1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ZHU ZHAI HOLDINGS LIMITED and )

PETER PUI TAK LEE, )

Plaintiffs, )

v. ) Case No. 20-cv-4985

)

STEVEN IVANKOVICH, )

Defendant. )

MOTION FOR TURNOVER OF FUNDS HELD BY DEBTOR IVANKOVICH, P2 

PORTFOLIO MANAGEMENT, LLC, IVANKOVICH FAMILY, LLC OR, 

ALTERANATIVELY AN ORDER PROHIBITING TRANSFER OF FUNDS

Comes now, Zhu Zhai Holdings Limited and Peter Pui Tak Lee (“Plaintiffs”), and seeks a 

turnover order of funds identified as Ivankovich’s, and in support, states as follows:

INTRODUCTION

On May 31, 2022, this Court denied Steven Ivankovich (“Ivankovich”), P2 Portfolio 

Management LLC (‘P2 LLC”) and the Ivankovich Family LLC’s motion to quash and dismiss 

citations issued to them. It also granted Plaintiffs’ rule to show cause and ordered the citations be 

responded to by June 24, 2022. (DOC #197). In addition, this Court unfroze the accounts held at 

Stifel for the LLCs after finding that Plaintiffs failed to establish that those funds were 

Ivankovich’s. In response to this Court’s May 31, 2022 Order, Plaintiffs now set forth evidence 

that (1) Ivankovich himself has assets sufficient to satisfy the judgment and (2) the funds in the P2 

and Ivankovich Family accounts are Ivankovich’s funds. Ivankovich has already begun moving 

funds out of Stifel in an apparent attempt to prevent Plaintiffs from collecting on their judgment. 1

1 This motion is set for initial hearing on June 27, 2022. Given the relief requested, Plaintiffs submit that 

Ivankovich, P2 and Ivankovich Family should not be transferring any funds or assets.

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Ivankovich’s sworn personal financial statement shows he has a net worth well in excess 

of that necessary to pay the judgment. (Ex. 1, Ivankovich Personal Financial Statement).2 These 

Financial Statements were produced in this case and sworn to by Ivankovich. As the Court will 

see, there is enough money to pay the judgment many times over. Ivankovich either made a false 

statement in this document or has the funds to immediately pay the judgment. These funds should 

be turned over to the Plaintiffs or Ivankovich should be held in contempt.

Further, in a proceeding in the Supreme Court of New York Captioned Atlas v. Macquarie 

Texas Loan Holder, et.al., Index 651657/2017 (the “New York Case”), Ivankovich gave sworn 

testimony that establishes he was in ownership and control of the funds in the LLCs at issue.

3

 As 

outlined below, he testified that cash flowed freely to and from the LLC’s, the chain of ownership 

had plenty of assets, and that he could populate an entity with “signing of a pen and phone call in 

a matter of minutes.” (Ex. 2, pg. 278, ln.13 – pg. 304).

At minimum, Ivankovich’s testimony and the discovery evidence should allow this Court 

to maintain the status quo and not allow funds to be disbursed from Ivankovich, P2 LLC or the 

Ivankovich Family LLC until further discovery is completed. 

ARGUMENT

I. Ivankovich has sufficient assets to pay the judgment and should turnover the 

funds or be held in contempt.

In discovery, Ivankovich produced a personal financial statement, which he signed under 

oath, and which plainly shows that he has funds to satisfy the judgment. (Ex. 1). At the time 

Ivankovich’s financials were produced he was entrenched in this litigation and should not have 

2 This exhibit is submitted in camera as it has been designated confidential. 3 Notably, the issue in the New York Case was whether Ivankovich had sufficient funds to acquire property in an 

auction that was previously owned by his entities and foreclosed on. Ivankovich went to great lengths to show the 

LLCs at issue here had funds that could be transferred at a 

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been transferring assets. As such, the mere fact that the financial statement is from August 26, 

2020 should be of no consequence—those funds should still be within Ivankovich’s control, and 

if they are not, that strongly suggests he transferred them in an attempt to make himself judgment 

proof. This Court should Order the turnover of the judgment amount or hold Ivankovich in 

contempt of Court.

It should also be noted that within days (maybe hours) of this Court lifting the freeze on 

the Stifel accounts, Ivankovich’s lawyers ordered the money to be transferred out. It is not yet 

know where the request to transfer the funds was made to. However, this is certainly further 

evidence that Ivankovich owns and controls the LLCs’ funds. (Ex. 3, 6/9/22 Wandner Email Re: 

Transfer). Concerningly, it also shows that Ivankovich may be taking steps to avoid paying the 

judgment, which is all the more reason to grant the present motion. 

II. An Order of turnover is now warranted given there is sufficient evidence that P2 

and Ivankovich Family holds funds of Ivankovich’s. 

In denying Plaintiff’s prior motion for turnover (DOC#186), this Court found Plaintiff had 

not yet “sufficiently established” that the assets held were assets of judgement debtor Ivankovich. 

It cited R & J Construction Supply Co. v. Adamusik, 2017 IL App (1st) 160778, which found that 

there cannot be a basis for a judgment to stand against a third-party when it had no assets of the 

debtor and no relationship with the debtor. (Id. at ¶ 21). It further noted that there must be a 

reasonable basis or some evidence that the third party had assets of the judgment debtor. (Id. at ¶ 

14). 

Plaintiffs now have such evidence. P2 LLC and Ivankovich Family have $10,991.073 and 

$19,042.437.51 in assets respectively. (Ex. 2, Stifel Amended Citation Response). And there is a

reasonable basis to find that P2 LLC and Ivankovich Family LLC hold assets that belong to 

Ivankovich. (Ex. 2, pg. 278 -304).

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In the New York Case, Ivankovich testified that LLCs that held accounts at Stifel (which 

include P2 LLC and Ivankovich Family LLC) were accounts he could draw checks on and that 

that the Ivankovich family was 100% owners of those LLCs. (Ex. 1, pg. 137, ln. 2-10). Ivankovich 

testified:

Q. And what did you end up doing?

A. We started wiring the -- this was my call, what I thought would be the most 

efficient way to do it -- we started wiring money to Chase where we had 

accounts in. It was near the auction. Being a big money sender bank that, you 

know, issues cashier's checks and stuff quickly, I had calls into the bank at

Stifel telling them, look, we need to be prepared to wire money into a Chase 

account first thing in the morning when you get there because we need to 

generate this cashier’s check and went to the bank directly with our head of asset 

management Ravi Malli who flew in that morning early and we immediately went 

to the bank ... But plan B would have been Stifel immediately delivering us a 

cashier's check. 

(Ex. 2, pg. 132-133;134). 

Q. Now, in terms of the Stifel accounts, some of those accounts -- whose names are 

those accounts in?

A. Various sundry from family LLC to trust accounts to individual family 

members, my father, my mother.

Q. Was some of them in the names of your father?

A. Yes.

Q. And you?

A. Not the statements that were produced for -- during the process of this 

litigation but there are trust accounts that I have.

Q. And would those accounts had been available for Stifel could draw a check 

on?

A. Absolutely, yes. 

(Ex. 2, pg. 136-137).

...

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Q. Have you ever asked for funds from your father before?

A. For transactions, all the time.

Q. Has he ever turned you down?

A. Never. Just to clarify that, even though it's a family situation, we try and run it 

like a company. Nobody could draw that kind of money without, you know, one 

or two signatures so that's just the way we set things up to go. 

(Ex. 2, pg. 137). 

...

Q. So when you signed that certificate and said in the present tense that that 

company has the funds, you were relying on funds elsewhere, true?

A. We were relying on the funds in the chain of ownership of those companies.

Q. You were relying on funds that were held by the Ivankovich family, true?

A. Correct. Who are the 100 percent owners of those companies. I will remind 

you, counselor, those are pass-through entities so... 

(Ex. 2, pg. 278).

...

Q. Is it your understanding that cash can flow freely between those entities?

A. Sure.

Q. And the control of all those entities is ultimately held by who?

A. By 80 percent myself and -- 20 percent myself and 80 percent Anthony 

Ivankovich.

Q. 80 percent you?

A. 20 percent me and 80 percent Anthony Ivankovich with me being the sole 

managing member. 

(Ex. 2, pg. 279).

...

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Q. Okay. Now, can you explain to me, sir, how it is that on October 30th, 2017 

and this is about five months after -- more than five months after the closing 

of my client's purchase of the equity interest in the properties, how you could

represent to the Court that that entity was in a strong financial condition?

A. I take that to mean that the overall Atlas entity, which includes the Atlas 

principles. We could capitalize that entity in five minutes. 

(Ex. 2, pg. 303).

...

Q. How is it that your counsel could represent to this Court yesterday that that 

entity has no assets?

A. The specific entity doesn't, but the chain of ownership, as I said, has plenty of 

assets. We could populate that entity with the signing of a pen and a phone 

call in a matter of minutes.

Q. Is it your testimony, sir, in this Court under oath that you have the authority 

to move money as you see fit to that entity or away from that entity?

A. I don't have the authority, but I have the ability. 

(Ex. 2, pg. 304). 

...

Q. So am I right on the 27th you made an effort to make a series of transfers 

from those properties, LLCs into that Atlas account, JP Morgan Chase, 

right?

A. Those and other accounts, correct. 

(Ex. 2, pg. 308).

Ivankovich testified he had the ability to move money in and out of the LLCs accounts 

freely, including for his own purpose. He testified that the Ivankovich family owned 100% of 

the funds. (Ex. 1, pg. 278, ln. 18-20). Ivankovich went so far as to say he could populate an 

entity with the signing of a pen and a phone call within a matter of minutes. (Ex. 1, pg. 304, ln. 

11-13). This was sworn testimony that he gave under oath in a case where he sought tens of 

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millions of dollars in damages. Nonetheless, now he wants this Court to believe the exact 

opposite of what he previously said – that the funds held in P2 LLC and Ivankovich Family LLC 

are not his. They were his when it was convenient for him in the New York Case – they are not 

his in this matter when he seeks to avoid his financial obligations. 

III. If this Court is not Inclined to Order the Turnover of Funds held in the P2 LLC 

and Ivankovich Family LLC accounts, then they should not be allowed to transfer

funds to any other accounts from any of its accounts 

There is now sufficient evidence before this Court that the LLCs assets are those of 

Ivankovich. Based on Ivankovich’s history of ignoring his obligations to his investors and this 

Court, it is likely that he will soon be transferring money that could be used to pay this judgment 

out of the LLCs and to any unknow account. In order to maintain the status quo, Plaintiffs request 

that if a turnover is not ordered that P2 LLC and the Ivankovich Family LLC be Ordered not to 

transfer any of the approximately $29,000,000 between the two accounts out of the LLCS. 

Plaintiffs further request that this Court consider setting this matter for an evidentiary hearing after 

the citations are answered and Ivankovich be Ordered to appear.

CONCLUSION

WHEREFORE, Plaintiffs seek a turnover Order from this Court in an amount that will 

fully satisfy the judgment amount, interest and attorneys’ fees, or alternatively, Order all accounts 

remain frozen until further discovery is completed.

Dated: June 16, 2022. Respectfully submitted,

/s/ Amir Tahmassebi

Amir Tahmassebi, Bar #6287787

Konicek & Dillon, P.C.

70 W. Madison, Suite 2060

Chicago, IL 60602

(312) 328-9166 (Direct)

(630) 262-9659 (Fax)

amir@konicekdillonlaw.com

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Steven Lammers, Bar #6294413

Mandel Rauch & Lammers, P.C.

704 Adams Street, Suite F

Carmel, IN 46032

(317) 581-7440 (Direct)

(317) 848-6197 (Fax)

slammers@mhmrlaw.com

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that a true and correct copy of the foregoing was filed 

with the Court on June 16, 2022 causing all counsel of record to be served via the Court’s 

CM/ECF filing system. 

/s/ Amir R. Tahmassebi

Amir R. Tahmassebi

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From: Jason Wandner <jason@wandnerlaw.com> 

Sent: Thursday, June 9, 2022 8:16 PM

To: Marc S. Dobin <mdobin@dobinlaw.com>

Cc: Gary Goldstein <gary@gagpa.com>

Subject: Re: Stifel

Marc please confirm that all the frozen money will be unfrozen and

promptly available to be transferred if it has not already been done.

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