Documents
Indictment in U.S. vs. Hall and Landersman
Oct. 15, 2014
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 1 of 11 PageID# 810
,
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IMOPF^cpllfiT
IN THE UNITED STATES DISTRICT COURT FOR THE
I 3 2i;i4
EASTERN DISTRICT OF VIRGINIA
'; '.' ' < .>!»-.!(,/ i (tor
Alexandria Division
Criminal No: l:13cr419
UNITED STATES OF AMERICA
Count 1: 18 U.S.C. § 371
(Conspiracy)
LEE HALL,
(Counts 1 and 2)
Count 2: 18 U.S.C. §§ 641 and 2
(Theft of Government Money)
and
MARK STUART LANDERSMAN,
a.k.a. Mark Stuart,
(Count 1)
Forfeiture
Defendants
SUPERSEDING INDICTMENT
March 2014 Term - At Alexandria
COUNT ONE
(Conspiracy)
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At All Times Relevant to This Indictment:
1.
The defendant, MARK STUART LANDERSMAN, a.k.a. Mark Stuart, resided and
owned businesses in Temecula, California. Businesses associated with LANDERSMAN include
Advanced Machining and Engineering (AME), Fourth Street Automotive, Fourth Street Racing,
and American Manufacturing and Consulting. LANDERSMAN was the President of AME.
2. LEE HALL and at least one other conspirator were civilian employees of the
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 1 of 11 PageID# 810
,
IHi!)
IMOPF^cpllfiT
IN THE UNITED STATES DISTRICT COURT FOR THE
I 3 2i;i4
EASTERN DISTRICT OF VIRGINIA
'; '.' ' < .>!»-.!(,/ i (tor
Alexandria Division
Criminal No: l:13cr419
UNITED STATES OF AMERICA
Count 1: 18 U.S.C. § 371
(Conspiracy)
LEE HALL,
(Counts 1 and 2)
Count 2: 18 U.S.C. §§ 641 and 2
(Theft of Government Money)
and
MARK STUART LANDERSMAN,
a.k.a. Mark Stuart,
(Count 1)
Forfeiture
Defendants
SUPERSEDING INDICTMENT
March 2014 Term - At Alexandria
COUNT ONE
(Conspiracy)
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At All Times Relevant to This Indictment:
1.
The defendant, MARK STUART LANDERSMAN, a.k.a. Mark Stuart, resided and
owned businesses in Temecula, California. Businesses associated with LANDERSMAN include
Advanced Machining and Engineering (AME), Fourth Street Automotive, Fourth Street Racing,
and American Manufacturing and Consulting. LANDERSMAN was the President of AME.
2. LEE HALL and at least one other conspirator were civilian employees of the
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 2 of 11 PageID# 811
Department of Navy who worked at a government office in the Eastern District of Virginia, and
who resided in the Eastern District of Virginia.
3. MARK STUART LANDERSMAN was not licensed by the Bureau of Alcohol,
Tobacco, Firearms, and Explosives (ATF) to manufacture and sell firearms, nor had he appliedwith
ATF for a license to manufacture and sell firearms. LANDERSMAN had not paid any special
occupational taxes required for manufacturers and dealers of firearms, nor had he registered as a
dealer and manufacturer of firearms.
4. CACI Incorporated is a government contract company headquartered in Arlington,
Virginia, in the Eastern District of Virginia.
THE CONSPIRACY
From in and around 2011 through in and around July 2013, in the Eastern District of
Virginia and elsewhere, the defendants, LEE HALL and MARK STUART LANDERSMAN,
knowingly combined, conspired, confederated and agreed together and with others, known and
unknown to the grand jury, to commit the following offenses against the United States of America:
(1) to willfully engage in the business of manufacturing and dealing in firearms, namely,
silencers, and in the course of such business did ship firearms in interstate commerce,
not being a licenseddealer and manufacturer of firearms within the meaning of Chapter
44, Title 18, United States Code, in violation of Title 18, United States Code, Section
922(a)(1)(A);
(2) to deliver firearms, namely silencers, in interstatecommerce which have not been
registered as required by the National Firearms Act in violation of Title 26, United
States Code, Section 58610);and
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 2 of 11 PageID# 811
Department of Navy who worked at a government office in the Eastern District of Virginia, and
who resided in the Eastern District of Virginia.
3. MARK STUART LANDERSMAN was not licensed by the Bureau of Alcohol,
Tobacco, Firearms, and Explosives (ATF) to manufacture and sell firearms, nor had he appliedwith
ATF for a license to manufacture and sell firearms. LANDERSMAN had not paid any special
occupational taxes required for manufacturers and dealers of firearms, nor had he registered as a
dealer and manufacturer of firearms.
4. CACI Incorporated is a government contract company headquartered in Arlington,
Virginia, in the Eastern District of Virginia.
THE CONSPIRACY
From in and around 2011 through in and around July 2013, in the Eastern District of
Virginia and elsewhere, the defendants, LEE HALL and MARK STUART LANDERSMAN,
knowingly combined, conspired, confederated and agreed together and with others, known and
unknown to the grand jury, to commit the following offenses against the United States of America:
(1) to willfully engage in the business of manufacturing and dealing in firearms, namely,
silencers, and in the course of such business did ship firearms in interstate commerce,
not being a licenseddealer and manufacturer of firearms within the meaning of Chapter
44, Title 18, United States Code, in violation of Title 18, United States Code, Section
922(a)(1)(A);
(2) to deliver firearms, namely silencers, in interstatecommerce which have not been
registered as required by the National Firearms Act in violation of Title 26, United
States Code, Section 58610);and
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 3 of 11 PageID# 812
(3) to cause a matter and thing, namely checks, to bedelivered bymail, for the purpose of
executing a scheme and artifice to defraud and for obtaining money by false and
fraudulent pretenses, representations, and promises, having devised a scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1341.
MANNER AND MEANS OF THE CONSPIRACY
The primary purpose of the conspiracy was to make money by manufacturing firearms,
specifically silencers, a.k.a. suppressors, and selling them to the government. The manner and
means bywhich the conspirators conducted the conspiracy included the following:
1.
It was partof the conspiracy thatmembers of the conspiracy played different
roles and took upon themselves different tasks to accomplish the objectives of the conspiracy.
2.
It was further partof theconspiracy thatmembers of the conspiracy sought,
facilitated, and received a government contract to make suppressors.
3.
It was further part of the conspiracy that members of the conspiracy
made false statements to avoid scrutiny, circumvent requirements, and receive a government
contract.
4.
It was furtherpart of the conspiracy that members of the conspiracy
arranged to have firearms, specifically suppressors, manufactured in California and shipped in
interstate commerce.
5.
It was further part of the conspiracy that members of the conspiracy made false
statements to receive paymentfor illegally manufactured and unregisteredfirearms.
6.
It was further part of the conspiracy that members of the conspiracy caused
checks to be delivered through the mail as payment for the manufacture of the firearms.
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(3) to cause a matter and thing, namely checks, to bedelivered bymail, for the purpose of
executing a scheme and artifice to defraud and for obtaining money by false and
fraudulent pretenses, representations, and promises, having devised a scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1341.
MANNER AND MEANS OF THE CONSPIRACY
The primary purpose of the conspiracy was to make money by manufacturing firearms,
specifically silencers, a.k.a. suppressors, and selling them to the government. The manner and
means bywhich the conspirators conducted the conspiracy included the following:
1.
It was partof the conspiracy thatmembers of the conspiracy played different
roles and took upon themselves different tasks to accomplish the objectives of the conspiracy.
2.
It was further partof theconspiracy thatmembers of the conspiracy sought,
facilitated, and received a government contract to make suppressors.
3.
It was further part of the conspiracy that members of the conspiracy
made false statements to avoid scrutiny, circumvent requirements, and receive a government
contract.
4.
It was furtherpart of the conspiracy that members of the conspiracy
arranged to have firearms, specifically suppressors, manufactured in California and shipped in
interstate commerce.
5.
It was further part of the conspiracy that members of the conspiracy made false
statements to receive paymentfor illegally manufactured and unregisteredfirearms.
6.
It was further part of the conspiracy that members of the conspiracy caused
checks to be delivered through the mail as payment for the manufacture of the firearms.
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OVERT ACTS
In furtherance of the conspiracy and to effect the objects thereof, the defendants and their
conspirators performed the following overt acts in the Eastern District of Virginia andelsewhere:
1.
In and around April 2011, MARK STUART LANDERSMAN sent an
email to a conspirator in which he referenced an MK15 sustainable suppressor proposal.
2.
On or about June 6,2012, a conspirator sent an email from his governmentemail
account to a Department of Navy official, requesting a three million dollars ($3,000,000)
supplement to the operational budgetof the Deputy Undersecretary of the Navy (DUSN) Plans,
Policy, Oversight and Integration (PPOI) Intelligence Directorate to conduct studies, research,
assessments, and analysis.
3.
On or about August 13,2012, a conspirator sent an email to MARK
STUART LANDERSMAN requesting the proper name of his company.
4.
On or about August 14,2012, MARKSTUART LANDERSMAN sent an email
to a conspirator's government email, providing his company name as "Advanced Machining and
Engineering," as well as a telephone number and company website.
5.
On or about August 14,2012, a conspirator, via his government
email, forwarded MARK STUART LANDERSMAN'S email containing the company information
to LEE HALL's government email.
6.
On or about August 14,2012, a conspirator sent an email, via his government
email, to MARK STUART LANDERSMAN with a website link. The email stated "Look this
over ... Looks very much like what we're going to send you ..." The website link is to an article
entitled "How I Built a 300 AAC Blackout Suppressor." The article chronicles how the author
manufactured a rifle silencer. The first line of the website's narrative states: "Warning: You must
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 4 of 11 PageID# 813
OVERT ACTS
In furtherance of the conspiracy and to effect the objects thereof, the defendants and their
conspirators performed the following overt acts in the Eastern District of Virginia andelsewhere:
1.
In and around April 2011, MARK STUART LANDERSMAN sent an
email to a conspirator in which he referenced an MK15 sustainable suppressor proposal.
2.
On or about June 6,2012, a conspirator sent an email from his governmentemail
account to a Department of Navy official, requesting a three million dollars ($3,000,000)
supplement to the operational budgetof the Deputy Undersecretary of the Navy (DUSN) Plans,
Policy, Oversight and Integration (PPOI) Intelligence Directorate to conduct studies, research,
assessments, and analysis.
3.
On or about August 13,2012, a conspirator sent an email to MARK
STUART LANDERSMAN requesting the proper name of his company.
4.
On or about August 14,2012, MARKSTUART LANDERSMAN sent an email
to a conspirator's government email, providing his company name as "Advanced Machining and
Engineering," as well as a telephone number and company website.
5.
On or about August 14,2012, a conspirator, via his government
email, forwarded MARK STUART LANDERSMAN'S email containing the company information
to LEE HALL's government email.
6.
On or about August 14,2012, a conspirator sent an email, via his government
email, to MARK STUART LANDERSMAN with a website link. The email stated "Look this
over ... Looks very much like what we're going to send you ..." The website link is to an article
entitled "How I Built a 300 AAC Blackout Suppressor." The article chronicles how the author
manufactured a rifle silencer. The first line of the website's narrative states: "Warning: You must
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 5 of 11 PageID# 814
have a BATFE Form 1 with tax stamp before you start to legally build a suppressor. National
Firearms Act (NFA) rules apply and you can do hard prison time for violating the law."
7.
On or about August 14,2012, MARK STUART LANDERSMAN replied to the
AAC Blackout Suppressor email, stating"Wow! Very simple."
8.
Onor about August 15,2012, an email was sent from the Department of
Navy's Financial Management Division indicating that the DUSN PPOI Intelligence Directorate
received two million dollars ($2,000,000) of the three million dollar ($3,000,000) budgetary
supplement requested by the conspirator.
9.
On or about August 17,2012, a funding documentwas signedthat
caused approximately $1,932,376 ofthe budgetary supplement requested by the conspirator tobe
transferred from the Department of Navy to CACI.
10.
In and around October 2012, LEE HALL contacted CACI to facilitate
a sole source, or no-bid, contract between the Department ofNavy and MARK STUART
LANDERSMAN for the manufacture of suppressors.
11.
On or about October 29, 2012, MARK STUART LANDERSMAN quoted
CACI a price of $1, 657, 750 to manufacture 349 Signature Suppressors. The quote specified a
50% deposit required with the purchase order and"30 days Net upon receipt of order."
12.
On or about October 29,2012, MARK STUART LANDERSMAN certified
to CACI that AME was engaged in the fabrication of articles for experimental and scientific
purposes andtherefore was not required to register with the Directorate of Defense Trade Controls,
U.S. Department of State.
13.
In and around November 2012, MARK STUART LANDERSMAN
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 5 of 11 PageID# 814
have a BATFE Form 1 with tax stamp before you start to legally build a suppressor. National
Firearms Act (NFA) rules apply and you can do hard prison time for violating the law."
7.
On or about August 14,2012, MARK STUART LANDERSMAN replied to the
AAC Blackout Suppressor email, stating"Wow! Very simple."
8.
Onor about August 15,2012, an email was sent from the Department of
Navy's Financial Management Division indicating that the DUSN PPOI Intelligence Directorate
received two million dollars ($2,000,000) of the three million dollar ($3,000,000) budgetary
supplement requested by the conspirator.
9.
On or about August 17,2012, a funding documentwas signedthat
caused approximately $1,932,376 ofthe budgetary supplement requested by the conspirator tobe
transferred from the Department of Navy to CACI.
10.
In and around October 2012, LEE HALL contacted CACI to facilitate
a sole source, or no-bid, contract between the Department ofNavy and MARK STUART
LANDERSMAN for the manufacture of suppressors.
11.
On or about October 29, 2012, MARK STUART LANDERSMAN quoted
CACI a price of $1, 657, 750 to manufacture 349 Signature Suppressors. The quote specified a
50% deposit required with the purchase order and"30 days Net upon receipt of order."
12.
On or about October 29,2012, MARK STUART LANDERSMAN certified
to CACI that AME was engaged in the fabrication of articles for experimental and scientific
purposes andtherefore was not required to register with the Directorate of Defense Trade Controls,
U.S. Department of State.
13.
In and around November 2012, MARK STUART LANDERSMAN
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 6 of 11 PageID# 815
represented that he required fifty percent ofthe total payment, or $828,875, for the contract before
beginning work on the suppressors. LANDERSMAN represented that this payment was
necessary to purchase materials to manufacture the suppressors.
14.
In and around November 2012, MARK STUART LANDERSMAN
signed a contract with CACI to manufacture approximately 349 suppressors forthe Department of
Navy, in which he warranted to comply with the provision of all applicable federal, state and local
laws, regulations, rules and orders, in the performance of the contract.
15.
On or about November 9,2012, in response to concerns by CACI regarding the
50% deposit forthesuppressors, LEE HALL informed CACI thatthe Department ofNavy accepts
the financial burden of providing funds in advance of procurement. HALL further stated that we
will not hold CACI responsible for vendor complications due to this fact.
16.
On or about November 14,2012, LEE HALL represented to CACI that "we
have determined the price quote by AME to be fair, reasonable and accurate."
17.
On or about November 19,2012, MARK STUART LANDERSMAN certified
that he was not engaged in the manufacture of defensearticles and therefore was not required to
register with the Directorate of DefenseTrade Controls, U.S. Department of State.
18.
In and around December 2012, in Arlington, Virginia, in the Eastern District
of Virginia, CACImaileda checkin the amountof $828,875 to MARK STUART LANDERSMAN
as a fifty percent up-front payment for the manufacture of approximately 349 suppressors.
19.
In and around December 2012, MARK STUART LANDERSMAN entered
into an agreement with an individual in Temecula, California to manufacture the components for
approximately 349 suppressors. LANDERSMAN paid the individual approximately $2,000 for
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represented that he required fifty percent ofthe total payment, or $828,875, for the contract before
beginning work on the suppressors. LANDERSMAN represented that this payment was
necessary to purchase materials to manufacture the suppressors.
14.
In and around November 2012, MARK STUART LANDERSMAN
signed a contract with CACI to manufacture approximately 349 suppressors forthe Department of
Navy, in which he warranted to comply with the provision of all applicable federal, state and local
laws, regulations, rules and orders, in the performance of the contract.
15.
On or about November 9,2012, in response to concerns by CACI regarding the
50% deposit forthesuppressors, LEE HALL informed CACI thatthe Department ofNavy accepts
the financial burden of providing funds in advance of procurement. HALL further stated that we
will not hold CACI responsible for vendor complications due to this fact.
16.
On or about November 14,2012, LEE HALL represented to CACI that "we
have determined the price quote by AME to be fair, reasonable and accurate."
17.
On or about November 19,2012, MARK STUART LANDERSMAN certified
that he was not engaged in the manufacture of defensearticles and therefore was not required to
register with the Directorate of DefenseTrade Controls, U.S. Department of State.
18.
In and around December 2012, in Arlington, Virginia, in the Eastern District
of Virginia, CACImaileda checkin the amountof $828,875 to MARK STUART LANDERSMAN
as a fifty percent up-front payment for the manufacture of approximately 349 suppressors.
19.
In and around December 2012, MARK STUART LANDERSMAN entered
into an agreement with an individual in Temecula, California to manufacture the components for
approximately 349 suppressors. LANDERSMAN paid the individual approximately $2,000 for
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 7 of 11 PageID# 816
the purchase of materials to make the 349 suppressors. LANDERSMAN paid the individual a
total of approximately $10,000 to manufacture the components for approximately 349 suppressors.
20.
In and around December 2012, MARK STUART LANDERSMAN picked up
the completed manufactured components, bearing no serial numbers, for the approximately 349
suppressors from the individual in Temecula, California.
21.
On or about February 13,2013, MARK LANDERSMAN tendered the fully
assembled approximately 349 suppressors, bearing no serial numbers, to a FedEx location in
Temecula, California, for shipmentin interstate commerce to their destination in Maryland.
22.
In and around February and March 2013, while on administrative leave,
LEE HALL signed a Material Inspectionand Receiving Report (DD FORM 250), and dated it
February 14,2013, stating that he accepted the approximately 349 suppressors at their destination,
that the suppressors conformed to the contract, and that the suppressors were received in apparent
good condition, despite never having examined the approximately 349 suppressors.
23.
On or about February 19, 2013, FedEx delivered the approximately 349
suppressors shippedby MARK LANDERSMAN and bearing no serial numbers, to their
destination in Maryland.
24.
In and around April 2013, in Arlington, Virginia, within the Eastern District
of Virginia, having receivedthe DD FORM250 signedby LEE HALL, CACI mailed a checkto
MARK LANDERSMAN in the amount of $828,875 as the remaining payment for the
approximately 349 suppressors bearing no serial numbers.
25.
During a telephone conversation on or about April 18,2013, having never taken
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 7 of 11 PageID# 816
the purchase of materials to make the 349 suppressors. LANDERSMAN paid the individual a
total of approximately $10,000 to manufacture the components for approximately 349 suppressors.
20.
In and around December 2012, MARK STUART LANDERSMAN picked up
the completed manufactured components, bearing no serial numbers, for the approximately 349
suppressors from the individual in Temecula, California.
21.
On or about February 13,2013, MARK LANDERSMAN tendered the fully
assembled approximately 349 suppressors, bearing no serial numbers, to a FedEx location in
Temecula, California, for shipmentin interstate commerce to their destination in Maryland.
22.
In and around February and March 2013, while on administrative leave,
LEE HALL signed a Material Inspectionand Receiving Report (DD FORM 250), and dated it
February 14,2013, stating that he accepted the approximately 349 suppressors at their destination,
that the suppressors conformed to the contract, and that the suppressors were received in apparent
good condition, despite never having examined the approximately 349 suppressors.
23.
On or about February 19, 2013, FedEx delivered the approximately 349
suppressors shippedby MARK LANDERSMAN and bearing no serial numbers, to their
destination in Maryland.
24.
In and around April 2013, in Arlington, Virginia, within the Eastern District
of Virginia, having receivedthe DD FORM250 signedby LEE HALL, CACI mailed a checkto
MARK LANDERSMAN in the amount of $828,875 as the remaining payment for the
approximately 349 suppressors bearing no serial numbers.
25.
During a telephone conversation on or about April 18,2013, having never taken
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 8 of 11 PageID# 817
possession or inspected the approximately 349 suppressors, bearing no serial numbers, after they
arrived at their destination, LEE HALL described the suppressors as non-attributable suppressor
systems.
(All in violation ofTitle 18, United States Code, Section 371.)
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 8 of 11 PageID# 817
possession or inspected the approximately 349 suppressors, bearing no serial numbers, after they
arrived at their destination, LEE HALL described the suppressors as non-attributable suppressor
systems.
(All in violation ofTitle 18, United States Code, Section 371.)
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 9 of 11 PageID# 818
COUNT TWO
(Theft of Government Property)
THE GRAND JURY FURTHER CHARGES THAT:
From in and around October 2012 through in and around April 2,2013, in Arlington
County, Virginia and elsewhere within the Eastern District of Virginia, defendant LEE HALL,
knowingly andwillfully converted to theuseof another, andwithout authority, conveyed, money of
the Department of Navy, an agency of the United States; namely, LEE HALL, withoutauthority,
directed CACI to pay Mark Landersman $1,675,750 in Department ofNavy funds to manufacture
approximately 349 suppressors.
(In violation of Title 18, United States Code, Sections 641 and 2.)
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 9 of 11 PageID# 818
COUNT TWO
(Theft of Government Property)
THE GRAND JURY FURTHER CHARGES THAT:
From in and around October 2012 through in and around April 2,2013, in Arlington
County, Virginia and elsewhere within the Eastern District of Virginia, defendant LEE HALL,
knowingly andwillfully converted to theuseof another, andwithout authority, conveyed, money of
the Department of Navy, an agency of the United States; namely, LEE HALL, withoutauthority,
directed CACI to pay Mark Landersman $1,675,750 in Department ofNavy funds to manufacture
approximately 349 suppressors.
(In violation of Title 18, United States Code, Sections 641 and 2.)
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 10 of 11 PageID# 819
FORFEITURE COUNT
If convicted of either count of this Indictment, the defendants, MARK STUART
LANDERSMAN and LEE HALL, shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property,
real or personal, which constitutes or is derived from proceeds traceable to a violation charged in
this Indictment. This property includes, but is not limited to, the following:
1. Approximately $796,354 in United States currency seized from MARK STUART
LANDERSMAN'S JP Morgan Chase Bank accounts;
2. A 1988 Black Porsche 911 Turbo, VIN WP0EB0937JS070551;
3. A 2013 Red Ford F-150 Raptor Pickup Truck, VIN 1FTFW1R6XDFA80061;
4. A 2012 Black Ford Explorer, VIN 1FMHK7D86CGA20847;
5. A Blue and Yellow Ford Ranger Off-Road Racing Vehicle marked "Redneck
Injunearin," "Fourth Street Racing," and "1750";
6. A certificate for 5000 Shares of Latitude 33 Brewing Company Common Stock
registered to MARK LANDERSMAN;
7. A $99,000 Promissory Note from Latitude 33 Brewing Company to MARK
LANDERSMAN, dated December 31,2012.
8. A 1970 Blue Plymouth Roadrunner, VIN RM23NOE104065;
9. A 1996 Jimco Class 10 Sand Rail Off-Road Racing Vehicle;
10. A Miller Dynasty Tig Welder, Serial No. MD160149L; and
11. All equipment, machines and other assets of Advanced Machining and
Engineering, Inc.
If convicted of Count One of this Indictment, the defendants shall forfeit to the United
States, pursuant to Title 18, United States Code, Section 924(d)(1), the approximately 349 silencers
seized from a government facility in Maryland.
10
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 10 of 11 PageID# 819
FORFEITURE COUNT
If convicted of either count of this Indictment, the defendants, MARK STUART
LANDERSMAN and LEE HALL, shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property,
real or personal, which constitutes or is derived from proceeds traceable to a violation charged in
this Indictment. This property includes, but is not limited to, the following:
1. Approximately $796,354 in United States currency seized from MARK STUART
LANDERSMAN'S JP Morgan Chase Bank accounts;
2. A 1988 Black Porsche 911 Turbo, VIN WP0EB0937JS070551;
3. A 2013 Red Ford F-150 Raptor Pickup Truck, VIN 1FTFW1R6XDFA80061;
4. A 2012 Black Ford Explorer, VIN 1FMHK7D86CGA20847;
5. A Blue and Yellow Ford Ranger Off-Road Racing Vehicle marked "Redneck
Injunearin," "Fourth Street Racing," and "1750";
6. A certificate for 5000 Shares of Latitude 33 Brewing Company Common Stock
registered to MARK LANDERSMAN;
7. A $99,000 Promissory Note from Latitude 33 Brewing Company to MARK
LANDERSMAN, dated December 31,2012.
8. A 1970 Blue Plymouth Roadrunner, VIN RM23NOE104065;
9. A 1996 Jimco Class 10 Sand Rail Off-Road Racing Vehicle;
10. A Miller Dynasty Tig Welder, Serial No. MD160149L; and
11. All equipment, machines and other assets of Advanced Machining and
Engineering, Inc.
If convicted of Count One of this Indictment, the defendants shall forfeit to the United
States, pursuant to Title 18, United States Code, Section 924(d)(1), the approximately 349 silencers
seized from a government facility in Maryland.
10
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 11 of 11 PageID# 820
(Pursuant to Title 18, United States Code, Sections 924(d) and 981(a)(1)(C), andTitle28, United
States Code, Section 2461(c); and Rule 32.2(a), Federal Rules of Criminal Procedure.)
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FOREPERSON
Dana J. Boente
Acting Unned States.
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Morris R. Parker, Jr,
AssistairtJaited States Attoj
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Patricia Haynes
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Assistant United States Attorney
11
Case 1:13-cr-00419-LMB Document 156 Filed 03/13/14 Page 11 of 11 PageID# 820
(Pursuant to Title 18, United States Code, Sections 924(d) and 981(a)(1)(C), andTitle28, United
States Code, Section 2461(c); and Rule 32.2(a), Federal Rules of Criminal Procedure.)
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FOREPERSON
Dana J. Boente
Acting Unned States.
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'A/jn.f\
Morris R. Parker, Jr,
AssistairtJaited States Attoj
,y*^u&d<i.
Patricia Haynes
/
Assistant United States Attorney
11