Case 1:23-cr-00585-JSR Document 39 Filed 07/16/24 Page 1 of 4
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`X
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`UNITED STATES OF AMERICA
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`- v. -
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`CONSENT PRELIMINARY ORDER
`OF FORFEITURE/
`MONEY nJDGMENT
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`KAKHA KA TSADZE,
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`23 Cr. 585 (JSR)
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`Defendant.
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`X
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`WHEREAS, on or about November 8, 2023, KAKHA KATSADZE (the
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`"Defendant"), among others, was charged in a Sealed Indictment, 23 Cr. 585 (JSR) (the
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`"Indictment"), with conspiracy to commit Hobbs Act extortion, in violation of Title 18, United
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`States Code, Section 1951 (Count One); and Hobbs Act extortion, in violation of Title 18, United
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`States Code, Sections 1951 and 2 (Count Two);
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`WHEREAS, the Indictment included a forfeiture allegation as to Counts One and
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`Two of the Indictment, seeking forfeiture to the United States, pursuant to Title 18, United States
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`Code, Section 981(a)(l)(C) and Title 28, United States Code, Section 2461(c), of any and all
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`property, real and personal, that constitutes or is derived from proceeds traceable to the
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`commission of the offenses charged in Counts One and Two of the Indictment, including but not
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`limited to a sum of money in United States currency representing the amount of proceeds traceable
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`to the commission of the offenses char~ _in Coun~s
`~\y\t
`~ WHEREAS, on or about li..m@ 2-1 , 20
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`e and Two of the Indictment;
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`the Defendant pied guilty to Count Two of
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`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 Two of the Indictment and agreed to forfeit
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`to the United States, pursuant to Title 18, United States Code, Section 981 (a)(l )(C) and Title 28,
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`United States Code, Section 246l(c), a sum of money equal to $19,000 in United States currency,
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`Case 1:23-cr-00585-JSR Document 39 Filed 07/16/24 Page 2 of 4
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`representing the proceeds traceable to the commission of the offense charged in Count Two of the
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`Indictment;
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`WHEREAS, the Defendant consents to the entry of a money judgment in the
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`amount of$19,000 in United States currency, representing the amount of proceeds traceable to the
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`offense charged in Count Two of the Indictment that the Defendant personally obtained, for which
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`the Defendant is jointly and severally liable with co-defendants Vazha Gabadadze a/k/a ''Natan
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`Yusupov," Teimuraz Tavberidze a/k/a "Tava," and Davit Tikaradze a/k/a "Dato," (the "Co(cid:173)
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`defendants") to the extent forfeiture money judgments are entered against the Co-defendants in
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`this case; and
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`WHEREAS, the Defendant admits that, as a result of acts and/or omissions of the
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`Defendant, the proceeds traceable to the offense charged in Count Two 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 and between the United States
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`of America, by its attorney Damian Williams, United States Attorney, Assistant United States
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`Attorneys Varun A. Gumaste and Chelsea L. Scism, of counsel, and the Defendant and his counsel,
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`Tony Mirvis, Esq., that:
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`1.
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`As a result of the offense charged in Count Two of the Indictment, to which
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`the Defendant pied guilty, a money judgment in the amount of $19,000 in United States currency
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`(the "Money Judgment"), representing the amount of proceeds traceable to the offense charged in
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`Count Two of the Indictment that the Defendant personally obtained, for which the Defendant is
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`jointly and severally liable with the Co-defendants to the extent forfeiture money judgments are
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`entered against the Co-defendants in this case, shall be entered against the Defendant.
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`Case 1:23-cr-00585-JSR Document 39 Filed 07/16/24 Page 3 of 4
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`1
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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 Judgment is final as to the Defendant KAKHA
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`KA TSADZE, and shall be deemed part of the sentence of the Defendant, and shall be included in
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`the judgment of conviction therewith.
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`3.
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`All payments on the outstanding money judgment shall be made by postal
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`money order, bank or 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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`York, Attn: Illicit Finance and Money Laundering Unit, 26 Federal Plaza, New York, New York
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`10278 and shall 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 Judgment into the Assets Forfeiture Fund, and the United States shall have clear
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`title 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 needed to 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 amend it as necessary, pursuant to Rule 32.2 of the Federal
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`Rules of Criminal Procedure.
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`Case 1:23-cr-00585-JSR Document 39 Filed 07/16/24 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 deemed an 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
`York
`Southern i ;tric~~
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`By: ~ : : : : : - :
`V ARUN A. GUMASTE
`CHELSEA L. SCISM
`Assistant United States Attorney
`26 Federal Plaza
`New York, NY 10007
`(212) 637-1023 /-2105
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`KAKHA KA TSADZE
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`µ£z
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`KAKHA KA TSADZE
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`By:
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`By:
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`TONYMIRVIS
`The Mirvis Law Firm, P.C.
`28 Dooley Street, 3rd Floor
`Brooklyn, NY 11235
`(718) 934-4141
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`SO ORDERED:
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`HONO ~ ~
`UNITED STATES DISTRICT JUDGE
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`1/lb(:i.~
`DATE
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`7 /lcJV)
`DATE
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