IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

UNITED STATES OF AMERICA, :

:

Plaintiff, :

:

: CASE NO: 1:18-CR-109-(2)

 v. :

: JUDGE COLE

SERGHEI VERLAN, :

:

Defendant. :

PLAINTIFF UNITED STATES OF AMERICA=S 

MOTION FOR ORDER TO APPLY MONIES HELD

BY THE FEDERAL BUREAU OF INVESTIGATION

FOR PAYMENT OF RESTITUTION JUDGMENT

Now comes the United States of America, by and through counsel, and moves this Court 

for an Order authorizing the Federal Bureau of Investigation to turn over to the United States Clerk 

of Courts all monies it has in its possession, received from Defendant, Serghei Verlan, to apply to 

Defendant restitution obligation. The grounds for this motion are more fully set forth in the 

accompanying Memorandum in Support. 

Respectfully submitted,

KENNETH L. PARKER

United States Attorney

s/Bethany J. Hamilton

BETHANY J. HAMILTON(0075139)

Assistant United States Attorney

Attorney for Plaintiff

303 Marconi Boulevard, Suite 200

Columbus, Ohio 43215

(614)469-5715

Fax: (614)469-5240

Email: Bethany.Hamilton@usdoj.gov

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MEMORANDUM IN SUPPORT

On December 19, 2022, Defendant Serghei Verlan (ADefendant@) plead guilty to the 

Conspiracy To Participate In Racketeering Activity (Doc. 279). Defendant was sentenced to 

72 months imprisonment with credit for time served, beginning September 13, 2018. Defendant 

was ordered to pay a $100 special assessment and restitution for the victims in this case in an 

amount to be determined. Although the final restitution amount has yet to be determined, it is 

anticipated to be in excess of a million dollars.

Counsel for Plaintiff has been informed that the Federal Bureau of Investigation (AFBI@) is 

in possession of funds which were taken from the Defendant at the time of arrest in the amount of 

$3,984.18. Plaintiff seeks an Order authorizing the FBI to turn over the funds in its possession 

owned by Defendant for purposes of partially satisfying Defendant’s outstanding restitution 

obligation. 

Pursuant to 18 U.S.C. ' 3613(a), the United States is permitted to enforce a criminal 

judgment using the practices and procedures for enforcement of civil judgments under Federal or 

state law. The financial litigation unit of the United States Attorney’s Office (AUSAO@) is 

responsible for collecting criminal penalty assessments, restitution, and fines. 18 U.S.C. '

3612(c)(1)-(3). Therefore, the USAO has the full responsibility for collecting the restitution 

obligation imposed against Defendant. 

Once the Court enters judgment in a criminal case, a lien arises in favor of the United States 

against all of a Defendant’s real and personal property. 18 U.S.C. ' 3613(c). Hence, a lien arose 

against Defendant’s property on the entry of this judgment. 

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Because the United States Government has a right to collect criminal judgments, and has a 

valid lien against all Defendant’s real and personal property, any money being held by a 

government agency in which Defendant has a substantial interest is subject to the government=s 

continuing interest in the satisfaction of that judgment. 

Based upon the foregoing, the Government respectfully requests that this Court issue an 

Order authorizing the FBI to turn over to the United States of America any and all of the funds 

currently in its possession belonging to Defendant, Serghei Verlan, to be applied to the restitution 

obligation imposed against Defendant, made payable to the United States District Court Clerk, and 

sent to The United States District Court Clerk, 110 Potter Steward U.S. Courthouse, 100 East Fifth 

Street, Cincinnati, Ohio 45202.

Respectfully submitted,

KENNETH L. PARKER

United States Attorney

s/Bethany J. Hamilton

BETHANY J. HAMILTON(0075139)

Assistant United States Attorney

Attorney for Plaintiff

303 Marconi Boulevard, Suite 200

Columbus, Ohio 43215

(614)469-5715

Fax: (614)469-5240

Email: Bethany.Hamilton@usdoj.gov

Case: 1:18-cr-00109-DRC Doc #: 283 Filed: 02/01/23 Page: 3 of 4 PAGEID #: 2026
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CERTIFICATE OF SERVICE

A true copy of the above and foregoing Plaintiff United States Of America’s Motion For Order 

To Apply Monies Held By The Federal Bureau Of Investigation For Payment Of Restitution Judgment

was electronically filed with the Clerk of the Court using the CM/ECF system and mailed to 

Defendant’s last known address, Serghei Verlan, FCI Elkton, P.O. Box 129, Lisbon, Ohio 44432 by 

first class mail, postage prepaid, this 1st day of February, 2023.

s/Bethany J. Hamilton

BETHANY J. HAMILTON(0075139)

Assistant United States Attorney

Case: 1:18-cr-00109-DRC Doc #: 283 Filed: 02/01/23 Page: 4 of 4 PAGEID #: 2027