Exhibit 4 (Maronick Affidavit) — USA v. Qureshi (Dkt. 29.4)

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Affidavit of Thomas J. Maronick Jr, Esq., Exhibit 4, Case 1:22-cr-00330-JKB, Document 29-4, dated 11/20/23. Maronick states that Maronick Law LLC represented Ayaz Qureshi as the second attorney in the federal case, the first being Patrick Smith, and that Qureshi spoke with counsel without an interpreter and never requested an Urdu interpreter other than for the Pre-Sentence meeting. Maronick states that sentencing was postponed more than once while the Government sought to continue use of Qureshi in a cooperation situation. Maronick states that counsel did not threaten or coerce Qureshi to take a plea, and that Qureshi did not indicate dissatisfaction until the filing of the Motion to Withdraw Guilty Plea. Maronick states that at the plea hearing the Court went through the plea agreement line by line.

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Case 1:22-cr-00330-JKB Document 29-4 Filed 11/21/23. Page1of2

Affidavit of Thomas Maronick Jr Esq.

| am Thomas J Maronick Jr, Esq., and | swear and affirm that the following is true and accurate to the
best of my knowledge, information and belief that:

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| and my office Maronick Law LLC represented Ayaz Qureshi in his federal case in question

| was the second attorney who represented him to my knowledge in this same matter, the first
being Patrick Smith

At all times relevant, Mr. Qureshi was able to speak with me without the assistance of an
interpreter, or, in the case of his pre-sentence investigation meeting, with an interpreter as
backup

That Mr. Qureshi hired me as his second attorney after a plea agreement for the present case
had been proposed by the government that he indicated having full knowledge of, and
understanding of.

Counsel asked during their first meeting if Mr. Qureshi needed an interpreter for any aspect of
their work together.

Mr. Qureshi indicated that he was an American citizen and understood English, and further never
once requested an Urdu interpreter for his meetings with counsel or any other purpose other
than as brought on for the Pre-Sentence meeting

Mr. Qureshi brought a copy of the initial plea agreement proffered with prior counsel with him
to multiple meetings in the e in Glen Burnie where he met this attorney

Mr. Qureshi indicated to counsel that he wanted to see if anything could be done to do better
than that plea agreement and to explore trial options

Present counsel indicated wanting to seek that end and met with him in the office, often with his
wife being present, and without need or request for an interpreter

After discussion of the case, counsel believed strongly, that it was in the best interests of Mr.
Qureshi to consider cooperating with the Government

Counsel and Mr. Qureshi worked with the Government ina cooperation situation in which Mr.
Qureshi sought to help his chances at sentencing by the minimum of accepting responsibility for
his actions

In fact, the sentencing in this case was postponed more than once as the Government sought to
continue use of Mr. Qureshi for a potential better situation for him

At no time did counsel threaten or coerce or force Mr. Qureshi to take a plea, that he felt it was
in the Defendant's best interest

At no time did counsel tell Mr. Qureshi he would quit if he wouldn’t take the plea, but did tell
him that the plea was in his interest, and if he wanted to try the case but didn’t agree with with
counsel’s advice, he could certainly hire another lawyer if he felt that his current counsel's advice
was not to his satisfaction, so as to not have a philosophical conflict on the case

Mr. Qureshi did not indicate any dissatisfaction with counsel until the filing of his Motion to
Withdraw Guilty Plea

That he went through the entire plea agreement, collectively, in his office with Mr. Qureshi and
also discussed the plea agreement over the phone with Mr. Qureshi.

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EXHIBIT 4
Case 1:22-cr-00330-JKB Document 29-4 Filed 11/21/23 Page 2 of 2

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Signed,

Further, while Mr. Qureshi admitted nervousness at the plea hearing, any purported lack of
understanding at the plea hearing was entirely addressed by this Court, as the Court went
through the plea agreement line by line with Mr. Qureshi so as to ascertain his full and complete
understanding

Mr. Qureshi had time to discuss any questions or concerns with present counsel, but at the end,
agreed to the plea on the record in front of This Court

Mr. Qureshi indicated satisfaction with this counsel at the plea hearing on the record

Mr. Qureshi was explained every aspect of the plea agreement before signing it and had full
understanding of it.

Counsel believed his acceptance of funds for a company that had no employees was strong
evidence of his involvement and Mr. Qureshi’s purported defenses were better as mitigation, or
as part of cooperation with the Government and that was conveyed.

Counsel had regular contact with Mr. Qureshi both in in-office meetings and through calls

While Mr. Qureshi had inaccurate or wrong beliefs about his level of culpability under the law,
counsel carefully went through his concerns, questions, and beliefs in making sure all potential
defenses were explored before coming to a decision to proceed with a plea.d

While counsel can make no representations as to mental fitness, as he’s not a doctor, counsel
notes that Mr. Qureshi met with him and cooperated with him throughout, responded to his
questions, took part in his own defense, discussed strategies, and was fully engaged to counsel’s
knowledge and belief to be able to participate in his defense.

Thomas J. Maronick Jr, Esq. 11/20/23

EXHIBIT 4


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