Affidavit Exhibit B - Defendant Qureshi Affidavit — USA v. Qureshi (Dkt. 20-2, D. Md.)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00330-JKB · Doc. 20-2 · 2023-08-29 · Docket on CourtListener

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AFFIDAVIT OF
MR. AYAZ OURESHI
I, t\yaz Qureshi, hereby solemnly swear and affirm, under penalty of perjury, that the
following statements I make are true and accurate to the best of my information, knowledge and
belief.
l. .[ am over the age of l8 and competent to make this affidavit.
2. 'Ihis affidavit and its contents were translated to me in Urdu, my native language, and
that I underrstand its contents as drafted in English.
3. ll am s;ubmitting this affidavit in support of my Motion to Vacate my guilty plea entered
in criminal no. l:22CR00330-001.
4. During my Rule 11 hearing when I plead guilty, I did not fully appreciate or
comprehend the,nature of what I was doing.
5. I required the assistance of an interpreter, Urdu, and was never provided one by the
Court. I informe:d my then-attomey that I required one for Couft, but was told I did not need one.
6. I was also never advised by my then-attomey of the contents of the plea agreement that
I signed. Becausie I lacked the vocabulary for English legal terms, I could not read it myself and
comprehend its contents. My then-attorney also never explained to me the contents of the
agreement., the nature of the charges or even the sentencing range under the guidelines.
7. In preparation of my criminal case, I met my then-attorney only 3-4 times, and during
these meetings, I asked for an interpreter but was never provided one.
8. Prior 1.o my Rule I I hearing, my attomey threatened me by saying, "if I did not plead
guilty, he vvill qttit being my lawyer." Before saying that, my lawyer also told me,"Ayez, you qre
here to ple'a guilty, when you appear infront of the Judge, what ever he says or reads, don't say
anything, e:xcept Yes Your Honoltr." After that is when he told me that he will quit if I didn't
follow his wordr;. I was afraid to say anything because my lawyer told me not to speak or saying
anything.
9. I never had a chance to fully comprehend the plea agreement by reading it through or
having it translarted to me in Urdu. I was also told by my then-lawyer that I had to sign the plea
agreement quickly because it was a good opportunity and I had to sign it before the Government
" changes tlheir minds."
10. I felt extremely pressured to plead guilty because of my then-attomey's statements to
Case 1:22-cr-00330-JKB     Document 20-2     Filed 08/29/23     Page 1 of 3

me. My then-lawyer said to me, "plead guilty, its goodfor you anclfor me." He also told me
when I go in front of the Judge that I should just say,"Yes, your Honor," to thejudge's
questions.
11. Had I understood what I was doing and the consequenci:s I now face, I would not
have accepted t.he plea agreement, and instead would have elected to go to trial to prove my
innocence,
12. I would have raised the defense that I was a victim of PPP loan fraud, and not the
principle a,ctor. I would have raised the defense that I was misled and tricked by Adam into
participating in a loan scheme, when I had never had such intent.
13. I would have raised the defense that Adam forged my signatures on my company tax
returns, without my knowledge, and that he prepared the supporting documents for the Ppp
loans, without my knowledge.
14. I would have raised the defense that I had originally met with Adam because he
claimed he, could help me repair my credit, and then help me obtain a bank approval letter to buy
a house. I'woulcl have raised the defense that I originally paid him $900.00 to help me repair my
credit.
15. I would have raised the defense that I never originated an intent to obtain an ppp loan,
rather it wtts Adam that suggested I pursue it, and Adam who ultimately prepared applications,
documents and exhibits in support, on my behalf without my understanding and appreciation of
what he was pursuing.
16. I would have raised the defense that once I received the PPP loan money, I informed
Adam that I did not agree to borrow this much money, that I had never agreed to a loan for
$250,000.Cr0.
17. I would have raised the defense that I informed Adam, that all this money should be
returned, but Adam told me that was not possible, and that I had to spend the money on payroll.
18. I would have raised the defense that I never had enough employees in my company to
support that I needed this much money, and that had I known this was what Adam was doirrg, I
would never have agreed to accept his help.
19. I would have raised the defense that Adam stated for his time and efforts, he would
collected a fee o.f $75,000.00 from the PPP loan proceeds, and that if I wanted to return all the
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money, that I would also have to refund the $75,000.00 personally, as he would not be ref,unding
any portion of the money he received.
20, My rthen-attorney never once listened or understood that I was not a principle actor in
a conspiracy with Adam. Since learning what the word "conspiracy" meant, I understand now
that I did not have any type of agreement between Adam and myself to defraud the federal
government through the PPP loan process. Instead, I was misled by Adam and merely foll,cwed
his advice to apply for what I thought was a business loan to help my company survive through
Covid.
SWORN'IO BiE TRUE:
tl
@ 
;--''
Hrtr.AV"-a,ur.,,hi
Date:
?i, - 23
State of Maryland
County of Montgomery County, to wit:
NotaryPublic 
r .l
My Commis:;ion E:xpires: +/ t V! >C
Qureshi_, krrown to me (or s
and acknowledged that he executed the same for the purpose therein contained, and attested to the truth ofthe
contents therein.
In witness whereof, I hereunto set my hand and official seal.
[Printed Nanre of J.,lotary Public]
MAFY BETH CANC
Aoril 14,2026
Nctarv Pubr ic-MarYland
Montgom{rrY CountY
Mv Commission ExPires
Case 1:22-cr-00330-JKB     Document 20-2     Filed 08/29/23     Page 3 of 3

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