Case 1:23-cr-00118-AT Document 488 Filed 01/07/25 Page 1 of 15 Case 1:23-cr-00118-AT Document 488
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`Filed 01/04 26spPageniyof 15
`DOCUMENT
`
`ELECTRONICALLY FILED
`
`DOC #:
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`DATEFILED:
`
`1/7/2025
`
`UNITED STATES OF AMERICA
`
`-v.-
`
`YVETTE WANG,
`a/k/a “Yanping,”
`alk/a “Y,”
`
`|
`
`Defendant.
`
`:
`
`:
`
`:
`
`CONSENT PRELIMINARY ORDER
`OF FORFEITUREAS TO SPECIFIC
` PROPERTY/MONEY JUDGMENT
`
`$4.23 Cr. 118 (AT)
`
`WHEREAS, onor about May 2, 2024, YVETTE WANG(the “Defendant”), was
`
`charged in a two-count Superseding Information, S4 23 Cr. 118 (AT) (the “Information”), with
`
`conspiracy to commit wire fraud, in violation of Title 18, United States Code, Section 371 (Count
`
`One); and conspiracy to commit money laundering, in violation of Title 18, United States Code,
`
`Section 371 (Count Two);
`
`WHEREAS, the Information includeda forfeiture allegation as to Count Oneof the
`
`Information, seeking forfeiture to the United States, pursuant to Title 18, United States Code,
`
`Sections 981(a)(1)(C), and Title 28, United States Code, Section 2461(c), of any andall property,
`
`real and personal, that constitutes or is derived from proceeds traceable to the commission of the
`
`offense charged in Count Oneof the Information;
`
`WHEREAS, the Information included a forfeiture allegation as to Count Two of
`
`the Information, seeking forfeiture to the United States pursuantto Title 18, United States Code,
`
`Section 982(a)(1), of any andall property, real and personal, involved in the offense charged in
`
`Count Twoofthe Information, or any property traceable to such property, including butnot limited
`
`to a sum of money in United States currency representing the amountof property involved in the
`
`offense charged in Count Two ofthe Information;
`
`

`

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`WHEREAS, on or about May 3, 2024, the Defendant pled guilty to Counts One
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`and Two of the Information, pursuant to a plea agreement with the Government, wherein the
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`Defendant admitted the forfeiture allegation with respect to Counts One and Two of the
`
`Information and agreed to forfeit to the United States, pursuant to Title 18, United States Code,
`
`Sections 981(a)(1)(C), 982(a)(1) and Title 28, United States Code, Section 2461(c): a sum of
`
`money equalto approximately $1.4 billion in United States currency, representing (i) the proceeds
`
`traceable to the commission of the offense charged in Count One of the Information; and (ii) the
`
`property involved in the offense charged in Count Twoof the Information;
`
`WHEREAS,the Defendant consents to the entry of a money judgment in the
`
`amount of $1,400,000,000 in United States currency representing (i) the proceeds traceable to the
`
`commission of the offense charged in Count Oneof the Information that the Defendant personally
`
`obtained; and(ii) the property involved in the offense charged in Count Two of the Information,
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`for which the Defendantis jointly and severally liable with co-defendant, Miles Guo (the “Co-
`
`defendant”) to the extent a forfeiture money judgmentis entered against the Co-defendantin this
`
`case;
`
`WHEREAS, the Defendant further consents to the forfeiture of all her right, title
`
`andinterest in the followingassets:
`
`a.
`
`b.
`
`$64,826.87 in United States currency formerly on deposit in Account
`Number 5090037713 at Silvergate Bank held in the name of “Hamilton
`Opportunity Fund SPC,” seized by the Government on or about September
`18, 2022;
`
`$75,000,000.00 in United States currency formerly on deposit in Account
`Number 5090037705 at Silvergate Bank held in the name of “Hamilton
`Opportunity Fund SPC,” seized by the Government on or about September
`18, 2022;
`
`

`

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`$467,343.00 in United States currency formerly on deposit in Account
`Number 5090037754 at Silvergate Bank held in the nameof “Hamilton
`Opportunity Fund SPC,” seized by the Government on or about September
`18, 2022;
`
`$89,992,861.75 in United States currency formerly on deposit in Account
`Number 5090042770 at Silvergate Bank held in the name of “Hamilton
`Opportunity Fund SPC,” seized by the Government on or about September
`18, 2022;
`
`$1,683,077.40 in United States currency formerly on deposit in Account
`Number5090042762 at Silvergate Bank held in the name of “Hamilton
`Opportunity Fund SPC,” seized by the Government on or about September
`18, 2022;
`
`$85,899,889.20 in United States currency formerly on deposit in Account
`Number5090042853 at Silvergate Bank held in the name of “Hamilton
`Opportunity Funds SPC,” seized by the Governmenton or about
`September18, 2022;
`
`$48,230,709.62 in United States currency formerly on deposit in Account
`Number 5090030288 at Silvergate Bank held in the name of “Hamilton
`Investment Management”Ltd., seized by the Government on or about
`September 18, 2022;
`
`$1,800,000.00 in United States currency formerly on deposit in Account
`Number5090037739 at Silvergate Bank held in the name of “Hamilton
`Opportunity Fund SPC,” seized by the Governmenton or about September
`18, 2022;
`
`$4,643,744.70 in United States currency formerly on deposit in Account
`Number 7801000590 at FV Bankheld in the name of “Himalaya
`International Reserves, Ltd.,” seized by the Government on or about
`September 20, 2022;
`
`$14,599,257.25 in United States currency formerly on deposit in Account
`Number 7801000254 at FV Bankheld in the name of “Himalaya
`International Clearing, Ltd.,” seized by the Governmenton or about
`September 20, 2022;
`
`k,
`
`$12,620,625.39 in United States currency formerly on deposit in Account
`Number MBI10103-0000 at Mercantile Bank International held in the
`nameof “G Club International Ltd.,” seized by the Government on or
`about October 16, 2022;
`
`

`

`Case 1:23-cr-00118-AT Document 488 Filed 01/07/25 Page 4 of 15
`Case 1:23-cr-00118-AT Document 488
`Filed 01/07/25
`Page 4of15
`
`I.
`
`m.
`
`n.
`
`0.
`
`p.
`
`q.
`
`r.
`
`S.
`
`$10,008,284.04 in United States currency formerly on deposit in Account
`Number MBI10133-0000 at Mercantile Bank International held in the
`name of “Himalaya International Clearing Ltd.,” seized by the
`Government between on or about October 16, 2022 and on or about March
`10, 2023;
`
`$3,090,856.54 in United States currency formerly on deposit in Account
`Number MBI10137-0000 at Mercantile Bank International held in the
`name of “Hamilton Capital Holding Ltd.,” seized by the Government
`between on or about October 16, 2022 and on or about March 10, 2023;
`
`$272,350,429.22 in United States currency formerly on deposit in Account
`Number MBI10138-0000 at Mercantile Bank International held in the
`nameof “Himalaya International Reserves Ltd.,” seized by the
`Government between on or about October 16, 2022 and on or about March
`10, 2023;
`
`$310,594.31 in United States currency formerly on deposit in Account
`Number MBI10139-0000 at Mercantile Bank International held in the
`name of “Himalaya International Financial Group Ltd.,” seized by the
`Government between on or about October 16, 2022 and on or about March
`10, 2023;
`
`$1,187,278.87 in United States currency formerly on deposit in Account
`Number MBI10171-0000 at Mercantile Bank International held in the
`name of “Hamilton Investment Management Ltd.,” seized by the
`Government between on or about October 16, 2022 and on or about March
`10, 2023;
`
`$47,888.50 in United States currency formerly on deposit in Account
`Number MBI10172-0000 at Mercantile Bank International held in the
`name of “G Fashion International Limited,” seized by the Government on
`or about October 16, 2022;
`
`$7,715.00, in United States currency formerly on deposit in Account
`Number7801000589 at FV Bank held in the name of “Himalaya
`International Financial Group, Ltd.,” seized by the Government on or
`about September 20, 2022;
`
`$176,983.37 in United States currency formerly on deposit in Account
`Number MBI10183-0000 at Mercantile Bank International held in the
`nameof “Himalaya Currency Clearing Pty Ltd.,” seized by the
`Governmenton or about October 16, 2022;
`
`

`

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`$2,745,377.75 in United States currency formerly on deposit in Account
`Number 9878904409 at Manufacturers & Traders Trust Co. held in the
`name of “GETTR USA,Inc.,” seized by the Government on or about
`September18, 2022;
`
`$9,899,659.19 in United States currency formerly on deposit in Account
`Number 157525208185 at US Bank held in the name of “G Fashion,”
`seized by the Government on or about September18, 2022;
`
`£3,005 in poundssterling currency seized from the Defendant’s apartment
`by the Governmenton or about March 15, 2023;
`
`$1,180 Hong KongDollars seized from the Defendant’s apartment by the
`Government on or about March 15, 2023;
`
`¥600 Chinese Yuanseized from the Defendant’s apartment by the
`Government on or about March 15, 2023;
`
`$138,440.00 in United States currency seized from the Defendant’s
`apartment by the Governmenton or about March 15, 2023;
`
`All that lot or parcel of land, together with its buildings, appurtenances,
`improvements,fixtures, attachments, and easements,located at 675
`Ramapo Valley Road, Mahwah, New Jersey 07430, Parcel No. 3300021-
`03-00001-02 and described as Lot Number: 1.02 Block: 21.03 District: 33
`City, Municipality, Township: MAHWAH TWP(the “Subject Property”);
`
`A Bugatti Chiron Super Sport, bearing Vehicle Identification Number
`VF9SW3V3XNM795047seized by the Governmenton or about May 11,
`2023;
`
`A Lamborghini Aventador SVJ Roads, bearing Vehicle Identification
`Number ZHWUN6ZD2MLA10393 seized by the Governmenton or about
`March 15, 2023;
`
`A Rolls Royce Phantom EWB,bearing Vehicle Identification Number
`SCATT8C08MU206445 seized by the Government on or about March 20,
`2023;
`
`A 46m 2014 Feadship superyacht “Lady May” (ex Como), bearing IMO
`Number 112359, MMSI Number319059500, and Callsign ZGDQ9;
`
`The following personal property seized by the Government from the
`Subject Property on or about March 15, 2023:
`
`aa,
`
`bb.
`
`ce.
`
`dd.
`
`ee.
`
`

`

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`i. A Bosendorfer 185VC Porsche #49539 piano with custom bench;
`
`ii. A Railis Design Iceland Contemporary Poseidon Bed with
`Nightstands, Ebony Veneer, Brass, Velvet;
`
`iii. A Histens 2000T md mattress;
`
`iv. A Hastens 2000T sf mattress;
`
`v. A Wembe watch storage box;
`
`vi. A Samsung Q900 Series QN98Q900RBF 98” QLED Smart TV — 8K;
`
`vii. A LouisXV Style French Ormolu-Mounted Mahogany Commodeby
`Joseph Emmanuel Zweiner;
`
`A “K’ang Hsi” extensiontable in etched and patinated pewter and
`viii.
`bronze with hand-painted enamel colors by Philip & Kelvin LaVerne;
`
`ix. A “Punto ‘83”table in stainless steel with mesh tabletop with
`adjustable height and adjustable petals by Gabriella Crespi, Italy 1982;
`
`x. Philip and Kelvin LaVerne Still Life Musicale 1960s bronze wall
`plaque with colored enamel;
`
`xi. Philip and Kelvin LaVerne Venus Contemplating 1960s bronze wall
`plaque with colored enamel;
`
`xii. Philip and Kelvin LaVerne Chinoi Plaque #14 limited edition 1960s
`bronze and pewterplaque;
`
`Baroque Style Carved Gilt Wood Frame,late 19th Century 44.75"
`xiii.
`X 38.5";
`
`xiv.
`
`Pair of ormolu-mounted display cabinets in the style of Francois
`Linke;
`
`xv. Ormolu mounted single doorvitrine with curved glass sides and front,
`resting on hooffeet;
`
`xvi.
`
`Ornate wroughtiron table with inlaid marble top. Book matched
`center cartouche, black outline;
`
`Philip and Kelvin LaVerne Special Eternal Forest Game Table
`xvii.
`labeled on underside bronze and pewter;
`
`

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`xviii. Philip and Kelvin LaVerne Marriage Whirl oriental motif
`boomerang shaped bronze, pewter, and enamel;
`
`xix.
`
`Philip and Kelvin LaVerne Eternal Forest Cocktail Table bronze
`and pewter with colored enamel;
`
`xx. Pair of Sévres-style porcelain jardiniere/vases having white ground
`with gold accents, ormolu mounts;
`
`xxi.
`
`A Sévres-style porcelain jardiniere/vase having a dark blue ground
`with gold accents, ormolu mounts;
`
`Pair of Louis XVIstyle giltwood console tables with white marble
`xxii.
`tops. H-37.5" x W-6;
`
`xxili. Pair of octagonal marble pedestals, white with gray veins. H-32" x
`Diameter-23";
`
`xxiv. Louis XV style French table desk, ormolu mounted marquetry,
`with leather top;
`
`Philip and Kelvin LaVerne Festival Console with waterfall ends,
`xxv.
`signed on the top 1960s;
`
`xxvi. Philip and Kelvin LaVerne Special Festival Console with waterfall
`ends, signed on the top 1960s;
`
`xxvii. Philip and Kelvin LaVerne Kuan Su Coffee Table bronze and
`pewter/silver-tone metal top with floral;
`
`xxviii. Philip and Kelvin LaVerne Chan round bronze, pewter, and
`enamel table with Chinese motif;
`
`xxix. Regencystyle cerule x-base footstools with paw feet, red velvet
`upholstery, and fringe;
`
`Earlier 20th c. Bar Cabinet with sterling silver mounted vertical
`xxx.
`stiles, cartouches, andball;
`
`1960s Maison Jansen style French brass, black patina, and smoked
`xxxi.
`glass coffee table;
`
`xxxii. French ormolu mounted marquetry inlaid table desk with single
`frieze drawer. Finished front and back;
`
`

`

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`xxxiii. Pair of French Empirestyle gilt and patinated bronze ormolu
`mounted tables with black marble tops;
`
`xxxiv. Empire-style center table with book-matched flamed veneertop;
`
`Jansen Style Two-tier Bouillotte Table on fluted tripod pedestal
`xxxv.
`with ormolu mounts, marble top;
`
`xxxvi. Boulle-style Bureau Plat silver and gold metal scrolling design
`table desk inlaid with tortoiseshell;
`
`xxxvii. Tabriz, from Iran, modern production. 13' 8" x 20'. Quality: 45 raj.
`Cotton warp and weft;
`
`Bidjar, from Iran, first quarter of the 20th c. 14'5" x 19' 7".
`XXXVili.
`Woolweft, cotton warp;
`
`xxxix. Bidjar, from Iran, late 19th - early 20th c. 12'3" x 19'. Wool warp
`and weft, woolface;
`
`xl. Pair of mid-19th c. Louis XV style paraclose mirrors, floral;
`
`xli. Italian Tuscan antique giltwood mirror with plume-toppedurnfinial;
`
`xlii.
`
`Two (2) Regencystyle giltwood mirrors with urn andfloral finial;
`
`xliii.. Giltwood Louis XV style overmantel double mirror;
`
`xliv.
`
`Two (2) Italian Neoclassical giltwood pier mirrors;
`
`xlv._Pairof Italian Florentine style giltwood mirrors each with a plume;
`
`Italian giltwood mirror with rococo crest with cross-hatched
`xlvi.
`panels;
`
`xlvii. Pair of French Régencestyle giltwood mirrors,the crest with a
`plume;
`
`xlviii. Pair of giltwood mirrors each with a plumed maskcrest;
`
`Pair of Empire 19th c. gilt bronze floor torcheres embellished with
`xlix.
`lion masks draped;
`
`

`

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`1. Pair of 18-light Baccarat Torcheres. H-95" x W-26". Dimensionsare
`approximate;
`
`li. 19th c Silver and tortoiseshell mounted table cabinet, with enamel
`inset;
`
`lii. Pair of small figural patinated black and gilt bronze candlesticks;
`
`liii. Pair of gilt bronze chenet with obelisk, lion mask, dolphin;
`
`liv. Pair of marble pedestals having a square top, round column;
`
`lv. Pair of Regency style bronze patinated torcheres, attributed to English
`lamp manufacturer;
`
`lvi. Late Georgian Chippendale style hexagonal center table with cabriole
`legs and hairy paw andball;
`
`Philip and Kelvin LaVerne Chan elongated hexagonaltable,
`Ivii.
`mottled bronze on the top, bronze;
`
`Philip and Kelvin LaVerne Chan hexagonal pedestal, bronze on the
`lviii.
`top, bronze and pewter Chinese;
`
`lix. Philip and Kelvin LaVerne Les Chine Cocktail Table square mottled
`bronze top supported;
`
`Ix. Persian Silk Tabriz Rug, 7'7" x 11'2" located on 2nd Floor of the
`Subject Property;
`
`Ixi. Louis XV style giltwood pier mirror;
`
`Ixii.
`
`Pair of Louis XVstyle giltwood mirrors;
`
`Ixiii.
`
`Italian Tuscan giltwood mirror;
`
`French giltwood paraclose mirror with Louis XVIstyle floral
`Ixiv.
`wreath;
`
`Ixv.
`
`Chinese Chippendale Giltwood double parclose mirror;
`
`Louis XV style giltwood paraclose mirror (double frame) with
`Ixvi.
`shell and wavecrest;
`
`

`

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`Page 10of15
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`Ixvii. French Brass Three Panel Firescreen with Empire style swags and
`wreaths;
`
`Ixviii. Ferdinand Barbedienne (1810 - 1892) French Three-Piece Clock
`Garniture;
`
`lxix.
`
`Pair of Victorian urn and swag chenet H-18" x W-16" x D-6";
`
`Ixx.
`
`Pair of Louis XV style gilt bronze and brass andirons depicting
`cherubs;
`
`Ixxi.
`
`Louis XV style gilt bronze 'log cradle’;
`
`Ixxii. Pair of gilt bronze Louis XV style chenets;
`
`Ixxiii. French Tapestry Size 6'8" x 9'5"located on the 3rd Floorof the
`Subject Property;
`
`Ixxiv. Antique Chinese Export Cast Brass Pair of Foo Dogs;
`
`Ixxv.
`
`$9,895.00 in United States currency;
`
`Ixxvi. $1,000.00 in United States currency;
`
`Ixxvii. A ring with box;
`
`Ixxviii. A bracelet with box;
`
`Ixxix. $1,300.00 in United States currency;
`
`Ixxx.
`
`$394,040.00 in United States currency;
`
`Ixxxi. Yellow coins;
`
`Ixxxii. 5,000 Euros;
`
`Ixxxiii. $188,050 Hong Kongdollars;
`
`Ixxxiv. 250 Chinese Yuan;
`
`ff.
`
`88.
`
`$2,815,502.30 in United States currency formerly held in TD Bank N.A.
`account 440-549 1468; and
`
`$4,357,924.95 in United States currency formerly held in TD Bank N.A.
`account 440-5492044;
`
`

`

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`(a. through gg., collectively, the “Specific Property”), as constituting proceeds of the offenses
`
`charged in Count One that the Defendant personally obtained and/or property involved in the
`
`offense charged in Count Two ofthe Information;
`
`WHEREAS, the Defendant admits that, as a result of acts and/or omissions ofthe
`
`Defendant, the proceedstraceable to the offenses charged in Count Oneof the Information that the
`
`Defendantpersonally obtained and property involved in Count Twoof the Information cannot be
`
`located upon the exercise of due diligence, with the exception of the Specific Property; and
`
`WHEREAS,pursuantto Title 21, United States Code, Section 853(g), and Rules
`
`32.2(b)(3), and 32.2(b)(6) of the Federal Rules of Criminal Procedure, the Government is now
`
`entitled, pending any assertion of third-party claims, to reduce the Specific Property to its
`
`possession andto notify any andall persons who reasonably appear to beapotential claimant of
`
`their interest herein;
`
`IT IS HEREBY STIPULATED AND AGREED,by and between the United States
`
`of America, by Daniel Gitner, Attorney for the United States, Acting under Authority Conferred
`
`by 28 U.S.C. § 515, Assistant United States Attorneys Juliana N. Murray, Micah F. Fergenson,
`
`Ryan B. Finkel, and Justin R. Horton, of counsel, and the Defendant and his counsel, Brendan
`
`Quigley, Esq., that:
`
`1.
`
`As a result of the offenses charged in Counts One and Two of the
`
`Information,
`
`to which the Defendant pled guilty, a money judgment
`
`in the amount of
`
`approximately $1.4 billion in United States currency (the “Money Judgment”), representing the
`
`amount of proceeds traceable to the offense charged in Count One of the Information that the
`
`Defendantpersonally obtained and property involvedin the offense charged in Count Twoofthe
`
`

`

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`Information, for which the Defendantis jointly and severally liable with the Co-defendant, to the
`
`extent a forfeiture money judgment is entered against the Co-defendant in this case, shall be
`
`entered against the Defendant.
`
`2.
`
`As a result of the offenses charged in Counts One and Two of the
`
`Information, to which the Defendantpledguilty, all of the Defendant’s right, title and interest in
`the Specific Property is hereby forfeited to the United States for disposition in accordance with the
`
`law, subject to the provisions of Title 21, United States Code, Section 853.
`
`3.
`
`Pursuant to Rule 32.2(b)(4) ofthe Federal Rules of Criminal Procedure,this
`
`Consent Preliminary Order of Forfeiture as to Specific Property/Money Judgmentis finalas to the
`
`Defendant, YVETTE WANG,andshall be deemedpart ofthe sentence ofthe Defendant, and shall
`
`be included in the judgment of conviction therewith.
`
`4,
`
`All payments on the outstanding money judgment shall be made by postal
`
`money order, bank or certified check, made payable, in this instance, to the United States Marshals
`
`Service, and delivered by mail to the United States Attorney’s Office, Southern District of New
`
`York, Attn: Illicit Finance and Money Laundering Unit, 26 Federal Plaza, 38" Floor, New York,
`
`New York 10278 andshall indicate the Defendant’s name and case number.
`
`5.
`
`The United States Marshals Service is authorized to deposit the payments
`
`on the Money Judgmentin the Assets Forfeiture Fund, and the United States shall have cleartitle
`
`to such forfeited property.
`
`6.
`
`Upon entry of this Consent Preliminary Order of Forfeiture as to Specific
`
`Property/Money Judgment, the United States (or its designee) is hereby authorized to take
`
`possession of the Specific Property and to hold such property in its secure custody andcontrol.
`
`

`

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`Page 13 of15
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`7.
`
`Pursuantto Title 21, United States Code, Section 853(n)(1), Rule 32.2(b)(6)
`
`of the Federal Rules of Criminal Procedure, and Rules G(4)(a)(iv)(C) and G(5)(a)(ii) of the
`
`Supplemental Rules for Certain Admiralty and Maritime Claims and Asset Forfeiture Actions, the
`
`United States is permitted to publish forfeiture notices on the government
`
`internet site,
`
`www.forfeiture.gov. This site incorporates the forfeiture notices that have been traditionally
`
`published in newspapers. The United States forthwith shall publish the internet ad for at least thirty
`
`(30) consecutive days. Any person, other than the Defendant, claiming interest in the Specific
`
`Property mustfile a Petition within sixty (60) days from thefirst day of publication of the Notice
`
`on this official governmentinternet web site, or no later than thirty-five (35) days from the mailing
`
`of actual notice, whicheveris earlier.
`
`8.
`
`The published notice of forfeiture shall state that the petition (i) shall be for
`
`a hearing to adjudicate the validity of the petitioner’s alleged interest in the Specific Property,(ii)
`
`shall be signed by the petitioner under penalty of perjury, and(iii) shall set forth the nature and
`
`extentof the petitioner’s right,title or interest in the Specific Property, the time and circumstances
`
`of the petitioner’s acquisition of the right,title and interest in the Specific Property, any additional
`
`facts supporting the petitioner’s claim, and the relief sought, pursuant to Title 21, United States
`
`Code, Section 853(n).
`
`9.
`
`Pursuant to 32.2 (b)(6)(A) of the Federal Rules of Criminal Procedure, the
`
`Government shall send notice to any person who reasonably appears to be a potential claimant
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`with standing to contest the forfeiture in the ancillary proceeding.
`
`10.
`
`Upon adjudication ofall third-party interests, this Court will enter a Final
`
`Order of Forfeiture with respect to the Specific Property pursuant to Title 21, United States Code,
`
`Section 853(n), in which all interests will be addressed. All Specific Property forfeited to the
`
`

`

`Case 1:23-cr-00118-AT Document 488 Filed 01/07/25 Page 14 of 15
`Case 1:23-cr-00118-AT Document 488
`Filed 01/07/25
`Page 14of15
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`United States under a Final Order of Forfeiture shall be applied towards the satisfaction of the
`
`Money Judgment.
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`11.
`
`Pursuant to Title 21, United States Code, Section 853(p), the United States
`
`is authorized to seek forfeiture of substitute assets of the Defendant up to the uncollected amount
`
`of the Money Judgment.
`
`12.
`
`Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the
`
`United States Attorney’s Office is authorized to conduct any discovery neededto identify, locate
`
`or dispose of forfeitable property, including depositions, interrogatories, requests for production
`
`of documents and the issuance of subpoenas.
`
`13.
`
`The Court shall retain jurisdiction to enforce this Consent Preliminary Order
`
`of Forfeiture as to Specific Property/Money Judgment, and to amendit as necessary, pursuant to
`
`Rule 32.2 of the Federal Rules of Criminal Procedure.
`
`[REMAINDER OF PAGE LEFT INTENTIONALLY BLANK]
`
`

`

`Case 1:23-cr-00118-AT Document 488 Filed 01/07/25 Page 15 of 15
`Case 1:23-cr-00118-AT Document 488
`Filed 01/07/25
`Page 15of15
`
`14.
`
`The signature page of this Consent Preliminary Order of Forfeiture as to
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`Specific Property/Money Judgment may be executed in one or more counterparts, each of which
`
`will be deemedan original but all of which together will constitute one and the same instrument.
`
`AGREED AND CONSENTED TO:
`
`DANIEL GITNER
`Attorney for the United States
`Acting under Authority Conferred by 28 U.S.C. § 515
`
`nba /
`By: fi ym fin €
`
`JULIANA N. MURRAY
`RYAN B. FINKEL
`MICAH F. FERGENSON
`JUSTIN R. HORTON
`Assistant United States Attorneys
`26 Federal Plaza
`New York, NY 10278
`(212) 637-2314 / -6612 / -2190 / -2276
`
`YVETTE WANG
`
`By: ae —.,
`
`YVETTE WANG
`\
`
`wy, LSE
`
`BRENDAN QUIGLEY, ESQ.
`Attorney for Defendant
`Baker Botts LLP
`30 Rockefeller Plaza
`New York, NY 10112
`
`SO ORDERED:
`
`HONORABLE ANALISA TORRES
`UNITED STATES DISTRICT JUDGE
`
`j,
`[/4/ 2F
`
`AT
`
`[6/202
`
`DATE
`
`[oles
`
`DATE
`
`1/6/2025
`
`DATE
`
`