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    US v. Sullivan Indictment

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    Aaron Brecher
    Stephan Sullivan is charged with conspiracy to commit money laundering. From 2014 to 2016, Sullivan conspired with others to conduct financial transactions involving proceeds from unlawful drug distribution, intending to promote further drug trafficking and to conceal the source of the funds. If convicted, Sullivan will forfeit property involved in the conspiracy.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    US v. Sullivan Indictment

    Uploaded by

    Aaron Brecher
    99 views3 pages
    Stephan Sullivan is charged with conspiracy to commit money laundering. From 2014 to 2016, Sullivan conspired with others to conduct financial transactions involving proceeds from unlawful drug distribution, intending to promote further drug trafficking and to conceal the source of the funds. If convicted, Sullivan will forfeit property involved in the conspiracy.

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    D. Ore. 2018

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    Stephan Sullivan is charged with conspiracy to commit money laundering. From 2014 to 2016, Sullivan conspired with others to conduct financial transactions involving proceeds from unlawful drug distribution, intending to promote further drug trafficking and to conceal the source of the funds. If convicted, Sullivan will forfeit property involved in the conspiracy.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    99 views3 pages

    US v. Sullivan Indictment

    Uploaded by

    Aaron Brecher
    Stephan Sullivan is charged with conspiracy to commit money laundering. From 2014 to 2016, Sullivan conspired with others to conduct financial transactions involving proceeds from unlawful drug distribution, intending to promote further drug trafficking and to conceal the source of the funds. If convicted, Sullivan will forfeit property involved in the conspiracy.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Case 3:18-cr-00183-MO Document 1 Filed 04/24/18 Page 1 of 3

    UNITED STATES DISTRICT COURT

    DISTRICT OF OREGON

    PORTLAND DIVISION

    UNITED STATES OF AMERICA

    v. INFORMATION

    STEPHAN SULLIVAN, 18 u.s.c. § 1956(h)

    Defendant. Forfeiture Allegation

    THE UNITED STATES A,LLEGES:

    COUNT ONE
    (Conspiracy to Commit the Laundering of Monetary Instruments)
    (18 u.s.c. § 1956(h))

    Beginning on or about January 1, 2014 and continuing until October 1, 2016, within the

    District of Oregon, the Northern District of Georgia, and elsewhere, STEPHAN SULLIVAN,

    defendant herein, did knowingly combine, conspire, and agree with "A.K." and other persons

    known and unknown to the government, to commit offenses against the United States in

    violation of Title 18, United States Code, Section 1956, to wit: knowingly conduct and attempt

    to conduct financial transactions affecting interstate and foreign commerce, which involved the

    proceeds of a specified unlawful activity, that is Unlawful Distribution of a Controlled

    Substance, (1) with the intent to promote the carrying on of specific unlawful activity, that is

    Unlawful Distribution of a Controlled Substance, and (2) knowing that the transaction was

    designed in whole and in part to conceal and disguise the nature, location, source, ownership,
    Case 3:18-cr-00183-MO Document 1 Filed 04/24/18 Page 2 of 3

    and control of the proceeds of specified unlawful activity, that is Unlawful Distribution of a

    Controlled Substance, and that while conducting and attempting to conduct such financial

    transactions knew that the property involved in the financial transaction represented the proceeds

    of some form of unlawful activity in violation of Title 18, United States Code, Sections

    1956(a)(l )(A)(i), (a)(l )(B)(i), and 2.

    All in violation of Title 18, United States Code, Section 1956(h).

    FORFEITURE ALLEGATION

    Upon conviction of the offense alleged in Count One of this Information, STEPHAN

    SULLIVAN, defendant herein, shall forfeit to the United States pursuant to 18 U.S.C.

    § 982(a)(l), any and all property, real or personal, involved in the money laundering offense and

    all property traceable to such property, including but not limited to a money judgment for a sum

    of money equal to the amount of property involved in the money laundering conspiracy as

    alleged in Count One.

    SUBSTITUTE ASSETS

    If any of the above-described forfeitable property listed in Count One, 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, pursuant to 21 U .S.C. § 853(p) as incorporated by 18 U .S.C.

    Information, U.S. v. Stephan Sullivan Page2


    Case 3:18-cr-00183-MO Document 1 Filed 04/24/18 Page 3 of 3

    § 982(b), to seek forfeiture of any other property of said defendant up to the value of the

    forfeitable property described in these forfeiture allegations.


    ;.
    DATED this 2 t.J- day of April 2018.

    Presented by:

    BILLY J. WILLIAMS
    United States Attorney

    STEVEN T. MYGRANT, #031293


    Assistant United States Attorney

    JULIA E. JARRETT
    Assistant United States Attorney

    Information, U.S. v. Stephan Sullivan Page3

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