USA v. HandMemorandum regarding Restitution as to Jehu HandD. Mass.February 27, 2019UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS _____________________________ ) UNITED STATES OF AMERICA ) Criminal No. 15-cr-10386-WGY ) v. ) ) JEHU HAND, ) ) Defendant. ) _____________________________ ) JOINT MEMORANDUM REGARDING RESTITUTION AS TO JEHU HAND The parties respectfully request that the Court order the defendant to pay restitution in the amount of $486,953.44, which is the sum of the losses sustained by the individuals who responded to the government’s notifications concerning the Crown Marketing and Greenway Technology pump-and-dump schemes.1 See 18 U.S.C. § 3663A(a)(1)-(2) and (c)(1)(B). The 1 To notify potential victims of the Crown Marketing pump-and-dump, the government created a webpage in August 2016 (https://www.justice.gov/usao-ma/ticker-cwnm-j-hand-l-hand-and- hand) describing the fraud and directing potential victims who purchased Crown shares during the relevant period to contact the United States Attorney’s Office. The government also worked with FINRA to identify approximately 253 individuals who appeared to have lost the greatest amounts or resided in Massachusetts during the scheme, and sent letters to the aforementioned individuals. Based on the interviews conducted and the responses received, the government identified 39 individuals with losses totaling $331,362.41. Losses were calculated as the difference between the prices at which Crown shares were purchased and the prices at which Crown shares were sold. For those victims who continue to hold Crown shares, the current value of the shares has been calculated as $0.00. Losses exclude any gains made by sale of Crown shares. To notify potential victims of the Greenway Technology pump-and-dump, the government created a webpage in April 2016 (https://www.justice.gov/usao-ma/victim-and-witness- assistance-program/ticker-gwyt-brown-hand-and-katz) describing the fraud and directing potential victims who purchased Greenway shares during the relevant period to contact the United States Attorney’s Office. The government also worked with FINRA to identify approximately 168 individuals who appeared to have lost the greatest amounts as a result of their purchase of Greenway shares during the scheme. The government sent letters to the Case 1:15-cr-10386-WGY Document 201 Filed 02/27/19 Page 1 of 3 2 parties also ask that restitution be (1) joint and several among the defendants convicted of the Crown Marketing scheme for the $331,362.41 in losses sustained by the Crown victims and (2) joint and several among the defendants convicted of the Greenway Technology scheme for the $155,591.03 in losses sustained by the Greenway victims. Respectfully submitted, ANDREW E. LELLING United States Attorney By: /s/ Andrew Palid ANDREW PALID Special Assistant U.S. Attorney JAMES HERBERT Assistant U.S. Attorney JEHU HAND By: /s/ Eugene Iredale EUGENE IREDALE Iredale & Yoo, APC 105 West F. Street, 4th Flr. San Diego, CA 92101-9210 Dated: February 27, 2019 aforementioned individuals and received responses from 25 of these individuals with losses totaling $155,591.03. Losses were calculated as the difference between the prices at which Greenway shares were purchased and the prices at which Greenway shares were sold. For those victims who continue to hold Greenway shares, the current value of the shares has been calculated as $0.00. Losses exclude any gains made by sale of Greenway shares. Case 1:15-cr-10386-WGY Document 201 Filed 02/27/19 Page 2 of 3 3 CERTIFICATE OF SERVICE I hereby certify that this document, filed through the ECF system, will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF). Dated: February 27, 2019 /s/ Andrew J. Palid ANDREW J. PALID Case 1:15-cr-10386-WGY Document 201 Filed 02/27/19 Page 3 of 3
