Indictment — United States v. Jorge Abramovs (District of Nevada)

Summary

A Criminal Indictment in United States of America v. Jorge Abramovs, Case 2:21-cr-00027-RFB-DJA, Document 16, in the District of Nevada, filed 01/27/21. The cover page lists violations of 18 U.S.C. § 1344(2) (Bank Fraud), 18 U.S.C. § 1014 (False Statement to a Financial Institution), and 18 U.S.C. § 1957 (Monetary Transactions in Criminally Derived Property), and forfeiture allegations. The background allegations describe National Investment Group Corporation and National Legal Advisors In Care Corp. as Nevada corporations, state that Abramovs was listed as their president, and describe Financial Institutions A through G. The indictment then describes the Paycheck Protection Program and alleges a scheme beginning in or around April 2020, with counts for PPP loan applications, a false statement, and monetary transactions.

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Issuer: Source documents
Document type: Row095 1131936 Jorge Abramovs
Case: Row095 1131936 Jorge Abramovs

Cite this document

“Indictment — United States v. Jorge Abramovs (District of Nevada).” Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/row095-1131936-jorge-abramovs/, SHA-256 7cb095b956a494aa78c176039e1df137950d2eeb2b7e91817a7a35f3280d7801.

Full text

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 1 of 19

NICHOLAS A. TRUTANICH
United States Attorney

Nevada Bar Number 13644
JESSICA OLIVA

Assistant United States Attorney

501 Las Vegas Boulevard South, Suite 1100 —__FILED RECEIVED
Las Vegas, Nevada 89101 —— ENTERED ____ SERVED ON

Telephone: (702) 388-6336 COUNSEL/PARTIES OF RECORD

Email: jessica.oliva@usdoj.gov

JAN 27 202i
DANIEL S. KAHN

Acting Chief, Fraud Section

a aa . CLERK US

Criminal Division, U.S. Department of Justice DISTRICT OF WEVA il
JOSEPH MCFARLANE BY:

DEPUTY

Trial Attorney

1400 New York Ave NW
Washington, D.C. 20530
Telephone: (202) 368-6049

Email: joseph.mcfarlane@usdoj.gov
Attorneys for the United States

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

UNITED STATES OF AMERICA, CRIMINAL INDICTMENT
Plaintiff, Case No.: 2:21-cr- oA
vs. VIOLATIONS:

JORGE ABRAMOVS, 18 U.S.C. § 1344(2) — Bank Fraud:

Defendant. 18 U.S.C. § 1014 ~ False Statement to a

Financial Institution; and

in Criminally Derived Property.

FORFEITURE ALLEGATIONS

THE GRAND JURY CHARGES THAT:

18 U.S.C. § 1957 — Monetary Transactions

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Background Allegations
At all times relevant to the Indictment, unless otherwise stated:

1. Defendant JORGE ABRAMOVS (“ABRAMOVS”) was a United States
citizen, residing in Las Vegas, Nevada.

2. National Investment Group Corporation (“NIGC”) was a domestic
corporation formed in the State of Nevada in 2018. Nevada Secretary of State records
identified ABRAMOVS as the President, Secretary, Treasurer, and Director of NIGC until
on or about October 14, 2020, when a different individual was identified as Secretary and
Treasurer with ABRAMOVS still listed as President.

3. National Legal Advisors In Care Corp. (“NLA”) was a domestic corporation
formed in the State of Nevada in 2019. Nevada Secretary of State records identified
ABRAMOVS as the President, Secretary, Treasurer, and Director of NLA as of on or
about July 1, 2019 through at least January 22, 2021. As discussed below, Abramovs
submitted loan applications on behalf of NLA and entities with similar names.

4. Financial Institutions A through G (the “Financial Institutions”) were all
financial institutions as defined by Title 18, United States Code, Section 20. Deposits at
Financial Institutions A, B, D, E, F, and G were insured by the Federal Deposit Insurance
Fund. Deposits at Financial Institution C were insured by the National Credit Union
Share Insurance Fund.

5. ABRAMOVS controlled, and had sole signatory authority over, Financial
Institution F account ending in 9757, Financial Institution F account ending in 9732, and

Financial Institution F account ending in 9740, among other accounts.

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 3 of 19

Paycheck Protection Program

6. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in or around March 2020 and designed to provide emergency financial
assistance to the millions of Americans who are suffering the economic effects caused by
the COVID-19 pandemic. One source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses for job retention
and certain other expenses, through a program referred to as the Paycheck Protection
Program (“PPP”).

7. In order to obtain a PPP loan, a qualifying business submitted a PPP loan
application, which was signed by an authorized representative of the business. The PPP
loan application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications in order to be
eligible to obtain the PPP loan. In the PPP loan application, the small business (through its
authorized representative) was required to state, among other things, its: (a) average
monthly payroll expenses; and (b) number of employees. These figures were used to
calculate the amount of money the small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan were required to provide documentation
showing their payroll expenses.

8. A PPP loan application was processed by a participating lender, such as a
financial institution. If a PPP loan application was approved, the participating lender
funded the PPP loan using its own monies. While the lender issued the PPP loan, the
Small Business Administration (“SBA”) provided a guarantee to the lender for the PPP

loan. Data from the application, including information about the borrower, the total

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amount of the loan, and the listed number of employees, was transmitted by the lender to
the SBA in the course of processing the loan.

9. PPP loan proceeds were required to be used by the business on certain
permissible expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP
allowed the interest and principal on the PPP loan to be entirely forgiven if the business
spent the loan proceeds on these expense items within a designated period of time and used
a certain percentage of the PPP loan proceeds on payroll expenses.

The Scheme to Defraud

10. Beginning in or around April 2020 and continuing until at least in or around
June 2020, ABRAMOVS knowingly executed, and attempted to execute, a scheme and
artifice to obtain the money and property owned by, and under the custody and control of,
Financial Institutions, namely, Financial Institutions A-G, by means of materially false and
fraudulent pretenses, representations, and promises, as further described below.

Purpose of the Scheme to Defraud

11. ‘It was the purpose of the scheme for ABRAMOVS to unjustly enrich himself
and others by fraudulently obtaining PPP loan proceeds.

Mauner and Means of the Scheme to Defraud

12. It was part of the scheme that from on or about April 16, 2020 until at least
on about June 15, 2020, ABRAMOVS submitted at least six applications for PPP loans for
NIGC. On each loan application, ABRAMOVS provided an EIN, number of employees,
and average monthly payroll for NIGC.

13. It was further part of the scheme that between on or about May 10, 2020 and
on or about June 5, 2020, ABRAMOVS submitted at least five more applications for PPP

loans on behalf of NLA or an entity with a similar name, such as National Legal Advisors

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or National Legal Advisors in Care (collectively, “the NLA entities”). ABRAMOVS signed
each of the loan applications as the authorized representative of the NLA entities. On each
loan application, ABRAMOVS provided an EIN, number of employees, and average
monthly payroll for the NLA entities.

14. Onor about June 15, 2020, ABRAMOVS submitted a PPP loan application
to Financial Institution G using the entity name of National Investment Group.
ABRAMOVS signed the loan application as the authorized representative of National
Investment Group. On the loan application, ABRAMOVS provided an EIN, number of
employees and average monthly payroll for National Investment Group.

15. In order to qualify for the above loans, ABRAMOVS submitted materially
false information about NIGC and NLA, including the number of employees and average
monthly payroll of the businesses. At times, ABRAMOVS also submitted false and
fraudulent supporting documentation with the loan applications, including fraudulent tax
documents. ABRAMOVS falsely certified that the loan proceeds would be used retain
workers and maintain payroll or make mortgage interest payments, lease payments, and
utility payments, when in fact ABRAMOVS intended to use the funds for personal
expenses.

16. Inaddition, on each loan application, ABRAMOVS certified that during the
period beginning on or about February 15, 2020 and ending on or about December 1, 2020,
the Applicant had not and would not receive another loan under the PPP. Instead, contrary
to these certifications, ABRAMOVS received multiple loans in the name of NIGC and
multiple loans in the name of NLA.

17. It was part of the scheme that, in order to obtain multiple PPP loans for the

same company, ABRAMOVS and others known and unknown to the Grand Jury created

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multiple EINs with the IRS, using different company names in order to obtain the EINs.
ABRAMOVS then used the various EINs on the loan applications and falsely claimed that
they were associated with the relevant business.

18. Intotal, ABRAMOVS received approximately $1,986,737 in PPP funds via
applications submitted to seven financial institutions.

19. ABRAMOVS spent proceeds of this fraud on luxury purchases for himself,
including two condominiums located in the Veer Towers in Las Vegas, Nevada, the
purchase of a 2020 Bentley, the purchase of a 2020 Tesla, and to pay off the mortgage on
an existing home in Nevada.

COUNTS ONE THROUGH FIVE

Bank Fraud
(18 U.S.C. § 1344(2))

20. The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
if fully set forth herein.

21. From in or around April 2020 through at least in or around June 2020, in the
State and Federal District of Nevada and elsewhere,

JORGE ABRAMOVS,

defendant herein, knowingly executed, and attempted to execute, a scheme and artifice to
obtain moneys, funds, credits, assets, securities, and property owned by, and under the
custody and control of, the Financial Institutions, by means of materially false and
fraudulent pretenses, representations, and promises.

22. On or about the dates identified below, in the State and Federal District of
Nevada, and elsewhere,

JORGE ABRAMOVS,

Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 7 of 19

defendant herein, knowingly executed and attempted to execute the above-described
scheme, each execution constituting a separate violation of Title 18, United States Code,

Section 1344(2).

‘COUNT [APPROXIMATE [~~ ~"~ DESCRIPTION OF EXECUTION
So Ee DATE oo}

") Submission to Financial Institution A of PPP loan
ONE April 16, 2020 application on the name of National Investment Group
Corporation seeking a loan in the amount of $134,662

Submission to Financial Institution B of PPP loan
TWO May 21, 2020 application in the name of National Legal Advisors In
Care Corp., seeking a Joan in the amount of $136,200

Submission to Financial Institution B of PPP loan
THREE May 22, 2020 application in the name of National Investment Group
Corporation seeking a loan in the amount of $138,000

Submission to Financial Institution C of PPP loan
FOUR June 1, 2020 application in the name of National Legal Advisors
seeking a loan in the amount of $215,624

Submission to Financial Institution D of PPP loan

application in the name of National Investment Group
FIVE June 2, 2020 Corporation seeking a loan in the amount of
$199,276.04

All in violation of Title 18, United States Code, Section 1344(2).
COUNT SIX

False Statement to a Financial Institution
(18 U.S.C. § 1014)

23. The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
if fully set forth herein.
24. Onor about May 25, 2020, in the State and Federal District of Nevada,
JORGE ABRAMOVS,
defendant herein, knowingly made a false statement and report for the purposes of
influencing the action of a financial institution, namely, Financial Institution E, whose
accounts were insured by the Federal Deposit Insurance Corporation, upon an application,

agreement, and loan, to wit: false statements on a Borrower Application Form for a

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$93,403.16 loan under the Paycheck Protection Program from Financial Institution E about
the number of employees, the amount of monthly payroll, the EIN and tax filing history for
ABRAMOVS’ business, National Investment Group Corporation, and the intended use of
the loan proceeds, in violation of Title 18, United States Code, Section 1014.
All in violation of Title 18, United States Code, Section 1014.
COUNTS SEVEN THROUGH ELEVEN
Monetary Transactions in Criminally Derived Property
(18 U.S.C. § 1957)
25. The allegations in paragraphs 1 through 19 are re-alleged and incorporated as
if fully set forth herein.
26. From in or around April 2020 through at least in or around August 2020, in
the State and Federal District of Nevada and elsewhere,
JORGE ABRAMOVS,
defendant herein, knowingly engaged and attempted to engage in the following monetary
transactions by, through, and to a financial institution, in and affecting interstate and
foreign commerce, in criminally derived property of a value greater than $10,000, that is
the deposit, withdrawal, transfer, and exchange of United States currency, such property
constituting and having been derived from a specified unlawful activity, that is, the bank

fraud scheme and artifice alleged herein in paragraphs 1 through 19, in violation of 18

U.S.C. § 1344(2), all in violation of Title 18, United States Code, Section 1957:

$222,638.59 wire from Financial Institution F
SEVEN May 29, 2020 account ending in 9732 to Lawyer's Title of
Nevada Inc
FIGHT June 1, 2020 $251,024.21 wire from Financial Institution F

account ending in 9732 to Towbin Motorcars.

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NINE

June 9, 2020

$403,906.29 wire from Financial Institution F
account ending in 9740 to Lawyer’s Title of
Nevada Inc

TEN

June 16, 2020

$95,000 Electronic Withdrawal from Financial
Institution F account ending in 9757 to
PENNYMAC

ELEVEN

June 19, 2020

$54,804.25 Electronic Withdrawal from Financial
Institution F account ending in 9732 to Tesla
Motors.

All in violation of Title 18, United States Code, Section 1957

FORFEITURE ALLEGATION ONE

Bank Fraud

The allegations contained in Counts One through Five of this Criminal

Indictment are hereby realleged and incorporated herein by reference for the purpose of

alleging forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18

U.S.C. § 982(a)(2)(A).

Upon conviction of any of the felony offenses charged in Counts One

through Five of this Criminal Indictment,

JORGE ABRAMOVS,

defendant herein, shall forfeit to the United States of America, any property, real or

personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.

§ 1344, or a conspiracy to commit such offense:

defendant herein, shall forfeit to the United States of America, any property, real or

personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.

§ 1344, a specified unlawful activity as defined in 18 U.S.C §§ 1956(c)(7)(A) and

1961(1)(B), or a conspiracy to commit such offense:

defendant herein, shall forfeit to the United States of America, any property

constituting, or derived from, proceeds obtained directly or indirectly, as the result of

Case 2:21-cr-00027-RFB-DJA Document 16 Filed 01/27/21 Page 10 of 19

violations of 18 U.S.C. § 1344, or a conspiracy to violate such offense, affecting a financial

institution:

24.

1. anim personam criminal forfeiture money judgment including, but not
limited to, at least $1,986,737.46;
2. real property located at 3726 South Las Vegas Boulevard, Unit 509,
Las Vegas, Nevada; and
MORE PARTICULARLY DESCRIBED AS:

PARCEL 1:

UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON THAT
CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT
CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF PLATS, PAGE 42
AND AS SET FORTH IN THE DECLARATION OF COVENANTS,
CONDITIONS, AND RESTRICTIONS AND RESERVATION OF
EASEMENTS FOR VEER TOWERS RECORDED MAY 03, 2010 IN BOOK
20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
COUNTY RECORDER, CLARK COUNTY, NEVADA.

PARCEL 2:

AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE
COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
FORTH IN THE DECLARTION.

PARCEL 3:

AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS 1 AND 2
DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS
LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS 1
AND 2 IN THE DECLARATION AND AS SHOWN AND DELINEATED
UPON THE MAP REFFERED TO ABOVE.

PARCEL 4:

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OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07, 2010 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
SUPPORT AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01,
2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2020 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED
DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
DATED JANUARY 07, 2010 AND RECORDED JANUARY 07, 2010 IN BOOK
20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL
IMPROVEMENTS AND APPURTENANCES THEREON, APN: 162-20-714-020.

3. real property located at 3726 South Las Vegas Boulevard, Unit 1803,

Las Vegas, Nevada
MORE PARTICULARLY DESCRIBED AS:
PARCEL I:

UNIT ONE THOUSAND EIGHT HUNDRED THREE (1803) IN BUILDING
“W” IN VEER TOWERS, AS SHOWN ON THAT CERTAIN FINAL MAP OF
THE VEER TOWERS, A RESORT CONDOMINIUM SUBDIVISION ON FILE
IN BOOK 142 OF PLATS, PAGE 42 (THE “MAP”) AND AS SET FORTH IN
THE DECLARATION OF COVENANTS, CONDITIONS, AND
RESTRICTIONS AND RESERVATION OF EASEMENTS FOR VEER
TOWERS (THE “DECLARATION”) RECORDED MAY 03, 2010 IN BOOK
20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
COUNTY RECORDER, CLARK COUNTY, NEVADA (THE “OFFICIAL
RECORDS”.

PARCEL I:
AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE
COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY

ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
FORTH IN THE DECLARTION.

24.

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PARCEL IT:

AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS ONE (1) AND
TWO (2) DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED
AS LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS
ONE (1) AND TWO (2) IN THE DECLARATION AND AD SHOWN AND
DELINEATED UPON THE MAP REFFERED TO ABOVE.

PARCEL IV:

NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
20091201 AS INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION
OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07, 2010 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
SUPPORT AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01,
2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2010 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
SYSTEMS EASEMENTS, DATED DECEMBER 1, 2009 AND RECORDED
DECEMBER 1, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
DATED JANUARY 07, 2010 AND RECORDED JANUARY 7, 2010 IN BOOK
20100107 AS INSTRUMENT NO. 0000579, AND ALL IMPROVEMENTS AND
APPURTENANCES THEREON, APN: 162-20-714-153.

(all of which constitutes property).

3. If any property being subject to forfeiture pursuant to 18 U.S.C. §

981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18 U.S.C. § 982(a)(2)(A), as a result of any act or

omission of the defendant -

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

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c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided
without difficulty;

it is the intent of the United States of America, pursuant to 21 U.S.C. § 853(p), to seek
forfeiture of any other property of the defendant for the property listed above.

All pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c); 18 U.S.C. §
982(a)(2)(A); 18 U.S.C. § 1344; and 21 U.S.C. § 853(p).

FORFEITURE ALLEGATION TWO
False Statement to a Financial Institution

1, The allegations contained in Count Six of this Criminal Indictment are
hereby realleged and incorporated herein by reference for the purpose of alleging forfeiture
pursuant to 18 U.S.C. § 981{a)(1)(C) with 28 U.S.C. § 2461(c) and 18 U.S.C. §
982(a)(2)(A).

2. Upon conviction of the felony offense charged in Count Six of this Criminal
Indictment,

JORGE ABRAMOVS,

defendant herein, shall forfeit to the United States of America, any property, real or
personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
§ 1014, or a conspiracy to commit such offense:

conspiracy to commit such offense:

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defendant herein, shall forfeit to the United States of America, any property
constituting, or derived from, proceeds obtained directly or indirectly, as the result of
violations of 18 U.S.C. § 1014, or a conspiracy to violate such offense, affecting a financial
institution:

an in personam criminal forfeiture money judgment including, but not limited to, at
least $93,403.16 (property).

3. If any property being subject to forfeiture pursuant to 18 U.S.C. §
981(a)(1)(C) with 28 U.S.C. § 2461(c) and 18 U.S.C. § 982(a)(2)(A), as a result of any act or
omission of the defendant -

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided

without difficulty;

it is the intent of the United States of America, pursuant to 21 U.S.C. § 853(p), to seek
forfeiture of any other property of the defendant for the property listed above.

All pursuant to 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c); 18 U.S.C. §
982(a)(2)(A); 18 U.S.C. § 1014; and 21 U.S.C. § 853(p).

FORFEITURE ALLEGATION THREE
Engaging in Transactions in Unlawful Proceeds

1. The allegations contained in Counts Seven through Eleven of this Criminal

Indictment are hereby realleged and incorporated herein by reference for the purpose of

alleging forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) with 28 U.S.C. § 2461(c); 18 U.S.C.

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§ 981(a)(1)(C) with 28 U.S.C. § 2461(c); and 18 U.S.C. § 982(a)(1).
2. Upon conviction of any of the felony offenses charged in Counts Seven
through Eleven of this Criminal Indictment,
JORGE ABRAMOVS,
defendant herein, shall forfeit to the United States of America, any property, real or
personal, involved in transactions or attempted transactions in violation of 18 U.S.C. §
1957, or any property traceable to such property:
defendant herein, shall forfeit to the United States of America, any property, real or
personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
§ 1957, a specified unlawful activity as defined in 18 U.S.C §§ 1956(c)(7)(A) and
1961(1)(B), or a conspiracy to commit such offense:
defendant herein, shall forfeit to the United States of America, any property, real or
personal, involved in violations of 18 U.S.C. § 1957, or any property traceable to such
property:
1. an in personam criminal forfeiture money judgment including, but not
limited to, at least $978,834.31;
2. real property located at 3726 South Las Vegas Boulevard, Unit 509,
Las Vegas, Nevada; and
MORE PARTICULARLY DESCRIBED AS:
PARCEL 1:
UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON THAT
CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT
CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF PLATS, PAGE 42
AND AS SET FORTH IN THE DECLARATION OF COVENANTS,

CONDITIONS, AND RESTRICTIONS AND RESERVATION OF
EASEMENTS FOR VEER TOWERS RECORDED MAY 03, 2010 IN BOOK

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 16 of 19

20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE
COUNTY RECORDER, CLARK COUNTY, NEVADA.

PARCEL 2:

AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE
COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
FORTH IN THE DECLARTION.

PARCEL 3:
AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS 1 AND 2

DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS
LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS 1

AND 2 IN THE DECLARATION AND AS SHOWN AND DELINEATED

UPON THE MAP REFFERED TO ABOVE.
PARCEL 4:

NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND
OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT
CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED
DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK
20091201 AS INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS
AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION
OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07, 2010 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT,
DATED APRIL 28, 2010 AND RECORDED MAY 03, 2010 IN BOOK 20100503 AS
INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF
SUPPORT AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01,
2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS
INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2020 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED
DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
DATED JANUARY 07, 2010 AND RECORDED JANUARY 07, 2010 IN BOOK
20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL
IMPROVEMENTS AND APPURTENANCES THEREON, APN: 162-20-714-020.

3. real property located at 3726 South Las Vegas Boulevard, Unit 1803,

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 17 of 19

Las Vegas, Nevada
MORE PARTICULARLY DESCRIBED AS:
PARCEL I:

PARCEL II:

AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE
COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY
ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET
FORTH IN THE DECLARTION.

PARCEL III:

PARCEL IV:

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 18 of 19

INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY
THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT
AND ENCROACHMENT EASEMENTS, DATED JANUARY 07, 2010 AND
RECORDED JANUARY 07, 2010 IN BOOK 20100107 AS INSTRUMENT NO.
0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY
SYSTEMS EASEMENTS, DATED DECEMBER 1, 2009 AND RECORDED
DECEMBER 1, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF
OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST
AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS
DATED JANUARY 07, 2010 AND RECORDED JANUARY 7, 2010 IN BOOK
20100107 AS INSTRUMENT NO. 0000579, AND ALL IMPROVEMENTS AND
APPURTENANCES THEREON, APN: 162-20-714-153.

(all of which constitutes property).

3. _Ifany property being subject to forfeiture pursuant to 18 U.S.C. §
981(a)(1)(A) with 28 U.S.C. § 2461(c); 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(0);
and 18 U.S.C. § 982(a)(1), as a result of any act or omission of the defendant -

a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;

Cc. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty;

it is the intent of the United States of America, pursuant to 21 U.S.C. § 853(p), to seek
forfeiture of any other property of the defendant for the property listed above.

f/f

/ff

‘1

Sti

t//

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Case 2:21-cr-00027-RFB-DJA Document16 Filed 01/27/21 Page 19 of 19

All pursuant to 18 U.S.C. § 981(a)(1)(A) with 28 U.S.C. § 2461(c); 18 U.S.C. §
981(a)(1)(C) with 28 U.S.C. § 2461(c); 18 U.S.C. § 982(a)(1); 18 U.S.C. § 1957; and 21

U.S.C. § 853(p).

DATED this 27" day of January, 2021.

A TRUE BILL:

/S/
FOREPERSON OF THE GRAND JURY

DANIEL 8S. KAHN
Acting Chief, Fraud Section

OSEPH MCFARLANE J AOS
Trial Attorney

NICHOLAS A. TRUTANICH
United States Attorney

JESSICA OLIVA
Assistant United States Attorney

Attorneys for Plaintiff
UNITED STATES OF AMERICA

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