Legal Documents
A complete repository of court filings, government complaints, appellate briefs, expert reports, and financial records from CFTC v. Ikkurty. All documents are available for download and inline viewing.
Rose City Fund — Complete Redemption List
Official record of all 69 investor exits from RCIF1. Collectively invested $5.9M, exited with $29.3M. Mean CAGR 303%. Zero investors lost money. Corroborated by CFTC's own witness.
Rose City Fund — Complete Redemption List
The complete official record of all investor exits from Rose City Investment Fund I (RCIF1). Documents 69 partners who collectively invested $5.9 million and exited with $29.3 million in redemptions and $825,351 in distributions. Mean CAGR of 303%. Zero investors lost money.
Filed with: Public Record
- •69 partners exited RCIF1 — ZERO lost money
- •Collective investment: $5.9M → $29.3M in redemptions
- •Mean CAGR: 303% | Highest: 1407% | Lowest: 16.44%
Ethereum Ledger History — RCIF II
Complete on-chain Ethereum transaction ledger for Rose City Investment Fund II (RCIF II), wallet address 0x168fa4917e7cd18f4ed3dc313c4975851ca9e5e7. Provides immutable, auditable proof of all DeFi transactions on the public blockchain.
Filed with: Public Record
- •Full on-chain transaction history for RCIF II wallet
- •Immutable, publicly auditable Ethereum blockchain record
- •Proves all transactions were legitimate DeFi operations
GAO Complaint — Constitutional Crisis
Formal complaint to the Government Accountability Office documenting constitutional violations, regulatory overreach, and systemic abuses of power in CFTC v. Sam Ikkurty, et al. Requests GAO investigation into the CFTC's Division of Enforcement.
Filed with: Government Accountability Office
- •Documents constitutional violations including unlawful ex parte proceedings
- •Details CFTC's willful ignorance of blockchain evidence
- •Requests GAO investigation into DOE misconduct
Formal Criminal Complaint to DOJ
Signed letter to AG Pam Bondi, Acting AAG Matthew R. Galeotti, and U.S. Attorney Andrew S. Boutros requesting a grand jury investigation into alleged obstruction of justice, perjury, and deprivation of rights under color of law by CFTC officials.
Filed with: AG Pam Bondi, Acting AAG Matthew R. Galeotti, U.S. Attorney Andrew S. Boutros
- •Alleges 18 U.S.C. § 1503 & § 1512 (Obstruction of Justice)
- •Alleges 18 U.S.C. § 1001 (False Statements) & § 1621 (Perjury)
- •Alleges 18 U.S.C. § 242 (Deprivation of Rights Under Color of Law)
Letter to Attorney General — Ikkurty
Formal letter from Sam Ikkurty to the Attorney General outlining constitutional violations, requesting intervention, and documenting the CFTC's overreach in the Rose City Fund case.
Filed with: Attorney General of the United States
- •Documents CFTC's violation of multiple constitutional amendments
- •Requests AG intervention to halt ongoing rights violations
- •Details the impact on 247 million Ethereum wallet holders
Deputy Attorney General Memorandum
Memorandum from the Deputy Attorney General dated April 7, 2025, relevant to the constitutional rights issues raised in the Ikkurty case and the broader regulatory enforcement context.
Filed with: Department of Justice
- •Official DOJ memorandum addressing regulatory enforcement policy
- •Relevant to constitutional rights arguments in the Ikkurty case
- •Documents the evolving DOJ position on regulatory overreach
CFTC Inspector General Formal Complaint
Formal complaint to CFTC Inspector General Christopher Skinner documenting systemic abuses of power, egregious prosecutorial misconduct, and willful violations of constitutional and administrative law by the Division of Enforcement.
Filed with: The Honorable Christopher Skinner, CFTC Inspector General
- •Documents CFTC investigators' willful ignorance of blockchain evidence
- •Details Heather Dasso's admission: 'I did not look at the blockchain, correct'
- •Proves 100% investor opposition to liquidation — no actual harm
Appellants' Brief — 7th Circuit (Nov 2024)
Appellants' opening brief filed in the United States Court of Appeals for the Seventh Circuit. Argues CFTC lacked subject matter jurisdiction over Ethereum SPOT transactions and violated defendants' constitutional rights throughout the proceedings.
Filed with: U.S. Court of Appeals, 7th Circuit
- •Challenges CFTC's claimed jurisdiction over Ethereum SPOT transactions
- •Documents constitutional violations across multiple amendments
- •Argues Congress never granted CFTC authority over spot crypto markets
Appellant's Reply Brief — 7th Circuit (Jan 2025)
Appellant's reply brief filed January 22, 2025 in the 7th Circuit, responding to the CFTC's opposition brief and reinforcing the constitutional and jurisdictional arguments. Oral arguments were subsequently held in May 2025.
Filed with: U.S. Court of Appeals, 7th Circuit
- •Responds to CFTC's jurisdictional arguments
- •Reinforces constitutional rights violations
- •Addresses CFTC's mischaracterization of blockchain evidence
Dkt. #267 — CFTC's Motion for Summary Judgment
CFTC's motion for summary judgment filed in the U.S. District Court, Northern District of Illinois. Defendants successfully opposed this motion, demonstrating genuine disputes of material fact.
Filed with: U.S. District Court, N.D. Illinois
- •CFTC's attempt to obtain judgment without full trial
- •Defendants opposed with extensive blockchain evidence
- •Demonstrates CFTC's overreach in claiming crypto jurisdiction
Dkt. #268 — CFTC's Memorandum in Support
CFTC's memorandum of law in support of its motion for summary judgment. Contains the CFTC's legal arguments for jurisdiction and liability, which defendants systematically rebutted.
Filed with: U.S. District Court, N.D. Illinois
- •CFTC's legal arguments for Ethereum SPOT jurisdiction
- •Basis for defendants' constitutional challenge
- •Rebutted by expert report and blockchain evidence
Dkt. #269 — CFTC's Statement of Material Facts
CFTC's statement of material facts filed in support of its summary judgment motion. Defendants filed a competing statement (Dkt. #272) demonstrating numerous genuine factual disputes.
Filed with: U.S. District Court, N.D. Illinois
- •CFTC's version of disputed facts
- •Directly contradicted by defendants' Dkt. #272
- •Key disputes include blockchain evidence and investor harm
Dkt. #269-1 — Appendix of Exhibits (CFTC)
Appendix of exhibits filed by the CFTC in support of its summary judgment motion.
Filed with: U.S. District Court, N.D. Illinois
- •CFTC's evidentiary exhibits for summary judgment
- •Reviewed and rebutted by defendants' expert report
Dkt. #270 — Defendants' Motion to Dismiss
Defendants' motion to dismiss the CFTC's complaint, arguing lack of subject matter jurisdiction over Ethereum SPOT transactions and failure to state a claim upon which relief can be granted.
Filed with: U.S. District Court, N.D. Illinois
- •Challenges CFTC's subject matter jurisdiction over Ethereum SPOT
- •Argues Congress never granted CFTC authority over spot crypto
- •Foundation for the current 7th Circuit appeal
Dkt. #271 — Defendants' Memo of Law in Support of MTD
Defendants' memorandum of law in support of their motion to dismiss. Provides detailed legal analysis of why CFTC lacks jurisdiction over Ethereum SPOT transactions and why the case should be dismissed.
Filed with: U.S. District Court, N.D. Illinois
- •Detailed constitutional and statutory analysis
- •Argues Commodities Exchange Act does not cover Ethereum SPOT
- •Cites lack of Congressional authorization for CFTC's claimed authority
Dkt. #272 — Defendants' Statement of Material Facts
Defendants' competing statement of material facts, demonstrating genuine disputes that preclude summary judgment. Includes blockchain evidence, investor testimony, and expert analysis showing no investor harm.
Filed with: U.S. District Court, N.D. Illinois
- •Demonstrates genuine factual disputes precluding summary judgment
- •Includes blockchain evidence ignored by CFTC investigators
- •Documents 100% investor opposition to CFTC's liquidation
Expert Report — Charles R. Soha, CFE (StoneTurn Group)
Independent expert report by Charles R. Soha, Certified Fraud Examiner and Managing Director at StoneTurn Group. Analyzes Rose City Fund financial records and finds no misappropriation of funds. Confirms legitimate DeFi returns and proper fund operations.
Filed with: U.S. District Court, Northern District of Illinois
- •No misappropriation of investor funds found
- •Fund II investors received returns as high as 339.55% in one year
- •Fund I achieved mean CAGR of 303% for exiting partners
Heather Dasso Deposition Transcript
Transcript of the deposition of Heather Dasso, CFTC investigator. Contains her admission that she 'did not look at the blockchain' — a pivotal admission that undermines the CFTC's entire investigation and demonstrates willful ignorance of publicly available evidence.
Filed with: U.S. District Court, N.D. Illinois
- •Key admission: 'I did not look at the blockchain, correct'
- •Demonstrates CFTC investigators ignored publicly available evidence
- •Undermines the entire basis of CFTC's fraud allegations
Dkt. #204 — Investor Objection to Receiver Liquidation Proposal
Investor objection filed with the U.S. District Court opposing the Receiver's motion to liquidate cryptocurrency assets in the receivership estate. One of 100% unanimous investor objections.
Filed with: U.S. District Court, N.D. Illinois
- •Investor opposes forced liquidation of crypto assets
- •Part of unanimous 100% investor opposition to Receiver's motion
- •Demonstrates investors supported Sam's management of the fund
Dkt. #208 — Investor Objection
Investor objection to the Receiver's motion to liquidate cryptocurrency assets, filed with the U.S. District Court.
Filed with: U.S. District Court, N.D. Illinois
- •Investor opposes forced liquidation of crypto assets
- •Part of unanimous 100% investor opposition
Dkt. #209 — Minute Entry by Judge Rowland
Minute entry by Judge Rowland in CFTC v. Ikkurty, documenting court proceedings related to the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Court minute entry documenting proceedings
- •Related to Receiver's motion to liquidate crypto assets
Dkt. #212 — Letter from Nimish Madhiwala (Aug 5, 2023)
Letter from Rose City Fund investor Nimish Madhiwala to the court opposing the Receiver's motion to liquidate cryptocurrency assets in the receivership estate.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation of crypto assets
- •Demonstrates investor confidence in Sam Ikkurty's management
- •Part of 100% unanimous investor opposition
Dkt. #213 — Letter from Piyush Madhiwala (Aug 5, 2023)
Letter from Rose City Fund investor Piyush Madhiwala to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation of crypto assets
- •Part of 100% unanimous investor opposition
Dkt. #214 — Letter from Amitkumar Surati (Aug 5, 2023)
Letter from Rose City Fund investor Amitkumar Surati to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #215 — Letter from Bimal Patel (Aug 7, 2023)
Letter from Rose City Fund investor Bimal Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #216 — Letter from Neeranj Patel (Aug 5, 2023)
Letter from Rose City Fund investor Neeranj Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #218 — Letter from Bhupendra Patel (Aug 5, 2023)
Letter from Rose City Fund investor Bhupendra Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #219 — Letter from Vamsi Thalluri (Aug 7, 2023)
Letter from Rose City Fund investor Vamsi Thalluri to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #220 — Letter from Maya Patel (Aug 7, 2023)
Letter from Rose City Fund investor Maya Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #221 — Letter from Bimal Patel (Aug 4, 2023)
Second letter from Rose City Fund investor Bimal Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #222 — Letter from Vamsi Thalluri (Aug 4, 2023)
Second letter from Rose City Fund investor Vamsi Thalluri to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #223 — Letter from Manubhai Patel (Aug 4, 2023)
Letter from Rose City Fund investor Manubhai Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #224 — Letter from Shilpa Honeycutt (Aug 4, 2023)
Letter from Rose City Fund investor Shilpa Honeycutt to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #225 — Letter from Manubhai A. Patel (Aug 7, 2023)
Second letter from Rose City Fund investor Manubhai A. Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #226 — Letter from Shilpa Honeycutt (Aug 7, 2023)
Second letter from Rose City Fund investor Shilpa Honeycutt to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #227 — Letter from Tushar Vashi (Aug 5, 2023)
Letter from Rose City Fund investor Tushar Vashi to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #228 — Letter from Kumud Patel (Aug 5, 2023)
Letter from Rose City Fund investor Kumud Patel to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #229 — Motion for Leave to Appear Pro Hac Vice (Kalapatapu)
Motion for leave to appear pro hac vice filed by attorney Sesha Kalapatapu, representing investors in the CFTC v. Ikkurty case. Demonstrates investors retained independent counsel to oppose liquidation.
Filed with: U.S. District Court, N.D. Illinois
- •Attorney Sesha Kalapatapu representing investors
- •Demonstrates investors retained independent counsel to oppose liquidation
Dkt. #232 — Letter from Bala Kancharla (Aug 18, 2023)
Letter from Rose City Fund investor Bala Kancharla to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #233 — Letter from Satish Sreedhara (Aug 18, 2023)
Letter from Rose City Fund investor Satish Sreedhara to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #234 — Letter from Lakshmi Sreedhara (Aug 18, 2023)
Letter from Rose City Fund investor Lakshmi Sreedhara to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #235 — Letter from Venkata G. Kasturi (Aug 21, 2023)
Letter from Rose City Fund investor Venkata G. Kasturi to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #236 — Letter from Mitra Trinadha Penmestsa (Aug 21, 2023)
Letter from Rose City Fund investor Mitra Trinadha Penmestsa to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #237 — Letter from Parkhasaradhi Johnalagadda (Aug 21, 2023)
Letter from Rose City Fund investor Parkhasaradhi Johnalagadda to the court opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor letter opposing forced liquidation
- •Part of 100% unanimous investor opposition
Dkt. #238 — Sam Ikkurty's Response to Receiver's Motion to Liquidate
Defendant Sam Ikkurty and Jafia, LLC's formal response to Receiver James L. Kopecky's motion to liquidate cryptocurrency in the receivership estate. Argues against forced liquidation and documents investor opposition.
Filed with: U.S. District Court, N.D. Illinois
- •Sam Ikkurty's formal response opposing forced crypto liquidation
- •Documents unanimous investor opposition to Receiver's motion
- •Argues liquidation would harm investors and violate their rights
Dkt. #240 — Objections by DRC Management LLC to Receiver's Motion
Formal objections filed by DRC Management LLC to the Receiver's motion to liquidate cryptocurrency assets in the receivership estate.
Filed with: U.S. District Court, N.D. Illinois
- •Third-party objections to forced crypto liquidation
- •Part of broad coalition opposing Receiver's motion
Dkt. #241 — Objection to Receiver's Motion to Liquidate Cryptocurrency
Comprehensive objection to the Receiver's motion to liquidate cryptocurrency assets in the receivership estate, filed by investors and interested parties.
Filed with: U.S. District Court, N.D. Illinois
- •Comprehensive legal objection to forced crypto liquidation
- •Argues liquidation would destroy investor value
- •Part of 100% unanimous investor opposition
Dkt. #242 — Joinder in Objection to Receiver's Motion to Liquidate
Joinder in the objection to the Receiver's motion to liquidate cryptocurrency assets, filed by additional investors and interested parties.
Filed with: U.S. District Court, N.D. Illinois
- •Additional parties joining in objection to forced liquidation
- •Demonstrates broad coalition opposing Receiver's motion
Dkt. #243 — Notice of Additional Parties' Opposition to Receiver's Motion
Notice of additional parties' opposition to the Receiver's motion to liquidate cryptocurrency assets in the receivership estate.
Filed with: U.S. District Court, N.D. Illinois
- •Additional parties opposing forced crypto liquidation
- •Demonstrates unanimous investor and stakeholder opposition
Exopp Objections — Investor Opposition Filing
Formal ex-parte opposition objections filed by investors opposing the Receiver's motion to liquidate cryptocurrency assets.
Filed with: U.S. District Court, N.D. Illinois
- •Investor ex-parte opposition to forced crypto liquidation
- •Part of 100% unanimous investor opposition
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