The United States Department of Justice has filed a second amended civil complaint involving the Black Friday case dating back to April 15, 2011. The amended complaint targets assets that were allegedly purchased with illegal proceeds, and they include homes and/or cars purchased by Howard Lederer in the Las Vegas area; as well as two homes in Glendora, California bought by Ray Bitar.
The complaint examines bank records, check and wire transfer to determine that illegal funds were used to purchase a multitude of items, including but not limited to, real estate, renovations, vehicles, furniture, property taxes, pension plans, and 401k investment plans.
Here is language from the document filed on Monday, September 10 in the U.S. Court of the Southern District of New York directly related to the purchases:
“A review of bank records from the Howard Lederer account noted above at Wells Fargo Bank, N.A., held in the name of HH Lederer Consulting LLC, numbered 7655741861 (the “Lederer Consulting Account”), reflects that from approximately December 2006 through September 2011, at least $44,314,997.31 in United States currency that was directly tied to the criminal conduct described above was deposited into the Lederer Consulting Account.”
“A review of real property and banking records reflects that on or about April 19, 2010, Raymond Bitar ordered that a wire transfer of $566,388.36 be made from Pocket Kings, Ltd., to Master’s Realty Services, Inc. d/b/a Premier Service Escrow, as escrow for the purchase of the real property known as 1506 Forest Oaks Drive, Glendora, California 91741 (California APN: 8659-001-006) (the “Forest Oaks Property”).”
The U.S. Attorney’s Office is now seeking forfeitures in the following amounts from the individuals listed below since the expenditures detailed in the complaint were acquired using illegal funds, and it additionally asks for court costs:
The amended complaint includes many new Claims for Relief, including the Travel Act of 1961. The act prohibits interstate or foreign travel that intends to, “distribute the proceeds of any unlawful activity, or otherwise promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on, of any unlawful activity.” This gives the DOJ the ability to contend that the defendants used personal purchases to conceal gambling proceeds and illegal distributions.
The other 11 Claims for Relief in addition to the Travel Act, which is the second claim, include:
(1) Illegal Gambling, (3) Bank and Wire Fraud, (4) Wire Fraud, (5) Promotion Money Laundering and Conspiracy, (6) Concealment Money Laundering and Conspiracy, (7) International Money Laundering and Conspiracy, (8) Bulk Money Laundering and Conspiracy, (9) Promotion Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players, (10) Concealment Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players, (11) International Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players, (12) Bulk Money Laundering and Conspiracy Relating to Full Tilt Fraud Against Players.