Exhibit 1. Declaration — USA v. Barabash (Dkt. 39.1)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00232-JKB · Doc. 39-1 · 2025-04-14 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
UNITED STATES OF AMERICA 
 
v. 
 
ALEXANDER BARABASH, 
 
Defendant 
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CRIMINAL NO. JKB-22-232 
 
 
 
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DECLARATION OF SPECIAL AGENT DANIEL SCHELER 
I, Daniel Scheler, Special Agent with the United States Secret Service (“USSS”), do 
hereby declare: 
1. 
I am currently a Special Agent with the USSS.  I have been a Special Agent with 
the USSS since May 2014.  I am currently assigned to the USSS Baltimore Field Office as a Group 
Leader.  During my time with the USSS, I have been involved with multiple assignments.  These 
assignments include providing protection to the President and Vice President of the United States 
and investigating a variety of financial crimes.  These crimes include manufacturing counterfeit 
currency, identity theft, access device fraud, and wire/check/bank fraud.  To investigate these 
crimes, I have received extensive training in financial fraud investigative techniques and 
procedures.  In addition to being a Group Leader, I am also one of the Asset Forfeiture 
Representatives (“AFR”) for the USSS Baltimore Field Office and have been since 2016. 
2. 
As an AFR, I have received training pertaining to asset forfeiture laws.  My duties 
as an AFR include identifying assets to be targeted and seized during criminal investigations, 
assisting victims of financial crimes in attempting to recoup lost assets, and providing assistance 
to other law enforcement agencies in seizing the proceeds gained from financial fraud schemes. 
Case 1:22-cr-00232-JKB     Document 39-1     Filed 04/14/25     Page 1 of 3

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3. 
I am the case agent involved in the investigation of Alexander Barabash (the 
“Defendant”), and thus, I am familiar with efforts to locate the proceeds of his criminal conduct.   
4. 
In searching for proceeds of the Defendant’s criminal conduct, agents and 
employees of the USSS conducted an investigation into the Defendant’s assets, including assets 
directly traceable to his offense of conviction.  I and other employees of the USSS continue to 
monitor the Defendant’s finances. 
5. 
I am aware that a thorough investigation failed to locate all the proceeds of the 
Defendant’s offenses.  I am also aware that on June 27, 2023, the Court entered a Preliminary 
Order of Forfeiture imposing a money judgment in the amount of $1,295,000 against the 
Defendant.  ECF No. 32.  The Defendant still owes the full amount of that money judgment.  
6. 
Based on my communications with the investigators involved in this case, I have 
learned that diligent efforts to locate the proceeds of Defendant’s criminal offenses have been 
unsuccessful.  Based on my training and experience, I conclude that, due to the acts or omissions 
of the Defendant, the proceeds cannot be located with due diligence because they were transferred 
or sold to, or deposited with, a third party, placed beyond the jurisdiction of the Court, substantially 
diminished in value, or commingled with other property which cannot be divided without 
difficulty. 
7. 
I have learned that the Defendant owns real property located at 5575 E. Sheena 
Drive, Scottsdale, Arizona (the “Subject Property”).  
8. 
The Subject Property is subject to forfeiture as a substitute asset in partial 
satisfaction of the Defendant’s forfeiture money judgment, which remains outstanding. 
 
I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing is true 
and correct to the best of my knowledge, information, and belief. 
 
Case 1:22-cr-00232-JKB     Document 39-1     Filed 04/14/25     Page 2 of 3

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Executed this __12__ day of April, 2025. 
 
 
 
 
 
 
 
 
Daniel Scheler 
 
 
 
 
 
 
 
 
Daniel Scheler 
Special Agent 
United States Secret Service 
 
Case 1:22-cr-00232-JKB     Document 39-1     Filed 04/14/25     Page 3 of 3

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