Attachment A 

JOINT MOTION FOR ENTRY OF PROPOSED STIPULATED ORDER 

In re Sanctuary Belize Litigation, No. 18-3309 (D. Md.) 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 1 of 13
IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND 

SOUTHERN DIVISION

In re SANCTUARY BELIZE LITIGATION No: 18-cv-3309-PJM 

STIPULATED ORDER FOR PERMANENT INJUNCTION 

AND MONETARY JUDGMENT AGAINST DEFENDANT ATLANTIC 

INTERNATIONAL BANK LIMITED 

3ODLQWLIIWKH)HGHUDO7UDGH&RPPLVVLRQ3&RPPLVVLRQ ́RU3)7& ́ILOHGLWV&RPSODLQWIRU

3HUPDQHQW,QMXQFWLRQDQG2WKHU(TXLWDEOH5HOLHI3&RPSODLQW ́SXUVXDQWWR6HFWLRQERIWKH

)HGHUDO7UDGH&RPPLVVLRQ$FW3)7&$FW ́86&E, and the Telemarketing and 

&RQVXPHU)UDXGDQG$EXVH3UHYHQWLRQ$FW37HOHPDUNHWLQJ$FW ́86&-6108.

2Q-DQXDU\WKH&RXUWJUDQWHGWKH)7&¶VPRWLRQWRDPHQGVXEVWLWXWLQJWKH$PHQGHG

Complaint for Permanent Injunction and Other EquiWDEOH5HOLHI3$PHQGHG&RPSODLQW ́IRUWKH

&RPSODLQW  'HIHQGDQW$WODQWLF,QWHUQDWLRQDO%DQN/LPLWHG3$,%/ ́ZDVVHUYHGZLWKWKH

Complaint and summons, and subsequently with the Amended Complaint. The Commission 

and AIBL, by and through the Liquidator, stipulate to the entry of this Stipulated Order for 

Permanent Injunction and Monetary Judgment Against AIBL. 

IT IS THEREFORE ORDERED:

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Amended Complaint charges that AIBL, along with the other named 

Defendants, participated in deceptive acts or practices in violation of Section 5 of the FTC Act, 

15 U.S.C. § 45, as well as violations of the Telemarketing Sales Rule, 16 C.F.R. Part 310, in 

connection with the sale of lots in a development in Belize known variously as Sanctuary Bay, 

Sanctuary Belize, and The Reserve. 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 2 of 13
2

3. )ROORZLQJOLWLJDWLRQWKH&RXUWIUR]HDVVHWVWKH3$VVHW)UHH]H ́LQFOXGLQJ$VVHWV

comprised of cash and certain marketable securities and investments held by AIBL in certain 

bank accouQWVPDLQWDLQHGZLWK:HOOV)DUJR1$3:HOOV)DUJR ́$FWLYR,QWHUQDWLRQDO%DQN

3XHUWR5LFR3$FWLYR ́DQG%DQFUpGLWR,QWHUQDWLRQDO%DQN&RUSRUDWLRQ3XHUWR5LFR

3%DQFUpGLWR ́

4. 2Q$SULOWKH&HQWUDO%DQNRI%HOL]HWKH3&HQWUDO%DQN ́WKH%Hlizean

government regulator of AIBL, appointed Julian Murillo as liquidator of AIBL (in such capacity, 

WKH3/LTXLGDWRU ́DQGWKH&HQWUDO%DQNIRUPDOO\UHYRNHG$,%/¶VOLFHQVHWRRSHUDWH 

5. AIBL neither admits nor denies any of the allegations in the Complaint, except as 

specifically stated in this Order. AIBL admits the facts necessary to establish jurisdiction. 

6. 7KLV2UGHUUHVROYHVDOORIWKH)7&¶VDOOHJDWLRQVUHODWHGWR6DQFWXDU\%HOL]H

including all allegations against AIBL, except it reserves allegations against all Reserved 

Defendants, and the subordinates, agents, affiliates or subsidiaries of any Reserved Defendant, 

and any other entity any Reserved Defendants directly or indirectly control or controlled. This 

Order does not resolve any allegation regarding persons or entities not in Belize, or any 

allegation not related to Sanctuary Belize. 

7. AIBL waives any claims it may have under the Equal Access to Justice Act, 28 

U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, and 

agrees to bear their own costs and attorney fees. 

8. AIBL waives all rights to appeal or otherwise challenge or contest the validity of 

this Order. 

9. The Liquidator has authority to enter into this Stipulated Order on behalf of 

AIBL, and has exercised that authority to enter into this Stipulated Order. 

DEFINITIONS

A. 3AIBL ́ means Defendant Atlantic International Bank Limited and its 

subordinates, agents, affiliates or subsidiaries, except that in Sections III-X, AIBL means, 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 3 of 13
3

collectively, Defendant Atlantic International Bank Limited and its subordinates, agents, 

affiliates or subsidiaries, and the Liquidator. 

B. 3$,%/$VVHW ́ means any Asset of AIBL regardless of whether controlled by the 

Liquidator. 

C. 3$VVHW ́ means any legal or equitable interest in, right to, or claim to, any 

property, wherever located and by whomever held, whether tangible, intangible, digital, or 

otherwise, including, but not limited to, digital currencies, virtual currencies, digital tokens, and 

cryptocurrencies.

D. 3%HOL]HDQ/LTXLGDWLRQ3URFHHGLQJ ́ means the proceedings to wind-up and 

liquidate AIBL for which the Central Bank formally nominated the Liquidator, and any related 

litigation, administrative activity, or other related proceedings in Belize. 

E. 3&KDSWHU3URFHHGLQJ ́ means the matter bearing the caption In re Atlantic 

International Bank Limited, No. 19-16286 (Bankr. S.D. Fla.) currently pending before the United 

States Bankruptcy Court for the Southern District of Florida. 

F. 3Corporate Defendant(s) ́ means Global Property Alliance, Inc., Sittee River 

Wildlife Reserve, Buy Belize, LLC, Buy International, Inc., Foundation Development 

Management, Inc., Eco-Futures Development, Eco-Futures Belize Limited, Power Haus 

0DUNHWLQJ6DQFWXDU\%HOL]H3URSHUW\2ZQHUV¶$VVRFLDWLRQ3URGLJ\0anagement Group LLC, 

Foundation Partners, BG Marketing, LLC, Ecological Fox, LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, Southern Belize Realty LLC, Newport Land Group LLC, and their 

respective subsidiaries, affiliates, successors, and assigns. 

G. 3Defendant(s) ́ means the Corporate Defendants, Individual Defendants, and 

Relief Defendants, individually, collectively, or in any combination. 

H. 3,QGLYLGXDO'HIHQGDQWV ́ means Andris Pukke, Peter Baker, Luke Chadwick, 

John Usher, Rod Kazazi, Brandi Greenfield, Frank Costanzo, and Michael Santos, individually, 

collectively, or in any combination. 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 4 of 13
4

I. 3/LTXLGDWRU ́ means Julian Murillo, or any successor the Central Bank or other 

relevant Belizean authority having the power to do so appoints, to serve as liquidator for AIBL 

pursuant to Belizean law. 

J. 3/RW3XUFKDVHU ́ means any consumer who purchased a lot: (i) in Sanctuary 

Belize; (ii) located elsewhere, but that was transferred to Sanctuary Belize (with or without their 

consent); or (iii) within any area the Court determines to be part of the Receivership. 

1RWZLWKVWDQGLQJWKHIRUHJRLQJDFRQVXPHULVQRWD3ORWSXUFKDVHU ́LIWKHFRQVXPHUUHFHLYHGD

full refund, or payment from defendants or their agents for help selling lots. 

K. 30DQGDWH ́means the LiqXLGDWRU¶VLQVWUXFWLRQVDQGDXWKRULW\IURPWKH&HQWUDO

Bank of Belize to liquidate AIBL pursuant to Part XI of the Domestic Banks and Financial 

Institutions Act, 2012. 

L. 35HFHLYHU ́ means the Receiver appointed in Section IV of this Order and any 

deputy receivers who shall be named by the Receiver. 

M. 35HFHLYHUVKLS ́means the receivership in this action. 

N. 35HFHLYHUVKLS$VVHW ́ means any and all Assets ordered to be turned over to the 

Receiver pursuant to this Order. 

O. 35HFHLYHUVKLS(QWLWLHV ́ means the Corporate Defendants, 2729 Bristol LLC, and 

3905 Marcus LLC, as well as any other entity that: (1) is located at, registered to, or operated 

from 3333 Michelson Drive, Suite 500, Irvine, California, and assists, facilitates, or otherwise 

conducts business related to the sale of real estate in Belize; (2) assists, facilitates, or otherwise 

conducts business related to the acts identified in the Findings of Fact in this Order, and is owned 

or controlled by any Defendant; or (3) Receivership Assets that are corporations or other legal 

entities. 

P. 35HOLHI'HIHQGDQWV ́ means Angela Chittenden, Beach Bunny Holdings LLC, 

the Estate of John Pukke, John Vipulis, and Deborah Connelly. 

Q. 35HVHUYHG'HIHQGDQWV ́ include any Defendant other than AIBL. 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 5 of 13
5

R. 36DQFWXDU\%HOL]H ́ means the deYHORSPHQWDUHDLQ%HOL]HNQRZQDV36DQFWXDU\

%HOL]H ́36DQFWXDU\%D\ ́37KH5HVHUYH ́DQG36DQFWXDU\%D\:LOGOLIH5HVHUYH ́DQGDQ\RWKHU

area in Belize the Court determines to be part of the Receivership. 

ORDER

I. PERMANENT CESSATION OF BUSINESS ACTIVITIES 

IT IS ORDERED that AIBL shall not engage in any business activity other than for the 

purposes of the liquidation of AIBL, and upon completion of the Belizean Liquidation 

Proceeding, AIBL shall not engage in any business activity at all, and neither the Liquidator nor 

any other person or entity shall seek to re-license and operate the business of AIBL, whether 

pursuant to Section 109(17) of the Domestic Banks and Financial Institutions Act, 2012, § 

109(17) or otherwise. 

II. MONETARY JUDGMENT 

 IT IS FURTHER ORDERED that a judgment in the amount of twenty-three million 

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Liquidator are ordered to immediately effect the transfers in Section IV(A)-(B) and to execute 

the Assignment pursuant to Section IV(C). 

III. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

A. AIBL shall relinquish dominion and all legal and equitable right, title, and interest 

in all AIBL Assets paid, transferred, assigned, or relinquished pursuant to this Order and may not 

seek the return of any such Assets. 

B. Subject to the limitations set forth in subsection A of Section IV hereof, all money 

paid to the Commission pursuant to this Order may be deposited into a fund administered by the 

Commission or its designee to be used for equitable relief, including consumer redress and any 

attendant expenses for the administration of any redress fund. If a representative of the 

Commission decides that direct redress to consumers is wholly or partially impracticable or 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 6 of 13
6

money remains after redress is completed, the Commission may apply any remaining money for 

such other equitable relief (including consumer information remedies) as it determines to be 

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such equitable relief is to be deposited to the U.S. Treasury as disgorgement. AIBL has no right 

to challenge any actions the Commission or its representatives may take pursuant to this 

Subsection.

C. The Asset Freeze is modified to permit the transfers identified in this Order. 

Upon the payments, transfers, assignations, and relinquishments required under this Order, the 

Asset Freeze is dissolved as to AIBL (and the Receiver shall cooperate with any reasonable 

request by the Liquidator to confirm such dissolution), but otherwise remains in full force and 

effect. However, after AIBL completes the payments, transfers, assignations, and 

relinquishments required under this Order, AIBL may request, in writing, that the Commission 

file a notice in the above-captioned action stating that the Asset Freeze is dissolved as to AIBL. 

If AIBL has satisfied terms of the payments, transfers, assignations, and relinquishments 

required under this Order, the Commission will file such notice within five business days of the 

request. 

D. The Commission will not oppose the recognition of the Belizean Liquidation 

Proceeding in the Chapter 15 Proceeding as a foreign main proceeding under the United States 

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representative under the United States Bankruptcy Code. After AIBL delivers the executed 

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petition for recognition in the Chapter 15 Proceeding. 

E. The Commission will have a $6 million allowed, unsecured claim in the Belizean 

Liquidation Proceeding, entitled to the payment priority provided under Section 116(2)(j) of the 

Domestic Banks and Financial Institutions Act, 2012, § 116(2)(j). Service of this Order on the 

Liquidator suffices for the purposes of claim submission, and the Commission is not otherwise 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 7 of 13
7

required to file a claim in the Belizean Liquidation Proceeding. Regardless of when the Court 

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Proceeding is timely. 

IV. TRANSFERS TO RECEIVER 

 IT IS FURTHER ORDERED that Robb Evans & Associates LLC is appointed as 

Receiver for all Assets ordered to be turned over to the Receiver pursuant to this Order. The 

Receiver shall have full powers of an equity receiver under 28 U.S.C. § 959. The Receiver shall 

be solely the agent of this Court in acting as Receiver under this Order. 

A. At the time this Order is entered, all AIBL Assets subject to the Asset Freeze up 

to the maximum amount of $23,000,000 become Receivership Assets immediately, subject to the 

limitations on transfers detailed below. Notwithstanding anything else herein to the contrary, 

the Receiver is not permitted to use or spend the $23,000,000 obtained through this Order; any 

future expenditures from that amount will be subject to further order by this Court. 

B. Within fifteen calendar days of entry of this Order, and to satisfy the judgment in 

Section II, AIBL will transfer the following AIBL Assets to the Receiver in the following order 

up to a maximum amount of $23,000,000: 

(1) DOOFDVKKHOGLQ$,%/¶VDFFRXQWDW:HOOV)DUJREDQNWKH3:HOOV)DUJR

$FFRXQW ́LQFOXGLQJDFFRXQWQXPEHU-2077, less $100,000, which amount 

shall remain in the Wells Fargo Account; 

DOOFDVKKHOGLQ$,%/¶VDFFRXQWVDW$FWLYRWKH3$FWLYR$FFRXQW ́LQFOXGLQJ

account numbers 110007527 and 400003232; and 

DOOFDVKKHOGLQ$,%/¶VDFFRXQWDW%DQFUpGLWRWKH3%DQFUpGLWRDFFRXQW ́

including account number 1101003224. 

7KHVXPRIWKHFDVKWUDQVIHUUHGSXUVXDQWWRWKURXJKDERYHLVWKH3&DVK7RWDO ́  ,IWKH

sum of the Cash Total is less than $23,000,000, AIBL will, within seven calendar days, transfer 

to the Receiver additional funds sufficient to equal a total transfer of $23,000,000.00 in cash. 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 8 of 13
8

C. :LWKLQVHYHQFDOHQGDUGD\VRIWKLV2UGHU¶VHQtry, the Liquidator on behalf of 

$,%/ZLOOH[HFXWHDQDVVLJQPHQWWKH3$VVLJQPHQW ́WKDWDVVLJQVWRWKH5HFHLYHURQWKH

&RPPLVVLRQ¶VEHKDOIDOOULJKWVWLWOHRULQWHUHVWRIDQ\VRUWWKDW$,%/KROGVLQORDQVE\$,%/WR

Kanantik International Ltd., Mango Springs Development LLC and Southern Belize Holdings 

//&FROOHFWLYHO\WKH3&KDGZLFN3URSHUW\ ́DQGDQ\RWKHU$VVHWWKDWDQ\5HVHUYHG'HIHQGDQW

directly or indirectly holds or controls including Assets nominees hold or control on behalf of 

Reserved Defendants. AIBL will not take any action in Belize, the United States, or elsewhere 

to defeat, subvert or limit the Assignment, and it will provide such reasonable assistance 

necessary to support any effort to enforce it. Notwithstanding the foregoing, once AIBL 

executes the Assignment, nothing herein prevents AIBL or the Liquidator from taking any action 

WRVHOORURWKHUZLVHOLTXLGDWH$,%/¶VULJKWVWLWOHRULQWHUHVWRIDQ\VRUWLQDQ\$VVHWLI$,%/RU

the Liquidator has no reason to believe any Reserved Defendant directly or indirectly holds or 

controls such Asset. 

V. DUTIES AND AUTHORITY OF RECEIVER 

IT IS FURTHER ORDERED that the Receiver is directed and authorized to take 

exclusive control, custody, and possession of all AIBL Assets that become Receivership Assets. 

The Receiver will have the same powers, rights and duties with respect to AIBL Assets that 

become Receivership Assets as it has with respect to other Assets it holds as an equity receiver 

pursuant to other orders of this Court in this matter. 

VI. COMPENSATION OF RECEIVER 

 IT IS FURTHER ORDERED that the Receiver and all personnel hired by the Receiver as 

herein authorized, including counsel to the Receiver and accountants, are entitled to reasonable 

compensation for the performance of duties pursuant to this Order and for the cost of actual outof-pocket expenses incurred by them, from the Receivership Assets and Assets now held by, in 

the possession or control of, or which may be received by, the Receivership Estate. The 

Receiver shall file with the Court and serve on the parties periodic requests for the payment of 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 9 of 13
9

such reasonable compensation, with the first such request filed no more than sixty days after the 

date of entry of this Order. The Receiver shall not increase the hourly rates used as the basis for 

such fee applications without prior approval of the Court. 

VII. COOPERATION

 IT IS FURTHER ORDERED that, with respect to Subsections (A)-(D) below, for as long 

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continues, or August 1, 2020, whichever comes later: 

A. The Liquidator must cooperate with representatives of the Commission in this 

case and in any investigation related to or associated with the transactions or the occurrences 

concerning Reserved Defendants that are the subject of the Amended Complaint. 

B. Regarding the transactions or the occurrences concerning Reserved Defendants 

that are the subject of the Amended Complaint, to the extent that requested information or 

individuals are under the control of the Liquidator, AIBL must appear for interviews, discovery, 

hearings, trials, and any other proceedings that a Commission representative may reasonably 

request upon thirty calendar days written notice, or other reasonable notice, at such places and 

times in the United States as a Commission representative may designate, without the service of 

a subpoena. Any information, evidence or testimony provided by the Liquidator must be 

truthful and complete. 

C. Subject to its authority under the Domestic Banks and Financial Institutions Act, 

§ 118, and Section 25(1)(f) of the International Banking Act, Cap. 267 § 25(1)(f) (Rev. Ed. 

2011), the Liquidator will take any reasonable action the Commission or Receiver requests to 

DVVLVWDQ\/RW3XUFKDVHU¶VHIIRUWWRREWDLQWLWOHWRKLVRUKHUORWWRIDFLOLWDWHWKHGHYHORSPHQWRI

uniform and expedited procedures for Lot Purchasers to obtain title to their lots, or to facilitate 

development at Sanctuary Belize. 

D. AIBL will take any reasonable position that the Commission requests in any 

litigation, hearing or proceeding, in this forum or any other forum (in the United States, Belize or 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 10 of 13
10

elsewhere), or any reasonable action the Commission requests that is necessary to preserve the 

rights this Order provides. 

E. AIBL may not take any position in any litigation, hearing or proceeding, in this 

forum or any other forum (in the United States, Belize, or elsewhere), or take or fail to take any 

reasonable action, that interferes with, attempts to invalidate, or otherwise attempts to contest or 

limit any obligation this Order creates, or that interferes with, attempts to invalidate, or otherwise 

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5HFHLYHU¶VULJKWVXQGHUWKLV2UGHU 

F. The Liquidator shall provide the Commission with thirty calendar days advance 

written notice of (a) the conclusion of the Belizean Liquidation Proceeding, (b) the termination 

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UHFRUGVRI$,%/  8SRQWKH&RPPLVVLRQ¶VZULWWHQUHTXHVWAIBL will transfer such books, 

records, and electronically stored information to the Commission prior to destruction. 

VIII. ORDER ACKNOWLEDGMENT 

 IT IS FURTHER ORDERED that AIBL must obtain acknowledgments of receipt of this 

Order from the Liquidator and any other agent or employee of AIBL, and submit such 

acknowledgments of receipt of this Order sworn under penalty of perjury within ten calendar 

days of the entry of this order, or ten calendar days of when the employment or agency begins, 

whichever comes first. 

IX. RETENTION OF EXCLUSIVE JURISDICTION 

 IT IS FURTHER ORDERED that this Court retains exclusive jurisdiction of this matter 

for purposes of construction, modification, and enforcement of this Order. Notwithstanding any 

other provision herein, AIBL may not object to, assert the invalidity of, or otherwise contest or 

dispute any obligation this Order creates on jurisdictional grounds in this Court or any other 

forum in the United States, Belize, or otherwise. 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 11 of 13
11

SO ORDERED, this ____ day of ____________, 2019. 

 ___________________________________ 

 UNITED STATES DISTRICT JUDGE 

Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 12 of 13
Case 1:18-cv-03309-PJM Document 600-1 Filed 09/24/19 Page 13 of 13

SO STIPULATED AND AGREED: 

FOR THE FEDERAL TRADE COMMISSION: 

~ ------c::-- __ _ 

Jonathan Cohen Gcohen2@ftc.gov) 

Benjamin Theisman (btheisman@ftc.gov) 

Khouryanna DiPrima (kdiprima@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Ave., N.W., CC-9528 

Washington, DC 20580 

202-326-255 l (Cohen); -2223 (Theisman); 

-2880 (Kostner); -2029 (DiPrima); 

-3197 (facsimile) 

FOR DEFENDANT: 

Julian u · lo as ·quidator of 

of Atlantic [ntemat1onal Bank Limited 

12 

9 July, 2019 

Date