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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND 

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

[~ STIPULATED ORDER PARTIALLY MODIFYING THE COURT'S 

ORDERS AT DOCKET ENTRIES 1112 AND 1194 AS TO DEFENDANTS LUKE 

CHADWICK, PRODIGY MANAGEMENT GROUP LLC, BELIZE REAL ESTATE 

AFFILIATES LLC, EXOTIC INVESTOR LLC, AND SOUTHERN BELIZE REALTY 

LLC 

On October 31, 2018, Plaintiff the Federal Trade Commission ("Commission" or "FTC"), 

filed its Complaint for Permanent Injunction and Other Equitable Relief ("Complaint"), pursuant 

to Section 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 53(b), and the 

Telemarketing and Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 

U.S.C. §§ 6101-6108. On January 11, 2019, the Court granted the FTC's motion to amend, 

substituting the Amended Complaint for Permanent Injunction and Other Equitable Relief 

("Amended Complaint") for the Complaint. Defendants Luke Chadwick, Prodigy Management 

Group LLC, Belize Real Estate Affihates LLC, Exotic Investor LLC, and Southern Belize Realty 

LLC were served with the Amended Complaint and summons.. The Commission and 

Defendants Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC stipulate to the entry of this 

Stipulated Order Modifying the Court's Orders at Docket Entries 1112 and 1194 as to 

Defendants Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC ("Order") to resolve all matters in 

dispute between them in this action. 

IT IS THEREFORE ORDERED: 

Unless otherwise expressly specified herein, none of the Court's prior orders are 

,modified and all remain in full force and effect, including the following orders: (!) Docket 

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Entry 1112, Final Order for Permanent Injunction and Monetary Judgment Against Defaulting 

Defendants Jolm Usher, 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, Newport Land Group LLC, Power Haus Marketing, 

Prodigy Management Group LLC, Belize Real Estate Affiliates LLC, Exotic Investor LLC, 

Southern Belize Realty LLC, Sanctuary Belize Property Owners' Association, and the Estate of 

Jolm Pukke ("Default Order") and (2) Docket Entry 1194, Amended Final Order for Permanent 

Injunction and Monetary Judgment Against Defendants Andris Pukke, Peter Baker, and Luke 

Chadwick ("De Novo Order"). For clarity, unless otherwise expressly specified herein, the 

provisions of this Order are in addition to and not in lieu of any prior order or section of any 

prior order. 

FINDINGS 

In addition to the findings contained in the Default Order, the De Novo Order, and the 

Court's Memorandum Opinion at Docket Entry 1020, the Court finds as follows: 

1. Only for purposes of this action, Defendants Luke Chadwick, Prodigy 

Management Group LLC, Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern 

Belize Realty LLC admit the facts necessary to establish jurisdiction. 

2. Nothing in this Order waives any Fifth Amendment privilege that Luke Chadwick 

may have. 

3. Defendants Luke Chadwick, Prodigy Management Group LLC, Belize Real 

Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC waive any claims 

they 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 agree to bear their own costs and 

attorney fees. 

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4. Defendants Luke Chadwick, Prodigy Management Group LLC, Belize Real 

Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC waive all rights to 

appeal or otherwise challenge or contest the validity of this Order. 

DEFINITIONS 

Unless otherwise, expressly specified herein, the Definitions contained in the De Novo 

Order, DE 1194, apply to this Order. 

ORDER 

I. BAN ON REAL ESTATE GOODS AND SERVICES 

IT IS ORDERED that Luke Chadwick is permanently restrained and enjoined from 

advertising, marketing, promoting, or offering for sale, or assisting in the advertising, marketing, 

promoting, or offering for sale of any Real Estate Good or Service, whether directly or through 

an intermediary, including by consulting, brokering, planning, investing, or advising. 

As used in this Section, "Real Estate Good or Service" shall'mean any intere~t in, service 

related to, or development of, any real estate containing or involving more than four lots or units 

of any kind. 

Provided, however, that the Commission's agreement to this definition is expressly 

premised upon the truthfulness, accuracy, and completeness of Luke Chadwick's sworn 

statement regarding his ownership or control of real estate ("real estate submission") submitted 

to the Commission, namely his December 8, 2021 declaration submitted to counsel for the 

Commission on December 8, 2021. If, upon motion by the Commission, the Court finds that 

Luke Chadwick failed to disclose any ownership or control over real estate, directly or indirectly, 

or made any other material misstatement or omission in the real estate submission, "Real Estate 

Good or Service" as used in this section shall, retroactive to the date of entry of this Order, mean 

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any interest in, service related to, or development of, any real estate containing or involving three 

or more lots or units of any kind. 

Provided further, and for clarity only, this Section is in addition to and not in lieu of (I) 

Section I of the De Novo Order, and (2) Section I of the Default Order. 

II. MODIFICATION OF MONETARY PROVISIONS AS TO LUKE CHADWICK 

IT IS FURTHER ORDERED that: 

A. Sections IV. and V. of the De Novo Order shall no longer apply to Defendant 

Luke Chadwick as of the date this Order is entered. For clarity, nothing in this Order modifies 

Sections IV. and V. of the De Novo Order for any of the other Defendants, including Andris 

Pukke and Peter Baker, or otherwise releases them from any of their own obligations under those 

sections of the De Novo Order. 

B. Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC hereby turnover to the Receiver any 

and all legal or equitable interests, of any type, whether owned or controlled directly or 

indirectly, in any property or entity associated with the real estate developments known as 

Sanctuary Belize and Kanantik, and any other real estate development that Defendants ever 

previously controlled. For clarity only, the legal or equitable interests that this paragraph 

requires Luke Chadwick to tum over to the Receiver include, but are not limited to, all legal or 

equitable interests he may have, directly or indirectly, in Prodigy Management Group LLC, 

Belize Real Estate Affiliates LLC, Exotic Investor LLC, Southern Belize Realty LLC, Mango 

Springs Development Ltd., Palmaya Development Ltd., G&R Development Company of Belize 

Ltd., Kanantik International Limited, and Mango Springs Development LLC. 

C. Luke Chadwick, Prodigy Management Group LLC, B_elize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC relinquish dominion and all legal 

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and equitable right, title, and interest in all Assets turned over or relinquished pursuant to this 

Order, the Default Order, or the De Novo order and may not seek the return of any Assets. 

D. Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC individually, collectively, or in any 

combination, and their officers, agents, employees, and attorneys, and all other persons in active 

concert or participation with any of them, who receive actual notice of this Order, shall fully 

cooperate with and assist the FTC and the Receiver with the turnover of Assets pursuant to this 

Order, the Default Order, and the De Novo Order, and are hereby restrained and enjoined from 

· directly or indirectly: 

1. Interfering with the Commission's and Receiver's efforts to manage, or 

take custody, control, or possession of, the Assets ordered to be turned 

over to the Commission or the Receiver pursuant to any order of this 

Court; 

2. Transacting any of the business of any Receivership Entity or any entity 

that itself is a Receivership Asset; 

3. Transferring, receiving, altering, selling, encumbering, pledging, 

assigning, liquidating, or otherwise disposing of any Assets ordered to be 

turned over to the Commission or the Receiver pursuant to any order of 

this Court; or 

4. Refusing to cooperate with the Commission or the Receiver, or the 

Receiver's duly authorized agents, in the exercise of their duties or 

authority under any order of this Court. 

E. Any money paid to the FTC, for any reason, by, on behalf of, or derived from the 

assets of Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates LLC, 

Exotic Investor LLC, Southern Belize Realty LLC, Mango Springs Development Ltd., Mango 

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Springs Development LLC, Palmaya Development Ltd., Kanantik International Limited, and 

G&R Development Ltd. may be deposited into a fund administered by the FTC or its designees 

to be used for consumer relief, such as redress and any attendant expenses for the administration 

of any redress fund. Defendants have no right to challenge any actions the Commission or its 

representatives may take pursuant to this Subsection. 

F. The facts alleged in the Amended Complaint and otherwise previously found by 

the Court will be taken as true as to Luke Chadwick, Prodigy Management Group LLC, Belize 

Real Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC, without 

further proof, in any subsequent civil litigation by or on behalf of the Commission, including, but 

not limited to, any proceeding to enforce its rights pursuant to this Order, the Default Order, or 

the De Novo Order. Such proceedings would include a nondischargeability complaint in any 

bankruptcy case. 

G. The facts alleged in the Amended Complaint establish all elements necessary to 

sustain an action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, . ' 

11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes. 

H. Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC, acknowledge that their Taxpayer 

Identification Numbers (Social Security Numbers or Employer Identification Numbers), which 

they have previously submitted to the Commission, may be used for collecting and reporting on 

any delinquent amount arising out of this Order, in accordance with 31 U.S.C. § 7701. 

I. After Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate 

Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC have dismissed with 

prejudice all appeals from any prior orders of this Court, the Receiver shall transfer or relinquish 

to Luke Chadwick all rights it may have in the real estate located at 1828 Jamaica Road, Costa 

Mesa, CA 92626. 

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J. After Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate 

Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC have dismissed with 

prejudice all appeals from any prior orders of this Court, the asset freeze imposed on Luke 

Chadwick pursuant to the prior Temporary Restraining Order (DE 13) entered on November 5, 

2018, Interim Preliminary Injunction (DE 34) entered on November 20, 2018, or Preliminary 

Injunction (DE 615) entered on October 3, 2019, is hereby lifted as to Luke Chadwick. 

ill. DISMISSAL OF APPEALS 

IT IS FURTHER ORDERED that Luke Chadwick, Prodigy Management Group LLC, 

Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC shall 

immediately dismiss with prejudice all appeals from any prior orders of this Court, including the 

appeal docketed as Case No. 21-1.452 in the United States Court of Appeals for the Fourth 

Circuit, and further waive any rights to bring any subsequent appeals from any orders entered by 

this Court prior to tl).is Order. 

IV. COOPERATION 

IT IS FURTHER ORDERED that Luke Chadwick, Prodigy Management Group LLC, 

Belize Real Estate A~filiates LLC, Exotic Investor LLC, and Southern Belize Realty LLC must 

fully cooperate with representatives of the Commission in this case and in any investigation 

related to or associated with the transactions or the occurrences that are the subject of the 

Amended Complaint or subsequent findings by the Court. Luke Chadwick, Prodigy 

Management Group LLC, Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern 

Belize Realty LLC must provide truthful and complete information, evidence, and testimony. 

Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates LLC, Exotic 

Investor LLC, and Southern Belize Realty LLC must appear for interviews, discovery, hearings, 

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

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5 days written notice, or other reasonable notice, at such places and times as a Commission 

representative may designate, without the. service of a subpoena. 

V. ORDER ACKNOWLEDGMENT 

IT IS FURTHER ORDERED that Luke Chadwick, Prodigy Management Group LLC, 

Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC obtain 

acknowledgments ofreceipt of this Order: 

A. Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates 

LLC, Exotic Investor LLC, and Southern Belize Realty LLC within seven (7) days of entry of 

this Order, each must submit to the Commission an acknowledgment ofreceipt of this Order 

sworn under penalty of perjury. 

B. For twenty (20) years after entry of this Order, Luke Chadwick, Prodigy 

Management Group LLC, Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern 

Belize Realty LLC each must, for itsc;lf and any business that such Defendant, individually or 

collectively with any other Defendants, is the majority pwner or controls directly or indirectly, 

deliver a copy ofthis Order to: (1) all principals, officers, directors, and LLC managers and 

members; (2) all employees having managerial responsibilities for marketing, sales, or 

operations, and all agents and representatives who participate in marketing or sales; (3) all 

payment processors as well as all consultants or contractors who perform services in connection 

with marketing or sales; and ( 4) any business entity resulting from any change in structure as set 

forth in the Section titled Compliance Reporting in the Default Order or the De Novo Order. 

Delivery must occur within seven (7) days of entry of this Order for current personnel. For all 

others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which Luke Chadwick, Prodigy Management 

Group LLC, Belize Real Estate Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty 

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LLC deliver a copy of this Order, that Defondant must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

VI. RETENTlON OF JURISDICTION 

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

purposes of construction. modification, and enforcement of this Order. 

SO ORDERED, this __ day of ____ _,, 202_. 

SO STIPULATED AND AGREED: 

FOR THE .FEDERAL TRADE COMMISSION: 

~ ~-

- Jonathan Cohen (icohen2@ftc.gov) 

Benjainin Theisman (btheisman@ftc.gov) 

Christopher Erickson (cerickson@ftc.gov) 

Federal Trade Commission 

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

Washington, DC 20580 

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

a3671 (Erickson) -3197 (facsimile) · 

UNITED STATt;;S DISTRICT JUDGE 

FOR LUKE CHADWICK, PRODIGY MANAGEMENT GROUP LLC, BELIZE REAL 

ESTATE AFFILIAT LLC, EXOTIC INVESTOR LLC, AND SOUTHERN. BELIZE 

REALTYLLC 

/l.}1'1 /2 I 

Luke Chadw)e . . . . . . . Date ~ ~ /11divid1rgl_l:P m1d as an Officer of Prodigy Manageme.11t Group LLC, Belize ·Real Estate 

Affi/iate.r LLC. Exotic Investor LL€, wu/ Southem Belize Real{)! LL.C 

John B. Williams 

Williams Lopatto PLLC (admitted pro hac vice) 

1629 K Street, N.W., Suite 300 

Washington, DC 20006 

9 

Date 

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: 

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LLC deliver a copy of this Order, that Defendant must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order . 

. VI. RETENTION OF JURISDICTION 

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

purposes of construction, modification, and enforcement of this Order. 

SO ORDERED, this 1...3 day of&rcl, , 202 '2-:- - . -r 

SO STIPULATED AND AGREED: 

FOR THE FEDERAL TRADE COMMISSION: 

Jonathan Cohen (jcohen2@ftc.gov) 

Benjamin Theisman (btheisman@ftc.gov) 

Christopher Erickson ( cerickson@ftc.gov) 

Federal Trade Commission 

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

Washington, DC 20580 

202-326-2551 (Cohen); -2223 (Theisman); 

-3671 (Erickson) -3197 (facsimile) 

Date 

FOR LUKE CHADWICK, PRODIGY MANAGEMENT GROUP LLC, BELIZE REAL 

EST A TE AFFILIATES LLC, EXOTIC I.l'i'VESTOR LLC, AND SOUTHERN BELIZE 

REALTYLLC 

Luke Chadwick Date 

Individually and as an Officer of Prodigy Management Group LLC, Belize Real Estate 

Affiliates LLC, Exotic Investor LLC, and Southern Belize Realty LLC 

_V,/,., /j '4_/lti-4,,,,/£~. f}Jt 

Johrf B. Williams 1 • 

Williams Lopatto PLLC (admitted pro hac vice) 

1629 K Street, N.W., Suite 300 

Washington, DC 20006 

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Telephone: 202-296-1665 

E-mail: jbwilliams@williamslopatto.com 

and 

fbJ rr,t1_l(_, 

Neil H. Koslowe 

Potomac Law Group, PLLC 

1300 Pennsylvania Avenue, N.W., Suite 700 

Washington, DC 20004 

Telephone: 202-320-8907 

E-mail: nkoslowe@potomaclaw.com 

Counsel for Luke Chadwick, Prodigy Management Group LLC, Belize Real Estate Affiliates LLC. 

Exotic Investor LLC, and Southern Belize Real(v LLC 

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