Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 1 of 19 PageID #:5209
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`UNITED STATES OF AMERICA
`
`v.
`
`
`
`
`
`
`
`SHRADHA AGARWAL
`
`
`)
`)
`)
`)
`)
`
`No. 19 CR 864-2
`
`Judge Thomas M. Durkin
`
`
`
`PRELIMINARY ORDER OF FORFEITURE
`
`The United States filed an unopposed motion asking this Court to issue a
`
`preliminary order of forfeiture pursuant to of Title 18, United States Code, Sections
`
`981(a)(1)(C), 982(a)(2)(A), Title 28, United States Code, Section 2461(c), Title 21,
`
`United States Code, Section 853(p), and Fed. R. Crim. P. 32.2.
`
`(a) On November 21, 2019, a superseding indictment was returned
`
`charging SHRADHA AGARWAL with mail fraud, in violation of Title 18, United
`
`States Code, Section 1341 (Counts 1, 2, 4, 11, 23, and 25); wire fraud, in violation of
`
`Title 18, United States Code, Section 1343 (Counts 14, 15, 16, 17, 18, 19, 20, 22, 24,
`
`and 26), and bank fraud, in violation of Title 18, United States Code, Section 1344
`
`(Counts 9 and 13).
`
`(b)
`
`The superseding indictment sought forfeiture to the United States of
`
`any and all right, title and interest defendant SHRADHA AGARWAL may have in
`
`any property which constitutes and is derived from proceeds traceable to the charged
`
`mail and wire fraud offenses, as provided in Title 18, United States Code, Section
`
`981(a)(1)(C) and Title 28, United States Code, Section 2461(c); and any property
`
`which constitutes and is derived from proceeds obtained, directly or indirectly as to
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 2 of 19 PageID #:5210
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`the bank fraud offenses, as provided in Title 18, United States Code, Section
`
`982(a)(2)(A).
`
`(c)
`
`Beginning on January 24, 2023, a jury trial was held before this Court.
`
`(d) On April 11, 2023, the jury returned a verdict of guilty against defendant
`
`SHRADHA AGARWAL on Counts 1, 2, 4, 9, 11, 13, 14, 15, 16, 17, 18, 22, 24, 25, and
`
`26 of the superseding indictment, thereby making certain property subject to
`
`forfeiture pursuant to the provisions of Title 18, United States Code, Sections
`
`981(a)(1)(C), 982(a)(2)(A), and Title 28, United States Code, Section 2461(c).
`
`(e) Defendant SHRADHA AGARWAL waived her right to have the
`
`forfeiture allegations in the superseding indictment considered by the jury. It was
`
`agreed instead that this Court would consider the issues relating to the forfeiture.
`
`(f)
`
`Defendant SHRADHA AGARWAL does not wish to assert any claims to
`
`certain property listed in the forfeiture allegation of the superseding indictment. She
`
`further waives any right to be notified or to participate in any proceedings relating
`
`to the property. The undisputed assets, as listed in forfeiture allegations one and two
`
`of the superseding indictment, are I.b. and II.r.
`
`(g) Defendant SHRADHA AGARWAL does not oppose the entry of a
`
`personal money judgment in the amount of $13,700,000, which represents proceeds
`
`traceable to the offenses.
`
`(h) Defendant SHRADHA AGARWAL does not oppose the forfeiture of the
`
`following specific property to the United States, as property which represents
`
`proceeds defendant obtained as a result of the fraud offenses of conviction. The
`
`
`
`2
`
`

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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 3 of 19 PageID #:5211
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`following property is to be applied toward satisfaction of the personal money
`
`judgment:
`
`a. All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $60,000.00 in capital contributions submitted on or
`around May 31, 2018;
`
`b. All right, title, and interest in approximately 17.747958% of Investment
`Company A, held by Gravitas Holdings, LLC, purchased
`for
`approximately $2,537,695.00 on or about October 10, 2017;
`
`c. All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $15,000.00 in
`capital contributions submitted on or about April 24, 2018;
`
`d. All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $475,000.00
`in capital contributions submitted between August 1, 2017, and
`November 27, 2018;
`
`e. All right, title, and interest in Investment Fund C, including, but not
`limited to, $12,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about May 2, 2018;
`
`f. All right, title, and interest in Investment Fund D, including, but not
`limited to, $1,800,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, between March 2,
`2018, and July 9, 2019;
`
`g. All right, title, and interest in Investment Fund E, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $303,045.00 in
`capital contributions submitted between September 27, 2017, and July
`17, 2019;
`
`h. All right, title, and interest in Investment Fund F and Investment Fund
`G, held in the name of Gravitas Holdings, LLC, including, but not
`limited to, $2,235,621.00 in capital contributions submitted between
`June 2, 2017, and July 18, 2017;
`
`
`
`
`3
`
`

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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 4 of 19 PageID #:5212
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`i. Funds in the amount of $3,642,189 seized on September 30, 2021, which
`represents all right, title, and interest in Investment Fund H, held by
`Gravitas Holdings, LLC, including, but not limited to, $2,980,631.00 in
`capital contributions submitted between July 28, 2017, and July 1, 2019;
`
`j. All right, title, and interest in Investment Fund I, held by Gravitas
`Holdings, LLC, including, but not limited to, $319,489.00 in capital
`contributions submitted on or about June 28, 2019;
`
`k. Funds in the amount of $1,055,432.05 seized on June 14, 2021 which
`represents All right, title, and interest in Investment Fund J, held in
`the name of Gravitas Holdings, LLC, including, but not limited to,
`$1,526,821.96 in capital contributions submitted between May 9, 2019,
`and July 25, 2019;
`
`l. All right, title, and interest in approximately 60,053 shares of Series A2
`Preferred Stock of Start-up Company A, held in the name of Jumpstart
`Ventures II, LLC;
`
`m. All right, title, and interest in approximately 90,425 shares of Series B3
`Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`n. All right, title, and interest in approximately 252,045 shares of Series
`B4 Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`o. All right, title, and interest in Investment Fund K, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $2,222,238.00 in
`capital contributions submitted on or about August 14, 2017;
`
`p. All funds and assets on deposit in Account xxxxxx7618 at Kotak
`Mahindra Bank, including, but not limited to $2,000,000.00, held in the
`name of Shradha AGARWAL;
`
`q. All funds and assets on deposit in Account xxxxx6290 and all linked
`accounts at Pershing, LLC, held in the name of Gravitas Holdings, LLC,
`including, but not limited to, Accounts xxxxx6076, xxxxx6159,
`xxxxx3123, xxxxx3129, xxxxx7090, and xxxxx7108, including, but not
`limited to $7,461,413.17;
`
`
`r. All funds and assets on deposit in Account xxxxx6647 and all linked
`accounts at Pershing, LLC, held in the names of Shradha AGARWAL
`and AGARWAL Relative A, including but not limited to $2,050,383.62;
`
`
`
`4
`
`

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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 5 of 19 PageID #:5213
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`
`s. All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $280,000.00 in capital contributions submitted on or
`about January 5, 2017;
`
`t. All right, title, and interest in approximately 3,291 shares of common
`stock of Start-Up Company B, held in the name of Jumpstart Ventures
`II, LLC;
`
`u. All right, title, and interest in Start-Up Company C, including, but not
`limited to, $18,161.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`v. Funds in the amount of $25,004 seized on December 20, 2020, and all
`remaining right, title, and interest in shares of Investment Fund L,
`formerly known as Investment Fund M, held by Jumpstart Ventures II
`LLC, including, but not limited to, $1,000,000.00 in capital contributions
`submitted on or about May 9, 2016;
`
`w. Funds in the amount of $463,690 seized on May 3, 2021, and all
`remaining right, title, and interest in Investment Fund N, held by
`Jumpstart Ventures II LLC, including, but not limited to, $100,000.00
`in capital contributions submitted on or about June 28, 2016;
`
`x. Funds in the amount of $194,616.25 seized on July 8, 2021, and all
`remaining right, title, and interest in Investment Company C, held in
`the name of Jumpstart Ventures II, LLC, including, but not limited to,
`$50,000 in capital contributions submitted on or about January 5, 2017;
`
`y. All right, title, and interest in Investment Company D, held in the name
`of Jumpstart Ventures II, LLC, including, but not limited to,
`$200,000.00 in capital contributions submitted on or about August 8,
`2016;
`
`z. All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $175,000.00
`in capital contributions submitted between July 15, 2016, and June 14,
`2017;
`
`aa. All right, title, and interest in Investment Fund O, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $158,879.00
`
`
`
`5
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 6 of 19 PageID #:5214
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`in capital contributions submitted between August 8, 2016, and April
`28, 2017;
`
`bb. All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $75,000.00 in
`capital contributions submitted on or about August 12, 2016;
`
`cc. All right, title, and interest in Investment Fund C, including, but not
`limited to, $22,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about October 27, 2016;
`
`dd. All right, title, and interest in Investment Company E, including, but
`not limited to, $35,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about January 5,
`2017;
`
`ee. All right, title, and interest in Investment Fund P, including, but not
`limited to, $80,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`ff. All right, title, and interest in Investment Company F, including, but
`not limited to, $40,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about July 15,
`2016;
`
`gg. All right, title, and interest in Investment Fund Q, held in the name of
`Jumpstart Ventures II LLC, including, but not limited to, $45,000.00 in
`capital contributions submitted on or about October 11, 2016;
`
`hh.All right, title, and interest in approximately 250,454 shares of Series
`Preferred AA stock of Start-up Company D, held in the name of
`Jumpstart Ventures II, LLC;
`
`ii. All right, title, and interest in approximately 751,362 shares of common
`stock of Start-up Company D, held in the name of Jumpstart Ventures
`II, LLC;
`
`jj. All right, title, and interest in various items of jewelry purchased from
`Jewelry Company A on or about December 1, 2017, using funds from
`
`
`
`6
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 7 of 19 PageID #:5215
`
`
`
`Account XXX3805 at Gold Coast Bank, including, but not limited to,
`jewelry and precious gems valued at approximately $200,000.00;
`
`kk. All funds and assets on deposit in Account xxxxxxxx3548 at RBL Bank
`Ltd., including, but not limited to $1,580,917.97, held in the name of
`Shradha AGARWAL;
`
`ll. All funds and assets on deposit in Account xxxxxxxx7836 at RBL Bank
`Ltd., including, but not limited to $333,977.77, held in the name of
`AGARWAL Relative A;
`
`All funds and assets on deposit in Account xxxxxxxx2006 at
`mm.
`HSBC, including, but not limited to $110,166.42, held in the name of
`AGARWAL Relative A; and
`
`nn.All right, title, and interest in approximately 705,417 shares of Series
`Series Seed-3 Preferred Stock of Start-up Company E, held in the name
`of Jumpstart Ventures II, LLC.
`
`
`Accordingly, it is hereby ORDERED, ADJUDGED and DECREED:
`
`1.
`
`A judgment is entered against defendant SHRADHA AGARWAL in the
`
`amount of $13,700,000, as proceeds obtained by the defendant traceable to the
`
`violations of conviction of Title 18, United States Code, Sections 1341, 1343 and 1344,
`
`as provided in Title 18, United States Code, Sections 981(a)(1)(C), 982(a)(2)(A), and
`
`Title 28, United States Code, Section 2461(c).
`
`2.
`
`Pursuant to Title 18, United States Code, Sections 981(a)(1)(C),
`
`982(a)(2)(A), Title 28, United States Code, Section 2461(c), and Federal Rule of
`
`Criminal Procedure 32.2, all right title, and interest defendant may have in funds in
`
`the amount of $13,700,000 is hereby forfeit to the United States of America for
`
`disposition according to law.
`
`3.
`
`Pursuant to Title 18, United States Code, Sections 981(a)(1)(C),
`
`982(a)(2)(A), Title 28, United States Code, Section 2461(c), and Fed. R. Crim. P. 32.2,
`
`
`
`7
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 8 of 19 PageID #:5216
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`all right title, and interest defendant may have in the following property is hereby
`
`forfeit to the United States of America for disposition according to law, as property
`
`which represents proceeds defendant obtained as a result of the offenses of conviction,
`
`to be applied toward satisfaction of the personal money judgment.
`
`(a)
`
`(b)
`
`(c)
`
`(d)
`
`(e)
`
`(f)
`
`(g)
`
`All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $60,000.00 in capital contributions submitted on or
`around May 31, 2018;
`
`All right, title, and interest in approximately 17.747958% of Investment
`Company A, held by Gravitas Holdings, LLC, purchased
`for
`approximately $2,537,695.00 on or about October 10, 2017;
`
`All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $15,000.00 in
`capital contributions submitted on or about April 24, 2018;
`
`All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $475,000.00
`in capital contributions submitted between August 1, 2017, and
`November 27, 2018;
`
`All right, title, and interest in Investment Fund C, including, but not
`limited to, $12,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about May 2, 2018;
`
`All right, title, and interest in Investment Fund D, including, but not
`limited to, $1,800,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, between March 2,
`2018, and July 9, 2019;
`
`All right, title, and interest in Investment Fund E, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $303,045.00 in
`capital contributions submitted between September 27, 2017, and July
`17, 2019;
`
`
`
`
`8
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 9 of 19 PageID #:5217
`
`(i)
`
`(j)
`
`(k)
`
`(h) All right, title, and interest in Investment Fund F and Investment Fund
`G, held in the name of Gravitas Holdings, LLC, including, but not
`limited to, $2,235,621.00 in capital contributions submitted between
`June 2, 2017, and July 18, 2017;
`
`Funds in the amount of $3,642,189 seized on September 30, 2021, which
`represents all right, title, and interest in Investment Fund H, held by
`Gravitas Holdings, LLC, including, but not limited to, $2,980,631.00 in
`capital contributions submitted between July 28, 2017, and July 1, 2019;
`
`All right, title, and interest in Investment Fund I, held by Gravitas
`Holdings, LLC, including, but not limited to, $319,489.00 in capital
`contributions submitted on or about June 28, 2019;
`
`Funds in the amount of $1,013,246.45 seized on June 14, 2021 which
`represents All right, title, and interest in Investment Fund J, held in
`the name of Gravitas Holdings, LLC, including, but not limited to,
`$1,526,821.96 in capital contributions submitted between May 9, 2019,
`and July 25, 2019;
`
`All right, title, and interest in approximately 60,053 shares of Series A2
`Preferred Stock of Start-up Company A, held in the name of Jumpstart
`Ventures II, LLC;
`
`(m) All right, title, and interest in approximately 90,425 shares of Series B3
`Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`(n) All right, title, and interest in approximately 252,045 shares of Series
`B4 Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`All right, title, and interest in Investment Fund K, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $2,222,238.00 in
`capital contributions submitted on or about August 14, 2017;
`
`All funds and assets on deposit in Account xxxxxx7618 at Kotak
`Mahindra Bank, including, but not limited to $2,000,000.00, held in the
`name of Shradha AGARWAL;
`
`All funds and assets on deposit in Account xxxxx6290 and all linked
`accounts at Pershing, LLC, held in the name of Gravitas Holdings, LLC,
`including, but not limited to, Accounts xxxxx6076, xxxxx6159,
`
`(l)
`
`(o)
`
`(p)
`
`(q)
`
`
`
`9
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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 10 of 19 PageID #:5218
`
`(r)
`
`(s)
`
`(t)
`
`(v)
`
`xxxxx3123, xxxxx3129, xxxxx7090, and xxxxx7108, including, but not
`limited to $7,461,413.17;
`
`All funds and assets on deposit in Account xxxxx6647 and all linked
`accounts at Pershing, LLC, held in the names of Shradha AGARWAL
`and AGARWAL Relative A, including but not limited to $2,050,383.62;
`
`All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $280,000.00 in capital contributions submitted on or
`about January 5, 2017;
`
`All right, title, and interest in approximately 3,291 shares of common
`stock of Start-Up Company B, held in the name of Jumpstart Ventures
`II, LLC;
`
`(u) All right, title, and interest in Start-Up Company C, including, but not
`limited to, $18,161.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`All right, title, and interest in Investment Company D, held in the name
`of Jumpstart Ventures II, LLC, including, but not limited to,
`$200,000.00 in capital contributions submitted on or about August 8,
`2016;
`
`(w) All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $175,000.00
`in capital contributions submitted between July 15, 2016, and June 14,
`2017;
`
`All right, title, and interest in Investment Fund O, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $158,879.00
`in capital contributions submitted between August 8, 2016, and April
`28, 2017;
`
`All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $75,000.00 in
`capital contributions submitted on or about August 12, 2016;
`
`All right, title, and interest in Investment Fund C, including, but not
`limited to, $22,000.00 in capital contributions submitted by or on behalf
`
`(x)
`
`(y)
`
`(z)
`
`
`
`10
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 11 of 19 PageID #:5219
`
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about October 27, 2016;
`
`(aa) All right, title, and interest in Investment Company E, including, but
`not limited to, $35,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about January 5,
`2017;
`
`(bb) All right, title, and interest in Investment Fund P, including, but not
`limited to, $80,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`(cc) All right, title, and interest in Investment Company F, including, but
`not limited to, $40,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about July 15,
`2016;
`
`(dd) All right, title, and interest in Investment Fund Q, held in the name of
`Jumpstart Ventures II LLC, including, but not limited to, $45,000.00 in
`capital contributions submitted on or about October 11, 2016;
`
`(ee) All right, title, and interest in approximately 250,454 shares of Series
`Preferred AA stock of Start-up Company D, held in the name of
`Jumpstart Ventures II, LLC;
`(ff) All right, title, and interest in approximately 751,362 shares of common
`stock of Start-up Company D, held in the name of Jumpstart Ventures
`II, LLC;
`
`(gg) All right, title, and interest in various items of jewelry purchased from
`Jewelry Company A on or about December 1, 2017, using funds from
`Account XXX3805 at Gold Coast Bank, including, but not limited to,
`jewelry and precious gems valued at approximately $200,000.00;
`
`(hh) All funds and assets on deposit in Account xxxxxxxx3548 at RBL Bank
`Ltd., including, but not limited to $1,580,917.97, held in the name of
`Shradha AGARWAL;
`
`(ii) All funds and assets on deposit in Account xxxxxxxx7836 at RBL Bank
`Ltd., including, but not limited to $333,977.77, held in the name of
`AGARWAL Relative A;
`
`
`11
`
`
`
`
`
`

`

`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 12 of 19 PageID #:5220
`
`(jj)
`
`All funds and assets on deposit in Account xxxxxxxx2006 at HSBC,
`including, but not limited to $110,166.42, held in the name of
`AGARWAL Relative A; and
`
`(kk) All right, title, and interest in approximately 705,417 shares of Series
`Series Seed-3 Preferred Stock of Start-up Company E, held in the name
`of Jumpstart Ventures II, LLC.
`
`Pursuant to the provisions of Title 21, United States Code, Section
`
`4.
`
`853(p), as incorporated by Title 28, United States Code, Section 2461(c) and Title 18,
`
`United States Code, Section 982(b)(1), and Fed. R. Crim. P. 32.2, all right title, and
`
`interest defendant may have in funds in the amount of $3,816,824.52 turned over to
`
`the FBI from Law Firm B on July 13, 2020, shall be forfeit to the United States for
`
`disposition according to law, as a substitute asset to the extent necessary to satisfy
`
`the $13,700,000 personal money judgment.
`
`5.
`
`Pursuant to the provisions of Title 21, United States Code, Section
`
`853(g), as incorporated by Title 28, United States Code, Section 2461(c) and Title 18,
`
`United States Code, Section 982(b)(1), upon entry of this preliminary order of
`
`forfeiture, United States Marshals Service, Federal Bureau of Investigation, or any
`
`other authorized law enforcement agency, shall seize and take custody of the
`
`foregoing property for disposition according to law.
`
`6.
`
`Specifically, the following accounts shall be liquidated and distributed
`
`as follows:
`
`a. All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $60,000.00 in capital contributions submitted on or
`around May 31, 2018;
`
`
`
`
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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 13 of 19 PageID #:5221
`
`b. All right, title, and interest in approximately 17.747958% of Investment
`Company A, held by Gravitas Holdings, LLC, purchased
`for
`approximately $2,537,695.00 on or about October 10, 2017;
`
`c. All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $15,000.00 in
`capital contributions submitted on or about April 24, 2018;
`
`d. All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $475,000.00
`in capital contributions submitted between August 1, 2017, and
`November 27, 2018;
`
`e. All right, title, and interest in Investment Fund C, including, but not
`limited to, $12,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about May 2, 2018;
`
`f. All right, title, and interest in Investment Fund D, including, but not
`limited to, $1,800,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, between March 2,
`2018, and July 9, 2019;
`
`g. All right, title, and interest in Investment Fund E, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $303,045.00 in
`capital contributions submitted between September 27, 2017, and July
`17, 2019;
`
`h. All right, title, and interest in Investment Fund F and Investment Fund
`G, held in the name of Gravitas Holdings, LLC, including, but not
`limited to, $2,235,621.00 in capital contributions submitted between
`June 2, 2017, and July 18, 2017;
`
`i. All right, title, and interest in Investment Fund I, held by Gravitas
`Holdings, LLC, including, but not limited to, $319,489.00 in capital
`contributions submitted on or about June 28, 2019;
`
`j. All right, title, and interest in approximately 60,053 shares of Series A2
`Preferred Stock of Start-up Company A, held in the name of Jumpstart
`Ventures II, LLC;
`
`
`
`
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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 14 of 19 PageID #:5222
`
`k. All right, title, and interest in approximately 90,425 shares of Series B3
`Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`l. All right, title, and interest in approximately 252,045 shares of Series
`B4 Preferred Stock of Start-up Company A, held in the name of Gravitas
`Holdings, LLC;
`
`m. All right, title, and interest in Investment Fund K, held in the name of
`Gravitas Holdings, LLC, including, but not limited to, $2,222,238.00 in
`capital contributions submitted on or about August 14, 2017;
`
`n. All funds and assets on deposit in Account xxxxxx7618 at Kotak
`Mahindra Bank, including, but not limited to $2,000,000.00, held in the
`name of Shradha AGARWAL;
`
`o. All funds and assets on deposit in Account xxxxx6290 and all linked
`accounts at Pershing, LLC, held in the name of Gravitas Holdings, LLC,
`including, but not limited to, Accounts xxxxx6076, xxxxx6159,
`xxxxx3123, xxxxx3129, xxxxx7090, and xxxxx7108, including, but not
`limited to $7,461,413.17;
`
`p. All funds and assets on deposit in Account xxxxx6647 and all linked
`accounts at Pershing, LLC, held in the names of Shradha AGARWAL
`and AGARWAL Relative A, including but not limited to $2,050,383.62;
`
`q. All right, title, and interest in Investment Fund A, held in the name of
`Jumpstart Ventures II, LLC,
`including, but not
`limited to,
`approximately $280,000.00 in capital contributions submitted on or
`about January 5, 2017;
`
`r. All right, title, and interest in approximately 3,291 shares of common
`stock of Start-Up Company B, held in the name of Jumpstart Ventures
`II, LLC;
`
`s. All right, title, and interest in Start-Up Company C, including, but not
`limited to, $18,161.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`t. All right, title, and interest in Investment Company D, held in the name
`of Jumpstart Ventures II, LLC, including, but not limited to,
`$200,000.00 in capital contributions submitted on or about August 8,
`2016;
`
`
`
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`

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`
`
`
`
`
`
`
`
`u. All right, title, and interest in Investment Fund B, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $175,000.00
`in capital contributions submitted between July 15, 2016, and June 14,
`2017;
`
`v. Funds in the amount of $25,004 seized on December 20, 2020, and all
`remaining right, title, and interest in shares of Investment Fund L,
`formerly known as Investment Fund M, held by Jumpstart Ventures II
`LLC, including, but not limited to, $1,000,000.00 in capital contributions
`submitted on or about May 9, 2016;
`
`w. Funds in the amount of $396,871 seized on May 3, 2021, and all
`remaining right, title, and interest in Investment Fund N, held by
`Jumpstart Ventures II LLC, including, but not limited to, $100,000.00
`in capital contributions submitted on or about June 28, 2016;
`
`x. Funds in the amount of $194,616.25 seized on July 8, 2021, and all
`remaining right, title, and interest in Investment Company C, held in
`the name of Jumpstart Ventures II, LLC, including, but not limited to,
`$50,000 in capital contributions submitted on or about January 5, 2017;
`
`y. All right, title, and interest in Investment Fund O, held in the name of
`Jumpstart Ventures II, LLC, including, but not limited to, $158,879.00
`in capital contributions submitted between August 8, 2016, and April
`28, 2017;
`
`z. All right, title, and interest in investments made with Investment
`Company B entities, held in the name of Gravitas Holdings, LLC and
`Jumpstart Ventures II, LLC, including, but not limited to $75,000.00 in
`capital contributions submitted on or about August 12, 2016;
`
`aa. All right, title, and interest in Investment Fund C, including, but not
`limited to, $22,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about October 27, 2016;
`
`bb. All right, title, and interest in Investment Company E, including, but
`not limited to, $35,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about January 5,
`2017;
`
`
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`
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`Case: 1:19-cr-00864 Document #: 468 Filed: 06/16/23 Page 16 of 19 PageID #:5224
`
`cc. All right, title, and interest in Investment Fund P, including, but not
`limited to, $80,000.00 in capital contributions submitted by or on behalf
`of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas Holdings,
`LLC, and Jumpstart Ventures II LLC, on or about January 5, 2017;
`
`dd. All right, title, and interest in Investment Company F, including, but
`not limited to, $40,000.00 in capital contributions submitted by or on
`behalf of Rishi SHAH, Shradha AGARWAL, Brad PURDY, Gravitas
`Holdings, LLC, and Jumpstart Ventures II LLC, on or about July 15,
`2016;
`
`ee. All right, title, and interest in Investment Fund Q, held in the name of
`Jumpstart Ventures II LLC, including, but not limited to, $45,000.00 in
`capital contributions submitted on or about October 11, 2016;
`
`ff. All right, title, and interest in approximately 250,454 shares of Series
`Preferred AA stock of Start-up Company D, held in the name of
`Jumpstart Ventures II, LLC;
`
`gg. All right, title, and interest in approximately 751,362 shares of common
`stock of Start-up Company D, held in the name of Jumpstart Ventures
`II, LLC;
`
`hh.All righ