Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 1 of 4
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`UNITED STATES OF AMERICA
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`-V.-
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`TARA ROSE,
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`CONSENT PRELIMINARY ORDER
`OF FORFEITURE/
`MONEY JUDGMENT
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`Defendant.
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`19 Cr. 789 (PGG)
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`WHEREAS, on or about November 6, 2019, TARA ROSE(the “Defendant”),
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`among others, was charged in one countof a thirty-two count Indictment, 19 Cr. 789 (PGG)(the
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`“Indictment”), with conspiracy to violate the Travel Act, in violation of Title 18, United States
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`Code, Section 371 (Count One);
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`WHEREAS, the Indictmentincluded,inter alia, a forfeiture allegation as to Count
`Oneof the Indictment, seeking forfeiture to the United States, pursuant to Title 18, United States
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`Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c) of any andall
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`property, including butnot limited to a sum of money in United States currency representing the
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`amount of proceeds traceable to the commission of the offense charged in Count One of the
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`Indictment that the Defendant personally obtained;
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`WHEREAS, on or about January 5, 2022, the Defendant pled guilty to Count One
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`of the Indictment, pursuant to a plea agreement with the Government, wherein the Defendant
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`admitted the forfeiture allegation with respect to Count Oneofthe Indictment and agreed to forfeit
`to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28,
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`United States Code, Section 2461(c), a sum of money equalto no less than $37,367 in United States
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 1 of 4
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`currency, representing the amountof proceeds traceable to the commission ofthe offense charged
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`in Count Oneof the Indictment, that the Defendant personally obtained;
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 2 of 4
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`WHEREAS, the Defendant consents to the entry of a money judgment in the
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`amount of $37,367 in United States currency, representing the amountof proceeds traceable to the
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`offense charged in Count Oneofthe Indictmentthat the Defendant personally obtained; and
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`WHEREAS, the Defendant admits that, as a result of acts and/or omissions of the
`Defendant, the proceedstraceable to the offense charged in Count One of the Indictment that the
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`Defendant personally obtained cannot be located upon the exercise of due diligence.
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`IT IS HEREBY STIPULATED AND AGREED,by andbetweenthe United States
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`of America, by its attorney Damian Williams, United States Attorney; Assistant United States
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`Attorneys, Mathew Andrews, Louis A. Pellegrino, and Stephanie Simon, of counsel; and the
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`Defendant, and her counsel, Daniel Parker, Esq., that:
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`1.
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`As a result of the offense charged in Count Oneofthe Indictment, to which
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`the Defendant pled guilty, a money judgment in the amount of $37,367 in United States currency
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`(the “Money Judgment’), representing the amount of proceedstraceable to the offense charged in
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`Count One of the Indictment that the Defendant personally obtained, shall be entered against the
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`Defendant.
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`2.
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`Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal Procedure,this
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`Consent Preliminary Order of Forfeiture/Money Judgmentis final as to the Defendant, TARA
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`ROSE,and shall be deemedpart of the sentence of the Defendant, and shall be included in the
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`judgment of conviction therewith.
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`3.
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`Alt payments on the outstanding money judgment shall be made by postal
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`moneyorder, bankor certified check, made payable,in this instance, to the United States Marshals
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`Service, and delivered by mail to the United States Attorney’s Office, Southern District of New
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 2 of 4
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 3 of 4
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`York, Attn: Money Laundering and Transnational Criminal Enterprises Unit, One St. Andrew’s
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`Plaza, New York, New York 10007 andshall indicate the Defendant’s name and case number.
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`4.
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`The United States Marshals Service is authorized to deposit the payments
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`on the Money Judgmentin the Assets Forfeiture Fund, and the United States shall have cleartitle
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`to such forfeited property.
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`5.
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`Pursuant to Title 21, United States Code, Section 853(p), the United States
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`is authorized to seek forfeiture of substitute assets of the Defendant up to the uncollected amount
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`of the Money Judgment.
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`6.
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`Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the
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`United States Attorney’s Office is authorized to conduct any discovery neededto identify, locate
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`or dispose of forfeitable property, including depositions, interrogatories, requests for production
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`of documents and the issuance of subpoenas.
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`7.
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`The Court shall retain jurisdiction to enforce this Consent Preliminary Order
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`of Forfeiture/Money Judgment, and to amendit as necessary, pursuant to Rule 32.2 of the Federal
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`Rules of Criminal Procedure.
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`[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 3 of 4
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`Case 1:19-cr-00789-PGG Document 929 Filed 12/05/22 Page 4 of 4
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`8.
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`The signature page of this Consent Preliminary Order of Forfeiture/Money
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`Judgment may be executed in one or more counterparts, each of which will be deemedan original
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`but all of which together will constitute one and the same instrument.
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`AGREED AND CONSENTED TO:
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`DAMIAN WILLIAMS
`United States Attorney for the
`Southern District of New York
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`Mies LEZibe
`NY
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`By:
`MATHEW ANDREWS
`LOUIS A. PELLEGRINO
`STEPHANIE SIMON
`Assistant United States Attorney
`One St. Andrew’s Plaza
`New York, NY 10007
`(212) 637-6526 / 2617
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`LEA EE
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`wy
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`DANIEL PARKER,ESQ.
`Attorney for Defendant
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`SO ORDERED:
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`11/23/2022
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`DATE
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`HONORABLE PAUL G. GARDEPHE
`UNITED STATES DISTRICT JUDGE
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