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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.

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§ 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

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