to the
United States Marshals Service, and delivered to the United States Attorney’s

Office, District of New Jersey, Attn: Asset Forfeiture and Money Laundering Unit,
Case 3:23-cr-00516-MAS Document 9 Filed 06/29/23 Page 4 of 11 PagelD: 51

970 Broad Street, 7th Floor, Newark, New Jersey 07102, and shall indicate the
defendant’s name and case number on the face of the check.

4. Until the defendant is sentenced, the United States Marshals Service
shall deposit all payments on the Money Judgment in its Seized Assets Deposit
Account. After the defendant is sentenced and the Judgment is entered on the
docket, all payments on the Money Judgment shall be forfeited to the United
States of America as substitute assets, pursuant to 21 U.S.C. § 853(p), and shall
be deposited in the Assets Forfeiture Fund.

Forfeited Specific Property

5. As a further result of the defendant’s conviction of the offenses
charged in the Information, pursuant to 18 U.S.C. § 982(a)(7), 18 U.S.C.
§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), and Fed. R. Crim. P. 32.2(b)(1) and (b)(2),
and based upon the plea agreement, all of the defendant’s right, title, and
interest in the property listed on the attached Exhibit A (the “Specific Property”),
which the defendant admits has the requisite nexus to the offenses charged in
the Information, is hereby forfeited to the United States of America for disposition
according to law, subject to the provisions of 21 U.S.C. § 853.

6. Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal
Procedure, the United States, its agent, or designee shall maintain or take
possession of the Specific Property and hold such property in its secure custody
and control.

7. Pursuant to 21 U.S.C. § 853(n)(1) and Rule 32.2(b)(6) of the Federal

Rules of Criminal Procedure, the United States shall publish notice of this Order
Case 3:23-cr-00516-MAS Document 9 Filed 06/29/23 Page 5 of 11 PagelD: 52

for at least 30 consecutive days on the government internet site
www.forfeiture.gov. The United States shall also send notice of this Order to any
person who reasonably appears to be a potential claimant with standing to
contest the forfeiture in the ancillary proceeding.

8. Pursuant to Fed R. Crim. P. 32.2(b)(6) and 21 U.S.C. § 853(n)(2) and
(n)(3), the notice of forfeiture must describe the forfeited property with reasonable
particularity, state the times by which a petition contesting the forfeiture must
be filed, and state the name and contact information for the government attorney
to be served with the petition. The notice shall also state that the petition (i)
shall be for a hearing to adjudicate the validity of the petitioner's alleged interest
in the Specific Property, (ii) shall be signed by the petitioner under penalty of
perjury, and (iti) shall set forth the nature and extent of the petitioner's right,
title or interest in the Specific Property, the time and circumstances of the
petitioner's acquisition of the right, title and interest in the Specific Property, any
additional facts supporting the petitioner's claim, and the relief sought.

9, Any person, other than the defendant, claiming an interest in the
Specific Property must file a petition within 60 days from the first day of
publication of notice on the government internet site, or no later than 35 days
from the mailing of direct notice, whichever is earlier, pursuant to Rule 32.2(b)(6)
of the Federal Rules of Criminal Procedure and Rules G(4) and G(5) of the
Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture

Actions.
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 6 of 11 PagelD: 53

10. Upon adjudication of all third-party interests, and after the
defendant is sentenced and the Judgment is entered on the docket, the Court
will enter a final order of forfeiture pursuant to 21 U.S.C. § 853(n)(7) and Fed. R.
Crim. P. 32.2(c)(2), in which all interests will be addressed.

Other Provisions

11. Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal
Procedure, this Order of Forfeiture shall be final against the defendant, shall be
made a part of the sentence of the defendant, and shall be included in the
judgment of conviction therewith.

12. Any forfeited money and the net proceeds derived from the sale of
forfeited specific property will be applied to the Money Judgment, in partial
satisfaction thereof.

13. Pursuant to Federal Rule of Criminal Procedure 32.2(b)(3) and 21
U.S.C. § 853(n), upon entry of this Order, and until the Money Judgment is fully
satisfied, the United States Attorney’s Office is authorized to conduct any
discovery needed to identify, locate, or dispose of assets to satisfy the Money
Judgment, or in connection with any petitions filed pursuant to 21 U.S.C.
§ 853(n), including depositions, interrogatories, requests for production of
documents, and the issuance of subpoenas.

14. The Clerk of the Court is directed to enter a Criminal Forfeiture
Money Judgment against the defendant in favor of the United States in the

amount of $21,721,676.31.
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 7 of 11 PagelD: 54

15. This Court shall retain jurisdiction to enforce this Order and to

amend it as necessary.

Dated: June yA , 2023

HON, MICHAEL A. SHIPP, U.S.D.J.

The undersigned hereby consent to
the form and entry of this Order:

PHILIP R. SELLINGER
United States Attorney

AL. Dated: 6/29/2023

By: SEAN M. SHERMAN
DeNAE M. THOMAS
BARBARA A. WARD

t United States Attorneys

Dated:

MARG/AGNIFILO, ESQ.
Attorney for Defendant
Alexander Schleider

ALEXANDER SCHLEIDER, Defendant
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 8 of 11 PagelD: 55

United States v. Alexander Schleider

Exhibit A

All right, title, and interest of Alex Schleider, Linda Schleider, Sephie

Schleider, George Schleider, and their affiliated entities in all funds and

other property on deposit in the following accounts:

Bank Account # Account Name Acct Address | Signers
M&T Bank | [M8310 | Labriut Diagnostics LLC [1000 Route | Linda
Operating Account 70, Suite 9, Schleider
Lakewood, NJ
08701
M&T Bank |QMM[s302 ‘| Labriut Diagnostics LLC | 1000 Route | Linda
Payroll 70, Suite 9, Schleider
Lakewood, NJ
08701
M&T Bank | QMMIs204 [ Labriut Diagnostics LLC | 1000 Route | Linda
Deposit Account 70, Suite 9, Schleider
Lakewood, NJ
08701
Bank of Linda Schleider and 315 Madison | Linda
America 1367 Sephie Schleider Avenue, Schleider,
Lakewood, NJ | Sephie
08701 Schleider
Bank of Linda Schleider 315 Madison | Linda
America 6826 Avenue, Schleider
Lakewood, NJ
08701
Bank of Linda Schleider 315 Madison | Linda
America 3080 Avenue, Schleider
Lakewood, NJ
08701
JPMChase_ | i035 821 Holiday Court LLC | 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | Qfo105 952 Spray Ave LLC 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | §foo0s 1601 Ist Ave LLC 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701

Exhibit A, page i of iv
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 9 of 11 PagelD: 56

Bank Account # Account Name Acct Address | Signers
JPMChase | (BB 185 2300 Oak Knoll LLC 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | e853 50 Cattus St LLC 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | 90357 593 E Veterans 1000 Route | Linda
Highway LLC 70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | 7209 1015 Zircon Dr LLC 1000 Route | Linda
70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | 9fos5s 3701 Hyde Hollywood [1000 Route | Linda
LLLC 70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | Fe855 A&L Diversified 1000 Route | Linda
Holdings LLC 70, Suite 9, Schleider
Lakewood, NJ
08701
JPMChase | [8407 Linda Schleider f | Linda
Stock Schleider
Portfolio Lakewood NJ
Account 08701
JPMChase | WMMMJ0205 | Linda Schieider Linda
Managed P| Schleider
Brokerage Lakewood NJ
Account 08701
JPMChase_ | 7356 Linda Schleider Linda
Schleider
Lakewood NJ
08701
Merrill WO 437 Linda Schleider Linda
Schleider
Lakewood NJ
08701

Exhibit A, page ii of iv
Case 3:23-cr-00516-MAS Document 9 Filed 06/29/23 Page 10 of 11 PagelD: 57

Bank Account # Account Name Acct Address | Signers
Merrill W9729 Linda Schleider Linda
Schleider
Lakewood NJ
08701
Merrill Wi9953 Linda Schleider P| Linda
Schleider
Lakewood NJ
08701
TD W3600 Linda Schleider f | Linda
Ameritrade Schleider
Lakewood NJ
08701
Coin Base | INO Linda Linda Schleider | | Linda
Schleider Schleider
Lakewood NJ
08701

2. All right, title, and interest of Alex Schleider, Linda Schleider, Sephie
Schleider, George Schleider, and their affiliated entities in the real

properties and appurtenances known as:
a. 821 Holiday Court, Toms River, NJ 08753
b. 952 Spray Avenue, Beachwood NJ 08722
c. 1601 lst Avenue, Toms River, NJ 08757
d. 2300 Oak Knoll Drive, Toms River, NJ 08757
e. 50 Cattus Street, Toms River, NJ 08753
f. 593 E. Veterans Highway, Jackson, NJ 08527
g. 1015 Zircon Drive, Toms River, NJ 08753
h. 4111S. Ocean Drive, Unit 3701, Hollywood, FL
The net proceeds from the sale of the following real properties and

appurtenances due to Alex Schleider, Linda Schleider, Sephie Schleider, and
George Schleider, and their affiliated entities:

Exhibit A, page iii of iv
Case 3:23-cr-00516-MAS Document9 Filed 06/29/23 Page 11 of 11 PagelD: 58

d.

1187 Treasure Avenue, Manahawkin, NJ
14 Mizzen Drive, Barnegat, NJ
27 Oak Leaf Lane, Toms River, NJ

2 Meir Shaham City Center, Jerusalem, Israel 94581

All funds held in trust for or belonging to Alex Schleider, Linda Schleider,

or their affiliated entities by the following attorneys or law firms:

a.

Yankee Brenner LLC

Brafman & Associates, P.C.

2020 Lincoln Navigator, VIN SLMJJ 2LT5L EL077 02

2020 Lincoln Navigator, VIN SLMJJ 2LT8L EL177 85

Exhibit A, page iv of iv


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