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4865-5165-2823.v1.34147.78623

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

ZHU ZHAI HOLDINGS LIMITED

AND PETER PUI TAK LEE,

Plaintiffs,

v.

STEVEN IVANKOVICH,

Defendant.

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Case No. 1:20-CV-04985

THE LLCS’ RESPONSE TO 

SPECIAL MASTER’S ORDER NO. 9

NOW COMES Pilgrim Warwick LLC; Pilgrim Coulter LLC; Pilgrim Windtree LLC; 

Pilgrim Caribbean Isle LLC; Pilgrim Forest Park LLC (collectively the “Pilgrim LLCs,” each a

“Pilgrim LLC”); Alliance HTFL LLC, (together with the Pilgrim LLCs, the “LLCs”); by and 

through their attorneys, Chuhak & Tecson, P.C., for their Response to Special Master’s Order No. 

9 (Doc. 324). In support of this Response, the LLCs state as follows:

1. On August 5, 2024, Honorable Judge Schenkier, Special Master, entered his Special 

Master Order No. 9 ordering that the Third Party LLCs and Defendant Steven Ivankovich provide 

the EIN numbers for the entities listed in Plaintiffs August 2, 2024, letter or provide compelling 

reason why they should not be required to do so by August 9, 2024. See Doc. 324.

2. After continued diligent search by the LLCs asset management vice president, 

Shanna Willis, the EINS for the following twenty-one entities were located and are attached hereto 

as Exhibit A: 

a. Alliance Holdings Investments, LLC

b. Alliance HTFL LP, LLC

c. Alliance HTTX LP, LLC

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d. Atlas Apartments Acquisition

e. Atlas Apartments Development

f. Atlas Apartment Homes

g. Atlas Brookview Managing Member

h. Atlas Exchange Court

i. Atlas Holdings Investments

j. Atlas Media City

k. Atlas Media City, LLC

l. Atlas MF Holdco

m. Atlas MF Mezz Borrower

n. Atlas Multifamily Three

o. Atlas Longfellow Arms

p. A & O Family LLC

q. Atlas Legends of El Paso

r. Atlas Mariposa Villas

s. Atlas River Oaks

t. Atlas Stone Bridge at City Park

u. Glencoe Family Dwelling LLC

3. No further EINs were located after a diligent search. 

4. Also attached hereto as Exhibit B is the previously produced list of accounts for 

each of the limited liability companies that lists each limited liability company by name, with the 

name of their bank, the account numbers, and ABA numbers for each bank. 

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5. Exhibit B includes bank information for the limited liability companies referenced 

in Plaintiffs’ August 2, 2024, letter.

6. Bearing in mind that the Special Master’s Order No. 1, dated March 19, 2024, 

required the Defendant and Third Party LLCs to provide information to serve subpoenas on all 

entities for which defendant “has the ability to transfer funds,” the Plaintiffs has such information 

(and has had that information for some time) considering it has each named limited liability 

company with account numbers as to their respective banks.

7. Accordingly, Plaintiffs may issue subpoenas to each of the identified banks with 

the name of the limited liability company and full account number. 

8. Such identifying information should be sufficient and, in undersigned Counsels’ 

combined decades’ experience in financial services litigation, is more information than many 

subpoenaing parties customarily have when issuing subpoenas to banks for a customer’s financial 

records. 

9. That Plaintiffs have sufficient information is underscored by the undisputed fact 

that Jeanette Ivankovich has received countless documents responsive to subpoenas she issued as 

to the various limited liability companies, with or without the EINs. 

10. In that light, if a bank responds that it cannot identify responsive documents with 

the name of the account holder and full account number, and that it can only identify such 

documents if it has the EIN for that specific entity, then the parties should address the bank’s 

response at that time. 

11. Of note, Plaintiffs do not claim that have insufficient information to subpoena (or 

otherwise don’t already possess documents) related to the PILGRIM LLCs to litigate the release 

or turnover of the LLCs’ funds deposited by Walker & Dunlop. 

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Respectfully submitted,

Pilgrim Warwick LLC, Pilgrim Coulter LLC, 

Pilgrim Windtree LLC, Pilgrim Caribbean Isle LLC, 

Pilgrim Forrest Park LLC, and Alliance HTFL LLC, 

/s/ C. Cy Porras

By: One of Its Attorneys

Michael Debre (IL Bar No. 6296197)

C. Cy Porras (IL Bar No. 6324512)

CHUHAK & TECSON, P.C.

120 S. Riverside Plaza, Suite 1700

Chicago, IL 60606

(312) 844-4313

mdebre@chuhak.com

cporras@chuhak.com

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EXHIBIT A

INCORPORATED

BY REFERENCE

ONLY

The Exhibit is uploaded

to JAMS and will be

Transmitted by

Separate Service

Case: 1:20-cv-04985 Document #: 325 Filed: 08/09/24 Page 5 of 6 PageID #:3956
EXHIBIT B

INCORPORATED

BY REFERENCE

ONLY

will be

Transmitted by

Separate Service

The Exhibit is

uploaded to JAMS and

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