An Open Letter to Chairman Selig: The Bar Complaint That Proves Your Attorneys Lied to a Federal Court

Dear Chairman Selig,

On April 10, 2026, I filed a formal bar complaint with the Illinois Attorney Registration and Disciplinary Commission against two senior attorneys in your Division of Enforcement: Candice Haan (IL Bar No. 6315007) and David A. Terrell (IL Bar No. 6196293). I am writing to you directly because the complaint documents conduct that occurred under your agency's supervision, and because you have publicly stated that you intend to end "regulation by enforcement." The evidence I have submitted to the ARDC tests whether that commitment is real.

The complaint is not a broad allegation of prosecutorial overreach. It is a precise, documented charge of two specific violations of the Illinois Rules of Professional Conduct, supported entirely by the CFTC's own court filings, its own investigator's sworn deposition, and its own forensic expert's report.

The False Statement

On May 10, 2022, Haan and Terrell filed a complaint in the Northern District of Illinois. Paragraph 2 of that complaint states, as a categorical fact: "The Defendants did not trade digital assets or commodity interests with participants' funds." This allegation is the foundational fraud theory of the entire case. Every subsequent finding — the asset freeze, the receiver appointment, the summary judgment, the $209 million judgment — rests on it.

At the time Haan and Terrell filed this allegation, they had conducted no blockchain analysis. This is not my assertion. It is the sworn testimony of their own lead investigator, Heather Dasso, who admitted under oath: "As far as this case, I did not look at the blockchain, correct."

What makes this allegation particularly indefensible is what the CFTC had already reviewed before filing. In the same proceeding, Dasso's own declaration quotes the fund's Limited Partnership Agreement stating that "the purpose of the Fund is to invest, hold and trade in digital currencies, cryptoassets, cryptocurrencies, decentralized application tokens and protocol tokens." It quotes the fund's Silvergate Bank account opening documentation stating the account's purpose includes "trading" and anticipated activity includes "wires to/from exchanges (Coinbase Pro) to buy crypto assets." Haan and Terrell filed a complaint saying the fund did not trade digital assets while simultaneously filing a declaration quoting documents that said it did.

The Raid and the Corrected Declaration That Corrected Nothing

On May 16, 2022, CFTC agents raided my home in Portland, Oregon. Haan and Dasso were present. I logged into my desktop and showed them Etherscan — the public blockchain ledger recording every transaction in the fund. Dasso told me it was the first time she had looked at it. This account is in a sworn memorandum I filed in the federal case on December 8, 2023 (Dkt. #312). The CFTC never challenged it.

Three days after the raid, on May 19, Haan and Terrell filed what they called a "corrected" declaration — the evidentiary basis for maintaining the asset freeze and receiver appointment. That declaration, filed after the CFTC had physical possession of the blockchain evidence, contains no mention of the blockchain, no mention of the 885 on-chain transactions totaling $134.9 million in inflows and $130.4 million in outflows, and no correction of the internal contradiction between the documents Dasso had reviewed and the Ponzi conclusion she had drawn. Illinois Rule of Professional Conduct 3.3(a)(3) imposes a continuing duty to correct false statements of material fact made to a tribunal. Haan and Terrell never discharged that duty.

What the Evidence Shows

The Ethereum blockchain is a public, immutable ledger. It recorded 885 on-chain transactions for the fund's wallets. The CFTC's own forensic expert, StoneTurn Group, concluded that any uninvested cash used to pay vendors was less than the management and performance fees disclosed to and collected from investors, and that I was current on all investor note liabilities until the court-appointed receiver froze the assets. Sixty-nine investors filed letters with the court. Not one complained of fraud, misappropriation, or loss. Every investor reported profitable returns.

The Question for the ARDC — and for You

I am not asking the ARDC to relitigate the merits of the case. I am asking it to investigate whether Haan and Terrell complied with their professional obligations as officers of the court. The question is narrow: can a government attorney file a categorical factual allegation that is directly contradicted by documents already in their possession, obtain an ex parte asset freeze and receiver appointment on that basis, and then file a "corrected" declaration after obtaining physical possession of the contradicting evidence — a declaration that corrects nothing?

Chairman Selig, you have the authority to answer that question without waiting for the ARDC. The record is public. The deposition transcript is public. The StoneTurn report is public. The investor letters are public. All of it is available at samikkurty.com/legal-documents.

The ARDC complaint is pending. The Seventh Circuit appeal is pending. The record does not change.

Respectfully,
Sam Ikkurty