Final Order of Forfeiture — United States v. Karen Chapon (D. Nev., Dkt. 145, filed 03/20/24)

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A Final Order of Forfeiture in United States v. Karen Chapon, aka "Karen Hannafious," Case 2:20-cr-00286-JCM-NJK, filed March 20, 2024, as Document 145, in the U.S. District Court for the District of Nevada. It recites that a Preliminary Order of Forfeiture (ECF No. 120) followed the plea of guilty and imposed an in personam criminal forfeiture money judgment of $596,931, that notice was posted on www.forfeiture.gov from September 1, 2023, through September 30, 2023, and that the United States Attorney's Office mailed notice to listed entities including Bank of America, the Small Business Administration, Cross River Bank and WebBank. The Court finds that no petition was filed. It orders $504,385.19 and cash in lieu of a gray 2018 Mercedes Benz G63 AMG sports utility vehicle forfeited and vested in the United States, with the money judgment of $596,931 recoverable from Chapon.

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Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 1 of 6

MAR 2 0 2024

i ADA

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, 2:20-CR-286-JCM-NJK
Plaintiff, Final Order of Forfeiture
v.
KAREN CHAPON,
aka “Karen Hannafious,”

Defendant.

The United States District Court for the District of Nevada entered a Preliminary
Order of Forfeiture under Fed. R. Crim. P. 32.2(b)(1) and (b)(2); 18 U.S.C. § 981(aX(1(C)
with 28 U.S.C. § 2461(c); 18 U.S.C. § 982(a)(2)(A); and 21 U.S.C. § 853(p) based upon the
plea of guilty by Karen Chapon, aka “Karen Hannafious,” to the criminal offense, forfeiting
the property and imposing an in personam criminal forfeiture money judgment set forth in
the Plea Agreement and Forfeiture Allegation One of the Criminal Indictment and shown
by the United States to have the requisite nexus to the offense to which Karen Chapon, aka
“Karen Hannafious,” pled guilty. Criminal Indictment, ECF No. 22; Change of Plea, ECF
No. 118; Plea Agreement, ECF No. 119; Preliminary Order of Forfeiture, ECF No. 120.

This Court finds that on the government’s motion, the Court may at any time enter
an order of forfeiture or amend an existing order of forfeiture to include subsequently

located property or substitute property under Fed. R. Crim. P. 32.2(e) and 32.2(b\(2\(C).

The in personam criminal forfeiture money judgment amount of $596,931 complies
with United States v. Lo, 839 F.3d 777 (9th Cir. 2016); Honeycutt v. United States, 581 U.S. 443
(2017); United States v. Thompson, 990 F.3d 680 (9th Cir. 2021); and United States v. Prasad, 18
F.4th 313 (9th Cir. 2021).
Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 2 of 6

This Court finds the United States published the notice of forfeiture in accordance
with the law via the official government internet forfeiture site, www.forfeiture.gov,
consecutively from September 1, 2023, through September 30, 2023, notifying all potential
third parties of their right to petition the Court. Notice of Filing Proof of Publication
Exhibits, ECF No. 121-1, p. 5.

This Court finds the United States notified known third parties by regular mail and
certified mail return receipt requested or by e-mail of their right to petition the Court. Notice
of Filing Service of Process — Mailing, ECF No. 128.

On September 21, 2023, the United States Attomey’s Office served Bank of America,
N.A. at Las Vegas, NV by regular and certified return receipt mail with the Preliminary
Order of Forfeiture and the Notice. Notice of Filing Service of Process — Mailing, ECF No.
128-1, p. 3, 7-14, 16-17.

On September 21, 2023, the United States Attorney’s Office served Bank of America,
c/o Moore & Van Allen PLLC, by regular and certified return receipt mail with the
Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process —
Mailing, ECF No. 128-1, p. 3, 7-14, 18-19.

On September 21, 2023, the United States Attorney’s Office served Bank of America
at Newark, DE by regular and certified return receipt mail with the Preliminary Order of
Forfeiture and the Notice. Notice of Filing Service of Process — Mailing, ECF No. 128-1, p.
3, 7-14, 20-21.

On September 21, 2023, the United States Attorney’s Office served Bank of America,
c/o CT Corporation System, Registered Agent, by regular and certified return receipt mail
with the Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process
- Mailing, ECF No. 128-1, p. 3, 7-14, 22-23.

On September 21, 2023, the United States Attorney’s Office served Goldfein

Attorneys at Law, Gregory Megrditchian, Attorney at Law, by regular and certified return

receipt mail with the Preliminary Order of Forfeiture and the Notice. Notice of Filing

Service of Process — Mailing, ECF No. 128-1, p. 3, 7-14, 24-25.
2
Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 3 of 6

On September 21, 2023, the United States Attorney’s Office served Daimler Trust,
Daimler Title Co., and Mercedes Benz Financial Services, LLC, by regular and certified
return receipt mail with the Preliminary Order of Forfeiture and the Notice. The return
receipt for the mailing was returned unsigned. Neither the certified mailing nor the regular
mailing were returned. US Postal Service tracking shows the certified mail was delivered.
Notice of Filing Service of Process — Mailing, ECF No. 128-1, p. 3, 7-14, 26-29.

On September 21, 2023, the United States Attorney’s Office served Small Business
Administration, c/o Saul Ramos, Director, by regular and certified return receipt mail with
the Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process —
Mailing, ECF No. 128-1, p. 4, 7-14, 30-31.

On September 21, 2023, the United States Attorney’s Office served Small Business
Administration, c/o Legal Department, by regular and certified return receipt mail with the
Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process —
Mailing, ECF No. 128-1, p. 4, 7-14, 32-33.

On September 21, 2023, the United States Attorney’s Office served Small Business
Administration, Office of Disaster Assistance, by regular and certified return receipt mail
with the Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process
- Mailing, ECF No. 128-1, p. 4, 7-14, 34-35.

On September 21, 2023, the United States Attorney’s Office served Cross River
Bank, Attn: Allan Komensky, by regular and certified return receipt mail with the
Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process —
Mailing, ECF No. 128-1, p. 4, 7-14, 36-37.

On September 21, 2023, the United States Attorney’s Office served Cross River
Bank, Attn: Legal Department, by regular and certified return receipt mail with the
Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process —
Mailing, ECF No. 128-1, p. 4, 7-14, 38-39.

On October 26, 2023, the United States Attorney’s Office served Cross River Bank,

Attention: Lauren Quandt, by regular and certified return receipt mail with the Preliminary
3
Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 4 of 6

Order of Forfeiture and the Notice. Notice of Filing Service of Process — Mailing, ECF No.
128-1, p. 4, 7-14, 40-41.

On September 21, 2023, the United States Attorney’s Office served WebBank, Attn:
Legal Department, in Salt Lake City, Utah, by regular and certified return receipt mail with
the Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of Process -
Mailing, ECF No. 128-1, p. 4, 7-14, 42-43.

On September 21, 2023, the United States Attorney’s Office served WebBank, c/o
Alan Garrett, Financial Crimes Compliance Manager, by regular and certified return receipt
mail with the Preliminary Order of Forfeiture and the Notice. Notice of Filing Service of
Process — Mailing, ECF No. 128-1, p. 4, 7-14, 44-45.

On September 21, 2023, the United States Attorney’s Office attempted to serve
WebBank, Attn: Legal Department, in Summit, NJ, by regular and certified return receipt
mail with the Preliminary Order of Forfeiture and the Notice. Both mailings were returned.
Notice of Filing Service of Process — Mailing, ECF No. 128-1, p. 4, 7-14, 46-48.

On September 25, 2023, the United States Attorney’s Office served WebBank with
the Preliminary Order of Forfeiture and the Notice via electronic mail per the request of
WebBank’s Customer Care. Notice of Filing Service of Process — Mailing, ECF No. 128-1,
p. 5, 7-14, 50.

This Court finds no petition was filed herein by or on behalf of any person or entity
and the time for filing such petitions and claims has expired.

This Court finds no petitions are pending regarding the property named herein and
the time has expired for presenting such petitions.

THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that
all possessory rights, ownership rights, and all rights, titles, and interests in the property
hereinafter described are condemned, forfeited, and vested in the United States:

1. $504,385.19; and
2. Cash in lieu of a gray 2018 Mercedes Benz G63 AMG sports utility vehicle

with vehicle identification number (VIN) WDCYC7DH6JX291626
4
Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 5 of 6

(all of which constitutes property); and

that the United States recover from Karen Chapon, aka “Karen Hannafious,” the in
personam criminal forfeiture money judgment of $596,931, and that the net equity of 2018
Mercedes after storage fees, costs, and expenses will be applied toward the payment of the
money judgment under Ninth Circuit cases, forfeiture statutes, and Fed. R. Crim. P.
32.2(b)(2)(A); and

the forfeiture of the money judgment and the property is imposed under Fed. R.
Crim. P. 32.2(6)(4)(A) and (b)(4)(B); Fed. R. Crim. P. 32.2(c)(2); 18 U.S.C. § 981(a(1(C)
with 28 U.S.C. § 2461(c); 18 U.S.C. § 982(a)(2)(A); and 21 U.S.C. § 853(n)(7) and 853(p);
that the money judgment shall be collected; and that the property and the collected amount
shall be disposed of according to law.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that under Fed. R.
Crim. P. 32.2(c) and 21 U.S.C. § 853(n){7), all possessory rights, ownership rights, and all
rights, titles, and interests in the property are extinguished and are not recognized for Karen
Chapon, aka “Karen Hannafious,” all third parties, and the following entities:

1. Bank of America;

2. Goldfein Attorneys at Law on behalf of Daimler Trust, Daimler Title Co., and
Mercedes Benz Financial Services, LLC;
Daimler Trust, Daimler Title Co., and Mercedes Benz Financial Services, LLC;
Small Business Administration;
Cross River Bank; and
WebBank.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that any and all

forfeited funds, including but not limited to, currency, currency equivalents, certificates of
deposit, as well as any income derived as a result of the government’s management of any

property forfeited herein, and the proceeds from the sale of any forfeited property shall be

disposed of according to law.
Case 2:20-cr-00286-JCM-NJK Document 145 Filed 03/20/24 Page 6 of 6

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Clerk send
copies of this Order to all counsel of record and three certified copies to the United States

Attorney’s Office, Attention Asset Forfeiture Unit.

STATES DISTRICT JUDGE


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