Legal Documents

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.

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)

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

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

CFTC Inspector General Referral — Haan & Terrell Misconduct

Formal referral letter to the CFTC Office of Inspector General (OIG) documenting alleged prosecutorial misconduct by CFTC attorneys Candice Haan and David A. Terrell in CFTC v. Sam Ikkurty et al. (Case No. 1:22-cv-02465). Requests OIG investigation into use of false declarations, concealment of blockchain evidence, and misrepresentations to the court.

Filed with: CFTC Office of Inspector General ([email protected])

• •Sent to CFTC OIG at [email protected] — the correct OIG address (not [email protected] which bounced)
• •Documents Dasso's admission she never reviewed blockchain records before filing her declaration
• •Requests OIG investigation into whether CFTC attorneys knowingly used false evidence

ARDC Bar Complaint — Candice Haan & David A. Terrell (v8, Final)

Final version (v8) of the bar complaint filed with the Attorney Registration and Disciplinary Commission (ARDC) of Illinois against CFTC attorneys Candice Haan (IL Bar No. 6315007) and David A. Terrell (IL Bar No. 6196293). Alleges violations of Illinois Rules of Professional Conduct including misrepresentation to the court, use of evidence known to be false, and failure to correct false statements. Filed April 2026.

Filed with: Attorney Registration and Disciplinary Commission (ARDC) of Illinois

• •Alleges Candice Haan and David A. Terrell violated Illinois Rules of Professional Conduct 3.3 (Candor Toward the Tribunal) and 3.4 (Fairness to Opposing Party)
• •Documents that CFTC attorneys used Dasso's declaration knowing it was based on no blockchain review
• •Cites Dasso deposition admission: 'As far as this case, I did not look at the blockchain, correct'

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

Dkt. #21 — Corrected Dasso Declaration (May 19, 2022)

The "corrected" declaration filed by CFTC investigator Heather Dasso on May 19, 2022 — three days after the CFTC seized the fund's complete blockchain records in a home raid. The corrected declaration does not reference, disclose, or acknowledge the blockchain evidence just seized, despite being labeled "corrected."

• •Filed May 19, 2022 — three days after CFTC seized blockchain records on May 16
• •Labeled "Corrected" by the CFTC — not by the court clerk
• •Does not disclose or reference the 885 blockchain transactions just seized

Dkt. #1 — CFTC Original Complaint (May 10, 2022)

The original CFTC complaint filed May 10, 2022, alleging fraud, misappropriation, and a Ponzi scheme against Sam Ikkurty and Rose City Income Fund. This document contains the foundational allegations that the fund "did not trade digital assets" — a claim directly contradicted by 885 on-chain blockchain transactions.

• •CFTC alleges fund "did not trade digital assets" — directly contradicted by blockchain evidence
• •Filed ex parte under seal — Sam had no opportunity to respond before asset freeze
• •Basis for TRO, asset freeze, and receiver appointment

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.

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

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.

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

Full Case Docket — CFTC v. Ikkurty (Case No. 1:22-cv-02465)

Complete docket listing for CFTC v. Sam Ikkurty et al., Case No. 1:22-cv-02465 (N.D. Ill.), showing all filings from the original complaint through the current appeal. This document provides the full procedural history of the case.

• •Complete procedural history of CFTC v. Sam Ikkurty
• •Case No. 1:22-cv-02465, U.S. District Court, N.D. Illinois
• •Seventh Circuit Appeal No. 24-2684 currently pending

Receiver's Tenth Status Report

The court-appointed receiver's tenth status report, detailing the administration of the receivership estate, asset liquidation, and ongoing proceedings. This document shows the ongoing cost of the receivership to investors and the fund estate.

• •Details ongoing receivership administration costs
• •Shows liquidation of fund assets over receiver's objection of investors
• •100% of investors opposed the receivership and liquidation

Dkt. #312 — Sam Ikkurty Sworn Memorandum with Blockchain Evidence

Sam Ikkurty's sworn memorandum submitted to the district court presenting the complete blockchain evidence: 885 on-chain transactions, $134.9M in digital assets purchased, $130.4M sold, and 126 ETH receive transactions. This document was filed after the CFTC seized the blockchain records and demonstrates that all fund activity was verifiable on the public Ethereum blockchain.

• •885 verifiable on-chain transactions documented on public Ethereum blockchain
• •$134.9M in digital assets purchased, $130.4M sold — real trading activity
• •126 ETH receive transactions returning value directly to fund wallet

StoneTurn Group — Full Expert Report (Dkt. #272-1)

Complete forensic accounting report by StoneTurn Group, the CFTC's own court-appointed forensic expert. StoneTurn concluded that a Ponzi scheme was mathematically impossible given the on-chain activity, confirmed all investors who exited did so profitably, and found no evidence of misappropriation consistent with the CFTC's allegations.

• •CFTC's own forensic expert — appointed by the court, not by Sam
• •Found Ponzi scheme mathematically impossible given blockchain activity
• •Confirmed all investors who exited the fund did so profitably

Heather Dasso Deposition Transcript

Full deposition transcript of CFTC lead investigator Heather Dasso. Under oath, Dasso admitted she never reviewed blockchain records before filing her declaration, that no investor complained to the CFTC, that the fund's investors were all profitable, and that her declaration did not support the Ponzi characterization used to obtain the asset freeze.

Filed with: U.S. District Court, N.D. Illinois

• •"As far as this case, I did not look at the blockchain, correct." (Dasso Dep. 69)
• •Admitted no investor proactively complained to the CFTC before the lawsuit
• •Confirmed her declaration did not support Ponzi characterization allegations

Dkt. #40 — Sam Ikkurty Answer to CFTC Complaint (Aug. 8, 2022)

Sam Ikkurty's formal answer to the CFTC's original complaint, filed August 8, 2022. The answer denies all material allegations, asserts affirmative defenses, and presents the blockchain evidence as the basis for contesting the Ponzi characterization.

Filed with: U.S. District Court, N.D. Illinois

• •Formal denial of all CFTC Ponzi scheme allegations
• •Asserts blockchain evidence as affirmative defense
• •Filed August 8, 2022 — after asset freeze and receiver appointment

Skadden & Kessler Initial Letter to Judge

Initial letter from Sam's counsel to the district court judge, presenting the blockchain evidence and requesting reconsideration of the asset freeze and receiver appointment. This letter was among the first formal presentations of the on-chain evidence to the court.

• •First formal presentation of blockchain evidence to the district court
• •Requests reconsideration of TRO and receiver appointment
• •Presents 885 on-chain transactions as direct rebuttal to CFTC allegations

TRO Hearing Transcript — May 11, 2022 (Dkt. #414)

Official transcript of the May 11, 2022 telephonic hearing before Judge Mary M. Rowland in which the CFTC obtained an ex parte statutory restraining order, receiver appointment, and asset freeze in 11 minutes — with no defense counsel present, missing exhibits, and the judge announcing "which I plan to do" before any argument was presented. The CFTC attorney stated on the record: "We have remained in a covert posture based on what we have observed in the records." Transcript filed as Docket #414 on November 20, 2024.

Filed with: U.S. District Court, N.D. Illinois — Judge Mary M. Rowland

• •Entire hearing lasted only 11 minutes (1:03–1:14 pm) — no defense counsel present
• •CFTC attorney Haan stated on the record: 'We have remained in a covert posture' — deliberately withheld notice to counsel
• •Judge Rowland announced 'which I plan to do' before any argument was presented — prejudgment on the record

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

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.

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.

Filed with: U.S. District Court, N.D. Illinois

• •Investor letter opposing forced liquidation
• •Part of 100% unanimous investor opposition

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.

Filed with: U.S. District Court, N.D. Illinois

• •Additional parties opposing forced crypto liquidation
• •Demonstrates unanimous investor and stakeholder 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. #237 — Letter from Parkhasaradhi Johnalagadda (Aug 21, 2023)

Letter from Rose City Fund investor Parkhasaradhi Johnalagadda to the court opposing the Receiver's motion.

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.

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. #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 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. #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.

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. #233 — Letter from Satish Sreedhara (Aug 18, 2023)

Letter from Rose City Fund investor Satish Sreedhara to the court opposing the Receiver's motion.

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.

Filed with: U.S. District Court, N.D. Illinois

• •Investor letter opposing forced liquidation
• •Part of 100% unanimous investor opposition

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.

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.

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.

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.

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.

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.

Filed with: U.S. District Court, N.D. Illinois

• •Investor letter opposing forced liquidation
• •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.

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.

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.

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.

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 opposing the liquidation.

Filed with: U.S. District Court, N.D. Illinois

• •Attorney Sesha Kalapatapu representing investors
• •Demonstrates investors retained independent counsel to oppose liquidation

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.

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. #214 — Letter from Amitkumar Surati (Aug 5, 2023)

Letter from Rose City Fund investor Amitkumar Surati to the court opposing the Receiver's motion.

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.

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.

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.

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.

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.

Filed with: U.S. District Court, N.D. Illinois

• •Investor letter opposing forced liquidation
• •Part of 100% unanimous 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