Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 1 of 16

1 Robert W. Wright
Attorney At Law
2
California Bar # 276653
3 716 Castro Street
Solana Beach, CA 92075
4
(858) 353-6591
5 bob.wright@mac.com
6
7 Attorneys for Plaintiff
8
9

UNITED STATES DISTRICT COURT

10

SOUTHERN DISTRICT OF CALIFORNIA

11
12
13
14
15
16
17
18
19
20
21
22

)
GLOBAL HOLDINGS, INC., a
)
Utah Corporation,
)
)
Plaintiff,
)
)
-v)
)
INVESTORSHUB.COM, a Florida )
Corporation, and DOES 1-20
)
inclusive,
)
)
Defendants.
)
)
)

23
24
25
26

///
///

Case No: '14CV2780 BTM JMA

COMPLAINT FOR:
1. INTENTIONAL
INTERFERENCE WITH
PROSPECTIVE ECONOMIC
ADVANTAGE
2. INTENTIONAL
INTERFERENCE WITH
CONTRACTUAL RELATIONS
JURY TRIAL DEMANDED

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 2 of 16

Plaintiff brings this action to stop Defendant InvestorsHub.com

2 (IHUB) and DOES 1-20 aggressive and illegal campaign to harm

3 Plaintiffs business and shareholder value through the wrongful
4 manipulation and contribution of IHUBs public message board content
5 resulting in loss of value to Plaintiffs shareholders. 1
6

Plaintiff GLOBAL HOLDINGS, INC, a Utah corporation, alleges

7 upon knowledge with respect to its own acts, and information and belief
8 as to all other matters, as follows:
9
10
11

THE PARTIES
1. Plaintiff, Global Holdings, Inc., (Global Holdings) is a
corporation incorporated under the laws of the State of Utah,

12

having its principal place of business in the State of California.

13

Global Holdings provides food and beverage productions,

14

distributions and vending services, and health related services

15
16
17
18
19
20
21

throughout North America and International Markets.

2.

Defendant Investorshub.com (IHUB) is a corporation with

its principal place of business in Tallahassee, Florida. Defendant

InvestorsHub.com operates publicly accessible Internet message boards
geared toward the securities investment community.
3.

Defendant Doe 1, screen name aMill is a member and

22

1 Defendants market manipulation tactics are well known to investors

23 and the SEC, which have resulted in a $4.78 million criminal penalty
24 and four year incarceration of Defendant IHUB operator Matthew
Brown. United States v. Matthew W. Brown, Crim. Action No. 09-4625 SLR (D. Del.). (Exhibit B).
26

COMPLAINT - 2

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 3 of 16

1 frequent publisher to the IHUB forum. The true name and capacity of
2 Doe 1 is unknown to Plaintiff. When its true name and capacity is
3 ascertained, Plaintiff will amend this Complaint by inserting its true
4 name and capacity herein. Plaintiff is informed and believes that this
5 DOE Defendant has diverse citizenship to the Plaintiff, and Plaintiff
6 will seek leave of court to allege his/her true name and citizenship when
7 ascertained.
8

4.

Defendant Doe 2, screen name bwilk1984 is a member and

9 frequent publisher to the IHUB forum. The true name and capacity of
10 Doe 2 is unknown to Plaintiff. When its true name and capacity is
11 ascertained, Plaintiff will amend this Complaint by inserting its true
12 name and capacity herein. Plaintiff is informed and believes that this
13 DOE Defendant has diverse citizenship to the Plaintiff, and Plaintiff
14 will seek leave of court to allege his/her true name and citizenship when
15 ascertained.
16

5.

Defendant Doe 3, screen name PennyPimper is a member

17 and frequent publisher to the IHUB forum. The true name and capacity
18 of Doe 3 is unknown to Plaintiff. When its true name and capacity is
19 ascertained, Plaintiff will amend this Complaint by inserting its true
20 name and capacity herein. Plaintiff is informed and believes that this
21 DOE Defendant has diverse citizenship to the Plaintiff, and Plaintiff
22 will seek leave of court to allege his/her true name and citizenship when
23 ascertained.
24
25
26

COMPLAINT - 3

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 4 of 16

6.

Defendants DOES 1 thru 20 inclusive, are sued herein under

2 fictitious names. Plaintiff is informed and believe, and thereon allege,

3 that each of the fictitiously named defendants is responsible in some
4 manner for the occurrences herein alleged, and that Plaintiffs damages
5 as herein alleged were proximately caused by those defendants.
6
7
8
9
10
11
12
13
14
15
16
17
18

JURISDICTION AND VENUE

7.

pursuant to 28 U.S.C. 1332. Plaintiff Global Holdings is a Utah

corporation with its principal place of business in California. Defendant
IHUB is a Florida corporation with its principal place of business in
Missouri. The amount in controversy exceeds the sum of $75,000,
exclusive of interest and costs.
8.

Venue is proper in this Court pursuant to 28 U.S.C.

1391(a)(2).
9.

The Court has personal jurisdiction over the Defendant in

that Defendant has sufficient minimum contacts with California, and

the injury to the Plaintiff occurred in this judicial district.
GENERAL ALLEGATIONS

19
20

This Court has diversity jurisdiction over this action

10.

IHUB is an online forum for serious investors to gather and

21 share market insights in a dynamic environment. IHUB boasts

22 506,564 members, and an average of 40,000 posts daily. (Exhibit A).
23

11.

Existing and potential securities investors rely on the IHUB

24 message boards for astute market insight and a civil level of

25 discourse. (Exhibit A).
26

COMPLAINT - 4

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 5 of 16

12.

The IHUB forum includes a message board2 dedicated to

2 posts concerning Plaintiffs stock. (GBHD message board).

3

13.

The IHUB message boards are supervised by moderators

4 working on behalf of IHUB, who have the power to edit and remove any
5 post at will.
6

14.

Upon information and belief, on a continuous and ongoing

7 basis, Defendant IHUB deleted factual and verifiable GBHD message

8 board posts submitted by IHUB members while maintaining and
9 featuring negative posts concerning Plaintiff and Plaintiffs stock, and
10 has thus manipulated and altered the true content of the information
11 on the GBHD message board, thereby misrepresenting member
12 comments. As a result, the vast majority of remaining posts concerning
13 Plaintiff include outright personal attacks, derogatory and vindictive
14 comments, and patently false information.
15

15.

In November, 2014, and several occasions over the past

16 years, members have reported and questioned this activity to IHUB.

17 IHUB consistently and without exception fails to respond to these
18 complaints and failed to take any action to rectify said complaints.
19

16.

Upon information and belief, IHUB employees,

20 representatives, or agents have posted fictitious derogatory comments,

21 personal attacks, and patently false information concerning Plaintiff on
22 the GBHD message board, resulting in significant damage to Plaintiffs
23 stock value.
24
25

http://investorshub.advfn.com/Global-Holdings-Inc-GBHD-7431/

26

COMPLAINT - 5

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 6 of 16

17.

Upon information and belief, through wrongful manipulation

2 of GBHD message board content, Defendant has schemed to devalue

3 Plaintiffs stock in an effort to gain control of a significant amount of the
4 stock, where Defendants then plan on using IHUB as a vehicle to
5 artificially increase stock value and then sell (i.e. pump and dump).
6 IHUB is no stranger to the world of manipulative trading.3
7
8
9
10

COUNT ONE
INTENTIONAL INTERFERENCE WITH PROSPECTIVE
ECONOMIC ADVANTAGE
18.

Plaintiffs incorporate by reference paragraphs 1 through 17

11 of this Complaint.
12
19.
The IHUB forum is targeted to the investment community
13 and currently boasts 506,564 members, and an average of 40,000 posts
14 daily. (Exhibit A).
15

20.

Defendants forum members include many of Plaintiffs

16 existing shareholders and hundreds of thousands of potential investors.

17
21.
As a result of Defendants wrongful acts, Plaintiffs existing
18 and prospective shareholders are misled into believing that Plaintiffs
19 stock is less valuable, resulting in diminished interest in acquiring the
20 stock and shareholder actions (ex. sale of stock) contributing to the
21
22

3 Defendants market manipulation tactics are well known to investors

23 and the SEC, which have recently resulted in a $4.78 million criminal
24 penalty and four year incarceration of Defendant IHUB operator
Matthew Brown. United States v. Matthew W. Brown, Crim. Action No.
25 09-46-SLR (D. Del.). (Exhibit B).
26

COMPLAINT - 6

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 7 of 16

1 devaluation of the stock.

2

22.

As a direct and proximate result of Defendants conduct,

3 Plaintiffs stock value was damaged, and absent injunctive relief will
4 continue to be irreparably harmed by Defendants acts.
5

23.

Unless Defendants conduct is enjoined, Plaintiff and its

6 goodwill and reputation will suffer irreparable injury which cannot be

7 adequately calculated or compensated solely by money damages.
8
9
10

COUNT TWO
INTENTIONAL INTERFERENCE WITH CONTRACTUAL
RELATIONS

11
12

24.

Plaintiffs incorporate by reference paragraphs 1 through 23

13 of this Complaint.
14

25.

In 2014, Plaintiff executed a contract with a third party to

15 distribute said third partys products.

16

26.

Defendant learned of this contract through Plaintiffs press

17 releases publicized through multiple channels, including the IHUB

18 message boards.
19

27.

Defendants wrongful acts as described above resulted in the

20 third partys decision to rescind the contract.

21

28.

As a direct and proximate result of Defendant's wrongful

22 acts, Plaintiff has been damaged in an amount to be determined at trial,

23 which amount Plaintiff believes to exceed $75,000.
24
25
26

COMPLAINT - 7

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page 8 of 16

1 WHEREFORE, Plaintiff prays judgment against Defendant as follows:

2
3
4
5
6
7
8

1. Enter judgment against Defendant and in favor of Plaintiff with

respect to each claim for relief alleged in this Complaint;
2. award Plaintiff injunctive relief, compensatory damages,
punitive damages, and its costs and attorneys fees on its state
law claims; and
3. award such other and further relief as the Court may deem
proper

9
10
11

DEMAND FOR A JURY TRIAL

Plaintiff hereby demands trial by jury of all eligible claims.

12
13
14
15
16
17
18
19

Respectfully submitted,
November 20, 2014

/s/ Robert W. Wright

Robert W. Wright, (SBN: 276653)
Attorney for Plaintiff Global Holdings
716 Castro Street
Solana Beach, CA 92075
(858) 353-6591
bob.wright@mac.com

20
21
22
23
24
25
26

COMPLAINT - 8

Case 3:14-cv-02780-BTM-JMA Document 1 Filed 11/20/14 Page

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EXHIBIT A

You are Guest on WEB3

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 1 ofPage
7 PageID
10 of 16
#: 297

Ad 24jB

Exhibit "B"

(Rev. 06'05) 11.Jlgrrc:lt in a GirIInaI Case

&lee!: 1

r;l6
8 '

UNITED STATES DISTRICT COURT

District of Delaware

JUDGMENT IN A CRIl ;[INAL CASE

UNITED STATES OF AMERICA

V.
Case Number: 09-CR-46-SL. ~

MATTHEW W. BROWN

USM Number: 48370-112

John R. Garey, Esq.
Defendant's Attorney

THE DEFENDANT:
_0

~ pleaded gUilty to count(s)

r '.

L IV. V, and VIII of the Indictm;o:nt

pleaded nolo contendere to count(s)

which was accepted by the court.

r)

'\

...-}

--,

was found guilty on count(s)

after a plea of not gUilty.

The defendant is adjudicated guilty of these offenses:

Title & Section

Offe Ise Ended

Nature of Offense

Count

Ii

CONSPIRACY TO COMMIT SECURITIES FRAUD IN VIOLATION OF lS.78j(b) and 78ff

and TITLE 17 CF.R. SEC 240JOb-5

2/2007

18:1956(h)

CONSPIRACY TO COMMIT MONEY LAUNDERING

2/2007

IV

18:371

CONSPIRACY TO COMMIT SECURITIES FRAUD IN VIOLATION OF 1578j(b) and 78ft

and TITLE 17 CF.R SEC 240.10b5

2/2007

18:371

The defendant is sentenced as provided in pages 2 through

the Sentencing Reform Act of 1984.

_7_ _ _ _ of this judgment. ~ 'he sentence is imposed pursuant to

LJ The defendant has been found not guilty on count(s)

~ Count( s)

II. Ill. VI and VII

[J is

~ are dismissed on the motion of the United States.

It is ordered that the defendant must notify the United States attorney for this district within 30 jays of any change of name. residence.
or mailing address until all fines, restitution. costs. and special assessments imposed bv this iudgl ae'nt are fully paid. If ordered to pa~
restitution..-the defendant must notify the court and United States attorney of material changes in eco: [omic circumstances.
.
~"SL_!

.::) L;
~

C"")

..

:::

May 18. 2011

,

Dare oflmposirion of Judgment

kif: j)~~

SIgnature of JUdge.f:t!!.

------------

c..)

w
a
Lj

''''

Honorable Sue L. Robinson, Unil ed States District Judge

Name and Title of Judge

Date

2
EXHIBIT B

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 2 ofPage
7 PageID
11 of 16
#: 298

AO "'j'';SB

(Re\, , 06/05) Judgment in a Cnminal Case

Sheet I A

DEFENDANT: MATTHEW W. BROWN

CASE NUMBER: 09-CR-46-SLR

,udgment Page

ADDITIONAL COUNTS OF
Title & Section
18:1956(h)

Nature of Offense

_2__ of _7_ __

CONVICTIO~

Offe lse Ended

CONSPIRACY TO COMMIT MONEY LAUNDERING 2/200"

Count

VIII

I
II

I
I

!
3
EXHIBIT B

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 3 ofPage
7 PageID
12 of 16
#: 299
\

h024'3B

(Rev. 06/05) Judgment in Crimmal Case

Sheel 2 imprisonment
JUlgment Page

,.;;.3_ _

of

DEFENDANT: MATIHEW W. BROWN

CASE NUMBER:09-CR-46-SLR

IMPRISONMENT
The defendant is hereby committed to the custody of the United States Bureau of Prisons to be imprisoned for a
total term of: 48 MONTIIS

The term of 48 months shall run concurrently on Counts L IV, V and VIII. The defe ldant's conditions of

release remain in effect until he surrenders for service of this sentence.

I:8l

The court makes the following recommendations to the Bureau of Prisons:

THE COURT RECOMMENDS THAT THE DEFENDANT BE PLACED IN A FA :ILITY NEAR THE

DISTRICT OF RELEASE: THE NORTHERN DISTRICT OF FLORIDA.

o The defendant is remanded to the custody of the United States Marshal.

o The defendant shall surrender to the United States Marshal for this district:

U at __________ D a.m,
o p.m.
on

as notified by the United States MarshaL

I:8l

The defendant shall surrender for service of sentence at the institution designated by the Bun au of Prisons:

before 2 p.m. on

as notified by the United States MarshaL

June 17.2011

--------------------

o as notified by the Probation or Pretrial Services Office,

RETURN
I have executed this judgment as follows:

Defendant delivered on

to
0PY of this judgment.

i~

\;
",1\'

l By
1t
,~

--

lEGAl. INSTRUMENTS EXAMINER

.....

-~~

~--~~~-

--

4
EXHIBIT B
~

_--.,.. . .,~"J'~..J

UNITE[ STATES MARSHAL

DEPUTY UN TED STATES MARSHA:"

_7_ _ __

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 4 ofPage
7 PageID
13 of 16
#: 300
AD 245B

(Rev. 06/05) Judgment In a Criminal Case

Sheet 3 SupervIsed Release

----

. udgment Page _4_ _ of 7

DEFENDANT: MATTHEW W. BROWN

CASE NUMBER: 09-CR-46-SLR

SUPERVISED RELEASE
Upon release from imprisonment, the defendant shall be on supervised release for a term of 3 YEI.;:;R;.;;.S~_ _ _ _ _ _ _ _ _ _ __

The term 00 years supervised release shall run concurrently on Counts I, IV, V and VIII.
The defendant must report to the probation office in the district to which the defendant is relea ;ed within 72 hours of release from the
custody of the Bureau of Pnsons.
The defendant shall not commit another federal, state or local crime.
The defendant shall not unlawfully possess a controlled substance. The defendant shall refrain fro n any unlawful use of a controlled
substance. The defendant shall submit to one drug test within 15 days of release from imprisonme 1t and at least two periodic drug tests
thereafter, as determined by the court.
The above drug testing condition is suspended, based on the court's determination that the de fendant poses a low risk of
future substance abuse. (Check, if applicable.)

t8l
t8l

The defendant shall not possess a firearm, ammunition, destructive device. or any other dangerous Wf apon. (Check, if applicable.)
The defendant shall cooperate in the collection of DNA as directed by the probation officer. :Check, if applicable.)

U The defendant shall register with the state sex offender registration agency in the state where the defendant resides, works, or is a
student, as directed by the probation officer. (Check, if applicable.)

U The defendant shall participate in an approved program for domestic violence. (Check, if ap! Ilicable.)
If this judgment imposes a fine or restitution, it is a condition of supervised release that the d ~fendant pay in accordance with the
Schedule of Payments sheet of this judgment.
The defendant must comply with the standard conditions that have been adopted by this court a; well as with any additional conditions
on the attached page.
.
.

STANDARD CONDITIONS OF SUPERVISION

1)

the defendant shall not leave the judicial district without the permission of the court or pro!: ition officer;

2)

the defendant shall report to the probation officer and shall submit a truthful and complete, Iritten report within the first five days
of each month:

3)

the defendant shall answer truthfully all inquiries by the probation officer and follow the in! tructions of the probation officer:

4)

the defendant shall support his or her dependents and meet other family responsibilities;

5)

the defel'\dant shall work regularly at a lawful occupation, unless excused by the probation ( fficer for schooling, training, or other
acceptable reasons;

6)

the defendant shall notify the probation officer at least ten days prior to any change in resid :nce or employment:

7)

the defendant shall refrain from excessive use of alcohol and shall not purchase, possess, us~, distribute, or administer any

controlled substance or any paraphernalia related to any controlled substances, except as pnscribed by a physician;

8)

the defendant shall not frequent places where controlled substances are illegally sold, used, jistributed, or administered;

9)

the defendant shall not associate with any persons enga$ed in criminal activity and shall not lssociate with any person convicted of
a felony, unless granted permission to do so by the proDation officer;

10)

the defendant shall permit a orobation officer to visit him or her at any time at home or else vhere and shall permit confiscation of
any contraband observed in plain view of the probation officer;
.

IIj

the defendant shall notify the probation officer within seventy-two hours of being arrested or q lestioned by a iaw enforcement officer:

12)

the defendant shall not enter into any agreement to act as an informer or a special allent of.. law enforcement agency without the
permission of the court; and

~
.

13)

as directed by the probation officer, the defendant shall notify third parties of risks that r lay be occasioned by the defendant's
criminal record or personal historv or characteristics and shall permit the probation officer to nake such notifications and to confirm
the defendant's compliance with such notification requirement.

5
EXHIBIT B

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 5 ofPage
7 PageID
14 of 16
#: 301
AO 2J :B

l&ev, 06/05) Judgment in a Criminal Case

Sheet 3C Supervised Release
hdgmentPage _5_ _ of _7_ __

DEFENDANT: MATTHEWW. BROWN

CASE NUMBER:09-CR-46-SLR

SPECIAL CONDITIONS OF SUPERVISION

1.) THE DEFENDANT SHALL NOT WORK IN ANY CAPACITY INVOLVIN<I THE REGISTERING,

SALE, PROMOTION OR BROKERING OF SECURITIES DURING THE TERl'I1 OF SUPERVISION

ABSENT COURT ORDER.

6
EXHIBIT B

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 6 ofPage
7 PageID
15 of 16
#: 302
AO 24, 'l

(R'iv, 06/05) Judgment In a Criminal Case

Sheet 5 Cnmlnal Monetary Penalties
Judg nent Page ..,;.6_ __

DEFENDANT: MATTHEW W. BROWN

CASE NUMBER: 09-CR-46-SLR

of _7_ _ _ __

CRIMINAL MONETARY PENALTIES

The defendant must pay the total criminal monetary penalties under the schedu Ie of payments on Sheet 6.

TOTALS

Fine

Assessment
$ 400.00 ($100.00 per count)

Restitution

$50,000.00

D The determination of restitution is deferred until ---

S n/a

An Amended Judgment in a Crin inal Case (AO 245C) will be entered

after such determination.

[J The defendant must make restitution (including community restitution) to the following payet s in the amount listed below.
If the defendant makes a partial payment, each payee shall receive an approximatelv proportionei payment unless specified otherwis~ in
the priority order or percentage payment column below. However, pursuant to 18 tJ .S.C, 366~ (I), all nonfederal victims must be paid
before the United States is paid,
Name of Payee

TOTALS
[J

Total Loss*

Restitution Ordered

$ -----------

Priority or Percentage

$----------------

Restitution amount ordered pursuant to plea agreement $ _ _ _ _ _ _ _ _ __

The defendant must pay interest on restitution and a fine of more than $2.500, unless the rest tution or fine is paid in full before tht'
fifteenth day after the date of the judgment pursuant to 18 U.S.C. 3612(f). All of the payment options on Sheet 6 may be subject
to penalties for delinquency and default, pursuant to 18 U.S.C, 3612(g),

o The court determined that the defendant does not have the ability to pay interest and it is ord. red that:
o

the interest requirement is waived for the

the interest requirement for the

fine

fine

restitu tio n.

restitution is modified as follows:

* Findings for the totai amount of losses are required under Chapters I09A, 110, 110A. and 113A
after September \3, 1994. but before April 23, 1996,
7
EXHIBIT B

'Title 18 for offenses committed on or

Case
Case
1:09-cr-00046-SLR
3:14-cv-02780-BTM-JMA
DocumentDocument
77 Filed 12/13/11
1 Filed 11/20/14
Page 7 ofPage
7 PageID
16 of 16
#: 303

...

AO 24 g

(R!!v. 06/05) Judgment in a Criminal Case

Sheet 6 Schedule of Payments
udgment Page

of ....;.7_ _ __

DEFENDANT: MATllIEWW. BROWN

CASE NUMBER: 09-CR-46-SLR

SCHEDULE OF PAYMENTS
Having assessed the defendant's ability to pay, payment of the total criminal monetary penalties a'e due as follows:
A

I8l

Lump sum payment of $ 50.400.00

0
I8l

not later than

in accordance

due immediately, balance due

,or

C,

I8l

D,

or

[8j F beloW; or

[8j F tx low); or

I8l

Payrrent to begin irnr:redia1ely (IDlY be combined with

Payrrent in equal
(e.g., V\eekiy, nunthly, quanerly) inst:al.lIrents of $
over a p;;riod of
(e.g., rronths or years), to co~
(e.g., 30 or 60 days) aft:!!' the date ofthisjudgrr.ent; or

[8j

Payrr:ent in equal rronthly

(e.g., V\eekly, nunthly, quarterly) installrrents of $ 2,000.00
over a p;;riod of
ore year
(e.g., nunths or years), to ~ce 30
30 or 60 days) aft :!!' release from imprisornrent to a
term of supervision; or

E
F

C,

I8lD,or

Payrrent during the term of supervised release will cornrr:ence within

(e.~ ., 30 or 60 days) after release from
imprisornrent. 'The court will set the pa)'lll.'mt plan based on an asseSSl.1::eIlt of the defer dant's ability to pay at that tiJ:re; or
Special instructions regarding the payrrent of criminal rn:::netary penalties:

The defendant sball ray $25,000.00 within 30 days of sentencing. Any l:ulance Wlich rerrnins ~d sball be plld according to
the installrrent schedule in D above. 1he defendant is encouraged to JEticipate in the inmate 1inancial resp:msibility program
during the term of impriSOnrn:mL

~~ tbe court has ~ly m:lered ~, ifthis jlXbm"ent iIrp::lres irq:riSCll1rll:rt, JDYlrellt of CI irriml ~p31alties is ~ cJur-tng
lITlprl~. All Cl1lll1nal nunetary penalties, except those pa)'lll.'mts rmde through the Federal Bureau of Prisons' lnrrme FmancIai
RespJnsibility ~ are rm:Ie to tbe clerk oftbe court

The defendant shall receive credit for all payments previously m:tde toVvard any criminal nunetar ! penalties imposed

Joint and Several

Iefendant and eo-Iefendant"Nmres and Case Numbers (including defendant number), Tota Arrount. Joint and Several
and corresponding payee, if appropriare.

Arro~

1he defendant shall pay the cast of prosecution.

The defendant shall pay the following court cast(s):

I8l

The defendant shall forfeit the defendant's interest in the following propeny to the United St: ttes:
Pursuant to the Preliminary Order of Forfeiture (D.I. 54), the defendant shall forfeil to the united States $4,798,138.0(.

Pa~

shall be ~lied in the following order: (1) assessrn;:n:.1, (2) restitution principa)., (3) resti :urian interest, (4) fine princip:ll,
(5) fine interest, (6) COlTIll1UIlity restitution, (7) pellalties.. and (8) coSts, incluciing cast of prosecuti )I1 and court costs.

8
EXHIBIT B