Matt Brown former ihub owner /Jonathan Curshen/Dee

Matt Brown former ihub owner /Jonathan Curshen/Deep Capture


A. The Trip to Costa Rica

The defendant makes a number of factual claims about a trip to Costa Rica alleged in paragraph 31(g) of the Second Superseding Indictment. That trip is alleged as an overt act in furtherance of the conspiracy to commit money laundering charged in Count 9. The defendant does not deny that the trip occurred. Instead, he claims the following:

• the purpose of the trip was to attend a Halloween Party;

• Matt Brown invited co-defendant Dynkowski on the trip; Matt Brown invited co-defendant Dynkowski on the trip;

• during the trip, Brown, Dynkowski, and the defendant went to a bar with Jonathan Curshen, the owner of Red Sea Management;
Brown, Dynkowski, and the defendant stayed in separate rooms;

• Brown, Dynkowski, and the defendant attended the Halloween party;

• Brown and Dynkowski "accepted an invitation" to tour Mr. Curshen's offices;

• the defendant shopped at a mall to purchase gifts for his children and arranged to meet Brown and Dynkowski at the hotel.

Defendant's motion at 12-13. The defendant claims that this information is exculpatory. At best, however, it can only be construed as a general denial that he traveled to Costa Rica with the intent to further the money laundering conspiracy. There is nothing in these facts that undermines the allegation that one purpose of the trip was to set up an off-shore account, or that otherwise would have had a material effect on the decision to indict; to the contrary, the facts alleged by the defendant merely confirm that he traveled with Dynkowski to Costa Rica as alleged in the indictment.

B. The Alleged Brown-Curshen Relationship

The defendant also asserts that Mr. Brown and Mr. Curshen had a relationship that pre¬dated the Costa Rica trip, and thus Brown and Dynkowski "did not need Mr. Mangiapane's assistance" in opening an account to further the laundering of the funds off-shore.[2] Defendant's Motion at 14. Once again, even assuming arguendo that it is correct, this alleged fact does not tend to disprove the charges as alleged in the indictment. While the fact that the defendant accompanied Dynkowski to Costa Rica to make a relevant introduction would tend to prove the government's case, the fact that Brown had "a relationship" of some undefined sort with Mr. Curshen prior to the trip does not tend to negate the allegation in the indictment.

[2]The indictment makes no reference in Count 9 to Red Sea Management or Jonathan Curshen. For present purposes, this response will assume arguendo that the communications with Mr. Curshen and Red Sea Management in Costa Rica are relevant to the claim that Dynkowski and the defendant traveled to Costa Rica for the purpose of establishing an off-shore account.

Moreover, paragraph 31 lists ten (10) additional overt acts in furtherance of the conspiracy charged in Count 9. The defendant's motion sets forth no allegedly exculpatory evidence to undermine those acts. As a result, his claim that the grand jury would not have indicted had it heard the asserted facts is meritless.



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A Deep Capture team member, working undercover, once traveled to Costa Rica to meet Curshen. On multiple occasions, this creep admitted to our undercover vigilante that he participated in illegal naked short selling – and threatened to kill anyone who revealed this. Curshen also admitted laundering money for criminal short sellers, and described special debit cards that could not be traced to their users. These cards, Curshen said, were used to pay off government officials and journalists.