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Indictment in U.S. vs. Hall and Landersman

Oct. 15, 2014

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Page 1 from Indictment in U.S. vs. Hall and Landersman
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 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
Page 2 from Indictment in U.S. vs. Hall and Landersman
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
Page 3 from Indictment in U.S. vs. Hall and Landersman
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.
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.
Page 4 from Indictment in U.S. vs. Hall and Landersman
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 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
Page 5 from Indictment in U.S. vs. Hall and 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 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
Page 6 from Indictment in U.S. vs. Hall and 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
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
Page 7 from Indictment in U.S. vs. Hall and Landersman
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
Page 8 from Indictment in U.S. vs. Hall and Landersman
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.)
Page 9 from Indictment in U.S. vs. Hall and Landersman
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.)
Page 10 from Indictment in U.S. vs. Hall and Landersman
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
Page 11 from Indictment in U.S. vs. Hall and Landersman
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.) A TRUE BILLpUfguSWtdtim frSovemmentAc!,*' the btpal ttfthia paphas been filod un&Ts&iVrtlta LWs Office . FOREPERSON Dana J. Boente Acting Unned States. L JL 'A/jn.f\ Morris R. Parker, Jr, AssistairtJaited States Attoj ,y*^u&d<i. Patricia Haynes / 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.) A TRUE BILLpUfguSWtdtim frSovemmentAc!,*' the btpal ttfthia paphas been filod un&Ts&iVrtlta LWs Office . FOREPERSON Dana J. Boente Acting Unned States. L JL 'A/jn.f\ Morris R. Parker, Jr, AssistairtJaited States Attoj ,y*^u&d<i. Patricia Haynes / Assistant United States Attorney 11