1:25-cv-01907
06/18/2025
Open
Public and Administrative - Forfeiture
illegal activities; to promote and enhance cooperation among federal and foreign law enforcement agencies; and most importantly, to recover assets that may be used to compensate victims.1
3. This Court has original jurisdiction of this civil action by virtue of 28 U.S.C. § 1345 because it has been commenced by the United States and by virtue of 28 U.S.C. § 1355 (a) because it is an action for the recovery and enforcement of a forfeiture under an Act of Congress.
4. This Court has in rem jurisdiction over the Defendant Property under 28 U.S.C. § 1355 (b).
5. Venue is proper in this judicial district under 18 U.S.C. § 3238 and 28 U.S.C. §§ 1355 (b) and 1395 (a), (b), and (c).
6. The United States files this in rem forfeiture action to seek forfeiture of Defendant Property as constituting proceeds of wire fraud and wire fraud conspiracy offenses, committed in violation of 18 U.S.C. §§ 1343 , 1349 , 2, and 3, and as involved in money laundering and money laundering offenses, committed in violation of 18 U.S.C. 1956 (a)(1)(B)(i), 1956 (h), and 2, and 3.
7. Procedures for this action are mandated by Rule G of the supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions and, to the extent applicable, 18 U.S.C. §§ 981 and 983 and the Federal Rules of Civil Procedure.
8. 18 U.S.C. § 981(a)(1)(A) mandates forfeiture of any property, real or personal, involved in a transaction or attempted transaction in violation of section 18 U.S.C. §§ 1956 , 1957 ,
1 U.S. Department of Justice, Asset Forfeiture Program, https://www.justice.gov/afp. (Last accessed Jun. 17, 2025 ).
or 1960 , or any property traceable to such property.
9. 18 U.S.C. § 981(a)(1)(C) mandates forfeiture of property constituting or derived from proceeds traceable to wire fraud, conspiracy to commit wire fraud, or any offense constituting “specified unlawful activity” as defined by 18 U.S.C. § 1956 (c)(7), or a conspiracy to commit such offense. A violation of 18 U.S.C. § 1343 , or a conspiracy to commit that offense, constitutes specified unlawful activity under 18 U.S.C. § 1956 (c)(7)(A) as an offense listed in 18 U.S.C. § 1961 (1)(B).
10. Title 18 U.S.C. § 1343 provides that whoever, having devised or intending to devise any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises, transmits or causes to be transmitted by means of wire, radio, television communication in interstate or foreign commerce, any writings, signs, signals, pictures, or sounds for the purpose of executing such scheme or artifice, commits the violation of wire fraud.
11. Title 18 U.S.C. § 1349 provides that whoever attempts or conspires to commit a violation of 18 U.S.C. § 1343 shall be subject to the same penalties as those prescribed for the offense, the commission of which was the object of the attempt or conspiracy.
12. Title 18 U.S.C. § 1956 (a)(1)(B)(i) provides in relevant part that whoever, knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity— . . . knowing that the transaction is designed in whole or in part . . . to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity” is guilty of concealment money laundering.
Page 3Presiding Judge
Amir H. Ali
Plaintiff
UNITED STATES OF AMERICA
Defendant
APPROXIMATELY 225,364,961 USDT
Plaintiff Attorney
Rick E. Blaylock, Jr.
Defendant Attorneys
Michael Burshteyn
Michael A Pusateri
(#15) MOTION Motion to Seal and Proceed Under Pseudonyms by APPROXIMATELY 225,364,961 USDT. (Burshteyn, Michael) (Entered: 10/03/2025)
(#14) CLAIM Verified Claims of Victim-Claimants Identified in Schedule A by APPROXIMATELY 225,364,961 USDT. (Yakobi, Rafael) (Entered: 10/03/2025)
Declaration
(#13) Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Nathan Muyskens, of Service of Minute Order Filing fee $ 100, receipt number ADCDC-11991728. Fee Status: Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration)(Pusateri, Michael) (Entered: 09/29/2025)
Declaration
(#12) Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Marcelo Barros, of Service of Minute Order Filing fee $ 100, receipt number ADCDC-11984693. Fee Status: Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration)(Pusateri, Michael) (Entered: 09/25/2025)
Declaration
MINUTE ORDER granting #11 motion for leave to appear pro hac vice. Attorney Rafael Yakobi is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
MINUTE ORDER granting #10 motion for leave to appear pro hac vice. Attorney Agustin M. Barbara is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
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Exhibit
Exhibit
Docket(#15) MOTION Motion to Seal and Proceed Under Pseudonyms by APPROXIMATELY 225,364,961 USDT. (Burshteyn, Michael) (Entered: 10/03/2025)
[-] Read LessDocket(#14) CLAIM Verified Claims of Victim-Claimants Identified in Schedule A by APPROXIMATELY 225,364,961 USDT. (Yakobi, Rafael) (Entered: 10/03/2025)
[-] Read LessDocketMINUTE ORDER. The Court is in receipt of the #13 motion for pro hac vice admission of Nathan Muyskens as counsel for forthcoming third-party claimants. Under the comment to Local Civil Rule 83.2(c)(2), "as a general matter, attorneys who engage in the practice of law from an office located in the District of Columbia and who file papers in this Court should be a member of the Bar of this Court and the District of Columbia Bar." The motion is granted given that Muyskens represents that he is a member of the D.C. Bar, and he is encouraged to apply for admission to this Court's Bar as soon as possible. Muyskens is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocketMINUTE ORDER granting #12 motion for leave to appear pro hac vice. Attorney Marcelo Barros is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocketMINUTE ORDER granting #11 motion for leave to appear pro hac vice. Attorney Rafael Yakobi is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocketMINUTE ORDER granting #10 motion for leave to appear pro hac vice. Attorney Agustin M. Barbara is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocketMINUTE ORDER granting #9 motion for leave to appear pro hac vice. Attorney Daniel G. Boyle is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocketMINUTE ORDER granting #8 motion for leave to appear pro hac vice. Attorney Michael Burshteyn is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). #Click for instructions. Signed by Judge Amir H. Ali on 10/2/2025. (lcaha3) (Entered: 10/02/2025)
[-] Read LessDocket(#13) Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Nathan Muyskens, of Service of Minute Order Filing fee $ 100, receipt number ADCDC-11991728. Fee Status: Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration)(Pusateri, Michael) (Entered: 09/29/2025)
[-] Read LessDocket(#12) Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Marcelo Barros, of Service of Minute Order Filing fee $ 100, receipt number ADCDC-11984693. Fee Status: Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration)(Pusateri, Michael) (Entered: 09/25/2025)
[-] Read LessDocket(#8) Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Michael Burshteyn, of Service of Minute Order Filing fee $ 100, receipt number CDCDC-11984443. Fee Status: Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration)(Pusateri, Michael) (Entered: 09/25/2025)
[-] Read LessDocketNOTICE OF ERROR regarding #7 MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Burshteyn; Boyle, Barbara, Yahobi, Barros, Muyskens, Fee Status: No Fee Paid.. The following error(s) need correction: Declaration must have an original, ink signature. Other- A separate Motion to Appear PHV should be docketed for each attorney. Pro Hac Vice motions must be accompanied by a payment of $100 for each attorney (LCvR 83.2(c)(2)). Please refile. (mg) (Entered: 09/24/2025)
[-] Read LessDocket(#7) NOTICE OF ERROR.....MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Burshteyn; Boyle, Barbara, Yakobi, Barros, Muyskens, Fee Status: No Fee Paid. by APPROXIMATELY 225,364,961 USDT. (Attachments: #1 Declaration, #2 Motion for Pro Hac Vice, #3 Declaration, #4 Motion for Pro Hac Vice, #5 Declaration, #6 Motion for Pro Hac Vice, #7 Declaration, #8 Motion for Pro Hac Vice, #9 Declaration, #10 Motion for Pro Hac Vice, #11 Declaration)(Pusateri, Michael) Modified on 9/24/2025 to correct docket text (rj). Modified on 9/24/2025 (mg). (Entered: 09/23/2025)
[-] Read LessDocket(#6) NOTICE of Appearance by Michael A Pusateri on behalf of APPROXIMATELY 225,364,961 USDT (Pusateri, Michael) (Entered: 09/23/2025)
[-] Read LessDocket(#5) NOTICE of Publication by UNITED STATES OF AMERICA (Attachments: #1 Exhibit)(Blaylock, Rick) (Entered: 08/08/2025)
[-] Read LessDocket(#4) STANDING ORDER. The parties are ordered to comply with the directives set forth in the attached standing order. See document for details. Signed by Judge Amir H. Ali on 7/14/2025. (lcaha3) (Entered: 07/14/2025)
[-] Read LessDocket(#3) WARRANT for Arrest In Rem Issued Electronically (zmtm) (Entered: 06/18/2025)
[-] Read LessDocketCase Assigned to Judge Amir H. Ali. (zmtm) (Entered: 06/18/2025)
[-] Read LessDocket(#2) REQUEST for Issuance of Warrant in rem by UNITED STATES OF AMERICA. (Blaylock, Rick) Modified docket entry event on 6/18/2025 (zmtm). Modified on 6/18/2025 (zmtm). (Entered: 06/18/2025)
[-] Read LessDocket(#1) COMPLAINT against APPROXIMATELY 225,364,961 USDT (Fee Status:Filing Fee Waived) filed by UNITED STATES OF AMERICA. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit, #17 Exhibit, #18 Exhibit, #19 Exhibit, #20 Exhibit, #21 Exhibit, #22 Exhibit, #23 Exhibit, #24 Exhibit, #25 Exhibit, #26 Exhibit, #27 Exhibit, #28 Exhibit, #29 Exhibit, #30 Exhibit, #31 Exhibit, #32 Exhibit, #33 Exhibit, #34 Exhibit, #35 Exhibit, #36 Exhibit, #37 Exhibit, #38 Exhibit, #39 Exhibit, #40 Civil Cover Sheet)(Blaylock, Rick) (Entered: 06/18/2025)
[-] Read Less