WALLWALL #30
Sam Ikkurty
Posted April 12, 2026
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FORMAL COMPLAINT PURSUANT TO ILLINOIS
SUPREME COURT RULE 751
Submitted to: Attorney Registration & Disciplinary Commission of
the Supreme Court of Illinois 130 East Randolph Drive, Suite 1500,
Chicago, Illinois 60601 Email: [email protected]
Date: April 10, 2026
Complainant: Sam Ikkurty a/k/a Sreenivas I. Rao 7028 West Waters
Avenue, Apt. 145, Tampa, FL 33634 [email protected] | 813-
389-3380
Attorneys Subject to This Complaint:
Respondent 1: Candice Haan, Illinois Bar No. 6315007 Senior Trial
Attorney, Division of Enforcement Commodity Futures Trading
Commission 77 West Jackson Boulevard, Suite 800, Chicago, Illinois
60604
Respondent 2: David A. Terrell, Illinois Bar No. 6196293 Chief Trial
Attorney, Division of Enforcement Commodity Futures Trading
SUPREME COURT RULE 751
Submitted to: Attorney Registration & Disciplinary Commission of
the Supreme Court of Illinois 130 East Randolph Drive, Suite 1500,
Chicago, Illinois 60601 Email: [email protected]
Date: April 10, 2026
Complainant: Sam Ikkurty a/k/a Sreenivas I. Rao 7028 West Waters
Avenue, Apt. 145, Tampa, FL 33634 [email protected] | 813-
389-3380
Attorneys Subject to This Complaint:
Respondent 1: Candice Haan, Illinois Bar No. 6315007 Senior Trial
Attorney, Division of Enforcement Commodity Futures Trading
Commission 77 West Jackson Boulevard, Suite 800, Chicago, Illinois
60604
Respondent 2: David A. Terrell, Illinois Bar No. 6196293 Chief Trial
Attorney, Division of Enforcement Commodity Futures Trading
Commission 77 West Jackson Boulevard, Suite 800, Chicago, Illinois
60604
Underlying Case: Commodity Futures Trading Commission v. Sam
Ikkurty, et al. Case No. 1:22-cv-02465 (U.S. District Court, N.D.
Illinois) Seventh Circuit Appeal No. 24-2684 (pending)
I. INTRODUCTION
This complaint alleges violations of Illinois Rules of Professional
Conduct 3.3(a)(1) and 3.3(a)(3) by Candice Haan (IL Bar No.
6315007) and David A. Terrell (IL Bar No. 6196293), attorneys in the
CFTC’s Division of Enforcement, arising from their prosecution of
CFTC v. Ikkurty, Case No. 1:22-cv-02465 (N.D. Ill.).
The violations are grounded in a documented, sequential record:
First, Haan and Terrell filed a categorical factual allegation — that the
Complainant’s fund “did not trade digital assets” — that is directly
contradicted by documents they had already reviewed and quoted in
their own investigator’s declaration.
Second, after obtaining physical possession of the contradicting
blockchain evidence during a home raid, they filed a “corrected”
60604
Underlying Case: Commodity Futures Trading Commission v. Sam
Ikkurty, et al. Case No. 1:22-cv-02465 (U.S. District Court, N.D.
Illinois) Seventh Circuit Appeal No. 24-2684 (pending)
I. INTRODUCTION
This complaint alleges violations of Illinois Rules of Professional
Conduct 3.3(a)(1) and 3.3(a)(3) by Candice Haan (IL Bar No.
6315007) and David A. Terrell (IL Bar No. 6196293), attorneys in the
CFTC’s Division of Enforcement, arising from their prosecution of
CFTC v. Ikkurty, Case No. 1:22-cv-02465 (N.D. Ill.).
The violations are grounded in a documented, sequential record:
First, Haan and Terrell filed a categorical factual allegation — that the
Complainant’s fund “did not trade digital assets” — that is directly
contradicted by documents they had already reviewed and quoted in
their own investigator’s declaration.
Second, after obtaining physical possession of the contradicting
blockchain evidence during a home raid, they filed a “corrected”
sworn declaration that omitted that evidence, contained an internal
contradiction apparent on its face, and served as the sole evidentiary
basis for maintaining an ex parte asset freeze and receiver
appointment.
Each violation is supported by record evidence: docket filings, sworn
deposition testimony, and the declarant’s own quoted sources. The
Complainant is not asking the ARDC to relitigate the merits of the
underlying case. He is asking the ARDC to investigate whether Haan
and Terrell complied with their professional obligations as officers of
the court. The ARDC is not being asked to determine the merits of the
CFTC’s enforcement action or the correctness of the judgment; it is
asked only to determine whether Respondents violated their duties of
candor under Rules 3.3(a)(1) and 3.3(a)(3).
Jurisdiction: Haan and Terrell are licensed members of the Illinois
bar. The underlying proceedings occurred in the Northern District of
Illinois. The ARDC has jurisdiction under Illinois Supreme Court Rule
751. The McDade Amendment, 28 U.S.C. § 530B, expressly requires
federal attorneys to comply with the professional responsibility rules
of the states in which they practice.
contradiction apparent on its face, and served as the sole evidentiary
basis for maintaining an ex parte asset freeze and receiver
appointment.
Each violation is supported by record evidence: docket filings, sworn
deposition testimony, and the declarant’s own quoted sources. The
Complainant is not asking the ARDC to relitigate the merits of the
underlying case. He is asking the ARDC to investigate whether Haan
and Terrell complied with their professional obligations as officers of
the court. The ARDC is not being asked to determine the merits of the
CFTC’s enforcement action or the correctness of the judgment; it is
asked only to determine whether Respondents violated their duties of
candor under Rules 3.3(a)(1) and 3.3(a)(3).
Jurisdiction: Haan and Terrell are licensed members of the Illinois
bar. The underlying proceedings occurred in the Northern District of
Illinois. The ARDC has jurisdiction under Illinois Supreme Court Rule
751. The McDade Amendment, 28 U.S.C. § 530B, expressly requires
federal attorneys to comply with the professional responsibility rules
of the states in which they practice.
II. FACTUAL BACKGROUND
A. The Fund and Its Documented Operations
The Complainant is the managing partner of Rose City Income Fund
(RCIF), a digital asset investment fund registered with the Securities
and Exchange Commission (CIK No. 0001842816, Exhibit E). The
fund operated pursuant to a Private Placement Memorandum
(“PPM”), a Subscription Agreement, and a Limited Partnership
Agreement (“LPA”) — collectively, the “Fund Documents” — which
were provided to, reviewed by, and acknowledged in writing by every
investor before any capital was committed.
The fund’s stated investment strategy, disclosed in the PPM, was to
invest in digital assets and cryptocurrency staking. The LPA expressly
defined “Net Profits” to include “unrealized profits and losses with
respect to all Digital Asset positions.” The fund retained Intertrust
Group as its independent fund administrator, responsible for
calculating NAV, preparing investor statements, and wiring all
distributions. The Complainant did not personally control investor
funds — all payments were made by Intertrust in accordance with the
Fund Documents.
The fund invested in ERC-20 tokens on the Ethereum blockchain. The
Ethereum blockchain — a public, immutable ledger — records 885
A. The Fund and Its Documented Operations
The Complainant is the managing partner of Rose City Income Fund
(RCIF), a digital asset investment fund registered with the Securities
and Exchange Commission (CIK No. 0001842816, Exhibit E). The
fund operated pursuant to a Private Placement Memorandum
(“PPM”), a Subscription Agreement, and a Limited Partnership
Agreement (“LPA”) — collectively, the “Fund Documents” — which
were provided to, reviewed by, and acknowledged in writing by every
investor before any capital was committed.
The fund’s stated investment strategy, disclosed in the PPM, was to
invest in digital assets and cryptocurrency staking. The LPA expressly
defined “Net Profits” to include “unrealized profits and losses with
respect to all Digital Asset positions.” The fund retained Intertrust
Group as its independent fund administrator, responsible for
calculating NAV, preparing investor statements, and wiring all
distributions. The Complainant did not personally control investor
funds — all payments were made by Intertrust in accordance with the
Fund Documents.
The fund invested in ERC-20 tokens on the Ethereum blockchain. The
Ethereum blockchain — a public, immutable ledger — records 885
on-chain transactions for the fund’s wallets, totaling USD 134.9
million in inflows and USD 130.4 million in outflows (Exhibit D).
This record was publicly available at all times, including on May 10,
2022, when Haan and Terrell filed their complaint.
B. The Central Factual Allegation
On May 10, 2022, Haan and Terrell filed a complaint in the Northern
District of Illinois (Dkt. #1). Paragraph 2 of that complaint states:
“The Defendants did not trade digital assets or
commodity interests with participants’ funds and return
profits as promised; instead they misappropriated
participants’ funds.” (Dkt. #1, p. 2, ¶ 2.)
This allegation is the foundational fraud theory of the entire case. It is
stated as a categorical fact, not as a legal inference or characterization.
At the time Haan and Terrell filed this allegation, they had conducted
no blockchain analysis. This is confirmed by the sworn deposition
testimony of their lead investigator, Heather Dasso:
“As far as this case, I did not look at the blockchain,
correct.” (Dkt. #250-2, Exhibit C.)
What makes this allegation particularly indefensible is what the
CFTC had already reviewed and quoted before filing. The
million in inflows and USD 130.4 million in outflows (Exhibit D).
This record was publicly available at all times, including on May 10,
2022, when Haan and Terrell filed their complaint.
B. The Central Factual Allegation
On May 10, 2022, Haan and Terrell filed a complaint in the Northern
District of Illinois (Dkt. #1). Paragraph 2 of that complaint states:
“The Defendants did not trade digital assets or
commodity interests with participants’ funds and return
profits as promised; instead they misappropriated
participants’ funds.” (Dkt. #1, p. 2, ¶ 2.)
This allegation is the foundational fraud theory of the entire case. It is
stated as a categorical fact, not as a legal inference or characterization.
At the time Haan and Terrell filed this allegation, they had conducted
no blockchain analysis. This is confirmed by the sworn deposition
testimony of their lead investigator, Heather Dasso:
“As far as this case, I did not look at the blockchain,
correct.” (Dkt. #250-2, Exhibit C.)
What makes this allegation particularly indefensible is what the
CFTC had already reviewed and quoted before filing. The
following three paragraphs from Dasso’s own declaration — filed in
the same proceeding — are directly on point:
Dkt. #21, ¶ 16 (Dasso quoting the LPA, Section 1.03):
”[T]he purpose of the Fund is to invest, hold and trade in
digital currencies, cryptoassets, cryptocurrencies,
decentralized application tokens and protocol tokens,
blockchain based assets and other cryptofinance and
digital assets.”
Dkt. #21, ¶ 35 (Dasso quoting the Silvergate Bank account opening
documentation):
The account’s stated purpose includes “trading” and
anticipated activity includes “wires to/from exchanges
(Coinbase Pro) to buy crypto assets.”
Dkt. #21, ¶ 44 (Dasso confirming the fund paid investors their
promised 15% annual return on a monthly basis throughout the period
in question.)
The contradiction is direct and documentary. The CFTC filed a
complaint stating the fund “did not trade digital assets.” Their own
investigator’s declaration, filed in the same proceeding, quotes the
fund’s governing agreement stating the fund’s purpose is to trade
the same proceeding — are directly on point:
Dkt. #21, ¶ 16 (Dasso quoting the LPA, Section 1.03):
”[T]he purpose of the Fund is to invest, hold and trade in
digital currencies, cryptoassets, cryptocurrencies,
decentralized application tokens and protocol tokens,
blockchain based assets and other cryptofinance and
digital assets.”
Dkt. #21, ¶ 35 (Dasso quoting the Silvergate Bank account opening
documentation):
The account’s stated purpose includes “trading” and
anticipated activity includes “wires to/from exchanges
(Coinbase Pro) to buy crypto assets.”
Dkt. #21, ¶ 44 (Dasso confirming the fund paid investors their
promised 15% annual return on a monthly basis throughout the period
in question.)
The contradiction is direct and documentary. The CFTC filed a
complaint stating the fund “did not trade digital assets.” Their own
investigator’s declaration, filed in the same proceeding, quotes the
fund’s governing agreement stating the fund’s purpose is to trade
digital assets, and quotes the fund’s bank account documentation
stating the account exists to buy crypto assets via Coinbase Pro.
Preemption of the “good-faith characterization” defense: Haan and
Terrell may argue that “did not trade” was a good-faith
characterization of bank records showing net fiat outflows. This
defense fails on two independent grounds. First, Rule 3.3(a)(1)
prohibits categorical factual assertions that are directly contradicted by
documents already in counsel’s possession. The LPA and Silvergate
account opening documents — both reviewed and quoted in Dkt. #21
— stated the fund trades digital assets. A categorical assertion made in
direct contradiction of documents already in counsel’s possession
cannot constitute good-faith characterization. Second, the willful
blindness doctrine applies: Haan and Terrell, prosecuting a case about
a DeFi fund, had an obligation to examine the publicly available
blockchain record before making categorical assertions about what the
fund traded. See In re Edmonds, 2014 IL 117696.
C. The Ex Parte Orders
On May 10–11, 2022, relying on the complaint’s allegations, Haan
and Terrell obtained ex parte orders freezing the Complainant’s assets
and appointing a receiver (Dkt. #6, #7, #8). The court had no
opportunity to hear from the defendant. It relied entirely on the
stating the account exists to buy crypto assets via Coinbase Pro.
Preemption of the “good-faith characterization” defense: Haan and
Terrell may argue that “did not trade” was a good-faith
characterization of bank records showing net fiat outflows. This
defense fails on two independent grounds. First, Rule 3.3(a)(1)
prohibits categorical factual assertions that are directly contradicted by
documents already in counsel’s possession. The LPA and Silvergate
account opening documents — both reviewed and quoted in Dkt. #21
— stated the fund trades digital assets. A categorical assertion made in
direct contradiction of documents already in counsel’s possession
cannot constitute good-faith characterization. Second, the willful
blindness doctrine applies: Haan and Terrell, prosecuting a case about
a DeFi fund, had an obligation to examine the publicly available
blockchain record before making categorical assertions about what the
fund traded. See In re Edmonds, 2014 IL 117696.
C. The Ex Parte Orders
On May 10–11, 2022, relying on the complaint’s allegations, Haan
and Terrell obtained ex parte orders freezing the Complainant’s assets
and appointing a receiver (Dkt. #6, #7, #8). The court had no
opportunity to hear from the defendant. It relied entirely on the
representations of Haan and Terrell and on the declaration of
Investigator Dasso.
D. The May 16, 2022 Raid
On May 16, 2022, CFTC agents raided the Complainant’s home in
Portland, Oregon. Attorney Haan and Investigator Dasso were present.
The CFTC seized the Complainant’s computers, hard drives, and all
financial records, including complete Ethereum blockchain wallet
data.
The Complainant filed a sworn memorandum in the underlying case
on December 8, 2023 (Dkt. #312), describing the events of the raid in
detail. That memorandum — filed in federal court and unchallenged
by the CFTC — states:
“I then logged into my desktop while Ms. Dasso and Mr.
Kopecky were hovering over my shoulder, I went to
Etherscan and showed all the assets that we hold. I
showed all the OTC transactions where we received ETH
for US dollar wire transfers. They both told me that this is
the first time they are looking at Etherscan. They were not
aware of any of our digital assets up to this day.” (Dkt.
#312, p. 4.)
Investigator Dasso.
D. The May 16, 2022 Raid
On May 16, 2022, CFTC agents raided the Complainant’s home in
Portland, Oregon. Attorney Haan and Investigator Dasso were present.
The CFTC seized the Complainant’s computers, hard drives, and all
financial records, including complete Ethereum blockchain wallet
data.
The Complainant filed a sworn memorandum in the underlying case
on December 8, 2023 (Dkt. #312), describing the events of the raid in
detail. That memorandum — filed in federal court and unchallenged
by the CFTC — states:
“I then logged into my desktop while Ms. Dasso and Mr.
Kopecky were hovering over my shoulder, I went to
Etherscan and showed all the assets that we hold. I
showed all the OTC transactions where we received ETH
for US dollar wire transfers. They both told me that this is
the first time they are looking at Etherscan. They were not
aware of any of our digital assets up to this day.” (Dkt.
#312, p. 4.)
The same memorandum documents that during the six-hour
questioning session, Dasso did not know: what a PPM was; what a “2
and 20” fee structure meant; that the fund served only accredited
investors; that the fund had an independent fund administrator
(Intertrust Group); that the fund had an auditor (Richey May); or that
the fund had filed with the SEC. (Dkt. #312, pp. 2–4.) Attorney Haan
was present throughout this session.
Dasso’s subsequent deposition admission — “I did not look at the
blockchain, correct” (Dkt. #250-2) — is entirely consistent with and
corroborated by the sworn account in Dkt. #312. Both the
memorandum and the deposition admission are part of the federal
court record. The CFTC never filed any response or objection to
the sworn assertions in Dkt. #312.
E. The Dasso Declaration — Filed After the Raid, Omitting What
Was Seized
Dasso’s declaration was executed on May 9, 2022 — one day before
the complaint was filed. It was subsequently filed with the court as
Dkt. #21 on May 19, 2022 — three days after the raid. The version
filed on May 19 was designated a “corrected” declaration. Despite
being filed after the raid, it contains no correction, no supplement, and
no disclosure of any of the blockchain evidence in the CFTC’s
possession.
questioning session, Dasso did not know: what a PPM was; what a “2
and 20” fee structure meant; that the fund served only accredited
investors; that the fund had an independent fund administrator
(Intertrust Group); that the fund had an auditor (Richey May); or that
the fund had filed with the SEC. (Dkt. #312, pp. 2–4.) Attorney Haan
was present throughout this session.
Dasso’s subsequent deposition admission — “I did not look at the
blockchain, correct” (Dkt. #250-2) — is entirely consistent with and
corroborated by the sworn account in Dkt. #312. Both the
memorandum and the deposition admission are part of the federal
court record. The CFTC never filed any response or objection to
the sworn assertions in Dkt. #312.
E. The Dasso Declaration — Filed After the Raid, Omitting What
Was Seized
Dasso’s declaration was executed on May 9, 2022 — one day before
the complaint was filed. It was subsequently filed with the court as
Dkt. #21 on May 19, 2022 — three days after the raid. The version
filed on May 19 was designated a “corrected” declaration. Despite
being filed after the raid, it contains no correction, no supplement, and
no disclosure of any of the blockchain evidence in the CFTC’s
possession.
The declaration was filed as the evidentiary basis for maintaining the
asset freeze, receiver appointment, and restraining order. It contained
no mention of the blockchain, the 885 on-chain transactions, the
fund’s SEC registration, its independent fund administrator (Intertrust
Group), or its legal counsel (Seward & Kissel LLP).
The declaration’s scope of investigation (¶ 5) lists: bank account
records, NFA registration certifications, internet and computer
database searches, the LPA, and websites and social media. It does not
mention Etherscan, any blockchain analytics tool, or any examination
of the fund’s digital asset trading activity — despite the fact that the
case is premised on a digital asset fund and Dasso describes her role as
including the analysis of “digital asset trading accounts” (¶ 2).
F. The Internal Contradiction in the Declaration
The declaration contains a self-defeating internal contradiction that
Haan and Terrell, as the attorneys of record who signed the complaint
and filed the declaration, were obligated to identify and correct before
filing.
Dasso reviewed and quoted the LPA (¶ 16), which states the fund’s
purpose is to trade digital assets. She reviewed and quoted the
Silvergate bank account opening documentation (¶ 35), which states
the account exists to buy crypto via Coinbase Pro. She identified USD
9.2 million in transfers to Genie Technologies Pte Ltd, affiliated with
asset freeze, receiver appointment, and restraining order. It contained
no mention of the blockchain, the 885 on-chain transactions, the
fund’s SEC registration, its independent fund administrator (Intertrust
Group), or its legal counsel (Seward & Kissel LLP).
The declaration’s scope of investigation (¶ 5) lists: bank account
records, NFA registration certifications, internet and computer
database searches, the LPA, and websites and social media. It does not
mention Etherscan, any blockchain analytics tool, or any examination
of the fund’s digital asset trading activity — despite the fact that the
case is premised on a digital asset fund and Dasso describes her role as
including the analysis of “digital asset trading accounts” (¶ 2).
F. The Internal Contradiction in the Declaration
The declaration contains a self-defeating internal contradiction that
Haan and Terrell, as the attorneys of record who signed the complaint
and filed the declaration, were obligated to identify and correct before
filing.
Dasso reviewed and quoted the LPA (¶ 16), which states the fund’s
purpose is to trade digital assets. She reviewed and quoted the
Silvergate bank account opening documentation (¶ 35), which states
the account exists to buy crypto via Coinbase Pro. She identified USD
9.2 million in transfers to Genie Technologies Pte Ltd, affiliated with
ZebPay — an overseas cryptocurrency exchange (¶¶ 40–42). She
confirmed that the fund was paying investors their promised 15%
annual return on a monthly basis (¶ 44). She then concluded, at
paragraph 45, that investor distributions were funded by other
investors’ deposits — a Ponzi scheme — because “no deposits ever
came into the account from Genie” (¶ 40).
The logical gap is not subtle. Dasso identified USD 9.2 million sent to
a cryptocurrency exchange and observed that no fiat wire transfers
came back. She never examined whether the exchange returned value
in the form of cryptocurrency tokens — the standard mechanism by
which a DeFi fund receives returns from a crypto exchange. The
blockchain shows exactly this. The “Ponzi” conclusion in ¶ 45 is built
on a fiat-only analysis of a crypto fund, conducted by an investigator
who never looked at the blockchain.
The internal contradiction between paragraphs 16, 35, 40–42, and 44
on one hand, and the “misappropriation” conclusion at paragraph 45
on the other, was apparent on the face of the declaration. Haan and
Terrell, as the attorneys of record, filed this declaration without
correction.
G. The Dasso Deposition — Sworn Admission
In her deposition (Dkt. #250-2, Exhibit C), Investigator Dasso
admitted under oath:
confirmed that the fund was paying investors their promised 15%
annual return on a monthly basis (¶ 44). She then concluded, at
paragraph 45, that investor distributions were funded by other
investors’ deposits — a Ponzi scheme — because “no deposits ever
came into the account from Genie” (¶ 40).
The logical gap is not subtle. Dasso identified USD 9.2 million sent to
a cryptocurrency exchange and observed that no fiat wire transfers
came back. She never examined whether the exchange returned value
in the form of cryptocurrency tokens — the standard mechanism by
which a DeFi fund receives returns from a crypto exchange. The
blockchain shows exactly this. The “Ponzi” conclusion in ¶ 45 is built
on a fiat-only analysis of a crypto fund, conducted by an investigator
who never looked at the blockchain.
The internal contradiction between paragraphs 16, 35, 40–42, and 44
on one hand, and the “misappropriation” conclusion at paragraph 45
on the other, was apparent on the face of the declaration. Haan and
Terrell, as the attorneys of record, filed this declaration without
correction.
G. The Dasso Deposition — Sworn Admission
In her deposition (Dkt. #250-2, Exhibit C), Investigator Dasso
admitted under oath:
“As far as this case, I did not look at the blockchain,
correct.”
Dasso further confirmed that: no investor had complained to her about
missing payments; she was unaware of any investor who had exited
the fund at a loss; and her declaration never used the words “Ponzi
scheme.”
H. The CFTC’s Own Forensic Expert
The CFTC retained StoneTurn Group as its forensic expert.
StoneTurn’s report (Dkt. 272-1, Exhibit G) concluded that any
uninvested cash used to pay vendors was less than the management
and performance fees disclosed to and collected from investors in their
monthly statements, and that the Complainant was current on all
investor note liabilities until the court-appointed receiver froze the
assets. The CFTC’s own forensic expert did not support the Ponzi
characterization.
I. The Investor Record
Every investor who participated in the fund filed a letter with the court
(Dkt. #204–243, Exhibit F). Sixty-nine letters were submitted. Not one
investor complained of fraud, misappropriation, or loss. Every
investor reported profitable returns.
correct.”
Dasso further confirmed that: no investor had complained to her about
missing payments; she was unaware of any investor who had exited
the fund at a loss; and her declaration never used the words “Ponzi
scheme.”
H. The CFTC’s Own Forensic Expert
The CFTC retained StoneTurn Group as its forensic expert.
StoneTurn’s report (Dkt. 272-1, Exhibit G) concluded that any
uninvested cash used to pay vendors was less than the management
and performance fees disclosed to and collected from investors in their
monthly statements, and that the Complainant was current on all
investor note liabilities until the court-appointed receiver froze the
assets. The CFTC’s own forensic expert did not support the Ponzi
characterization.
I. The Investor Record
Every investor who participated in the fund filed a letter with the court
(Dkt. #204–243, Exhibit F). Sixty-nine letters were submitted. Not one
investor complained of fraud, misappropriation, or loss. Every
investor reported profitable returns.
III. RULE VIOLATIONS
Count I — Rule 3.3(a)(1): False Statement of Fact to a Tribunal
Illinois Rule of Professional Conduct 3.3(a)(1) prohibits a lawyer from
knowingly making a false statement of fact to a tribunal. The
allegation in Dkt. #1, p. 2, ¶ 2 — “The Defendants did not trade digital
assets or commodity interests with participants’ funds” — is a
categorical statement of fact. It is directly contradicted by: (a) 885
publicly verifiable on-chain transactions (Exhibit D); (b) the LPA,
which the CFTC had reviewed and quoted in Dkt. #21, ¶ 16, stating
the fund’s purpose is to trade digital assets; and © the Silvergate
account opening documentation, which the CFTC had reviewed and
quoted in Dkt. #21, ¶ 35, stating the account exists to buy crypto
assets via Coinbase Pro.
Illinois courts and the ARDC apply the willful blindness doctrine to
the “knowingly” element of Rule 3.3(a)(1). See In re Edmonds, 2014
IL 117696. Haan and Terrell, as attorneys prosecuting a case about a
DeFi fund, had an obligation to examine the publicly available
blockchain record before making categorical assertions about what the
fund traded. Their failure to do so — while simultaneously reviewing
and quoting Fund Documents that stated the fund trades digital assets
— was willful blindness. After the May 16 raid, they had actual
possession of the blockchain evidence. Rule 3.3(a)(1) imposes a
Count I — Rule 3.3(a)(1): False Statement of Fact to a Tribunal
Illinois Rule of Professional Conduct 3.3(a)(1) prohibits a lawyer from
knowingly making a false statement of fact to a tribunal. The
allegation in Dkt. #1, p. 2, ¶ 2 — “The Defendants did not trade digital
assets or commodity interests with participants’ funds” — is a
categorical statement of fact. It is directly contradicted by: (a) 885
publicly verifiable on-chain transactions (Exhibit D); (b) the LPA,
which the CFTC had reviewed and quoted in Dkt. #21, ¶ 16, stating
the fund’s purpose is to trade digital assets; and © the Silvergate
account opening documentation, which the CFTC had reviewed and
quoted in Dkt. #21, ¶ 35, stating the account exists to buy crypto
assets via Coinbase Pro.
Illinois courts and the ARDC apply the willful blindness doctrine to
the “knowingly” element of Rule 3.3(a)(1). See In re Edmonds, 2014
IL 117696. Haan and Terrell, as attorneys prosecuting a case about a
DeFi fund, had an obligation to examine the publicly available
blockchain record before making categorical assertions about what the
fund traded. Their failure to do so — while simultaneously reviewing
and quoting Fund Documents that stated the fund trades digital assets
— was willful blindness. After the May 16 raid, they had actual
possession of the blockchain evidence. Rule 3.3(a)(1) imposes a
continuing duty to correct false statements of material fact made to a
tribunal. Haan and Terrell never discharged that duty.
Dkt. #312 establishes a further and independent basis for this count.
Dasso’s declaration (Dkt. #21) presented the CFTC’s investigation as
thorough and drew specific conclusions about the fund’s fee structure,
investor distributions, and alleged misappropriation (¶¶ 16, 35, 44–
45). Yet the sworn account in Dkt. #312 — unchallenged by the CFTC
— establishes that during the six-hour raid, Dasso did not know what
a PPM was, did not know what a “2 and 20” fee structure meant, did
not know the fund served only accredited investors, and had never
reviewed the PPM prior to the raid. A declaration that presents
conclusions about a fund’s fee disclosures and investment strategy as
the product of a thorough investigation, when the investigator lacked
basic knowledge of the governing documents she herself quoted, is a
materially misleading statement of fact to the tribunal within the
meaning of Rule 3.3(a)(1).
Count II — Rule 3.3(a)(3): Failure to Correct a False Statement
Through Material Omission
Rule 3.3(a)(3) requires a lawyer to take reasonable remedial measures,
including disclosure to the tribunal, when the lawyer has offered
material evidence and later comes to know of its falsity. After the May
16, 2022 raid, Haan and Terrell were in possession of the blockchain
tribunal. Haan and Terrell never discharged that duty.
Dkt. #312 establishes a further and independent basis for this count.
Dasso’s declaration (Dkt. #21) presented the CFTC’s investigation as
thorough and drew specific conclusions about the fund’s fee structure,
investor distributions, and alleged misappropriation (¶¶ 16, 35, 44–
45). Yet the sworn account in Dkt. #312 — unchallenged by the CFTC
— establishes that during the six-hour raid, Dasso did not know what
a PPM was, did not know what a “2 and 20” fee structure meant, did
not know the fund served only accredited investors, and had never
reviewed the PPM prior to the raid. A declaration that presents
conclusions about a fund’s fee disclosures and investment strategy as
the product of a thorough investigation, when the investigator lacked
basic knowledge of the governing documents she herself quoted, is a
materially misleading statement of fact to the tribunal within the
meaning of Rule 3.3(a)(1).
Count II — Rule 3.3(a)(3): Failure to Correct a False Statement
Through Material Omission
Rule 3.3(a)(3) requires a lawyer to take reasonable remedial measures,
including disclosure to the tribunal, when the lawyer has offered
material evidence and later comes to know of its falsity. After the May
16, 2022 raid, Haan and Terrell were in possession of the blockchain
evidence that directly contradicted the central factual allegation they
had made to the court. They were also aware of the fund’s SEC
registration, auditor, fund administrator, and legal counsel — none of
which appeared in the complaint or in Dasso’s subsequent declaration.
The “corrected” declaration filed on May 19 — after the raid —
contains no correction of the material omissions. It does not disclose
the blockchain evidence. It does not disclose the fund’s SEC
registration. It does not disclose the fund’s professional service
providers. It does not disclose the internal contradiction between the
documents Dasso reviewed (¶¶ 16, 35) and the conclusion she drew (¶
45). Haan and Terrell, as the attorneys of record who filed this
declaration, were obligated to ensure it did not contain material
omissions that rendered its conclusions misleading. See In re
Edmonds, 2014 IL 117696.
Pattern of Misconduct — Rule 8.4©
The foregoing violations, taken together, reflect a pattern of conduct
involving misrepresentation within the meaning of Rule 8.4©. Haan
and Terrell filed a categorical factual allegation without evidentiary
basis, in direct contradiction of documents they had already reviewed
(May 10). They obtained physical possession of the contradicting
evidence during the raid (May 16). They then filed, through their
supervisee, a “corrected” sworn declaration that omitted that evidence
had made to the court. They were also aware of the fund’s SEC
registration, auditor, fund administrator, and legal counsel — none of
which appeared in the complaint or in Dasso’s subsequent declaration.
The “corrected” declaration filed on May 19 — after the raid —
contains no correction of the material omissions. It does not disclose
the blockchain evidence. It does not disclose the fund’s SEC
registration. It does not disclose the fund’s professional service
providers. It does not disclose the internal contradiction between the
documents Dasso reviewed (¶¶ 16, 35) and the conclusion she drew (¶
45). Haan and Terrell, as the attorneys of record who filed this
declaration, were obligated to ensure it did not contain material
omissions that rendered its conclusions misleading. See In re
Edmonds, 2014 IL 117696.
Pattern of Misconduct — Rule 8.4©
The foregoing violations, taken together, reflect a pattern of conduct
involving misrepresentation within the meaning of Rule 8.4©. Haan
and Terrell filed a categorical factual allegation without evidentiary
basis, in direct contradiction of documents they had already reviewed
(May 10). They obtained physical possession of the contradicting
evidence during the raid (May 16). They then filed, through their
supervisee, a “corrected” sworn declaration that omitted that evidence
and contained an internal contradiction apparent on its face (May 19).
They continued to prosecute through summary judgment without
correcting the record. They obtained a USD 209 million judgment on
that foundation. The deliberate omission of known contradicting
evidence from a sworn declaration filed after that evidence was in
counsel’s possession constitutes misrepresentation within the meaning
of Rule 8.4©. See In re Karavidas, 2013 IL 115767.
IV. RELIEF REQUESTED
The Complainant respectfully requests that the ARDC:
1. Open a formal investigation into the conduct of Candice Haan (IL
Bar No. 6315007) and David A. Terrell (IL Bar No. 6196293).
2. Issue a formal inquiry to both attorneys requiring a written, sworn
response to the following specific questions: (a) What was the
evidentiary basis for the factual allegation in Dkt. #1, p. 2, ¶ 2 at
the time of filing, given that the CFTC had already reviewed the
LPA (Dkt. #21, ¶ 16) and the Silvergate account opening
documents (Dkt. #21, ¶ 35), both of which stated the fund trades
digital assets? (b) Why did the “corrected” declaration filed on
May 19 — after the May 16 raid — contain no disclosure of the
blockchain evidence in the CFTC’s possession? © Why was the
They continued to prosecute through summary judgment without
correcting the record. They obtained a USD 209 million judgment on
that foundation. The deliberate omission of known contradicting
evidence from a sworn declaration filed after that evidence was in
counsel’s possession constitutes misrepresentation within the meaning
of Rule 8.4©. See In re Karavidas, 2013 IL 115767.
IV. RELIEF REQUESTED
The Complainant respectfully requests that the ARDC:
1. Open a formal investigation into the conduct of Candice Haan (IL
Bar No. 6315007) and David A. Terrell (IL Bar No. 6196293).
2. Issue a formal inquiry to both attorneys requiring a written, sworn
response to the following specific questions: (a) What was the
evidentiary basis for the factual allegation in Dkt. #1, p. 2, ¶ 2 at
the time of filing, given that the CFTC had already reviewed the
LPA (Dkt. #21, ¶ 16) and the Silvergate account opening
documents (Dkt. #21, ¶ 35), both of which stated the fund trades
digital assets? (b) Why did the “corrected” declaration filed on
May 19 — after the May 16 raid — contain no disclosure of the
blockchain evidence in the CFTC’s possession? © Why was the
internal contradiction between paragraphs 16, 35, and 45 of the
Dasso declaration not corrected before filing?
3. Consider the full evidentiary record — including the Dasso
deposition admission, the StoneTurn forensic report, the 885 on-
chain blockchain transactions, and the 69 investor letters — in
evaluating the nature and duration of the conduct.
V. EXHIBITS
All primary exhibits are publicly accessible at samikkurty.com/legal-
documents. Physical copies are attached. Direct links are provided
below for the ARDC’s convenience.
Exhibit A — Dkt. #1 — CFTC Original Complaint (May 10, 2022)
See p. 2, ¶ 2 for the false factual allegation; signed by Haan and
Terrell https://samikkurty.com/legal-documents/dkt-1-original-
complaint
Exhibit B — Dkt. #21 — Corrected Dasso Declaration (May 19,
2022) ¶ 16 quotes LPA stating fund trades digital assets; ¶ 35 quotes
Silvergate docs; ¶ 45 draws Ponzi conclusion without blockchain
analysis Available via PACER, Case No. 1:22-cv-02465 (N.D. Ill.),
Dkt. #21
Dasso declaration not corrected before filing?
3. Consider the full evidentiary record — including the Dasso
deposition admission, the StoneTurn forensic report, the 885 on-
chain blockchain transactions, and the 69 investor letters — in
evaluating the nature and duration of the conduct.
V. EXHIBITS
All primary exhibits are publicly accessible at samikkurty.com/legal-
documents. Physical copies are attached. Direct links are provided
below for the ARDC’s convenience.
Exhibit A — Dkt. #1 — CFTC Original Complaint (May 10, 2022)
See p. 2, ¶ 2 for the false factual allegation; signed by Haan and
Terrell https://samikkurty.com/legal-documents/dkt-1-original-
complaint
Exhibit B — Dkt. #21 — Corrected Dasso Declaration (May 19,
2022) ¶ 16 quotes LPA stating fund trades digital assets; ¶ 35 quotes
Silvergate docs; ¶ 45 draws Ponzi conclusion without blockchain
analysis Available via PACER, Case No. 1:22-cv-02465 (N.D. Ill.),
Dkt. #21
Exhibit C — Dkt. #250-2 — Dasso Deposition Transcript (Sept. 5,
2023) Sworn admission: “I did not look at the blockchain, correct”
https://samikkurty.com/legal-documents/heather-dasso-deposition
Exhibit D — Ethereum Blockchain Ledger — 885 on-chain
transactions Public on-chain record directly contradicting Dkt. #1, p.
2, ¶ 2; independently verifiable at etherscan.io
https://samikkurty.com/blockchain-evidence
Exhibit E — SEC EDGAR — CIK No. 0001842816 Confirms fund’s
SEC registration, omitted from complaint and declaration
https://samikkurty.com/legal-documents/sec-form-d-rose-city-fund-ii-
2021 https://samikkurty.com/legal-documents/sec-form-da-rose-city-
fund-ii-2022
Exhibit F — Investor Letters (Dkt. #204–243) 69 letters confirming
profitability; zero complaints of fraud https://samikkurty.com/legal-
documents/investor-objection-dkt-204 Full collection:
https://samikkurty.com/legal-documents (filter: Investor Objections)
Exhibit G — StoneTurn Forensic Report (Dkt. 272-1, Oct. 16, 2023)
CFTC’s own forensic expert does not support Ponzi characterization
https://samikkurty.com/legal-documents/expert-report-stoneturn
Exhibit H — Dkt. #312 — Complainant’s Sworn Memorandum (Dec.
8, 2023) Sworn account of the May 16, 2022 raid; documents that
2023) Sworn admission: “I did not look at the blockchain, correct”
https://samikkurty.com/legal-documents/heather-dasso-deposition
Exhibit D — Ethereum Blockchain Ledger — 885 on-chain
transactions Public on-chain record directly contradicting Dkt. #1, p.
2, ¶ 2; independently verifiable at etherscan.io
https://samikkurty.com/blockchain-evidence
Exhibit E — SEC EDGAR — CIK No. 0001842816 Confirms fund’s
SEC registration, omitted from complaint and declaration
https://samikkurty.com/legal-documents/sec-form-d-rose-city-fund-ii-
2021 https://samikkurty.com/legal-documents/sec-form-da-rose-city-
fund-ii-2022
Exhibit F — Investor Letters (Dkt. #204–243) 69 letters confirming
profitability; zero complaints of fraud https://samikkurty.com/legal-
documents/investor-objection-dkt-204 Full collection:
https://samikkurty.com/legal-documents (filter: Investor Objections)
Exhibit G — StoneTurn Forensic Report (Dkt. 272-1, Oct. 16, 2023)
CFTC’s own forensic expert does not support Ponzi characterization
https://samikkurty.com/legal-documents/expert-report-stoneturn
Exhibit H — Dkt. #312 — Complainant’s Sworn Memorandum (Dec.
8, 2023) Sworn account of the May 16, 2022 raid; documents that
Haan and Dasso stated it was “the first time they are looking at
Etherscan”; unchallenged by the CFTC https://samikkurty.com/legal-
documents/dkt-312-sworn-memorandum
VI. CONCLUSION
This complaint presents two discrete, documented violations of the
Illinois Rules of Professional Conduct, each supported by record
evidence, and a pattern of conduct that reflects misrepresentation
within the meaning of Rule 8.4©.
Haan and Terrell filed a categorical factual allegation — that the fund
did not trade digital assets — in direct contradiction of documents
they had already reviewed and quoted in their own investigator’s
declaration. After the May 16 raid, they filed a “corrected” declaration
that omitted the contradicting evidence in their possession and that
contained an internal contradiction apparent on its face. Rule 3.3(a)(3)
required them to correct this. They did not.
The Complainant respectfully requests that the ARDC open a formal
investigation.
Respectfully submitted,
Etherscan”; unchallenged by the CFTC https://samikkurty.com/legal-
documents/dkt-312-sworn-memorandum
VI. CONCLUSION
This complaint presents two discrete, documented violations of the
Illinois Rules of Professional Conduct, each supported by record
evidence, and a pattern of conduct that reflects misrepresentation
within the meaning of Rule 8.4©.
Haan and Terrell filed a categorical factual allegation — that the fund
did not trade digital assets — in direct contradiction of documents
they had already reviewed and quoted in their own investigator’s
declaration. After the May 16 raid, they filed a “corrected” declaration
that omitted the contradicting evidence in their possession and that
contained an internal contradiction apparent on its face. Rule 3.3(a)(3)
required them to correct this. They did not.
The Complainant respectfully requests that the ARDC open a formal
investigation.
Respectfully submitted,
Sam Ikkurty a/k/a Sreenivas I. Rao
Date: _______________
7028 West Waters Avenue, Apt. 145 Tampa, FL 33634
[email protected] 813-389-3380
This complaint is submitted pursuant to Illinois Supreme Court Rule
751. All factual allegations are drawn from court filings and sworn
deposition testimony. Copies of all cited docket entries are attached as
exhibits.
Date: _______________
7028 West Waters Avenue, Apt. 145 Tampa, FL 33634
[email protected] 813-389-3380
This complaint is submitted pursuant to Illinois Supreme Court Rule
751. All factual allegations are drawn from court filings and sworn
deposition testimony. Copies of all cited docket entries are attached as
exhibits.
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Posted2026-04-12T14:42:35.000Z
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