LEVITIN 51 Pieces of Property Complaint

Case 3:10-cv-00774-JCH Document 1 Filed 05/18/10 Page 1 of 68
UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA,:
Plaintiff,:
v.: Civil No.
51 PARCELS OF PROPERTY LOCATED:

IN NEW HAVEN, CONNECTICUT,:
AT THE FOLLOWING ADDRESSES::
(1) 197-199 BASSETT STREET:

(2) 25-29 BATTER TERRACE:
(3) 81-83 BEERS STREET:
(4) 501 BLATCHLEY AVENUE:
(5) 136 CARLISLE STREET:
(6) 561 CENTRAL AVENUE:
(7) 115 CLAY STREET:
(8) 15 COLBY COURT:
(9) 141 COUNTY STREET:
(10) 270 DAVENPORT AVENUE:
(11) 280 DAVENPORT AVENUE:
(12) 108 DEWITT STREET:
(13) 205-207 DOVER STREET:
(14) 161 EDGEWOOD AVENUE:
(15) 357 ELLSWORTH AVENUE:
(16) 363 ELLSWORTH AVENUE:
(17) 212-214 ENGLISH STREET:
(18) 286 EXCHANGE STREET: May 18, 2010
(19) 299 GREENWICH AVENUE:
(20) 222 HALLOCK AVENUE:
(21) 89 HAZEL STREET:
(22) 314 HOWARD AVENUE:
(23) 490 HOWARD AVENUE:
(24) 456 HUNTINGTON STREET:
(25) 88-89 HURLBURT STREET:
(26) 186 JAMES STREET:
(27) 265 JAMES STREET:
(28) 382 LOMBARDSTREET:
(29) 19-21 NORTON STREET:
(30) 279-281 NORTON STREET:
(31) 353 ORCHARD STREET:
(32) 378-380 ORCHARD STREET:
(33) 95 PARDEE STREET

(34) 122-124 PLYMOUTH STREET:
(35) 97-99 ROCK CREEK ROAD
(36) 41 SHEFFIELD AVENUE
(37) 8 SHELTER STREET
(38) 37-39 SHELTER STREET
(39) 140 SHELTON AVENUE
(40) 418 SHELTON AVENUE
(41) 334-336 SHERMAN AVENUE:
(42) 342 SHERMAN AVENUE
(43) 55-57 THOMPSON STREET
(44) 443 VALLEY STREET
(45) 56-58 VICTORY DRIVE
(46) 159 WEST STREET
(47) 579-581 WHALLEY AVENUE:
(48) 583-585 WINCHESTER AVENUE:
(49) 872-874 WINCHESTER AVENUE:
(50) 510 WINTHROP AVENUE
(51) 573 WINTHROP AVENUE
WITH ALL APPURTENANCES AND:

IMPROVEMENTS THEREON,
Defendants.
[CLAIMANTS: MENACHEM LEVITIN,:

161 EDGEWOOD, LLC, ADM
HOLDINGS, LLC, BATIA, LLC,
BEIT AVIV, LLC, BEIT AVIV II, LLC,:
L & I INVESTMENTS, LLC,
MOSHE, LLC, NEW HAVEN
INVESTMENT GROUP, LLC,
PARNOSA, LLC, SHEMESH, LLC,
SOLO INVESTMENTS, LLC, VIK
HOLDINGS, LLC., WHITE OAK
NEW HAVEN, LLC, WASHINGTON:
MUTUAL BANK, FLAGSTAFF
BANK AND CITIMORTGAGE, INC.]:
VERIFIED COMPLAINT OF FORFEITURE
Plaintiff, United States of America, by its attorneys, David B. Fein, United States
Attorney for the District of Connecticut, and Julie G. Turbert, Assistant United States Attorney,
brings this complaint and alleges as follows in accordance with Supplemental Rule G(2) of the
Federal Rules of Civil Procedure:
NATURE OF ACTION
1. This is a civil action in rem brought to enforce the provision of Title 18, United
States Code, Section 981(a)(1)(A) for the forfeiture of property involved in a financial
transaction in violation of Title 18, United States Code, Sections 1956 or 1957, or to enforce the
provision of Title 18, United States Code, Section 981(a)(1)(C) for the forfeiture of property
which constitutes or is derived from proceeds traceable to an offense constituting specified
unlawful activity (as defined in 18 U.S.C. 1956(c)(7)), namely wire fraud in violation of 18
U.S.C. 1343, or conspiracy to commit such offense.
THE DEFENDANTS IN REM
2. The real property defendants are 51 parcels of property located in New Haven,
Connecticut at the following addresses: (1) 97-199 Bassett Street, (2) 25-29 Batter Terrace, (3)
81-83 Beers Street, (4) 501 Blatchley Avenue, (5) 136 Carlisle Street, (6) 561 Central Avenue,
(7) 115 Clay Street, (8) 15 Colby Court, (9) 141 County Street, (10) 270 Davenport Avenue, (11)
280 Davenport Avenue, (12) 108 Dewitt Street, (13) 205-207 Dover Street, (14) 161 Edgewood
Avenue, (15) 357 Ellsworth Avenue, (16) 363 Ellsworth Avenue, (17) 212-214 English Street,
(18) 286 Exchange Street, (19) 299 Greenwich Avenue, (20) 222 Hallock Avenue, (21) 89 Hazel
Street, (22) 31 Howard Avenue, (23) 490 Howard Avenue, (24) 456 Huntington Street, (25) 88-
89 Hurlburt Street, (26) 186 James Street, (27) 265 James Street, (28) 382 Lombard Street, (29)
19-21 Norton Street, (30) 279-281 Norton Street, (31) 353 Orchard Street, (32) 378-380 Orchard
Street, (33) 95 Pardee Street, (34) 122-124 Plymouth Street, (35) 97-99 Rock Creek Road, (36)
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41 Sheffield Avenue, (37) 8 Shelter Street, (38) 37-39 Shelter Street, (39) 140 Shelton Avenue,
(40) 418 Shelton Avenue, (41) 334-336 Sherman Avenue, (42) 342 Sherman Avenue, (43) 55-57
Thompson Street, (44) 443 Valley Street, (45) 56-58 Victory Drive, (46) 159 West Street, (47)
579-581 Whalley Avenue, (48) 583-585 Winchester Avenue, (49) 872-874 Winchester Avenue,
(50) 510 Winthrop Avenue, and (51) 573 Winthrop Avenue, with all appurtenances and
improvements thereon (real property defendants), more particularly described in Attachment A,
which is attached hereto and incorporated herein by reference.
3. The record owners of the real property defendants are Menachem Levitin, 161
Edgewood, LLC, ADM Holdings, LLC, Batia, LLC, Beit Aviv, LLC, Beit Aviv II, LLC, L& I
Investments, LLC, Moshe, LLC, New Haven Investment Group, LLC, Parnosa, LLC, Shemesh,
LLC, Solo Investments, LLC, VIK Holdings, LLC., and White Oak New Haven, LLC. All of the
real property defendants are non-owner occupied residential properties.
4. The real property defendants have not been seized but are located within this
district and within the jurisdiction of the Court. The United States does not request authority
from the Court to seize the real property defendants at this time. The United States will, as
providedby 18 U.S.C. 985(b)(1) and (c)(1):
a. post notice of this action and a copy of the Complaint on the real property
defendants, and
b. serve notice of this action on the real property defendants
owner(s), and any other person or entity who may claim an
interest in the real property defendants, along with a copy
of this Complaint, and
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c. execute writs of entry for purposes of conducting an inspection and
inventory of each property, and
d. file a lis pendens in New Haven Land Records of the real
property defendants status as defendants in this in rem
action.
5. The United States will also, as provided in 19 U.S.C. 1606, appraise the real
property defendants when it executes the Writs of Entry.
JURISDICTION AND VENUE
4. Plaintiff brings this action in rem in its own right to forfeit and condemn the real
property defendants. This Court has jurisdiction over an action commenced by the United States
pursuant to 28 U.S.C. 1345, and over an action for forfeiture pursuant to 28 U.S.C. 1355(a).
5. This Court has in rem jurisdiction over the real property defendants pursuant to 28
U. S.C. 1355(b).
6. Venue is proper in this district pursuant to 28 U.S.C. 1355(b)(1), because the acts
or omissions giving rise to the forfeiture occurred in this district, and pursuant to 28 U. S.C.
1395, because the property is located in this district.
BASIS FOR FORFEITURE
7. The real property defendants are subject to forfeiture pursuant to
18 U.S.C. 981(a)(1)(A) because they constitute property involved in a financial transaction in
violation of Title 18, United States Code, Sections 1956 or 1957, or pursuant to 18 U.S.C.
981(a)(1)(C) because they constitute or are derived from proceeds traceable to an offense
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constituting specified unlawful activity (as defined in 18 U.S.C. 1956(c)(7)), namely wire
fraud in violation of 18 U.S.C. 1343, or conspiracy to commit such offense.
ACQUISITION OF 51 PARCELS OF PROPERTY BY

MENACHEM LEVITIN AND HIS ENTITIES
REAL PROPERTY DEFENDANT NO. (1) 197-199 BASSETT STREET
8. Real property defendant no. 1, located at 197-199 Bassett Street, was acquired by
New Haven Investment Group, LLC from HSBC Bank for $55, 200, by special warranty deed,
dated January 15, 2010, and recorded in Volume 8506, at Page 263 of the New Haven Land
Records.
9. According to the Assessor for the City of New Haven, 197-199 Bassett Street is
assessed at $114, 730.
REAL PROPERTY DEFENDANT NO. (2) 25-29 BATTER TERRACE
10. Real property defendant no. 2, located at 25-29 Batter Terrace, was acquired by
Solo Investments, LLC from HSBC Bank for $106, 750, by warranty deed, dated August 15,
2008, in Volume 8271, at Page 151 of the New Haven Land Records. On February 26, 2009,
Solo Investments, by Menachem Levitin, transferred title to the property to Menachem Levitin
for $1.00, by quit claim deed, dated February 26, 2009, and recorded on February 27, 2009, in
Volume 8349, at Page 132 of the New Haven Land Records.
11. According to the Assessor for the City of New Haven, 25-29 Batter Terrace is
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REAL PROPERTY DEFENDANT NO. (3) 81-83 BEERS STREET
12. Real property defendant no. 3, located at 81-82 Beers Street, was acquired by
Menachem Levitin from U.S. Bank, Trustee for $165, 000, by warranty deed, dated June 26,
2008, in Volume 8241, at Page 53 of the New Haven Land Records. On July 2, 2008,
Menachem Levitin transferred title to the property to Parnosa, LLC for $1.00 by quit claim deed,
dated July 2, 2008, and recorded on July 7, 2008, in Volume 8241, at Page 55 of the New Haven
Land Records.
13. According to the Assessor for the City of New Haven, 81-83 Beers Street is
REAL PROPERTY DEFENDANT NO. (4) 501 BLATCHLEY AVENUE
14. Real property defendant no. 4, located at 501 Blatchley Avenue, was acquired by
Solo Investments, LLC from Christina Bank and Trust Company for $62, 000.00, by warranty
deed, dated October 13, 2008, and recorded on October 14, 2008, in Volume 8306, at Page 261
of the New Haven Land Records. On November 10, 2008, Solo Investments, LLC, by
Menachem Levitin, transferred title to the property to Asset Holdings, LLC for $1.00, by quit
claim deed, dated November 10, 2008, and recorded on November 11, 2008, in Volume 8306, at
Page 265 of the New Haven Land Records. On November 10, 2008, Asset Holdings, LLC, by
Individual A, transferred title to Shemesh, LLC for $96, 000, by warranty deed, dated November
10, 2008, in Volume 8036, at Page 267 of the New Haven Land Records.
15. According to the Assessor for the City of New Haven, 501 Blatchley Avenue is
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REAL PROPERTY DEFENDANT NO. (5) 136 CARLISLE STREET
16. Real property defendant no. 5, located at 136 Carlisle Street, was acquired by Solo
Investments, LLC, from Deutsche Bank for $35, 600, by warranty deed, dated September 1, 2009,
and recorded on September 29, 2009, in Volume 8445, at Page 82 of the New Haven Land
Records. On September 10, 2009, Solo Investments, LLC transferred title to the property to
Moshe, LLC, by quit claim deed, recorded on September 29, 2009, in Volume 8445, at Page 85
of the New Haven Land Records.
17. According to the Assessor for the City of New Haven, 136 Carlisle Street is
REAL PROPERTY DEFENDANT NO. (6) 561 CENTRAL AVENUE
18. Real property defendant no. 6, located at 561 Central Avenue, was acquired by
Menachem Levitin from Deutsche Bank for $90, 000, by special warranty deed, dated October 22,
2008, and recorded on November 6, 2008, in Volume 8303, at Page 198 of the New Haven Land
Records.
19. According to the Assessor for the City of New Haven, 561 Central Avenue is
REAL PROPERTY DEFENDANT NO. (7) 115 CLAY STREET
20. Real property defendant no. 7, located at 115 Clay Street, was acquired by Solo
Investments, LLC from Lasalle Bank, Trustee for $52, 000, by special warranty deed, dated and
recorded on September 12, 2008, in Volume 8277, at Page 330 of the New Haven Land Records.
21. According to the Assessor for the City of New Haven, 115 Clay Street is assessed
at $143, 220.
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REAL PROPERTY DEFENDANT NO. (8) 15 COLBY COURT
22. Real property defendant no. 8, located at 15 Colby Court, was acquired by Solo
Investments, LLC, from Deutsche Bank, Trustee for $75, 500, by quit claim deed, dated
December 3, 2008, and recorded on December 9, 2008, in Volume 8315, at Page 300 of the New
Haven Land Records. On December 8, 2008, Solo Investments, LLC, by Menachem Levitin,
transferred title to the property to New Haven Investment Group, LLC for $1.00, by quit claim
deed, dated and recorded on December 8, 2008, in Volume 8315, at Page 303 of the New Haven
Land Records.
23. According to the Assessor for the City of New Haven, 15 Colby Court is assessed
at $166, 460
REAL PROPERTY DEFENDANT NO. (9) 141 COUNTY STREET
24. Real property defendant no. 9, located at 141 County Street, was acquired by
Menachem Levitin from Deutsche Bank Trust Company, Trustee for $91, 000, by limited
warranty deed, dated April 15, 2008, and recorded on May 5, 2008, in Volume 8200, at Page 286
of the New Haven Land Records. On April25, 2008, Menachem Levitin transferred title to the
property to Solo Investments, LLC for $1.00, by quit claim deed, dated April25, 2008, and
recorded on May 5, 2008, in Volume 8200, at Page 289 of the New Haven Land Records. On
June 19, 2008, Solo Investments, LLC transferred title to the property to Menachem Levitin for
$1.00, by quit claim deed, dated June 19, 2008, and recorded on June 25, 2008, in Volume 8233,
at Page 114 of the New Haven Land Records.
25. According to the Assessor for the City of New Haven, 141 County Street is
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REAL PROPERTY DEFENDANT NO. (10) 270 DAVENPORT AVENUE
26. Real property defendant no. 10, located at 270 Davenport Avenue, was purchased
by Individual Number 4 for $260, 000, by warranty deed, dated January 2, 2007, and recorded on
January 4, 2007, in Volume 7837, at Page 148 of the New Haven Land Records. Individual
Number 4 obtained a first mortgage from GMAC Mortgage, LLC in the original principal
amount of $208, 000, which mortgage is recorded in Volume7837, at Page 150, and a second
mortgage in the original principal amount of $39, 000, which mortgage is recorded in Volume
7837, at Page 169. On February 25, 2008, GMAC Mortgage, LLC recorded a lis pendens giving
notice of the pendency of a foreclosure action against Individual Number 4. On July 21, 2008,
GMAC Mortgage, LLC recorded a Certificate of Foreclosure. On July 28, 2008, GMAC
Mortgage, LLC transferred title to the property to Federal National Mortgage Association by quit
claim deed, recorded on July 28, 2008, in Volume 8251, at Page 191. On September 24, 2008,
Fannie Mae, a.k.a. Federal National Mortgage Association sold the property to Solo Investments,
LLC $52, 000, by warranty deed, dated and recorded on September 24, 2008, in Volume 8283, at
Page 90 of the New Haven Land Records.
27. According to the Assessor for the City of New Haven, 270 Davenport Avenue is
28. Real property defendant no. 11, located at 280 Davenport Avenue, was acquired by
Solo Investments, LLC from Deutsche Bank, Trustee for $23, 800, by quit claim deed, dated
August 31, 2009, and recorded on September 14, 2009, in Volume 8439, at Page 175 of the New
Haven Land Records.
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29. According to the Assessor for the City of New Haven, 280 Davenport Avenue is
REAL PROPERTY DEFENDANT NO. (12) 108 DEWITT STREET
30. Real property defendant no. 12, located at 108 Dewitt Street, was purchased by
Individual Number 1 for $150, 000 on October 27, 2004. On July 26, 2005, Individual Number 1
sold the property to Individual Number 2 for $235, 000, which warranty deed was recorded on
July 27, 2005, in Volume 7273, at Page 245 of the New Haven Land Records. On March 20,
2009, Bank of New York, Trustee for GMAC Mortgage recorded a Certificate of Foreclosure in
Volume 8357, at Page 168. On April23, 2009, Batia, LLC purchased the property from Bank of
New York as Trustee for $55, 000, by warranty deed, dated April23, 2009, and recorded on May
29, 2009, in Volume 8389, at Page 37. On May 22, 2009, Batia, LLC, by Menachem Levitin,
transferred title to Asset Holdings, LLC for $1.00, by quit claim deed, dated May 22, 2009, in
Volume 8389, at Page 39. On May 22, 2009, Asset Holdings, LLC, by Individual A, transferred
title to Shemesh, LLC for $121, 000, by warranty deed, dated May 22, 2009, and recorded on May
29, 2009, in Volume 8389, at Page 40.
31. According to the Assessor for the City of New Haven, 108 Dewitt Street is assessed
at $133, 420.
REAL PROPERTY DEFENDANT NO. (13) 205-207 DOVER STREET
32. Real property defendant no. 13, located at 205-207 Dover Street, was acquired by
Solo Investments, LLC from Federal Home Loan Mortgage Corporation for $82, 000, by warranty
deed, dated December 17, 2008, and recorded on December 19, 2008, in Volume 8321, at Page
69 of the New Haven Land Records.
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33. According to the Assessor for the City of New Haven, 205-207 Dover Street is
REAL PROPERTY DEFENDANT NO. (14) 161 EDGEWOOD AVENUE
34. Real property defendant no. 14, located at 161 Edgewood Avenue, was acquired by
Menachem Levitin and Individual Bfor $315, 000 by warranty deed, dated September 10, 2007,
Records. On September 24, 2007, Menachem Levitin and Individual Btransferred title to the
property to 161 Edgewood LLC for $1.00, by quit claim deed, dated September 24, 2007, and
recorded on October 18, 2007, in Volume 8200, at Page 242 of the New Haven Land Records.
35. Washington Mutual Bank may have an interest in real property defendant no. 14 by
virtue of a mortgage in the original principal amount of $309, 000, which mortgage is dated May
2, 2008, and recorded in Volume 8200, at Page 242 of the New Haven Land Records.
36. According to the Assessor for the City of New Haven, 161 Edgewood Avenue is
REAL PROPERTY DEFENDANT NO. (15) 357 ELLSWORTH AVENUE
37. Real property defendant no. 15, located at 357 Ellsworth Avenue, was purchased
by Individual Number 3 for $342, 000, by warranty deed, witnessed by Menachem Levitin, dated
and recorded on June 28, 2007, in Volume 799, at Page 135 of the New Haven Land Records.
On June 28, 2007, a mortgage in the original principal amount of $307, 800 to Sterling Empire
Funding was witnessed by Menachem Levitin and recorded in Volume 7995, at Page 139. On or
about August 19, 2008, Countrywide Home Loan Services recorded a lis pendens giving notice
of the pendency of a foreclosure action against Individual3. On or about November 19, 2009,
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Countrywide Home Loan Services recorded a Certificate of Foreclosure in Volume 8469, at Page
162. On or about November 16, 2009, Countrywide Home Loan Services conveyed title to
Federal National Mortgage Association by quit claim deed recorded in Volume 8469, at Page
165. On February 10, 2009, Menachem Levitin purchased the property from Federal National
Mortgage Association for $104, 000.00, by warranty deed recorded in Volume 8506, at Page 288
38. According to the Assessor for the City of New Haven, 357 Ellsworth Avenue is
39. Real property defendant no. 16, located at 363 Ellsworth Avenue, was purchased
by Individual Number 3 for $299, 900, by warranty deed, dated June 21, 2007, and recorded on
June 28, 2007, in Volume 7995, at Page 100 of the New Haven Land Records. On or about June
19, 2007, a mortgage in the original principal amount of $221, 925 to First Meridian Mortgage
was witnessed by Menachem Levitin and recorded in Volume 7795, at Page 103. On June 20,
2007, a second mortgage in the original principal amount of $44, 385 to Countrywide Mortgage
was witnessed by Menachem Levitin and recorded in Volume 7795, at Page 124. On or about
August 28, 2008, HSBC Bank USA, NA, Trustee recorded a lis pendens giving notice of the
pendency of a foreclosure action against Individual Number 3. On or about May 5, 2009, HSBC
Bank USA, NA, Trustee, recorded a Certificate of Foreclosure in Volume 8378, at Page 318. On
April 15, 2009, Menachem Levitin purchased the property from HSBC Bank, USA, NA, Trustee,
for $86, 200, by special warranty deed, recorded in Volume 8373, at Page 79 of the New Haven
Land Records.
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40. According to the Assessor for the City of New Haven, 363 Ellsworth Avenue is
REAL PROPERTY DEFENDANT NO. (17) 212-214 ENGLISH
41. Real property defendant no. 17, located at 212-214 English Street, was acquired by
Solo Investments, LLC from Countrywide Bank for $65, 200, by special limited warranty deed,
dated March 20, 2009, and recorded on April20, 2009, in Volume 8370, at Page 334 of the New
Haven Land Records. On April24, 2009, Solo Investments, LLC, by Menachem Levitin,
transferred title to Batia, LLC for $1.00, by quit claim deed, dated April24, 2009, and recorded
on May 12, 2009, in Volume 8381, at Page 174 of the New Haven Land Records.
42. According to the Assessor for the City of New Haven, 212-214 English Street is
REAL PROPERTY DEFENDANT NO. (18) 286 EXCHANGE STREET
43. Real property defendant no. 18, located at 286 Exchange Street, was acquired by
White Oak New Haven, LLC, from Capital Financial LLC for $82, 000, by warranty deed, dated
December 12, 2008, and recorded on December 23, 2008, in Volume 8321, at Page 275 of the
New Haven Land Records.
44. According to the Assessor for the City of New Haven, 286 Exchange Street is
REAL PROPERTY DEFENDANT NO. (19) 299 GREENWICH AVENUE
45. Real property defendant no. 19, located at 299 Greenwich Avenue, was acquired by
Moshe, LLC from New Rich Development, LLC for $30, 200, by warranty deed, dated November
23, 2009, and recorded in Volume 8461, at Page 225 of the New Haven Land Records.
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46. According to the Assessor for the City of New Haven, 299 Greenwich Avenue is
REAL PROPERTY DEFENDANT NO. (20) 222 HALLOCK AVENUE
47. Real property defendant no. 20, located at 222 Hallock Avenue, was acquired by
Solo Investments, LLC from HSBC Bank for $77, 600, by warranty deed, dated October 3, 2008,
and recorded on November 14, 2008, in Volume 8306, at Page 271 of the New Haven Land
Records. On November 7, 2008, Solo Investments, LLC, by Menachem Levitin, transferred title
to Asset Holdings, LLC for $1.00, by quit claim deed, dated November 7, 2008, and recorded on
November 14, 2008, in Volume 8306, at Page 274. On January 7, 2008, Asset Holdings, LLC
transferred title to Beit Aviv, LLC for $115, 000, by warranty deed, dated January 7, 2008, and
recorded in Volume 8306, at Page 276 of the New Haven Land Records.
48. According to the Assessor for the City of New Haven, 222 Hallock Avenue is
REAL PROPERTY DEFENDANT NO. (21) 89 HAZEL STREET
49. Real property defendant no. 21, located at 89 Hazel Street, was acquired by Solo
Investments, LLC from U. S. Bank National Association for $27, 100, by warranty deed, dated
February 1, 2010, and recorded in Volume 8507, at Page 285 of the New Haven Land Records.
Solo Investments, LLC, by Menachem Levitin, transferred title to VIK Holdings, LLC for $1.00,
by quit claim deed, dated February 9, 2010, and recorded in Volume 8507, at Page 288 of the
50. According to the Assessor for the City of New Haven, 89 Hazel Street is assessed
at $97, 160.
15
REAL PROPERTY DEFENDANT NO. (22) 314 HOWARD AVENUE
51. Real property defendant no. 22, located at 314 Howard Avenue, was acquired by
Solo Investements, LLC from HSBC Mortgage Services, for $120, 000.00, by deed dated
November 4, 2008, and recorded on November 11, 2008, in Volume 8305, at Page 231 of the
New Haven Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to
Asset Holdings, LLC for $1.00, by quit claim deed, dated October 31, 2009, and recorded on
November 12, 2008, in Volume 8305, at Page 235. Asset Holdings, LLC, by Individual A,
transferred title to the property to Shemesh, LLC for $186, 000, by warranty deed, dated
November 4, 2008, and recorded on November 12, 2008, in Volume 8305, at Page 233 of the
52. According to the Assessor for the City of New Haven, 314 Howard Avenue is
53. Real property defendant no. 23, located at 490 Howard Avenue, was acquired by
New Haven Investment Group, LLC from U.S. Bank, Trustee for $45, 000, by special warranty
deed, dated January 5, 2010, and recorded in Volume 8495, at Page 30 of the New Haven Land
Records.
54. According to the Assessor for the City of New Haven, 490 Howard Avenue is
REAL PROPERTY DEFENDANT NO. (24) 456 HUNTINGTON STREET
55. Real property defendant no. 24, located at 456 Huntington Street, was acquired by
Solo Investment Group, LLC from U.S. Bank, Trustee for $28, 000, by special warranty deed,
16
dated January 15, 2010, and recorded in Volume 8499, at Page 94 of the New Haven Land
Records. On January 24, 2010, Solo Investments, LLC, by Menachem Levitin, transferred title to
New Haven Investment Group, LLC for $1.00, by quit claim deed, dated January 24, 2010, and
recorded in Volume 8499, at Page 97 of the New Haven Land Records.
56. According to the Assessor for the City of New Haven, 456 Huntington Street is
REAL PROPERTY DEFENDANT NO. (25) 88-89 HURLBURT STREET
57. Real property defendant no. 25, located at 88-89 Hurlburt Street, was acquired by
Tami Research & Development, LLC from Citimortgage, Inc. for $57, 000, by warranty deed,
dated November 3, 2008, and recorded on November 28, 2008, in Volume 8312, at Page 73 of
the New Haven Land Records. Tami Research & Development, LLC, by Menachem Levitin,
transferred title to New Haven Capital Investment, LLC for $1.00, by quit claim deed, dated
November 24, 2008, and recorded on November 28, 2008, in Volume 8312, at Page 76. New
Haven Capital Investment, LLC, by Menachem Levitin, transferred title to New Haven
Investment Group, LLC for $1.00, by quit claim deed, dated February 11, 2009, and recorded on
February 12, 2009, in Volume 8343, at Page 312 of the New Haven Land Records.
58. According to the Assessor for the City of New Haven, 88-89 Hurlburt Street is
REAL PROPERTY DEFENDANT NO. (26) 186 JAMES STREET
59. On January 5, 2007, Individual Number 1 purchased real property defendant no. 26,
located at 186 James Street, for $262, 000, by warranty deed, recorded on January 9, 2007, in
Volume 7840, at Page 146 of the New Haven Land Records. Also on January 5, 2007,
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Individual Number 1 obtained two mortgages in the amounts of $185, 600 and $34, 800 from
Countrywide Home Loans, Inc., which mortgages are recorded in Volume 7840, page 148, and
Volume 7840, Page 165, respectively, of the New Haven Land Records. On or about January 23,
2008, Countrywide Home Loans, Inc. recorded a lis pendens giving notice of a foreclosure action
against Individual Number 1. In a short sale, Menachem Levitin purchased the property from
Individual 1 for $105, 000, by warranty deed, dated and recorded on September 17, 2008, in
Volume 8279, at Page 343. Menachem Levitin transferred title to Tami Research &
Development, LLC for $1.00, by quit claim deed, dated September 15, 2008 and recorded on
September 17, 2008, in Volume 8279, at Page 345. Tami Research & Development, LLC, by
Menachem Levitin, transferred title to New Haven Investment Group, LLC, by quit claim deed
dated December 2, 2009, and recorded in Volume 8473, at Page 21 of the New Haven Land
Records.
60. According to the Assessor for the City of New Haven, 186 James Street is assessed
at $132, 090.
61. Real property defendant no. 27, located at 265 James Street, was acquired by
Menachem Levitin from Novastar Morrgage for $95, 000, by deed, dated March 27, 2008, and
recording on April8, 2008, in Volume 8184, at Page 6 of the New Haven Land Records.
Menachem Levitin transferred title to Solo Investments, LLC for $1.00, by quit claim deed, dated
April3, 2008, and recorded on April8, 2008, in Volume 8184, at Page 7. Solo Investments,
LLC, by Menachem Levitin, transferred title to Menachem Levitin for $1.00, by quit claim deed,
18
dated June 19, 2008, and recorded on June 25, 2008, in Volume 8233, at Page 110 of the New
Haven Land Records.
62. Flagstaff Bank may have an interest in real property defendant no. 27 by virtue of a
mortgage in the original principal amount of $140, 000, dated January 5, 2009, and recorded in
63. According to the Assessor for the City of New Haven, 265 James Street is assessed
at $149, 310.
REAL PROPERTY DEFENDANT NO. (28) 382 LOMBARD STREET
64. Real property defendant no. 28, located at 385 Lombard Street, was acquired by
Solo Investments, LLC from Bank of New York for $166, 600, by special limited warranty deed,
dated October 2, 2008, and recorded on October 30, 2008, in Volume 8300, at Page 279 of the
New Haven Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to
Asset Holdings, LLC for $1.00, by quit claim deed, dated October 24, 2008, and recorded on
October 30, 2008, in Volume 8300, at Page 281. Asset Holdings, LLC transferred the property to
Beit Aviv, LLC for $206, 000, by warranty deed, dated October 24, 2008, and recorded on
October 30, 2008, in Volume 8300, Page 283 of the New Haven Land Records.
65. According to the Assessor for the City of New Haven, 3 82 Lombard Street is
REAL PROPERTY DEFENDANT NO. (29) 19-21 NORTON STREET
66. Real property defendant no. 29, located at 19-21 Norton Street, was acquired by
Parnosa, LLC from Deutsche Bank, Trustee for $75, 000, by warranty deed, dated August 8,
19
2008, and recorded on August 20, 2008, in Volume 8266, at Page 149 of the New Haven Land
Records.
67. According to the Assessor for the City of New Haven, 19-21 Norton Street is
68. On March 8, 2007, Individual Number 3 purchased real property defendant no. 30
located, at 279-281 Norton Street, for $363, 000, by warranty deed (witnessed by Menachem
Levitin), recorded on March 15, 2007, in Volume 7902, at Page 169 of the New Haven Land
Records. On March 9, 2007, Individual Number 3 obtained two mortgages in the amounts of
$288, 000 and $36, 00 from First Meridian Mortgage, which mortgages are recorded in Volume
79020, page 172, and Volume 7902, Page 189, respectively. On or about July 29, 2008, HSBC
Bank, USA, NA, Trustee, recorded a lis pendens giving notice of a foreclosure action against
Individual Number 3. On April26, 2009, HSBC, Bank, USA, NA obtained a Certificate of
Foreclosure which is recorded in Volume 8404, at Page 172. Solo Investments, LLC acquired
the property from HSBC Bank, Trustee for $112, 000, by special warranty deed, dated October 5,
2009, and recorded in Volume 8451, at Page 284 of the New Haven Land Records.
69. According to the Assessor for the City of New Haven, 279-281 Norton Street is
REAL PROPERTY DEFENDANT NO. (31) 353 ORCHARD STREET
70. Real property defendant no. 31, located at 385 Orchard Street, was acquired by L&
I Investments, LLC from Federal National Mortgage Association, for $66, 200 by warranty deed,
20
dated February 24, 2009, and dated February 27, 2009, in Volume 8349, at Page 129 of the New
Haven Land Records.
71. According to the Assessor for the City of New Haven, 353 Orchard Street is
REAL PROPERTY DEFENDANT NO. (32) 378-380 ORCHARD STREET
72. Real property defendant no. 32, located at 378-280 Orchard Street, was acquired by
Solo Investments, LLC from Bank of New York Mellon, for $97, 000 by warranty deed, dated
September 23, 2009, and recorded on October 1, 2009, in Volume 8446, at Page 239 of the New
Haven Land Records.
73. According to the Assessor for the City of New Haven, 378-380 Orchard Street is
REAL PROPERTY DEFENDANT NO. (33) 95 PARDEE STREET
74. Real property defendant no. 33, located at 95 Pardee Street, was acquired by Solo
Investments, LLC from Deutsche Bank, Trustee, for $43, 300, by special warranty deed, dated
July 9, 2009, and recorded on July 17, 2009, in Volume 8412, at Page 108 of the New Haven
Land Records.
75. According to the Assessor for the City of New Haven, 95 Pardee Street is assessed
at $127, 680.
REAL PROPERTY DEFENDANT NO. (34) 122-124 PLYMOUTH STREET
76. Real property defendant no. 34, located at 122-124 Plymouth Street, was acquired
by Menachem Levitin from Daniel and Virginia Sparano for $165, 000, by warranty deed, dated
April3, 2008, and recorded on April8, 2008, in Volume 8184, at Page 8 of the New Haven Land
21
Records. Menachem Levitin transferred title to Solo Investments, LLC for $1.00, by quit claim
deed, dated April3, 2008, and recorded on April8, 2008, in Volume 8184, at Page 11. Solo
Investments LLC, by Menachem Levitin, transferred title to Menachem Levitin for $1.00, by quit
claim deed, dated June 19, 2008, and recorded on June 25, 2008, in Volume 8233, at Page 112 of
the New Haven Land Records.
77. Citimortgage, Inc. may have an interest in real property defendant no. 34 by virtue
of a mortgage in the original principal amount of $245, 000, dated August 14, 2008, and recorded
in Volume 8265, at Page 129 of the New Haven Land Records.
78. According to the Assessor for the City of New Haven, 122 Plymouth Street is
assessed at $203, 350, and 124 Plymouth Street (vacant land) is assessed at $22,400.
REAL PROPERTY DEFENDANT NO. (35) 97-99 ROCK CREEK ROAD
79. Real property defendant no. 35, located at 97-99 Rock Creek Road, was acquired
by Asset Holdings, LLC from HSBC Bank USA for $80, 300, by warranty deed, dated May 22,
2009, and recorded in Volume 8389, at Page 42 of the New Haven Land Records. Asset
Holdings, LLC, by Individual A, transferred title to Shemesh, LLC for $140, 000, by quit claim
Deed dated May 26, 2009 in Volume 8389, at Page 44 of the New Haven Land Records.
80. According to the Assessor for the City of New Haven, 97-99 Rock Creek Road is
REAL PROPERTY DEFENDANT NO. (36) 41 SHEFFIELD AVENUE
81. Real property defendant no. 36, located at 41 Sheffield Avenue, was acquired by
Solo Investments, LLC from Citimortgage Inc., for $45, 000, by warranty deed, dated February 8,
22
82. According to the Assessor for the City of New Haven, 41 Sheffield Avenue is
REAL PROPERTY DEFENDANT NO. (37) 8 SHELTER STREET
83. Real property defendant no. 37, located at 8 Shelter Street, was acquired by L& I
Investments, LLC from GMAC Mortgage, LLC for $129, 600, by warranty deed, dated and
recorded on June 19, 2008, in Volume 8229, at Page 110 of the New Haven Land Records.
84. According to the Assessor for the City of New Haven, 8 Shelter Street is assessed
at $136, 360
REAL PROPERTY DEFENDANT NO. (38) 37-39 SHELTER STREET
85. Real property defendant no. 38, located at 37-39 Shelter Street, was acquired by
Solo Investments, LLC from HSBC Mortgage Services for $10.00 (transfer tax of $324.50
indicates purchase prices was $64, 900), by special limited warranty deed, dated August 20, 2009,
Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Moshe, LLC for
$1.00, by quit claim deed, dated August 31, 2009, and recorded on September 11, 2009, in
86. According to the Assessor for the City of New Haven, 37-39 Shelter Street is
REAL PROPERTY DEFENDANT NO. (39) 140 SHELTON AVENUE
87. Real property defendant no. 39, located at 140 Shelton Avenue, was acquired by L
&I Investments, LLC from U.S. Bank Trust for $90, 500, by warranty deed, dated and recorded
on December 19, 2008, in Volume 8321, at Page 62 of the New Haven Land Records.
23
88. According to the Assessor for the City of New Haven, 140 Shelton Avenue is
89. Real property defendant no. 40, located at 418 Shelton Avenue, was acquired by
Solo Investments, LLC from Novastar Mortgage Inc. for $57, 200, by special warranty deed,
dated June 29, 2009, and recorded on July 8, 2009, in Volume 8408, at Page 192 of the New
Haven Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Asset
Holdings, LLC for $1.00, by quit claim deed, dated July 6, 2009, and recorded in Volume 8408,
at Page 195. Asset Holdings, LLC, Individual A, transferred title to Shemesh, LLC for $111, 500,
by warranty deed, dated July 6, 2009, and recorded on July 8, 2009, in Volume 8408, at Page 196
90. According to the Assessor for the City of New Haven, 418 Shelton Avenue is
REAL PROPERTY DEFENDANT NO. (41) 334-336 SHERMAN AVENUE
91. The real property defendant no. 41, located at 334-336 Sherman Avenue, was
acquired by L& I Investmetns, LLC from New England Properties, LLC for $88, 000, by
warranty deed, dated March 20, 2009, and recorded on March 25, 2009, at Volume 8359, at Page
203 of the New Haven Land Records. L& I Investments, LLC transferred title to Solo
Investments, LLC for $1.00, by quit claim deed, dated April7, 2009, and recorded on April22,
1009, in Volume 8372, at Page 158. Solo Investments, LLC, by Menachem Levitin, transferred
title to New Haven Investment Group, LLC for $1.00, by quit claim deed, dated January 13,
24
92. According to the Assessor for the City of New Haven, 334-336 Sherman Avenue is
REAL PROPERTY DEFENDANT NO. (42) 342 SHERMAN AVENUE
93. Real property defendant no. 42, located at 342 Sherman Avenue, was acquired by
Solo Investments, LLC from HSBC Bank for $131, 200, by special warranty deed, dated June 23,
2009, and recorded ion July 13, 2009, in Volume 8410, at Page 217 of the New Haven Land
Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Asset Holdings, LLC
for $1.00, by quit claim deed, dated July 8, 2009, and recorded on July 14, 2009, in Volume
8410, at Page 220. Asset Holdings, LLC, by Individual A, transferred title to Shemesh, LLC for
$196, 600, by warranty deed, dated July 8, 2009, and recorded on July 14, 2009, in Volume 8410,
94. According to the Assessor for the City of New Haven, 342 Sherman Avenue is
REAL PROPERTY DEFENDANT NO. (43) 55-57 THOMPSON STREET
95. Real property defendant no. 43, located at 55-57 Thompson Street, was acquired by
Asset Holdings, LLC from JPMC Specialty Mortgage, LLC for $101, 200, by limited warranty
deed, dated April24, 2009, and recorded on May 14, 2009, in Volume 8383, at Page 65 of the
New Haven Land Records. Asset Holdings, LLC, by Individual A, conveyed the property to
Shemesh, LLC for $208, 000, by warranty deed, dated May 11, 2009, and recorded on May 14,
2009, in Volume 8383, at Page 67 of the New Haven Land Records.
96. According to the Assessor for the City of New Haven, 55-57 Thompson Street is
25
REAL PROPERTY DEFENDANT NO. (44) 443 VALLEY STREET
97. Real property defendant no. 44, located at 443 Valley Street, was acquired by Solo
Investments, LLC from U.S. Bank National Association for $30, 000, by warranty deed, dated
August 26, 2008, and recorded in Volume 8446, at Page 242 of the New Haven Land Records.
98. According to the Assessor for the City of New Haven, 443 Valley Street is assessed
at $94, 150.
REAL PROPERTY DEFENDANT NO. (45) 56-58 VICTORY DRIVE
99. Real property defendant no. 45, located at 56-58 Victory Drive, was acquired by
Solo Investments, LLC from Bank of America for $100, 600, by warranty deed, dated November
4, 2008, and recorded on December 17, 2008, in Volume 8319, at Page 287 of the New Haven
Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Asset
Holdings, LLC for $1.00, by quit claim deed, dated December 15, 2008, and recorded on
December 17, 2008, in Volume 8319, at Page 290. Asset Holdings, LLC, by Individual A,
conveyed the property to Shemesh, LLC for $156, 000, by warranty deed, dated December 15,
2008, and recorded on December 17, 2008, in Volume 8319, at Page 292 of the New Haven Land
Records.
100. According to the Assessor for the City of New Haven, 56-58 Victory Drive is
REAL PROPERTY DEFENDANT NO. (46) 159 WEST STREET
101. Real property defendant no. 46, located at 159 West Street, was acquired by New
Haven Investment Group, LLC from Bank of America for $10.00 and other valuable
consideration (tax stamps of $130.00 indicate a purchase price of $26, 000), by special limited
26
warranty deed, dated January 6, 2010, and recorded in Volume 8491, at Page 335 of the New
Haven Land Records.
102. According to the Assessor for the City of New Haven, 159 West Street is assessed
at $86, 940.
REAL PROPERTY DEFENDANT NO. (47) 579-581 WHALLEY AVENUE
103. Real property defendant no. 47, located at 579-581 Whalley Avenue, was acquired
by L& I Investments, LLC from Guardian Investments, LLC for $173, 000, by warranty deed,
dated and recorded on June 20, 2008, in Volume 8229, at Page 184 of the New Haven Land
Records.
104. According to the Assessor for the City of New Haven, 579-581 Whalley Avenue
is assessed at $212, 520.
REAL PROPERTY DEFENDANT NO. (48) 583-585 WINCHESTER AVENUE
105. Real property defendant no. 48, located at 583-585 Winchester Avenue, was
acquired by New Haven Investment LLC from Bank of New York, Trustee for $41, 900, by
special limited warranty deed, dated March 4, 2009, and recorded on April20, 2009, in Volume
8370, at Page 331 of the New Haven Land Records. New Haven Investment Group, LLC, by
Menachem Levitin, transferred title to Asset Holdings, LLC for $1.00, by quit claim deed, dated
April6, 2009, and recorded on April29, 2009, in Volume 8376, at Page74. Asset Holdings,
LLC transferred title to Shemesh, LLC for $96, 000, by warranty deed, dated April 13, 2009, and
recorded on April29, 2009, in Volume 8376, at Page 76 of the New Haven Land Records.
106. According to the Assessor for the City of New Haven, 583-585 Winchester
Avenue is assessed at $188, 790.
27
107. Real property defendant no. 49, located at 872-874 Winchester Avenue, was
acquired by Solo Investments, LLC from Robert Kielbasa, Jr. for $51, 000, by administrators
deed, dated May 1, 2009, and May 7, 2009, in Volume 8379, at Page 276 of the New Haven
Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Batia, LLC for
$1.00, by quit claim deed, on May 5, 2009, and recorded on May 7, 2009, in Volume 8379, at
Page 279 of the New Haven Land Records.
108. According to the Assessor for the City of New Haven, 872-874 Winchester
Avenue is assessed at $128, 870.
REAL PROPERTY DEFENDANT NO. (50) 510 WINTHROP AVENUE
109. Real property defendant no. 50, located at 510 Winthrop Avenue, was acquired by
Solo Investments, LLC from J.P. Morgan Chase, Trustee for $59, 900, by special warranty deed,
dated June 30, 2009, and recorded on August 20, 2009, in Volume 8429, at Page 1 of the New
Haven Land Records. Solo Investments, LLC, by Menachem Levitin, transferred title to Asset
Holdings, LLC for $1.00, by quit claim deed, dated August 11, 2009, and recorded on August 20,
2009, in Volume 8429, at Page 4. Asset Holdings, LLC, by Individual A, transferred title to
ADM Holdings, LLC for $85, 700, by warranty deed, dated August 11, 2009, and recorded on
August 20, 2009, in Volume 8429, at Page 5 of the New Haven Land Records.
110. According to the Assessor for the City of New Haven, 510 Winthrop Avenue is
28
111. Real property defendant no. 51, located at 573 Winthrop Avenue, was acquired by
New Haven Investment Group, LLC from Bank of New York, Trustee for $114, 000, by special
warranty deed, dated December 16, 2008, and recorded on December 30, 2008, in Volume 8324,
112. According to the Assessor for the City of New Haven, 573 Winthrop Avenue is
THE SCHEME UNDER INVESTIGATION
113. Special agents of the Federal Bureau of Investigation (FBI) have been
investigating a mortgage fraud scheme in New Haven individual buyers, and Connecticut real
estate brokers and sales people, mortgage brokers, and attorneys. It involves real estate
transactions involving the 51 real property defendants which consist of multi-family rental
properties.
114. The Federal Bureau of Investigation 2007 Mortgage Fraud Report describes a
number of mortgage fraud schemes, including "seller assistance scams" and "short sale scams."
In a typical seller assistance scam, a perpetrator solicits an anxious seller or his real estate agent
and offers to find a buyer for the property. The perpetrator negotiates the amount that the
property seller is willing to accept for the home. The perpetrator then hires an appraiser to inflate
the propertys value above the negotiated amount. The property is sold to a buyer who is
recruited by the perpetrator, and the sale documents reflect the inflated amount. The buyer takes
out a mortgage for the inflated amount. The seller then receives the asking price for the home
(which is lower than the inflated price), and the perpetrator either receives the difference between
29
the homes market value and the fraudulently inflated value or distributes the difference among
participants in the fraud. When the mortgage defaults, the lender forecloses on the house, but is
unable to sell it for the amount owed as a result of the inflated value. Some industry sources
have coined the phrase cash back purchase or one transaction flip to describe the scheme,
because it eliminates the need for two property transactions to generate a profit.
115. A real estate short sale is a type of pre-foreclosure sale in which the lender agrees
to sell a property for less than the mortgage owed. In a typical short sale scheme, the perpetrator
uses a straw buyer to purchase a home for the purpose of defaulting on the mortgage. Payments
are not made on the property loan so that the mortgage defaults. Prior to the foreclosure sale, the
perpetrator offers to purchase the property from the lender in a short sale agreement. The lender
agrees without knowing that the short sale was premeditated.
116. Special agents of the FBI have reviewed public documents of real estate
transactions in New Haven, and listings of real estate for sale through the Multiple Listing
Service (MLS) provided by a local real estate agent. The special agents also obtained the
mortgage records of over 50 recently foreclosed multi-family rental properties in New Haven, as
well as bank records and credit reports for some of the subjects of this investigation. In addition,
the special agents conducted interviews of people with knowledge of some of these real estate
transactions.
117. Based upon the investigation to date, there is reasonable cause to believe that
Menachem Yosef Levitin, a.k.a. Joseph Levitin, has been involved in mortgage fraud activity that
combines seller assistance scams and short sale scams. Levitin is a real estate sales person who
lives and works in New Haven, Connecticut.
30
118. The purchase price of the New Haven rental properties involved in this scam were
inflated by as much as $50, 000 to $100, 000 or more to allow the participants in the scheme to
extract cash from the fraudulent mortgages the buyers obtained. The mortgage applications for
the loans under investigation were usually faxed, or caused to be faxed, by Levitin to mortgage
companies and buyers outside the state of Connecticut. After collecting rents and paying the
mortgage for a few months to a year or more, the buyers stopped making their mortgage
payments and the property went into foreclosure. During the foreclosure process, Levitin tried to
purchase many of the houses at a short sale for a fraction of the outstanding mortgage. If the
mortgage company did not allow a short sale purchase, Levitin sometimes bid on the houses after
the foreclosure.
The Subjects
119. Menachem Yosef Levitin, a.k.a. Joseph Levitin, is a licensed real estate sales
person in Connecticut and has a pending application to be a broker. He has been doing business
as Levitin Management, LLC, Prestige Realty, LLC, and Pinsky, Chen & Levitin. He has office
space at 419 Whalley Avenue, Suite 202, New Haven. Levitin was the sales person for most of
the properties under investigation.
120. Individual Number 1, Individual Number 2, Individual Number 3, Individual
Number 4, Individual Number 5, and Individual Number 6 are all out-of-state residents. 1 They
are the buyers of most of the properties under investigation. Individual Number 1 was the first
one to buy property in New Haven, in December 2003. It appears that he brought the others into
1
The names of the individuals are being withheld at this time due to the ongoing criminal
investigation.
31
the mortgage fraud scheme because bank records show that Individual Number 1 received
commissions from Levitin and/or the closing attorneys for the other transactions.
Individual Number 1- Purchase of Twenty-Two New Haven Houses
121. Individual Number 1 purchased twenty-two multi-family houses in New Haven
from December 31, 2003 to June 22, 2007. His bank records indicate that he invested some
money into the repair of at least four of the earliest purchases and then resold those houses to
individuals unrelated to this investigation. The remaining houses appear to have been purchased
at inflated prices with mortgages close to the reported sale price, which allowed Individual
Number 1 to receive cash at the closing. He stopped paying his mortgages starting around July
2007 and fourteen of the houses went into foreclosure. After foreclosure, the houses were sold
by the banks for a fraction of what Individual Number 1 claimed to have paid for them. Another
house (624-626 Ferry Street) had a fire; Individual Number 1 collected the insurance proceeds
and re-sold the property. The remaining three properties (all of which he had purchased between
2003 and 2005) were re-sold to another individual.
122. Based upon law enforcement training and experience, persons engaged in
mortgage fraud often produce fraudulent leases for income properties to justify large mortgages.
For example, Individual Number 1's loan application dated December 20, 2006 filed with
Countrywide Home Loans, Inc. for the mortgage on 186 James Street, New Haven, appears to
include fictitious information about the income from at least one of his rental properties. It
claimed rental income of $3, 250 per month from a three-family home at 14 Bassett Street, New
Haven, which he bought on December 15, 2006. The mortgage application included copies of
three leases for 14-16 Bassett Street:
32
1 st floorIndividual C- 6/ 1/06 5/31 /07 -$1050 mo.

2nd floor Individual D- 10/1/06 9/30/07 -$1050 mo.
3rd floor Individual E- 4/1/06 3/31/07 -$1100 mo.
123. The names of those purported tenants were searched through two paid-for
database services that derive their information from credit reports. There were no indications
that anyone with those names ever resided at that address or, for that matter, anywhere else in
New Haven. Records were obtained from United Illuminating Company for all services provided
to tenants at 14-16 Bassett Street from January 1, 2006 to January 1, 2008. Although the leases
provided that the tenants were responsible for payment of electric services, United Illuminating
has no records of any services provided to Individuals C, D, and E2 at 14-16 Bassett Street during
that period. Instead, Individual Number 1 was billed for the 2nd Floor 14-16 Bassett Street
during this time period and another individual was billed for the 3rd Floor. Additionally, a
different individual was billed for 16 Bassett Street, which I believe is the 1 st Floor. The FBI has
reviewed the Bank of America checking account in which Individual Number 1 deposited his
rent checks and did not see any payment from anyone with the names listed on the leases
submitted in connection with the mortgage application for 14-16 Bassett Street namely,
Individuals C, D, and E.
124. The last property that Individual Number 1 purchased was an apartment building
with nine one-bedroom apartments located at 522 Elm Street, New Haven. Before the sale to
Individual Number 1, it was listed on the Multiple Listing Service on March 5, 2007 for
$545, 000. The MLS sheet claims it was sold on July 5, 2007 for $525, 000, but land records
2The names of the individuals are being withheld at this time due to the ongoing criminal
investigation.
33
show that it was sold to Individual Number 1 on June 22, 2007 for $670, 000. Individual Number
1 obtained two mortgages totaling $603, 000. The HUD settlement statement indicates that
Prestige Realty (i.e., Levitin) was paid a commission of $23, 625 (which is 4.5% of $525, 000, but
not a round percentage of $670, 000). A check from the Law Firm 1, the closing attorneys law
office, in the amount of $45, 414.33 payable to Individual Number 1 was deposited into
Individual Number 1's bank account on June 25, 2007. The memo section of the check had the
notation "Net-522 Elm Street New Haven." Individual Number 1 made no payments on that
mortgage. The property at 522 Elm Street went into foreclosure and after foreclosure was sold
for $200, 000. Individual Number 1 stopped paying all of his mortgages after his purchase of 522
Elm Street.
125. Individual Number 1 filed for Chapter 7 Bankruptcy on March 25, 2009. His
debts were discharged on July 2, 2009. He listed his motorcycles and cars as having secured
claims. The creditor holding those secured claims was Levitin Management LLC, a real estate
management company.
Sales From Individual Number 1 to Individual Number 2

and From Individual Number 4 to Individual Number 1
126. Individual Number 1 sold three houses to Individual Number 2 at gains of
$15, 000, $25, 000, and $85, 000. Individual Number 4 sold a house to Individual Number 1 at a
gain of $168, 000. All four of those houses went into foreclosure. After foreclosure, the houses
that Individual Number 4 and Individual Number 1 bought for $200, 000 -$400, 000 sold for
under $100, 000.
34
127. For example, a two-family house located at 108 Dewitt Street, New Haven (Real
Property Defendant No. 12) was sold on October 27, 2004 by an individual to Individual Number
1 for $150, 000. Less than a year later, on July 26, 2005, Individual Number 1 sold it to
Individual Number 2 for $235, 000. Individual Number 2 obtained a first mortgage on that date
in the amount of $211, 500 and refinanced a second mortgage a year later in the amount of
$45, 300. He stopped paying all of his mortgages, and the property was foreclosed on September
19, 2008. The lender, Bank of New York, sold it on May 22, 2009 to Batia, LLC, one of
Menachem Levitins entities, for $55, 000.
128. On April22, 2009, the amount of $32, 677.55 was wire transferred from
Menachem Levitins Wachovia Bank account number XXXXXXXXX 1666 to a bank account of
the Law Firm 1 for the purchase of the property located at 108 Dewitt Street, New Haven. On
April23, 2009, the property was conveyed to Batia, LLC, by warranty deed recorded in Volume
8389, at Page 37 of the New Haven Land Records. On May 22, 2009, Batia, LLC, by Menachem
Levitin, quit claimed the property to Asset Holdings, LLC, another one of Levitins enitites, for
$1.00. Also on May 22, 2009, Asset Holdings, LLC, by Individual A, conveyed the property to
Shemesh, LLC by Warranty deed for $121, 000.
Individual Number 4- Purchase of Ten New Haven Houses
129. Individual Number 4 purchased ten houses in New Haven from May 28, 2004 to
May 14, 2007 at what appear to be inflated prices between $185, 000 and $365, 000. He stopped
paying his mortgages starting approximately July 2007, and all ten of the houses went into
foreclosure and were then sold at prices between $34, 500 and $87, 000.
35
130. A review of MLS records and HUD Settlement Statements suggests that the
sellers of at least some of the subject properties agreed to an inflated sales price to allow the
buyers to receive cash back after the closing.
131. For example, on February 13, 2006, two sellers purchased a two-family home at
270 Davenport Avenue, New Haven (Real Property Defendant No. 10) for $105, 000. After some
renovations, a real estate agent listed the house on the Multiple Listing Service from May 2, 2006
to August 2, 2006 for $224, 960. They were apparently unable to find a buyer at that price, and
the listing expired. However, the sellers sold the house to Individual Number 4 on December 29,
2006 for $260, 000 more than $35, 000 above the asking price. Although they did not list this
property on the Multiple Listing Service, Pinsky, Chen & Levitin received a$12, 000 commission
on the sale.
132. For the 270 Davenport Avenue transaction (Real Property Defendant 10), GMAC
Mortgage Corporation provided $247, 000 in mortgages based on the sales price of $260, 000.
Law Firm 23 prepared a HUD-1 Settlement Statement that showed that the sellers received only
$195, 126.31 from the sale. Their closing costs were $2, 950.06. The balance of the mortgage
proceeds, nearly $50, 000, was apparently split among Levitin, Individual Number 4, Individual
Number 1 and others. (The HUD-1 showed Individual Number 1 receiving $5, 000 from the
mortgage proceeds, but it did not explain why. Bank records reflect a$5, 000 check deposited to
one of Individual Number 1's accounts on January 3, 2007 with the notation "Davenport.").
Three days after the closing, a check in the amount of $19, 000 drawn on the account of Law Firm
2, the closing attorneys law office, was deposited into Individual Number 4's bank account.
3The identity of Law Firm 2 is being withheld due to the ongoing investigation.
36
Individual Number 4 stopped making the mortgage payments and the property was foreclosed on
July 16, 2008. On September 24, 2008, the Federal National Mortgage Association (Fannie Mae)
sold the property following the foreclosure for $52, 000 to Solo Investment, LLC, one of
Menachem Levitins entities.
133. On September 22, 2008, the amount of $48, 811.00 was wire transferred from
Menachem Levitins Wachovia Bank account number XXXXXXXXX 1666 to a bank account of
the Law Firm 1 for the purchase of the property located at 270 Davenport Avenue, New Haven
(Real Property Defendant No. 10).
134. When a property is sold at a fraudulently inflated price, the seller has to pay
capital gains tax based on the inflated price. To avoid that result, a fictitious payment or credit
on the HUD-1 Settlement Statement is sometimes included to write down the inflated price.
Thus, for example, a repair credit of $40, 200 was included on the HUD-1 for the sale of 270
Davenport Avenue (Real Property Defendant No. 10) to Individual Number 4 on December 29,
2006, a repair credit of $34, 850 for the sale of 125 Spring Street to Individual Number 4 on
December 29, 2006, a repair credit of $28, 850 for the sale of 535 East Street to Individual
Number 4 on December 29, 2006, a repair credit of $33, 607 for the sale of 113 Poplar Street to
Individual Number 1 on December 26, 2006, a repair credit of $32, 995 for the sale of 237 West
Ivy Street to Individual Number 1 on December 26, 2006, and a repair credit of $50, 807 for the
sale of 23 Townsend Street to Individual Number 1 on December 26, 2006.
Individual Number 3- Purchase of Nine New Haven Houses
135. Individual Number 3 purchased nine multi-family houses in New Haven from
March 9, 2007 to December 7, 2007.
37
136. A two-family home at 273 Lloyd Street, New Haven was listed on the Multiple
Listing Service from December 29, 2006 to April2, 2007 by a real estate agent for $219, 900.
The price was lowered to $209, 900, but it did not sell and the listing expired. It was later sold to
Individual Number 3 on May 15, 2007, and land records indicate that the sale price was
$270, 000, more than $60, 000 above an asking price that had languished on the market for four
months. Individual Number 3 obtained a mortgage from Sterling Empire Funding in the amount
of $243, 000. Individual Number 3 stopped making mortgage payments. On May 27, 2008, a
civil action was filed in New Haven Superior Court against Individual Number 3 for foreclosure.
137. On May 8, 2009, Menachem Levitin of Prestige Realty listed 273 Lloyd Street in
the Multiple Listing Service for sale at $180, 000, with the notation "Subject to bank approval for
short sale."
138. There were two checks deposited into Individual Number 1's Bank of America
account that indicate that he received a commission on the 273 Lloyd Street transaction. One
check drawn on the account of Prestige Realty LLC, account number XXXXXXXX3556 at Bank
of America, and signed by Menachem Levitin for $5, 000 had a notation in the memo section
"273 Lloyd." The second check drawn on the account of Law Firm 3, 4 the closing attorney, for
$5, 000 had a notation in the memo section "[Seller], 273 Lloyd." Seller was the previous owner
who sold the property to Individual Number 3.
139. All of Individual Number 3's nine New Haven properties have gone into
foreclosure.
4The identity of Law Firm 3 is being withheld due to the ongoing criminal investigation.
38
Individual Number 5- Purchase of Seven New Haven Houses
140. Individual Number 5 purchased seven multi-family houses in New Haven from
June 12, 2007 to February 4, 2008.
141. On July 18, 2007, two sellers sold the three-family home at 64 Stevens Street,
New Haven, to 64 Stevens LLC for $161, 000. 64 Stevens LLC was formed on June 14, 2007 by
Menachem Levitin. On the same day, July 18, 2007, 64 Stevens Street, LLC sold the property to
Individual Number 5 for $295, 000, or $134, 00 more than what it had purchased the property for.
A review of Individual Number 1's Bank of America account revealed a deposited check drawn
on the account of the Law Firm 1, the closing attorneys law firm, made payable to Individual
Number 1 in the amount of $10, 000 with the notation "fee-64 Stevens Street."
142. Bank records reveal that checks drawn on a bank account of the Law Firm 1 were
paid to 64 Stevens, LLC, M. Levitin, and Prestige Realty. Specifically, a check drawn on a bank
account of the Law Firm 1 in the amount of $71, 276.48 made payable to 64 Stevens LLC or M.
Levitin was deposited into Menachem Levitins account number XXXXXXXXX 1666 at
Wachovia Bank on July 18, 2007. The check memo reads, Net Proceeds. A check in the
amount of $33, 354.12 was drawn on a bank account of the Law Firm 1 in the amount of
$33, 354.12 made payable to 64 Stevens, LLC was deposited into Levitin Managements account
numberXXXXXXXXX3716 at the Bank of America on July 30, 2007. The check memo reads,
net proceeds sale to Individual Number 5. A check drawn on a bank account of the Law Firm
1 in the amount of $20, 000 made payable to Prestige Realty was deposited into Levitin
Managements account numberXXXXXXXXX3716 at the Bank of America on July 30, 2007.
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143. Individual Number 5 fraudulently obtained a$206, 500 mortgage loan from Wells
Fargo for the property located at 64 Stevens Street, New Haven. Individual Number 5 did not
disclose, however, that he had seven additional mortgage loans totaling $1, 753,900, including a
$568, 200 mortgage with Mortgageit and a$125, 000 GMAC mortgage on property located at 755
Webster Avenue, New Rochelle, New York.
144. Individual Number 5 purchased seven houses in New Haven, and Individual
Number 1's bank records indicate that he received some type of payment for each of them. There
were two checks deposited into Individual Number 1's Bank of America account for Individual
Number 5's purchase of a two-family house at 148 Lloyd Street, New Haven. Both checks were
drawn on the account of the Law Firm 3 and dated June 12, 2007. The first was for $5, 000 made
payable to Individual Number 1 with a notation in the memo section "Quantum Family 148."
Quantum Family Partnership was the previous owner, who sold the property to Individual
Number 5. The second check, in the amount of $20, 000, was made payable to Prestige Realty
with a notation in the memo section "Quantum Family 148 Commission 148 Lloyd St, New
Haven." It was endorsed by Menachem Levitin and deposited into Individual Number 1's bank
account.
145. All seven of Individual Number 5's New Haven properties have gone into
foreclosure.
Individual Number 6- Purchase of Five New Haven Houses
146. Individual Number 6 purchased five multi-family houses in New Haven from
August 8, 2007 to October 22, 2007.
40
147. For example, a two-family house located at 151 Plymouth Street in New Haven
was listed on the MLS from December 8, 2006 to May 8, 2007 for $199, 900. It was sold to
Individual Number 6 on September 4, 2007 for $245, 000. A check in the amount of $2, 000
made payable to Individual Number 1 dated September 7, 2007, drawn on account
numberXXXXXXXXX3 55 6, held in the name of Prestige Realty, LLC at Bank of America with
a notation "151 Plymouth, was deposited into Individual Number 1's Bank of America account.
148. Notices of foreclosures have been recorded on the New Haven Land Records in
four of the five houses that Individual Number 6 purchased in New Haven. Bank records
indicate that Individual Number 1 received at least $17, 000 for Individual Number 6's five
transactions.
Short Sales
149. Although Levitin did not have any Multiple Listing Service contracts for the
houses, he received a commission for the sale of at least fourteen houses purchased by Individual
Number 1 and Individual Number 4. Individual Number 1 and Individual Number 4 stopped
making their mortgage payments on each of these properties. During the foreclosure
proceedings, Individual F, a real estate agent doing business as Platinum Associates, contacted
GMAC Mortgage Corporation's loss mitigation department on March 25, 2008, stating that he
had been authorized by Individual Number 1 to sell the below listed properties and had received
an offer from Menachem Levitin for short sales on seven houses:
(1) 517 Winchester Avenue

(2) 289 Division Street
(3) 21-23 Sheffield Street
(4) 261 West Ivy
(5) 37-39 Truman Street
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(6) 151 Saltonstall Avenue

(7) 1536 Ella Grasso Boulevard
150. In a letter dated August 6, 2008, from Platinum Associates to GMAC, Individual
F urged them to proceed with the short sale of 151 Saltonstall to Levitin before the copper pipes
were stolen. In an appraisal report, dated October 8, 2008, the appraiser noted that copper pipes
had been removed.
151. GMAC apparently did not allow any short sales to Levitin, but Levitin has
purchased one of the foreclosed Individual Number 1/Individual Number 4 houses in his name;
he purchased one in the name of Solo Investments, LLC; and his partner, Individual B, has
purchased one. I interviewed the purchaser of a foreclosed house in New Haven. That individual
described Levitin and said that he has been bidding on all of the foreclosures in New Haven.
152. Levitin succeeded in buying a house at 186 James Street, New Haven (Real
Property Defendant No. 26) by way of a short sale. Individual Number 1 bought the house on
January 5, 2007 for $262, 000, with $220, 400 in mortgages from Countywide Home Mortgage
Corporation. From this sale, Levitin received a commission in the amount of $11, 450.00 which
was deposited into his Prestige Realty, LLC account numberXXXXXXXXX3556 at Bank of
America on January 8, 2007. Individual Number 1 stopped paying the mortgage and Countywide
apparently agreed to a short sale to Menachem Levitin on or about September 17, 2008 for
$105, 000. Bank records indicate that the amount of $102, 679.03 was wire transferred from Tami
Research & Developments account numberXXXXXXX2399 at RBS Citizens Bank to the Law
Firm 1 on September 11, 2008. Also on September 11, 2008, check number 1569 drawn on
account number XXXXXXX3716 held in the name of Levitin Managment, LLC at the Bank of
42
America in the amount of $10, 000 was made payable to Parnosa, LLC with the notation,
purchase 186 James. On September 15, 2008, Menachem Levitin quit claimed the property for
$1.00 to Tami Research & Development, LLC. On December 2, 2009, Tami Research &
Development, LLC, by Menachem Levitin, quit claimed the property to New Haven Investment
Group, LLC.
153. The mortgage file for 522 Elm Street contains correspondence from Individual F
of Platinum Associates dated March 22, 2008, following Individual Number 1's default but prior
to the foreclosure. The correspondence stated that Individual F had a potential buyer for the
property and he was authorized by Individual Number 1 to discuss it with the lender.
154. Examination of records from the Connecticut Secretary of State and other sources
indicates that Menachem Levitin has participated in the organization of a number of limited
liability corporations as agent, member, or both. Many of these corporations have been involved
in real estate transactions, including many of the transactions discussed in this affidavit. Those
corporations include the following:
(1) 161 Edgewood, LLC

(2) L&I Investments, LLC
(3) Solo Investments, LLC
(4) Moshe, LLC
(5) Parnosa, LLC
(6) Tami Research and Development, LLC
(7) Beit Aviv, LLC
(8) Beit Aviv II, LLC
(9) New Haven Investment Group, LLC
(10) Shemesh, LLC
(11) White Oak New Haven, LLC
(12) Batia, LLC
(13) ADM Holdings, LLC
43
155. Additionally, there have been a number of real estate transactions in which
properties were purchased by Levitin and/or some of the above-listed corporations, and then
transferred to Asset Holdings, LLC, and then re-sold to Levitin and/or some of the above-listed
corporations. Records of the Connecticut Secretary of State indicate that Asset Holdings, LLC,
was formed by an individual, Individual A, and lists Levitin's post office box as its mailing
address. Moreover, the residential address listed for Individual A is a property owned by Levitin.
Individual A is employed by Levitin Management.
156. The special agents of the FBI have interviewed a cooperating witness (CW) in
the course of this investigation. The CW has purchased one or more properties in New Haven
through Levitin. Levitin told the CW that his company would take care of all aspects of real
estate management, including the placement and eviction of tenants, repairs, maintenance, and
rent collection. Levitin would get 10 percent of the rents as payment. Levitin told the CW that
he would also find properties that the CW could buy without using any of the CWs own money
157. The CW told special agents of the FBI that although the purchase and sale
agreement(s) stated that a deposit was given to the seller on the date of the agreement, no
deposits were in fact made. Indeed, the CW received some money at the closings.
158. The CW did not know what the formula was that determined how much money
he/she got back at the closing. Levitin would first obtain an appraisal, which would be the stated
purchase price on the purchase and sale agreement. Levitin would then negotiate a lower price
with the seller that would be the actual purchase price. Levitin told the CW that there would be
cash back if he could work it out. Levitin handled the negotiations. The CW had little or no
contact with the appraisers of the sellers.
44
159. The mortgage companies required copies of leases to substantiate the income from
the rental property. The CW told the special agents of the FBI that only about half of the unit
that the CW purchased were occupied. Levitin made fictitious leases for the unoccupied units
that were submitted in support of the fraudulent mortgage applications. Levitin made fictitious
leases in the CWs presence on Levitins computer.
160. Levitin offered to pay the CW a commission for anyone the CW brought to him
and purchased a house. The CW did, in fact, refer other purchasers to Levitin and received a
commission on their purchases.
POTENTIAL MONEY LAUNDERING
161. Based on the investigation, the FBI believes that money Levitin received from
approximately forty real estate transactions with Individual Number 1, Individual Number 4,
Individual Number 3, Individual Number 5 and Individual Number 6, was used to purchase and
renovate approximately fifty-one houses in New Haven that Levitin and other investors now own
and operate as rental properties.
162. Levitin's commissions for the real estate transactions generally ranged from
$12, 500.00 to $23, 625.00. Based on a review of Levitins bank records, he may have received
more than just the commissions. According to the purchase and sale agreement for the sale of
423 Blatchley Avenue from the seller to Individual Number 5, for example, Prestige Realty was
supposed to receive a commission of $20, 000. An examination of Levitin Managements Bank
of America bank account numberXXXXXXXXX3716 show that Levitin deposited one check
drawn on the account of the closing attorney labeled "423 Blatchley Ave" in the amount of
$9, 450.00. A second check in the amount of $30, 196.83 made payable to the seller was endorsed
45
and deposited instead into the Levitin Management account. Those figures do not correspond to
the HUD-1 Settlement Statement for the property.
163. Commission checks and other proceeds from the real estate transactions under
investigation were deposited into the Prestige Realty Account and the Levitin Management
account at Bank of America. The proceeds were then transferred to accounts in the name of
Menachem Levitin at Citizens Bank and Wachovia Bank.
164. Levitin attempted to purchase Individual Number 1's properties at short sales
during the foreclosure process, offering a fraction of the amount of Individual Number 1's
mortgages. With the exception of 186 James Street (Real Property Defendant No. 26), which he
purchased for $105, 000 at a short sale, the mortgage companies would not allow short sales to
Levitin. Levitin began bidding on foreclosed houses in New Haven and purchased forty-one
foreclosures from March 27, 2008 to February 10, 2010. The purchase prices ranged from
$23, 800 to $166, 000, which were low compared to the last sales price.
165. According to the records of the Connecticut Secretary of State, Levitin formed
eleven limited liability companies (LLCs) from April2, 2008 to August 9, 2009. Another, Asset
Holdings, LLC, was formed on October 14, 2008 by one of Levitin's employees, Individual A,
and listed Levitin's post office box as its mailing address.
166. Levitin has transferred many of the houses he purchased from one LLC to another
LLC two or three times. Levitin has transferred ten of the houses from one of his LLCs, then to
Asset Holdings, LLC and back to another one of his LLCs on the same day. For example, on
October 2, 2008, Solo Investment LLC, one of Levitin's limited liability companies, purchased a
house at 382 Lombard Street (Real Property Defendant No. 28) in a foreclosures sale from Bank
46
of New York for $166, 000. It was transferred to Asset Holdings, LLC for $1.00 on October 24,
2008. Individual A, acting on behalf on Assets Holdings, LLC, transferred it, on the same day, to
Beit Aviv, LLC for $206, 000. Beit Aviv, LLC is another limited liability company controlled by
Levitin.
SOURCE OF FUNDS USED TO PURCHASE

THE REAL PROPERTY DEFENDANTS
167. The money Levitin used to purchase the real property defendants has been traced
to the Prestige Realty, account numberXXXXXXXXX3556, and the Levitin Management,
account numberXXXXXXXXX3716, at Bank of America, as well as the Menachem Levitin
controlled accounts at Citizens bank and Wachovia bank.
168. The investigation revealed that the commissions Levitin received from the
properties purchased at overinflated prices were deposited into Levitins Prestige Realty account
numberXXXXXXXXX3556 at Bank of America, his Levitin Management account number
XXXXXXXX3716 at Bank of America, and account numberXXXXXXXXXX1666, held in the
name of Menachem Y. Levitin at Wachovia Bank. The investigation also revealed that Levitin
moved the funds from those accounts to other accounts in his name or the names of his entities
under his control, as well as to accounts held in the names of others for the purchase the real
property defendants.
169. Levitin used accounts in his name and in the names of his entities to facilitate the
fraudulent scheme. The investigation has revealed that Levitin used four accounts at the Bank of
America, held in the names of L& I Investments, LLC, Levitin Management, LLC, Menachem
Levitin, and Prestige Realty, LLC; six accounts at RBS Citizens Bank, held in names of
47
Menachem Yosef Levitin, New Haven Capital Investment, LLC, Parnosa, LLC, Shemesh, LLC,
Solo Investments, LLC, and Tami Research & Development, LLC; and one account at Wachovia
Bank, held in the name of Menachem Y. Levitin. Levitin used these accounts to purchase the
real property defendants.
REAL PROPERTY DEFENDANT NO. (1) 197-199 BASSETT STREET
170. On February 1, 2010, the amount of $57, 700.00 was wire transferred from account
numberXXXXXXX5998, held in the name of New Haven Capital Investment, LLC at RBS
Citizens Bank to a Peoples Bank account held in the name of Law Firm 1.5 The wire memo
indicates it is for 197 Bassett St. The New Haven Land Records indicate that on January 15,
2010, New Haven Investment Group, LLC purchased 197-199 Bassett Street for $55, 200.
REAL PROPERTY DEFENDANT NO. (2) 25-29 BATTER STREET
171. On June 25, 2008, check number 1482 drawn on account number
XXXXXXXXX3716, held in the name of Levitin Management, LLC at Bank of America in the
amount of $5, 000.00 was made payable to Total Realty, Inc. The New Haven Land Records
indicate that on August 15, 2008, Solo Investments, LLC purchased 25-29 Batter Street for
$106, 750.
REAL PROPERTY DEFENDANT NO. (3) 81-83 BEERS STREET
172. On May 14, 2008, check number 1456 drawn on account number
XXXXXXXX3716, held in the name of Levitin Management, LLC at Bank of America in the
amount of $5, 000.00 was made payable to Prudential CT Realty with a memo notation, Deposit
81-83 Beers. On June 2, 2008, check number 294 drawn on account number
5The identity of Law Firm 1 is being withheld due to the ongoing criminal investigation.
48
XXXXXXXXXX 1666, held in the name Menachem Y. Levitin, at Wachovia Bank in the amount
of $52, 750 was made payable to Parnosa, LLC with a memo notation, owner contribution/81
Beers. The New Haven Land Records indicate that on June 26, 2008, Menachem Levitin
purchased 81-83 Beers Street for $165, 000.
REAL PROPERTY DEFENDANT NO. (4) 501 BLATCHLEY AVENUE
173. The special agents of the FBI have traced monies from accounts controlled by
Menachem Levitin at Bank of America, RBS Citizens, and Wachovia to a bank account at
Peoples Bank held in the name of the Law Firm 1. It is believed that the monies from the
properties purchased at overinflated prices deposited into those accounts were ultimately used to
purchase 501 Blatchley Avenue.
REAL PROPERTY DEFENDANT NO. (5) 136 CARLISLE STREET
account number XXXXXX3877, held in the name of Solo Investments, LLC at RBS Citizens
Bank to a Peoples Bank account in the name of Law Firm 1. Law enforcement believe that
these funds were used for the purchase of 136 Carlisle Street, or one of the other real property
defendants. The New Haven Land Records indicate that on September 15, 2009, Solo
Investments, LLC purchased 136 Carlisle Street for $35, 600.
REAL PROPERTY DEFENDANT NO. (6) 561 CENTRAL AVENUE
175. On September 29, 2008, check number 235 drawn on account number
XXXXXXXXX 1666, held in the name of Menachem Y. Levitin at Wachovia Bank in the
amount of $2, 000.00 was made payable to Buyers Capital Real Estate with a memo notation,
49
deposit 561 Central. The New Haven Land Records indicate that on October 22, 2008,
Menachem Levitin purchased 561 Central Avenue for $90, 000.
REAL PROPERTY DEFENDANT NO. (7) 115 CLAY STREET
account number XXXXXXXX2166, held in the name of Menachem Y. Levitin at Wachovia
Bank to a Peoples Bank account in the name of Law Firm 1. Law enforcement believe that
these funds were used for the purchase of 115 Clay Street, or one of the other real property
defendants. The New Haven Land Records indicate that on September 12, 2008, Solo
Investments, LLC purchased 115 Clay Street for $52, 000.
REAL PROPERTY DEFENDANT NO. (8) 15 COLBY COURT
177. On November 10, 2008, the amount of $78, 000 was wire transferred from account
number XXXXXX6064, held in the name of Shemesh, LLC at RBS Citizens Bank to a Peoples
Bank account in the name of Law Firm 1. Law enforcement believe that these funds were used
for the purchase of 15 Colby Court, or one of the other real property defendants. On December
17, 2008, check number 991 drawn on account number XXXXXX7640, held in the name of New
Haven Investment Group, LLC at RBS Citizens Bank in the amount of $2, 000.00 was made
payable to Lavigne Mark & Rogers with a memo notation, Deposit 15 Colby CT. The New
Haven Land Records indicate that on December 3, Solo Investments, LLC purchased 15 Colby
Court for $75, 500.
REAL PROPERTY DEFENDANT NO. (9) 141 COUNTY STREET
50
purchase 141 County Street.
amount of $5, 200.00 was made payable to Weichert Regional Properties with a memo notation,
Deposit 270 Davenport Ave. On September 22, 2008, the amount of $48, 811 was wire
transferred from account number XXXXXXXXX 1666, held in the name of Menachem Y.
Levitin at Wachovia Bank to a Peoples Bank account in the name of Law Firm 1 with the
notation, 270 Davenport purchase. The New Haven Land Records indicate that on September
24, 2008, Solo Investments, LLC purchased 270 Davenport Avenue for $52, 000.
180. On August 26, 2009, check number 2062 drawn on account number
amount of $714.00 was made payable to Riccio Realty. The check indicates it is for the deposit
280 Davenport. The New Haven Land Records indicate that on August 31, 2009, Solo
Investments, LLC purchased 280 Davenport Avenue for $23, 800.
181. On September 11, 2009, the amount of $25,446.68 was wire transferred from
Bank, to a Peoples Bank account in the name of Law Firm 1. The wire memo indicates it was
for 280 Davenport.
51
REAL PROPERTY DEFENDANT NO. (12) 108 DEWITT STREET
182. On April22, 2009, the amount of $32, 677.55 was wire transferred from account
number XXXXXXXXX 1666, held in the name of Menachem Y. Levitin at Wachovia Bank, to a
Peoples Bank account in the name of Law Firm 1. Law enforcement believe that these funds
were used for the purchase of 108 Dewitt Street, or one of the other real property defendants. On
April23, 2009, Batia, LLC purchased 108 Dewitt Street for $55, 000.
REAL PROPERTY DEFENDANT NO. (13) 205-207 DOVER STREET
183. On December 17, 2008, the amount of $84, 119.96 was wire transferred from
account number XXXXXX4842, held in the name of Menachem Yosef Levitin at RBS Citizens
Bank to a Peoples Bank account held in the name of Law Firm 1. Law enforcement believe that
these funds were used for the purchase of 205-207 Dover Street, or one of the other real property
defendants. The New Haven Land Records indicate that on December 17, 2008, Solo
Investments, LLC purchased 205-207 Dover Street for $82, 000.
REAL PROPERTY DEFENDANT NO. (14) 161 EDGEWOOD AVENUE
184. On July 30, 2007, check number 20 drawn on account number
XXXXXXXX8340, held in the name of Menachem Levitin at Bank of America, in the amount of
$5, 000, was made payable to Gene Fontanella Real Estate. The check indicates it is for the
deposit 161 Edgewood Ave. The New Haven Land Records indicate that on September 10,
2007, Menachem Levitin and Individual B purchased 161 Edgewood Avenue for $315, 000.
185. On February 8, 2010, the amount of $14, 602.24 was wire transferred from account
number XXXXXX3877, held in the name of Solo Investments, LLC at RBS Citizens Bank to a
52
Peoples Bank account held in the name of Law Firm 1. Law enforcement believe that these
funds were used for the purchase of 357 Ellsworth Avenue, or one of the other real property
defendants. The New Haven Land Records indicate that on February 10, 2010, Menachem
Levitin purchased 357 Ellsworth Avenue for $104, 000.
186. On March 25, 2009, check number 1839 drawn on account number
XXXXXXXX3716, held in the name of Levitin Management, LLC at Bank of America, in the
amount of $2, 000.00 was made payable to Riccio Realty. The check indicates it is for the
deposit 363 Ellsworth Ave. The New Haven Land Records indicate that on April 15, 2009,
Menachem Levitin purchased 363 Ellsworth Avenue for $86, 200.
REAL PROPERTY DEFENDANT NO. (17) 212-214 ENGLISH STREET
187. On March 25, 2009, the amount of $68, 311.14 was wire transferred from account
number XXXXXX8183, held in the name of Batia, LLC at RBS Citizens Bank to a Peoples
Bank account held in the name of Law Firm 1. Law enforcement believe that these funds were
used for the purchase of 136 Carlisle Street, or one of the other real property defendants. The
New Haven Land Records indicate that on March 20, 2009, Solo Investments, LLC purchased
212-214 English Street for $65, 200.
REAL PROPERTY DEFENDANT NO. (18) 286 EXCHANGE STREET
188. On November 11, 2008, the amount of $57, 630.83 was wire transferred from
account number XXXXXX7632, held in the name of New Haven Investment Group, LLC at
RBS Citizens Bank to a Peoples Bank account held in the name of Law Firm 1. Law
enforcement believe that these funds were used for the purchase of 286 Exchange Street, or one
53
of the other real property defendants. The New Haven Land Records indicate that on December
12, 2008, White Oak New Haven, LLC purchased 286 Exchange Street for $104, 000.
REAL PROPERTY DEFENDANT NO. (19) 299 GREENWICH STREET
189. On November 18, 2009, the amount of $34, 000 was wire transferred from account
number XXXXXX6787, held in the name of Parnosa, LLC at RBS Citizens Bank to a Peoples
used for the purchase of 299 Greenwich Street, or one of the other real property defendants. The
New Haven Land Records indicate that on November 23, 2009, Moshe purchased 299
Greenwich Street for $30, 200.
REAL PROPERTY DEFENDANT NO. (20) 222 HALLOCK AVENUE
purchase 222 Hallock Avenue.
REAL PROPERTY DEFENDANT NO. (21) 89 HAZEL STREET
191. On February 1, 2010, the amount of $57, 700 was wire transferred from account
number XXXXXX5998, held in the name of New Haven Capital Investment, LLC at RBS
Citizens Bank to a Peoples Bank account held in the name of Law Firm 1. Law enforcement
believe that these funds were used for the purchase of 89 Hazel Street, or one of the other real
property defendants. The New Haven Land Records indicate that on February 9, 2010, Solo
Investments, LLC purchased 89 Hazel Street for $27, 100.
54
192. Check number 2407 drawn on account number XXXXXXXX3556, held in the
name of Prestige Realty, LLC at Bank of America, in the amount of $2, 000.00 was made payable
to Buyers Captial with a memo notation, Deposit for 314 Howard. On October 31, 2008, the
amount of $122, 891.44 was wire transferred from account number XXXXXX6064, held in the
name of Shemesh, LLC at RBS Citizens Bank to a Peoples Bank account held in the name of
Law Firm 1. Law enforcement believe that these funds were used for the purchase of 314
Howard Avenue, or one of the other real property defendants. The New Haven Land Records
indicate that on November 4, 2008, Solo Investments purchased 314 Howard Haven for
$120, 000.
193. On January 15, 2010, the amount of $47, 958.57 was wire transferred from
account number XXXXXX5998, held in the name of New Haven Capital Investment, LLC at
RBS Citizens Bank to a Peoples Bank account held in the name of Law Firm 1. The wire memo
indicates it is for 490 Howard. The New Haven Land Records indicate that on January 5,
2010, New Haven Investment Group, LLC purchased 490 Howard Avenue for $45, 000.
REAL PROPERTY DEFENDANT NO. (24) 456 HUNTINGTON STREET
indicates it is for Huntington St. The New Haven Land Records indicate that on January 15,
2010, Solo Investment Group, LLC purchased 456 Huntington Streetfor $28, 000.
55
REAL PROPERTY DEFENDANT NO. (25) 88-89 HURLBURT STREET
purchase 88-89 Hurlburt Street.
amount of $10, 000.00 was made payable to Parnosa, LLC. The check indicates it is for the
purchase 186 James Street. Also on September 11, 2008, the amount of $102, 679.03 was wire
transferred from account number XXXXXX2399, held in the name of Tami Research &
Development, LLC (one of Levitins entities) at RBS Citizens Bank, to a Peoples Bank account
held in the name of Law Firm 1. Law enforcement believe that these funds were used for the
purchase of 186 James Street, or one of the other real property defendants. The New Haven Land
Records indicate that on September 17, 2008, Menachem Levitin purchased 186 James Street for
$105, 000.
XXXXXXXX3716, held in the name of Levitin Management, LLC (one of Levitins entities) at
Bank of America in the amount of $5, 000.00 was made payable to Law Firm 1. The check
indicates it is for deposit 265 James Street. On April3, 2008, check number 1407 drawn on
56
account number XXXXXXXX3716, held in the name of Levitin Management, LLC at Bank of
America, in the amount of $29, 798.52, was made payable to Law Firm 1. The check indicates it
is for closing 265 James Street. The New Haven Land Records indicate that on March 27,
2008, Menachem Levitin purchased 265 James Street for $95, 000.
REAL PROPERTY DEFENDANT NO. (28) 382 LOMBARD STREET
198. On October 23, 2008, check number 85 drawn on account number
XXXXXXXX4671, held in the name of L& I Investments, LLC at Bank of America, in the
amount of $11, 144.30, was made payable to Law Firm 1. The check indicates it is for the
closing of 382 Lombard Street. The New Haven Land Records indicate that on October 2,
2008, Solo Investments, LLC (one of Levitins entities) purchased 382 Lombard Street for
$166, 600.00.
199. On July 28, 2008, check number 47 drawn on account number
amount of $15, 842.50, was made payable to Parnosa, LLC (one of Levitins entities). The check
indicates it is for the Purchase of 19-21 Norton Street. On July 28, 2008, check number 307
drawn on account number XXXXXXXXX 1666, held in the name of Menachem Y. Levitin, at
Bank of America, in the amount of $28, 437.50, was made payable to Parnosa, LLC. The check
indicates it is for the purchase of 19 Norton Street. On August 12, 2008, the amount of
$78, 080.34 was wire transferred from account number XXXXXX6787, held in the name of
Parnosa, LLC at RBS Citizens Bank, to a Peoples Bank account held in the name of Law Firm
1. Law enforcement believe that these funds were used for the purchase of 19-21 Norton Street,
57
or one of the other real property defendants. The New Haven Land Records indicate that on
August 8, 2008, Parnosa, LLC purchased 19-21 Norton Street for $75, 000.
RBS Citizens Bank to a Peoples Bank account held in the name of Law Firm 1. Law
enforcement believe that these funds were used for the purchase of 279-281 Norton Street, or one
of the other real property defendants. The New Haven Land Records indicate that on October 5,
2009, 279-281 Norton Street was purchased by Solo Investments, LLC for $112, 000.
REAL PROPERTY DEFENDANT NO. (31) 353 ORCHARD STREET
201. On February 23, 2009, check number 149 drawn on account number
XXXXXXX94671, held in the name of L& I Investments, LLC at Bank of America, in the
amount of $60, 900.67, was made payable to Law Firm 1. Law enforcement believe this check
was for the purchase of 353 Orchard Street. The New Haven Land Records indicate that on
February 24, 2009, L& I Investments, LLC purchased 353 Orchard Street for $66, 200.
REAL PROPERTY DEFENDANT NO. (32) 378-380 ORCHARD STREET
Bank to a Peoples Bank account in the name of Law Firm 1. The wire memo indicates it was
for 378 Orchard St. The New Haven Land Records indicate that on September 23, 2009, Solo
Investments, LLC purchased 378-380 Orchard Street for $97, 000.
58
REAL PROPERTY DEFENDANT NO. (33) 95 PARDEE STREET
203. On July 15, 2009, the amount of $44, 900.22 was wire transferred from account
numberXXXXXXX3877, held in the name of Solo Investments, LLC at RBS Citizens Bank to a
funds were used for the purchase of 95 Pardee Street, or one of the other real property
defendants. The New Haven Land Records indicate that on July 9, 2009, Solo Investments, LLC
purchased 95 Pardee Street for $43, 300.
REAL PROPERTY DEFENDANT NO. (34) 122-124 PLYMOUTH STREET
amount of $10, 000.00 was made payable to William Raveis Trustee with memo notation,
deposit 122-124 Plymouth New Haven. The New Haven Land Records indicate that on April
3, 2008, Menachem Levitin purchased 122-124 Plymouth Street for $165, 000.
REAL PROPERTY DEFENDANT NO. (35) 97-99 ROCK CREEK ROAD
205. On May 22, 2009, the amount of $82, 666.33 was wire transferred from account
used for the purchase of 97-99 Rock Creek Road, or one of the other real property defendants.
The New Haven Land Records indicate that on May 22, 2009, Asset Holdings, LLC purchased
97-99 Rock Creek Road for $80, 300.
59
REAL PROPERTY DEFENDANT NO. (36) 41 SHEFFIELD AVENUE
206. On February 10, 2010, the amount of $50, 590 was wire transferred from account
numberXXXXXXX3877, held in the name of Solo Investments, LLC at RBS Citizens Bank to a
Peoples Bank account held in the name of Law Firm 1 with a memo notation, 41 Sheffield.
The New Haven Land Records indicate that on February 8, 2010, Solo Investments, LLC
purchased 41 Sheffield Avenue for $45, 000.
REAL PROPERTY DEFENDANT NO. (37) 8 SHELTER STREET
purchase 8 Shelter Street.
REAL PROPERTY DEFENDANT NO. (38) 37-39 SHELTER STREET
208. On August 10, 2009, the amount of $65, 724.10 was wire transferred from account
used for the purchase of 37-39 Shelter Street, or one of the other real property defendants. The
New Haven Land Records indicate that on August 20, 2009, Solo Investments, LLC purchased
37-39 Shelter Street for $10.00 (transfer tax of $324.50 indicates a purchase price of $64, 900).
209. On December 17, 2008, the amount of $84, 119.96 was wire transferred from
account number XXXXXX4842, held in the name of Menachem Yosef Levitin at RBS Citizens
60
Bank to a Peoples Bank account held in the name of Law Firm 1. Law enforcement believe that
these funds were used for the purchase of 140 Shelton Avenue, or one of the other real property
defendants. The New Haven Land Records indicate that on December 19, 2008, L& I
Investments, LLC purchased 140 Shelton Avenue for $90, 500.
210. On June 30, 2009, the amount of $64, 906.47 was wire transferred from account
Bank account held in the name of Law Firm 1. The wire memo indicates it is for 418 Shelton.
The New Haven Land Records indicate that on June 29, 2009, Solo Investments, LLC purchased
418 Shelton Avenue for $57, 200.00.
REAL PROPERTY DEFENDANT NO. (41) 334-336 SHERMAN AVENUE
purchase 334-336 Sherman Avenue.
REAL PROPERTY DEFENDANT NO. (42) 342 SHERMAN AVENUE
212. On July 8, 2009, the amount of $141, 380.47 was wire transferred from account
Bank account held in the name of Law Firm 1. The wire memo indicates it is for 342
Sherman. The New Haven Land Records indicate that on June 23, 2009, Asset Holdings, LLC
purchased 342 Sherman Avenue for $30, 000.00.
61
REAL PROPERTY DEFENDANT NO. (43) 55-57 THOMPSON STREET
used for the purchase of 55-57 Thompson Street, or one of the other real property defendants.
The New Haven Land Records indicate that on April24, 2009, Asset Holdings, LLC purchased
55-57 Thompson Street for $208, 000.
REAL PROPERTY DEFENDANT NO. (44) 443 VALLEY STREET
214. On September 8, 2008, the amount of $32,490.28 was wire transferred from
account number XXXXXX6787, held in the name of Parnosa, LLC at RBS Citizens Bank, to a
Peoples Bank account held in the name of Law Firm 1. The wire memo indicates it is for 443
Valley Street. The New Haven Land Records indicate that on August 26, 2008, Solo
Investments, LLC purchased 443 Valley Street for $30, 000.00.
REAL PROPERTY DEFENDANT NO. (45) 56-58 VICTORY DRIVE
purchase 56-58 Victory Drive.
REAL PROPERTY DEFENDANT NO. (46) 159 WEST STREET
62
indicates it is for Sherman and West. The New Haven Land Records indicate that on January
6, 2010, New Haven Investment Group, LLC purchased 159 West Street for $10.00 and other
valuable consideration (tax stamps of $130.00 indicate a purchase price of $26, 000).
REAL PROPERTY DEFENDANT NO. (47) 579-581 WHALLEY AVENUE
217. On June 18, 2008, check number 30 drawn on account number
amount of $175, 000, was made payable to Law Firm 1. The check indicates it is for the
purchase of 579-581 Whalley Ave. The New Haven Land Records indicate that on June 20,
2008, L& I Investments, LLC purchased 579-581 Whalley Avenue for $173, 00.
218. On February 19, 2009, check number 99 drawn on account number
XXXXXX6064, held in the name of Shemesh, LLC at RBS Citizens Bank, the amount of
$42, 508.79 was made payable Law Firm 1, with a memo notation, Purchase 585 Winchester.
Check number 172 drawn on account number XXXXXXXX4671, held in the name of L& I
Investments, LLC at Bank of America, the amount of $2, 851 was made payable Law Firm 1,
with a memo notation, 585 Winchester. The New Haven Land Records indicate that on March
4, 2009, New Haven Investment, LLC purchased 5 83 -5 85 Winchester Avenue for $41, 900.
63
funds were used for the purchase of 872-874 Winchester Avenue, or one of the other real
property defendants. On February 9, 2009, check number 1746 drawn on account number
amount of $2, 000.00 was made payable to Sette Real Estate with memo notation, Deposit 872
Winchester. The New Haven Land Records indicate that on May 1, 2009, Solo Investments,
LLC purchased 872-874 Winchester Avenue for $51, 000.
funds were used for the purchase of 510 Winthrop Avenue, or one of the other real property
defendants. The New Haven Land Records indicate that on May 1, 2009, Solo Investments, LLC
purchased 510 Winthrop Avenue for $59, 900.
221. November 6, 2008, the amount of $117, 764.10 was wire transferred from account
number XXXXXX7139, held in the name of Beit Aviv, LLC at RBS Citizens Bank to a Peoples
used for the purchase of 573 Winthrop Avenue, or one of the other real property defendants. The
New Haven Land Records indicate that on December 16, 2008, New Haven Investment Group,
LLC purchased 573 Winthrop Avenue for $114, 000.
64
CONCLUSION
222. The Real Property Defendants were involved in a transaction or attempted
transaction, or traceable thereto, in violation of 18 U.S.C. 1956 and 1957, or represent
property which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C.
1343, and are therefore subject to forfeiture pursuant to 18 U.S.C. 981(a)(1)(A); or that they
constitute or are derived from proceeds traceable to an offense constituting specified unlawful
activity (as defined in 18 U.S.C. 1956(c)(7)), namely wire fraud in violation of 18 U.S.C.
1343, and are therefore subject to forfeiture pursuant to 18 U.S.C. 981(a)(1)(C).
WHEREFORE, the United States of America respectfully asserts that there is reasonable
belief that the 51 Real Property Defendants are subject to forfeiture to the United States pursuant
to 18 U.S.C. 981(a)(1)(A) or (C); and requests
(a) that pursuant to 18 U.S.C. 985(b)(2), and 18 U.S.C. 981(j), which permits the
Court to take any action to preserve the availability of the property subject to civil
forfeiture, the Court issue the proposed Writs of Entry submitted with this Verified Complaint
of Forfeiture authorizing the United States Marshals Service, or its delegate, to enter the 51 Real
Property Defendants, including any structures, on one or more occasions during the pendency of
this in rem forfeiture action:
(1) for the purpose of conducting an inspection and inventory and appraisal of the 51
Real Property Defendants, which inspection and inventory and appraisal may
include still and video photography;
65
(2) to be accompanied on any such occasion by any appraiser(s) selected by it to
appraise the condition and value of the 51 Real Property Defendants pursuant to
19 U.S.C. 1606;
(3) to be accompanied on any such occasion by any government or contract personnel
selected by it for the purpose of conducting an inventory of the 51 Real Property
Defendants; and
(4) to be accompanied on any such occasion by any federal, state, or local law
enforcement officers selected by it to ensure the safety of any person acting under
the Writs of Entry.
(b) that the Court decree that the forfeiture of the 51 Real Property Defendants to the
United States under 18 U.S.C. 981(a)(1)(A) or (C) is confirmed, enforced, and ordered;
(c) that the Court thereafter order that the United States Marshal, or his delegate, dispose
of the 51 Real Property Defendants as provided by law; and
66
(d) that the Court award Plaintiff United States all other relief to which it is entitled,
including the costs of this action.
Respectfully submitted,
DAVID B. FEIN
UNITED STATES ATTORNEY
/s/John B. Hughes
JOHN B. HUGHES
CHIEF, CIVIL DIVISION
ASSISTANT U. S. ATTORNEY
/s/Julie G. Turbert
JULIE G. TURBERT
ASSISTANT U.S. ATTORNEY
ATTORNEY BAR ct23398
157 CHURCH STREET
NEW HAVEN, CT 06510
TELEPHONE: (203) 821-3700
FAX: (203) 773-5373
EMAIL: Julie.Turbert@usdoj.gov
67
DECLARATION
I am a Special Agent of the Federal Bureau of Investigation, United States Department of
Justice, and the agent assigned the responsibility for this case.
I have read the contents of the foregoing Verified Complaint of Forfeiture and the
statements contained therein are true to the best of my knowledge and belief.
I declare under penalty of perjury that the foregoing is true and correct.
th
Executed on this 18 day of May 2010.
/s/ Claudia A. Mannix

CLAUDIA A. MANNIX
SPECIAL AGENT
FEDERAL BUREAU OF INVESTIGATION
Case 3:10-cv-00774-JCH Document 1-1 Filed 05/18/10 Page 1 of 23
REAL P _OPERTY 199 BASSEU STREET
1 tot certain pitoota Ix parole! ol los* 1119. tisobt4160. sibmdied ki See

of Now Nom and Slob ot bounded and
Piaw Ik Courdy
so lollowe
Y.: By Bono* Street 31 bet, axes of' batic
Y: By land now miof Hwy 11014noon, 9-11 fiat, mire or lass;

LY: By bend essw come* of neertic P: Masher, 31 foot, mole or low-
By land now or farm* ofiNlikowbt. Mairowt, 91 feat, More or lees.
6
'Re? YD J. NO, 2 25 _9 '4 R LUXE
A certain piece or parcel of land bagether, eke Is'ea improvements

thereon, situated in the Town of New lima, emantor efftew lanien, and the State
of Comsecticut, known as *25-29 Boger Timm, and bounded: IIPS8T: By the
Easterly lime of Baser Terrace, 40 *et, awn or km; NORTH: land now or
1114,
fartnerly of Morris BMW, 70 set, more or km, by a sh'night line drawn, parallel
and papendicalarly distance North 320 het freinfre Not* Ike Of George Street;
EAST: By land now or ihrmenly ofWaal is4 maw& 27 feet, more or
less; NORTH aptin; In port by land now or of "land Mary A.
Sullivan and in part by land row or formerlyof and MeV O'Meara, 80
feet, more or less; EAST again; By land moor y of Sge:. P. Snow, 21 feet;
SOUTH: By land new or of
formerly rib* J. Itaseatteh 50 feet, by a straight line
drawn parallel with and papendicidarly *ma North 270 feet from the North line
of George Street; SOUTHWEST: By land awn or fornierly of Planip J. Hasselback
14-141100 set, by a straight line fa** um* of 135 **rem with said last
mentioned Southedy list which memos! tan the the North
toward the West and SOUTH: arils: Bylaw! fortmerly
or of J. Hasselbach,
81 feet, 7 inches, more or less by a sneighthe drawn paraRel iiddi and
papesdiettlarly distance Soinh 40 set, fanathe first herein Northerly
line.
6.4. Nita STRE T
A main piens corpse* 01}5011,

afliew
Hama, State arOsanassaienc Skiers
Street:
WESTIIRLY: by Beers Sweet, 40 fast
NORTHINILY: band now or, of Antekien Ciinsago. by a Nne &ma at

iit anSPI iffod =raft
Bigitalif 1.5.5 Stet and
eats** iitna aa. orbit vibes
ummmemfAiWn' Anil* aadlinniag
22.000tea, ia Sorb efivaneas
uninnawn;
BASIBIALY: bY Ind Of0Wakkastiftit VIA bira fele

nOW Onfieboid
Brosson, 42. Mink mate or rats;
SOVENIALLY: by lend now ottoman* entassY It baud& 1"30 kat, mem or

less.
lemaktiaer with =sr

Air
7 41411
E.
at P.
24- ad
4'Y6 de
r
atirarro.w ablude
to
AU
.1sm
miOmmiart. 4
tip alia..110, 410410M110014
Isom
REAL PROMTIr DEFUNDANT NO. (5) 136 CARLISLE STREET
#441,
fiflo
i*,
strlitstaw agsvallietessli
as Num.
MOW: try earefektkittit, 36 ket, mese Wss:
111611LY: by heiteteteettakea. enemy A. Wet*, 9g feet, tom or loss;
10110":; r.shook, aged ia pot by

uk 35 Feet more
or boo;
WSW% brbrititsibroralleir*Otreirit 98 hot, more or loss
swoherre
owl say Federal,
SW* psovistioss of ..n.
tri. he
NW *tAlliodel Alpe idoses.
r.;.
Reid oda* twos to the Chy oftliow Diane doe istd ps8tablo.
k,
4011001016401 volikk a/01*w rose kayo not os yet
'w. AMY
WA fittkie roisoliiiiik
4-
..1d4-- 6; Mgt, 1 *bt
V;
filf easy iolkoolkordbosi or coastal wetlavoi%
l
it. Seteath fiatalik 'I- i
tif v
L, kivitool Wake
i; 1
i
Sewer or f!!!e s: ee -2, 1110)*R011igko*

Aoritroalry for lift CIty
REAL 1OREKTY111211100041.111.4(4.14 CENTRAL AVENUE
Ail that castaia ptame ac and all other

lonpnamanista bbeimbila
aad State of
as
follows:.
Coamettlient,
Aid,
.Di
81, de
i, COmaty of New Nevem
!Pomaded and described
MST: by COntral humane, 56 Beet, 3-1/2 inches, tore or less;
961961 by land now or 119 Beet, acre or 1604, by
:10=1:t Lim* ot:iME

of Central
1600
hivimante;
A:11111 7
..s,:
Amis.
northerly from the
the easterly line
EAST: by land now or fonmerly of William P. Duff, 40 foot, more or less;
SCOW again, in peat. ec ly of *Mem P. Duff, and in

pact bor laga0 le 401, 76 Beer, Piece or less,
said sonthenty 1. lime;
NOM: by land new dr banitaly lima IL eseeedserat, 160 feet.
MAL 161006141TIMPIIMOVAL V) cti,kY STREET
Nil
swot we toixtiremaisollefor-.
404100101rse1W.emen. wow,
tome twkidsobeirakill001110100L*0060.40611 Ate
s.
ST: wousisitOMatilifillamifiM/001/044 'wow oetz
known as
eerbaia
Inthe vauraPleirc.
lf Colby comet, and bomaded:
artrea the824-4'
of Commor tout,
/1169T: by Colby Coact, formerly beown as antis Ahem amine, ISO feet;
nears: by Land now or formerly of Neaboo eananda, 74 Sinn, more or lose, by n

straight Hat:
NW: by Lamd new or formerly of NfIllam E. Ferry, 146 JOIOCT
306,T6: by lead forgaeray
In..ejiama Catania, 36 Beet
now or move oc lees, by a
rmi thin.
RL4L_MEISWWWfita 9
r 4kteett, Mod in the
"c# `0"4410...
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r*
Crien, C. E., ea k
it: *11344
a: t9
4 A .4.,..
135 feet;
E..
136 kat.
fievialtdrot 35 ket
Moo 111
*6.10119ses
4fis4414011811141i4i
V: tc Gaff, -7.7
litt keit new et fiaratady ef
BASIMILIf: tig *dam, is elittesise E. Ikeysiiield, 9 ket, 8

481)11it
1494X81-111ELY: ItIF a,
efLot #I4, sow et fame* of
IMIlik mese er less.
P', e., 2749 VV 'TAVzi IL
titat cetuirtfmem or
the*"
siesta* in the Was z
iroewn as
NthETISERLY: lay Dissempio o,
*WOO*.,
-444t.'
125 bud** or-less:
StHEIENLY: tist **thaw or 25 feet.
raw es tog
sarVIEELY: bY 0111112.
Milwbtaiiirkak, etre. Theme ithown as 1268
EToyether Dowsiciatt Moodie, UPI, siore
**Abe ose of a stap' of landtheta dirrthe Eagerly side of pottaiths Mom Id MS

Dithathyost Mem, boustibit
2 3
Y
44''
Ewa
he Ai
Alta*attridSthethid. their
kiss
744,
111111Wir ifESS
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WESTERLY: bb"ir
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grilutzsatlfeetyinia
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..4kr ilmers, eater the sontiern
..441-Ellit 1641%
25 Ent sr
Elithaholi ao
'1'4
.....ii P- *Oa PwootY
Imam as aeirstive. ii t
Tegediet with say ris,St wry him *owe, *the fatathae herein; her
interest
in anise tolthElla
Mei Devenpert Avon* sad detralthat b
AR*, atkasPitaWaits blow as
Sytvia D.
s.Ccc %thaw to Jen= N.
Young and branded:
NORTHERLY: by *Iwo IT *WC
WESTIMILY: Dam*
by the,,
tasstik on
niadted thew Sythia D.
Etheatidet,
SOUTEERLY: by now* and Ana 44. Sebethid, 4
Stet. 4.
EASTERLY: by
migaligatin/gLAymaimp"asiaoliabiNgyA E
Num by IliblapOte Sieliiiwes. ism. sob. sis um/

Uwe. kr
Sc Irv.. at Mitt L wideuts*H. us us*. Imes
swim
iat Woo tonforZy
or se
our soiftedsuSiy SS *Mt. Mae
NW* fly Prossrly

MC MR or at ISAMMIL M. ISSIMS446, 344/ SIMS. VOA
REAL PAQIIIIIT 116411044T (12) 3 DEW= STREET
Egyfywcy: by IgellifbSes0t, VultbiNdt. foolecribroo

reoRetertm by kiwi now erfoafteribberidit eal% INA*
VORM1114.Y: bybknd ROW OraiiMOONINOW NOOK 274/2*040 meteor
SOkrtiVALY: by kitod adWeralSONIMINMONIM
REAL nr DIENNIMOW.1104,434,2116417 DOVER STREET
A* that .A, 4*
dietetot, "F
'4;r NO Stift oftsasectieut,
boom as r Sabows:
SOUTH: bY Dover Sweet, 35 fad, as= sr les*

EAST: by kopa ow or lbw* Aiii***Stono, 115 foot mow or less;
NORM: by loud now or Sim* of Mood (iikatooao, 35 ket, more or tow
WEST: by kamiootor or *moo* oriootoxistbi. Wood Co., Doom 115 feet, MGM
Or WS.
Less not, Aii lbak000ltio4otoi, psoriasis* set twit is

as nue
a cassfaaasa,
..sorr
itoot most 7 Iva
rosooRroi,, and *Ate kW I,
reeeted in WWI* EOM AbObiiiii. ftis
C2*
NO. (1.4) 161 EDGEWOOD AVENUE
the Towo
Salta
1
50.1ET
it ItA 4
Oiwit am or -I
isms* af /Ewa** -1
VW, 0
i
at
TY T, N.4) Iiiielt.TH A _Pt E
Sfooloo
.13^4
by VI.Lonoodi 10;;O*Or4 44 ittr*-4
stammui yr um Tsar ec steseasy of Awn WWI Inds f44. mos of 'fool
114011.4X4 by Irma wow or atoripoly off Aron A, Igiadrinh 44 *of; and
mom
4001100100*.
HEAL peolvaTy Rimpasiowmiketrioditil4MAIVOIXTI-1 AVENUE
AS Stri 40441,,
instioN,
iiimucts *war, Stieweit
3.0
'WEST: By ehmoiCitigailvio Sift& moo or keroi

NORM liky loot mw 4111,01 A. 1410 alkok row faiell 1+4. Foods J.
Riegas- ttos who.
Ey bad WO *ram** of boo A. OW** 52 SM, taw w log

SOW Itybotedit toc.00448010, Skew 11.14 iksm. mower
keit..
BEAL 12011111111101411111111.41111EM40440&214 ENGLISH
Salk bliErOlbfikeEt 374E2 itikstanuarke4
Sat brirretato E
sioNirr.
tiONSINIONICOMINIIIIMM,Ok
f.
ItAL11116.1111411101.011111011641111601.
Afilittirt
besiodit*
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sfam ked& sow eryieso souse Rei deo Ammo Fede00K }meek
imetter
now yr taw* low 00100, 1000 kook MIS% allageor keig
frosioliiivellallaNOMMIONNAMON 11$110C 4Pf less.
mottusgalREcamismillailagadfailealsiENUE
Mat forfigteutNikioita", se flek 24091064
so%
at 1.&016,a).
i.
044
1 kowndwilatt
.isitsw br400610.0*NagipAilase1s1kies*" v4stiothes.

b# alabeek Maseete, 33-1/3 /set,

*SS er lose:
NUM: by Second Sbr..t. 100.f.cle, NOM less:
Wen: by lairtd am/ or tiesesely c Seam P. Mem, 33-1/3
boot. oroVi or
SOME:
Mk. el
4
.:141 *TT
theseee.
*stet*
knitwear Siltimed ertt*
SOVISIBILY: 11PY 11413511414 **NC

NPOSTEIPLY: litibilittga* 040/WV tfriFistribitt 149 feet, moo or
161*;
349
:1141Pi
41.
5kie of HeivOill.
bousesel 01021
961134LY: by liewagil Armee. 4114aist. 7 *nee, ntepeorising

NORMIIRLY: by lagd new or fame* et Peter Relanoids, iitek Irno-z or Ws;
WESTIMINLY: %leg OE %oat, bowl now cc

febiNefy aw4C
SOUTHBRLY: by 6and now or010110010041001118000101010*****0141070.
.741:'`', 1.1 '4 J A 6:1
i0011111101 4tOmoir
5.
3111,. 6 !fit
a.-41
REAL PRDIPaRTYDRiall11.1111011000000miNGTON STREET

As this amatio
of
COINIWW0101400.06
NORM: 01101102441014 34 Olt feelhek *NC teal
EAST: br all*ord glat, Weak agre er leag
eerteneeZetalkollblemem.sowlietel Illeverea
SOME by bileihnear 31 feet
9 woe er
WBST: by boisl sow as ftwoollogillalpilik*MOM*014000. *se.
REAL WY DligiMMIVINOMINIURT STREET
=0.1111
and s
swat-
yv
EAST:
304706:
lir
:;:111"4- .wro.
lir
=11 4
RE PRaP Y IEF DAN NO. 6 I :6 JAMES S ET
ofkodwilk Ins and lamrecomordo

And temob& plow or,
b=go
Swoon eibmiod In No
Conner*" Mom an
follows:
cod Conney eilliw
so saidlOste of
Amos Woo* and boinnInd and clisalfted a*
EAST: by Janos elboofs. 33Feidm.asOd.Ssn

NORM by hod forms* of E. L. abcookoo, now or kis* of
Undo Mem, info* awe or low
WEST; by- bad mow orlon*** of likinelnal ihoolna,

lint, mower loom and
SOUTH: by hod own wrinnuoilly 'Chien Ccialts,

inot morriklino.
Non Hoven, CT
Sold inorcloso commonly Imown no US Janos SOMA,
PRO' t DE V. NE11, N. 27 65Ji S ET
All that certain ple4:e or partel of land, situated in the City of New Haven, County of
New Haven and State of Connecticut, and bounded and described as follows;
West- by James Street, 40 feet;
North- by land now or formerly of Michael and Mary Callahan, 100 feet;
East- by a line parallel with the west line, 40 feet; and
South- by land now or formerly of Elizabeth Boehm, 100 feet.

Sp Y ENDANT NO. 8 3 0
i S.
sawn
$.ctr..
soma braptialo -1000101111101040141W6**0014c.." la 6.4
wan bybreitaisoosAituit.raikl#14mit
Sitinetkinasoir Ilettherodijaele dind
2.
3.
11" /PER Y D_ DANT NO. 9 9,2 NO eN S T
That eentairs` pike or posed ittosswaks!sts situated

bathe Town ofNew Ewen, Coo" onlIstr illtnata MO i ofeonaectrcut, known as 19-21
Weskrly: by Norton Sink, 36 lbe4

87 said northedy line
Notthefly by land now or faunae* of *Aim H itHewitt, Sort, foina,
Wag maid and 32 ket southerly front the Sean* kik
of lend now or Ellof Clue
W. Coggysswell;
and
Easterly: by land now or Sannerly of Fraud* II cOggsswell, 36 Stet
amid Wain Mimi* 85 feet, more or iess,
goutherly: by land now or o
of 1 said rile being as the finks wasiftealier 1 4.

REAL PACIIIMBLTY 111111111011111$4111411,1^KtETON STREET
mosim or *ear
amsoluit ar toninclir s011ikanden sAtte, 135 feet nee or
IMEEMEYz *ad
la In toot wart.S.toeWawa,
Nonriamita
Mn att.
Itaanal
arlarbaileM040400... Okalar 125 bat raw or
All that coOrtrlin iwiego

eliofter i an tino
glom
lowoom an PIO 416110.01*
MST: fet4IMODI Sionfeit, 7.6 *ft, *SOO co
9311111: bir 3opid *Ow or Sitiritrat ofiff SAWA stroSolao, foot,

aims or loos;
MeV: by laud *Ow of Itoonfi-O*11# Entandolno a11, 46.73 foint,

mom or loos;
BONN: kr lam* gbiNIONNAV or 400110,, 98.2.3 0 or
34&&& &
Moot *OR Wks *Ws

ifilfaVerilla OWN* MO*
bud firoffififilt
trestaviation
5.1.1 taaot cortoaa bajadinais and aal

otbeft.
torgeftwomage 46,
SNOW OssuitY ot aft
linen SONO* of
moo 90reet, bemOdso
mad described as folleise:
BRAIMMNr: by Orchard Oteeet, 46 foot, onoe Or 1t0M;
UMWMUOMfit: by loftd now ee iftaiakewly of Abadrt *Logs, 140 feet, tete et

1414W;
WOOTIONLY: lo port by -/y of DONWWtiwies asd in part by

lama re0 Or et Alailit C. *Sot, is all, 4$ feet, are
or leis; ead
SCOTWORLY: by lard ROW Or .001011110 40 01.**Ati. 01010110sie, 142 feet,

more or loos.
1LL Ir. T
1111111111.1111111111111.1.11111111.1iii
i
itoftelionits-*ANN%
i intailli&W .VP Obellis4**04044
N r
MIRONUT; .7L, 0044V 016610- ar, tailder4 miliV "If *4

t,. r
eineellatixt
ti. *lbw
4. S T
ingaiiirag
sraielko SEVIleor. likbabbbffiemeets thereon'
siElfaa 11, *Conned:kat, and
bobtailed:
Way*: by INttwootOtWeet., *Ow MEP) Ire*, wore or fess;,
las011tok: bV 12411210W er fletigg** of 140111M A. MeV, teeiNuadred and thirty-seven

(13T) Root, Noe fr) "Mar satitik at *ON
Wesbeltir. bof 1,0 now or toomaidly of aliOne 3 Gerearicti, &Atom, N. Clark and Frank P.
clask, fatty ENV) fret, Woe Or ilk* dill
Stattattabi: tiy Wei wr f000teadY OPOSONOte E. Oak, OM firandred and thirty-seven (137)
feet. Eve (5") Widths, Mere or *Vt.
A eatiale Sato or pawl of lonal in taco of "No r

Camay of New Pitman and
State Of Ottatilitattlik titiown ao and described as felkess:
Sir. 142 feet, more or WS;

algid
ritere or tem
ALL *es ow elf

amen pnessisinameo
semainyif
P-
as Lateanad1)4.
"1"14"4"4 4414. Maw
r *ant***
mann% aillastiblds; ONO SPArmey
sevitA bit, ova, 1551110-5144,
e4disk IMO et fist *Me *gas senor riateili
mop ilioriek 15, leo* 1-144 bielasine.
Saidpsonsisas ides** as lies. 9944141111MWOWaftw1 ii 6nraisadan.
AA *OA
thosilek
it
Comoiesdlaii, hviaiter
wit. 410.1100,
43*,
1=fmitiiiista
eadi 4Plis
%ifset: WetaidaraS Amelift2101164

sew Its,terittilotitMetautifOrtaftivnitethatego L 144
lb*
Sat grati;mosfies446000011111#4 gait. mow box
Wog
***7.4611101411.10.11011110$10141ftisePo coilass,
6JA TZAIMMINAMI411111011k4MMOONLMR.51_M[
IS
MI dad cenanailkene or
inosnovements iisareen
sastromob bra as 5iiiiirrar et et Conareadmait, cod bet:Kneed
and described ts *dens:
East- by Sinew Swet, 35 fee4;
Seatb- by lamidennedy of Reeked C. Lome and Mary E. Lode, 846 feet, 8 Inches;
West- by land homer* of Ristemd C. Lowe and dewy E. Lee* 26 feet, more or less;
See* again- by land Alone* of Widtand C. Lowe aft* dewy E4. Loma, 14 feet, more or less;
West again- by bad ferenedy et woo
impostopiesse04, Oak 15 feet, mere or less; end
masa- by lend OGIN or inanveriy 011410.01******00,
k--.,,Z y it,
T
044h the beildfiegis and
a_
jw
ow**,
min*.
1s_t,.,,,, 1
.4,,,,,,
ROI *hi act!, ems Cogaaibtr at
Efate. 31-$9 agaikitec
111001a111010": 41111110Mie SaMitipg, 318 Rest;

10/11110116111-
dialairigtilablit mar.
RFALISOIRE&TYASPIMIPM00.11111100111111LT014 AVENUE
REAL Plig~iTY,41111001101111101.4110101KTON AVENUE
All that certain piece or 00110011 'idims and

isvrerviteats thermion', si
of New Raven arm State of
ttai
GESEIERESESIE
401 I
ee
i, County
Elhe2ton
Avenue, and bounde and as foliage:
Easterly: By Shelton Menne, 36 9112'6 feet, *ore

or less;
NORTHORLEY: By land new or formerly of Bennett L. Scott, 150

feet, more or less;
WESTERLY: By land new er formerly of Ella Beech, 39 9/12th

feet, more or less;
SOUTHERLY: By land now et /a 000#11. 1401. Hart, 150

feet, lucre ot
twat 1,101110wornibormugs 54044,01bm*41.41g

Nenti~mbitopic.14160***440_rem4
vowilyte4**41fteliftmowow
sweabovi.00441611114MN*040
SW'10)M.*u*. si*****40011*INNOMOSOMOONISW
11101NOINLY: by Sitelairs Amairse, Sfi *et, NO* or ktss;

Y: by Mit 1)001 or hale* of Itell*L. litacts.,, 143 fcbt, mereoe
116.111BINLY: ia
4.
.04111fititat, pug
111COMMtaiRt.Y: lest, 1041100111610$04. 4116*Nbird. 142 *et, neve
REAL FitialIMIR1411.101011141**115S41161061110014 S1WT
sermaanm .byibovisnistopoosictowerioN.
WitaftwkW: brialtidinarod. faletwintra.41-1*
koosispoisi"..00, 0114ummaricrs;
WIMEMILAt.
AL PROP DEF A 0. 44 443 VAL_EY S LET
.0
of*.
o..
*6%
'ROP F N130_4_4. 0.45 5, 58 W TO' Dm
thilteelain 11110142PletlantS
INNS,
Lot or Pared WS, tiler Mom.

Verily SerWee,
bac. 1.16, *PO stop or oak
sou T'41
r
ifhlrisSe 144,
a
es Renner
inekePse, lbefldendelft
Sesterly: hY !Attie. Viallift dee in part by let 140- 35, asthenia on

sad IIVAINUIR
Nertherty: by Let Mo. *Owen ea side Me, 1004 filet
Westerly: by Vietery.eiled, 81 feet
Southerly: ley tot tek Oik stemmas swage, Iftitd filet
REAL PROPE ANT NO. 46 1 9 ST ET
sill duet aortae !done er ili 1111101. 74# tike and ispoeveemats thereon,
gaWM
Vl
situated in doe iber of teet
biome as Alf Wet Streets
ad*
di
Ind desetrthed es
fainte:pf esevecriset,
WEN: by West Street, 30 feet;
Meat by bead eow or ifteteordy of lases item 0.5 font* wire sr low;
liddl in pert bp 10011 Mew er forstifief tleesle Carrel sad is part

by laud new Or dettettly of Gferles rifle* is gu, 39 fast, ller4
by land nos or fassisoly of Meese Nenbettp 115 feet* awn or lomos-

REAL, 7120114KTY Elowassammagiiimiwuzy AVENUE
'11"414 1,,
1004. 1.40
boxia
it515L6110i itatota.
mistiamt; 54
-11t,
46. *MO
lit Sow Team
Ballayia 14LIO*4ct,. aloft erica; by lat #f i Sale *Ng
atimmisT 47,16s2t, ne tor WA, kV 14100410160010"

Mailafili: 1
1900404ifiiiiiiiii*OfteirO*01
REAL *ffrnatnur AVENUE
ibbdrodit: bit iblibbaNkint***". UM*
Warlis 110041100014Maktudf***41111.10.141tot
aft* sr lb*
New* aira Witt alio* in *MI MOW

or**
Soft* by *Id *OW--MObbity INS40100, 131 EPIC
blow arks*
I"' 0490
vow** *vilikolosoolbootoo..."
sootodyt Z3 SW*.
140640$ ble #1414**41000/akellati.**

Ibbidtbdr arSIM40101**A1111.114111bek.
A sitrinie4' boi.**41400011414k411060011000040101**Isaiked.loswaticdt
Wresiterby: by Vrabsbmibit Mos% S libet sat
Ramo* by itimitsower Woo* 416 AwASkitek* *Wog*

UAL POOTSILIX 411111M1111111W SUR AVENUE
10,1.1*
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Air
Pfefilliiik thaws:*
OW: twIlibatralaer Aitentre, 1164.401itifeet
t 4. 4110
kaires,
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11011M: 11. 44, 4084111110* eviter

mei 1.4., taltommlitly
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StartiliaM/4-7
*aft efftaair *111*IN
Wile*
LEAL .111ERTYIIMMINIMMEAWAR4000.110koe AVENUE
WOOS. IiiMiteretiswifise****Goafts
11111111111ML
10,1******40400Lees4342 Oritantepas

LEVITIN 51 Pieces of Property Complaint

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Case 3:10-cv-00774-JCH Document 1 Filed 05/18/10 Page 1 of 68

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA,:

v.: Civil No.

51 PARCELS OF PROPERTY LOCATED:

(1) 197-199 BASSETT STREET:

(33) 95 PARDEE STREET

WITH ALL APPURTENANCES AND:

[CLAIMANTS: MENACHEM LEVITIN,:

VERIFIED COMPLAINT OF FORFEITURE

Federal Rules of Civil Procedure:

which constitutes or is derived from proceeds traceable to an offense constituting specified

U.S.C. 1343, or conspiracy to commit such offense.

THE DEFENDANTS IN REM

improvements thereon (real property defendants), more particularly described in Attachment A,

which is attached hereto and incorporated herein by reference.

real property defendants are non-owner occupied residential properties.

providedby 18 U.S.C. 985(b)(1) and (c)(1):

b. serve notice of this action on the real property defendants

owner(s), and any other person or entity who may claim an

interest in the real property defendants, along with a copy

of this Complaint, and

c. execute writs of entry for purposes of conducting an inspection and

inventory of each property, and

d. file a lis pendens in New Haven Land Records of the real

property defendants status as defendants in this in rem

property defendants when it executes the Writs of Entry.

JURISDICTION AND VENUE

1395, because the property is located in this district.

BASIS FOR FORFEITURE

7. The real property defendants are subject to forfeiture pursuant to

18 U.S.C. 981(a)(1)(A) because they constitute property involved in a financial transaction in

fraud in violation of 18 U.S.C. 1343, or conspiracy to commit such offense.

ACQUISITION OF 51 PARCELS OF PROPERTY BY

REAL PROPERTY DEFENDANT NO. (1) 197-199 BASSETT STREET

assessed at $114, 730.

REAL PROPERTY DEFENDANT NO. (2) 25-29 BATTER TERRACE

Volume 8349, at Page 132 of the New Haven Land Records.

assessed at $176, 890.

REAL PROPERTY DEFENDANT NO. (3) 81-83 BEERS STREET

assessed at $222, 740.

REAL PROPERTY DEFENDANT NO. (4) 501 BLATCHLEY AVENUE

assessed at $109, 410.

REAL PROPERTY DEFENDANT NO. (5) 136 CARLISLE STREET

of the New Haven Land Records.

assessed at $115, 290.

REAL PROPERTY DEFENDANT NO. (6) 561 CENTRAL AVENUE

assessed at $234, 150.

REAL PROPERTY DEFENDANT NO. (7) 115 CLAY STREET

REAL PROPERTY DEFENDANT NO. (8) 15 COLBY COURT

REAL PROPERTY DEFENDANT NO. (9) 141 COUNTY STREET

at Page 114 of the New Haven Land Records.

assessed at $142, 310.

REAL PROPERTY DEFENDANT NO. (10) 270 DAVENPORT AVENUE

Page 90 of the New Haven Land Records.

assessed at $84, 350.

REAL PROPERTY DEFENDANT NO. (11) 280 DAVENPORT AVENUE

Haven Land Records.

assessed at $91, 000.

REAL PROPERTY DEFENDANT NO. (12) 108 DEWITT STREET