Opinion
2:21-CR-027-RFB-DJA
10-07-2022
UNITED STATES OF AMERICA, Plaintiff, v. JORGE ABRAMOVS Defendant.
JASON M.FRIERSON United States Attorney DANIEL D. HOLLINGSWORTH Assistant United States Attorney
JASON M.FRIERSON United States Attorney DANIEL D. HOLLINGSWORTH Assistant United States Attorney
UNITED STATES OF AMERICA'S UNOPPOSED MOTION TO APPROVE SALE PRICE AND SALE TERMS FOR REAL PROPERTY LOCATED AT 3726 SOUTH LAS VEGAS BOULEVARD, UNIT 509, LAS VEGAS, CLARK COUNTY, NEVADA, AND ORDER
RICHARD F. BOULWARE UNITED STATES DISTRICT JUDGE
The United States moves this Court to approve the sale of 3726 South Las Vegas Boulevard, Unit 509, Las Vegas, Clark County, Nevada (property) for $325,000.
MORE PARTICULARLY DESCRIBED AS: PARCEL 1: UNIT 509 IN BUILDING WEST IN VEER TOWERS, AS SHOWN ON THAT CERTAIN FINAL MAP OF THE VEER TOWERS, A RESORT CONDOMINIUM SUBDIVISION ON FILE IN BOOK 142 OF PLATS, PAGE 42 AND AS SET FORTH IN THE DECLARATION OF COVENANTS, CONDITIONS AND RESTRICTIONS AND RESERVATION OF EASEMENTS FOR VEER TOWERS RECORDED MAY 03, 2010 IN BOOK 20100503 AS INSTRUMENT NO. 0002036, BOTH IN THE OFFICE OF THE COUNTY RECORDER, CLARK COUNTY, NEVADA. PARCEL 2: AN ALLOCATED INTEREST AS A TENANT-IN-COMMON IN THE COMMON ELEMENTS OF VEER TOWERS (INCLUDING ANY ANNEXATIONS THERETO), AS SHOWN BY THE MAP AND AS SET FORTH IN THE DECLARTION. PARCEL 3: AN EXCLUSIVE EASEMENT APPURTENANT TO PARCELS 1 AND 2 DESCRIBED ABOVE, OVER AREAS DEFINED AND DESCRIBED AS LIMITED COMMON ELEMENTS, IF ANY, ALLOCATED TO PARCELS 1 AND 2 IN THE DECLARATION AND AS SHOWN AND DELINEATED UPON THE MAP REFFERED TO ABOVE. PARCEL 4: NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS, USE AND OTHER PURPOSES ALL DESCRIBED IN THE DECLARATION AND IN THAT CERTAIN (A) DECLARTION OF CENTRAL PLANT EASEMENTS, DATED DECEMBER 01,2009 AND RECORDED DECEMBER 01,2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002884 OF OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF CENTRAL PLANT EASEMENTS, DATED JANUARY 07,2010 AND RECORDED JANUARY 07,2010 IN BOOK 20100107 AS INSTRUMENT NO. 0000577 OF OFFICIAL RECORDS; (B) PARKING AND ACCESS AGREEMENT, DATED APRIL 28,2010 AND RECORDED MAY 03,2010 IN BOOK 20100503 AS INSTRMENT NO. 0000515 OF OFFICIAL RECORDS; (C) DECLARATION OF SUPPORT AND ENCROACHMENT EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002885 OF OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRST AMENDMENT TO DECLARATION OF SUPPORT AND ENCROACHMENT EASEMENTS, DATED JANUARY 07,2010 AND RECORDED JANUARY 07,2010 IN BOOK 20100107 AS INSTRUMENT NO. 0000578 OF OFFICIAL RECORDS; AND (D) DECLARATION OF LIFE SAFETY SYSTEMS EASEMENTS, DATED DECEMBER 01, 2009 AND RECORDED DECEMBER 01, 2009 IN BOOK 20091201 AS INSTRUMENT NO. 0002886 OF OFFICIAL RECORDS, AND AS AMENDED BY THAT CERTAIN FIRS1 AMENDMENT TO DECLARATION OF LIFE SAFETY SYSTEM EASEMENTS DATED JANUARY 07,2010 AND RECORDED JANUARY 07,2010 IN BOOK 20100107 AS INSTRUMENT NO. 0000579 OF OFFICIAL RECORDS, AND ALL IMPROVEMENTS AND APPURTENANCES THEREON, APN: 162-20-714-020.
The reasons for this request are (1) to authorize Doug Sawyer to sell the property for $325,000 under the Court-ordered interlocutory sale and (2) to stop the continued increase of (a) the Clark County real property taxes, interest, and penalties and (b) HOA fees, interest, and penalties.
This Motion is made and is based on the papers and pleadings on file herein and the attached Memorandum of Points and Authorities.
Motion and Memorandum of Points and Authorities
This Court authorized the Interlocutory Sale of the property. Mr. Sawyer listed the price for $325,000. Kristen Paige Keel offered $325,000 to purchase the property. If this Court does not approve the sale, Ms. Keel will receive her earnest money deposit. Mr. Sawyer received other offers, but they failed to come to fruition.
Order, ECF No. 56, granting Motion for an Interlocutory Order of Sale of 3726 South Las Vegas Boulevard, Unit 509, ECF No. 54.
If this Court approves this offer and after the unpaid real estate taxes; the unpaid HOA fees; the broker commission and expenses; and escrow costs and fees, the remaining net sale proceeds will be payable to the United States Marshal Service deposited into an interest-bearing account. The net sale proceeds will constitute the amount to be retained by the Court as a substitute res under Supp. R. G(7)(b)(iii) and (iv).
The government has determined that (1) neither the buyer nor any individual who will be on the title after the completion of the sale is a felon; and (2) this sale represents an arms-length transaction under the law.
On October 5, 2022, Jorge Abramovs, through his counsel, Margaret W. Lambrose, agreed to the sale price of $325,000.
IT IS SO ORDERED: