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Home Source documents United States of America's Unopposed Motion to Approve Sale Price and Sale Terms for Real Property Located at 3726 South Las Vegas Boulevard, Unit 509, Las Vegas, Clark County, Nevada, and Order — United States of America v. Jorge Abramovs, 2:21-CR-027-RFB-DJA (Dkt. 123, D. Nev.)

United States of America's Unopposed Motion to Approve Sale Price and Sale Terms for Real Property Located at 3726 South Las Vegas Boulevard, Unit 509, Las Vegas, Clark County, Nevada, and Order — United States of America v. Jorge Abramovs, 2:21-CR-027-RFB-DJA (Dkt. 123, D. Nev.)

Summary

The United States' unopposed motion in United States of America v. Jorge Abramovs, 2:21-CR-027-RFB-DJA in the District of Nevada, filed 10/07/22 as Document 123, asking the court to approve the sale of Unit 509 in Veer Towers, Las Vegas, for $325,000. The court had earlier authorized an interlocutory sale (ECF No. 56); Doug Sawyer listed the property at $325,000 and Kristen Paige Keel offered that amount. The motion says approval would stop growing Clark County property taxes and HOA fees, and that after taxes, fees, commission and escrow costs the net proceeds go to the United States Marshal Service as a substitute res. Abramovs, through counsel Margaret W. Lambrose, agreed to the price on October 5, 2022. The order at the end bears Judge Richard F. Boulware's name and is dated October 7, 2022.

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Case 2:21-cr-00027-RFB-DJA Document 123 Filed 10/07/22 Page 1of3

JASON M. FRIERSON
United States Attorney

Nevada Bar Number 7709
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney
Nevada Bar. No. 1925
501 Las Vegas Boulevard South, Suite 1100
Las Vegas, Nevada 89101
(702) 388-6336
Daniel.Hollingsworth@usdoj.gov
Attorneys for the United States
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
UNITED STATES OF AMERICA, 2:21-CR-027-RFB-DJA
Plaintiff, United States of America’s Unopposed
Motion to Approve Sale Price and Sale
V. Terms for Real Property Located at 3726
South Las Vegas Boulevard, Unit 509, Las
JORGE ABRAMOVS, Vegas, Clark County, Nevada, and Order
Defendant.

The United States moves this Court to approve the sale of 3726 South Las Vegas

Boulevard, Unit 509, Las Vegas, Clark County, Nevada (property)! for $325,000.

"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:

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
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Case 2:21-cr-00027-RFB-DJA Document 123 Filed 10/07/22 Page 2 of 3

The reasons for this request are (1) to authorize Doug Sawyer to sell the property for
$325,000 under the Court-ordered interlocutory sale and (2) to stop the continued increase
of (a) the Clark County real property taxes, interest, and penalties and (b) HOA fees,
interest, and penalties.

This Motion is made and is based on the papers and pleadings on file herein and the
attached Memorandum of Points and Authorities.

Motion and Memorandum of Points and Authorities

This Court authorized the Interlocutory Sale of the property.” Mr. Sawyer listed the
price for $325,000. Kristen Paige Keel offered $325,000 to purchase the property. If this
Court does not approve the sale, Ms. Keel will receive her earnest money deposit. Mr.
Sawyer received other offers, but they failed to come to fruition.

If this Court approves this offer and after the unpaid real estate taxes; the unpaid
HOA fees; the broker commission and expenses; and escrow costs and fees, the remaining
net sale proceeds will be payable to the United States Marshal Service deposited into an
interest-bearing account. The net sale proceeds will constitute the amount to be retained by

the Court as a substitute res under Supp. R. G(7)(b)(iii) and (iv).

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 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 INBOOK
20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL
IMPROVEMENTS AND APPURTENANCES THEREON, APN: 162-20-714-020.

* Order, ECF No. 56, granting Motion for an Interlocutory Order of Sale of 3726 South Las

Vegas Boulevard, Unit 509, ECF No. 54.
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Case 2:21-cr-00027-RFB-DJA Document 123 Filed 10/07/22 Page 3of3

The government has determined that (1) neither the buyer nor any individual who

will be on the title after the completion of the sale is a felon; and (2) this sale represents an

arms-length transaction under the law.

On October 5, 2022, Jorge Abramovs, through his counsel, Margaret W. Lambrose,

agreed to the sale price of $325,000.
Dated: October 5, 2022.

JASON M. FRIERSON
United States Attorney

/s/ Daniel D. Hollingsworth
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney

ITIS SO ORDERED:

RICHARD F. BOULWARE
UNITED STATES DISTRICT JUDGE

DATED: October 7, 2022


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