Case :-cr-00-pmp-pal Document Filed 0/0/ Page of DANIEL G. BOGDEN United States Attorney Nevada Bar No. U.S. Attorney s Office Las Vegas Boulevard South, Suite000 Las Vegas, Nevada Telephone: 0-- Facsimile: 0-- Email: cristina.silva@usdoj.gov Attorneys for the United States UNITED STATES DISTRICT COURT DISTRICT OF NEVADA UNITED STATES OF AMERICA, v. Plaintiff, EMMANOUIL VARAGIANNIS, (aka Manny Varagiannis, Defendant. :-CR--PMP-(PAL 0 BILL OF PARTICULARS FOR FORFEITURE OF PROPERTY The United States of America, by and through Daniel G. Bogden, United States Attorney for the District of Nevada, and Cristina D. Silva,, hereby files the following Bill of Particulars for Forfeiture of Property. This Bill of Particulars for Forfeiture of Property is a clarification of, and is more specific than, the Forfeiture Allegation of the Criminal Indictment, and the United States hereby gives notice to the Defendant of this clarification and specificity with this Bill of Particulars concerning the Forfeiture of Property:
Case :-cr-00-pmp-pal Document Filed 0/0/ Page of 0 FORFEITURE ALLEGATION ONE (Structuring Financial Transactions to Evade Reporting Requirements. The allegations contained in Count One of the Criminal Indictment are hereby realleged and incorporated herein by reference for the purpose of alleging forfeiture pursuant to Title, United States Code, Section (c(.. Upon conviction of the felony offense charged in Count One of the Criminal Indictment, EMMANOUIL VARAGIANNIS (aka Manny Varagiannis, defendant herein, shall forfeit to the United States of America, all property, real or personal, involved in violations of Title, United States Code, Sections (a and (a(, and any property traceable thereto, or a conspiracy to commit such violations, an in personam criminal forfeiture money judgment of $,0,0.00 in United States Currency, including: Real property located at Bellota Drive, Las Vegas, Nevada, described as follows: Lot Seventeen ( in Block One ( of Sierra Oeste, as shown by Map thereof on file in Book, of Plats, Page in the Office of the County Recorder of Clark County, Nevada. Parcel ID: ---0; described as follows: Real property located at Red Rock Street, #, Las Vegas, Nevada, Parcel I: Unit A in Building of Redrock Park Subdivision, a condominium subdivision filed pursuant to the provisions of N.R.S..00 recorded in Book of Plats, Page, in the Official Records of the County Recorder, Clark County, Nevada and as defined in the that certain Declaration of Restrictions (Enabling Declaration establishing a plan for condominium ownership of Redrock Park Subdivision recorded November, in Book 0 of Official Records, Clark County, Nevada, as Document No..
Case :-cr-00-pmp-pal Document Filed 0/0/ Page of 0 Parcel II: An undivided / interest in and to the common area shown as common area Phase upon the Plat of Redrock Park Subdivision filed pursuant to the provisions of N.R.S..00 recorded in Book of Plats, Page, in the Official Records of the County Recorder, Clark County, Nevada and as defined in that certain Declaration of Restrictions (Enabling Declaration establishing a plan for condominium ownership of Redrock Park Subdivision recorded November, in Book 0 of Official Records, Clark County, Nevada as Document No.. Parcel III: A non-exclusive easement for ingress and egress, public utilities and private streets shown over Lot A (The Recreation Area and common areas Phase One ( and Two ( of the condominium project, as shown upon the Plat of Redrock Park Subdivision filed pursuant to the provisions of N.R.S..00 recorded in Book of Plats, Page, in the Official Records of the County Recorder, Clark County, Nevada and as defined in that certain Declaration of Restrictions (Enabling Declaration establishing a plan for condominium ownership of Redrock Park Subdivision recorded November, in Book 0 of Official Records, Clark County, Nevada as Document No.. Parcel IV: An exclusive easement to use that portion of the Common Area designated as Parking Space No. -A, as shown upon the Plat of Redrock Park Subdivision filed pursuant to the provisions of N.R.S..00 recorded in Book of Plats, Page, in the Official Records of the County Recorder, Clark County, Nevada and as defined in that certain Declaration of Restrictions (Enabling Declaration establishing a plan for condominium ownership of Redrock Park Subdivision
Case :-cr-00-pmp-pal Document Filed 0/0/ Page of 0 Parcel ID: --0-0. ( property. recorded November, in Book 0 of Official Records, Clark County, Nevada as Document No.. $,. in United States Currency; $,. in United States Currency; and $,.00 in United States Currency. If any property being subject to forfeiture pursuant to Title, United States Code, Section (c(, as a result of any act or omission of the defendant a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party; c. has been placed beyond the jurisdiction of the court; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States of America, pursuant to Title, United States Code, Section (p, to seek forfeiture of any properties of the defendants for the in personam criminal forfeiture money judgment of $,0,0.00 in United States Currency. All pursuant to Title, United States Code, Sections (a, (a(, and (c(; and Title, United States Code, Section (p. Dated this th day of June, 0. Respectfully submitted, DANIEL G. BOGDEN United States Attorney /s/ Cristina D. Silva
Case :-cr-00-pmp-pal Document Filed 0/0/ Page of PROOF OF SERVICE I, Cristina D. Silva, certify that the following individuals were served with copies of the Bill of Particulars for Forfeiture of Property on June, 0 by the below identified method of service: CM/ECF David T. Brown Brown, Brown & Premsrirut 0 S. Fourth Street, nd Floor Las Vegas, NV Email: master@brownlawlv.com Counsel for Emmanouil Varagiannis Richard A. Wright Wright Stanish & Winckler 00 S. Fourth Street, Suite 0 Las Vegas, NV Email: rick@wswlawlv.com Counsel for Emmanouil Varagiannis /s/ Cristina D. Silva 0