Motion for Forfeiture of Property Preliminary Motion for Forfeiture of Property — USA v. Qureshi (Dkt. 62, D. Md.)

Summary

The government's motion for a preliminary order of forfeiture against Ayaz Qureshi, Criminal No. RDB-22-330, U.S. District Court for the District of Maryland, filed 09/03/24 as Document 62 in case 1:22-cr-00330-JKB and signed /s/ Jared M. Beim, Assistant United States Attorney. It recites that an information filed September 19, 2022 charged Qureshi with wire fraud conspiracy and that he pleaded guilty on April 9, 2024, agreeing to a forfeiture money judgment of $250,723.00. In his stipulation of facts, the motion says, Qureshi admitted that he and a co-conspirator obtained a fraudulent PPP loan for Yazee, Inc. and that he fraudulently obtained $250,723. The government asks the court to enter the money judgment and include it in the sentence and judgment.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
UNITED STATES OF AMERICA 
v. 
AYAZ QURESHI, 
Defendant 
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CRIMINAL NO. RDB-22-330 
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UNITED STATES’ MOTION FOR PRELIMINARY ORDER OF FORFEITURE 
The United States of America, by its attorney, Erek L. Barron, United States Attorney for 
the District of Maryland, respectfully moves this Court for the issuance of a Preliminary Order of 
Forfeiture in the above-captioned case pursuant to 18 U.S.C. §§ 982(a)(2)(A) and (b), 21 U.S.C. 
§ 853(p) and Rule 32.2(b) of the Federal Rules of Criminal Procedure.  A proposed Preliminary
Order of Forfeiture is submitted herewith.  In support thereof, the United States sets forth the 
following: 
1.
On September 19, 2022, United States of America filed an Information, charging
AYAZ QURESHI (the “Defendant”) with Wire Fraud Conspiracy, in violation of 18 U.S.C. 
§ 1349 (Count One).  ECF No. 1.
2.
The Information also included a forfeiture allegation, which provided notice that
the United States intended to seek forfeiture, pursuant to 18 U.S.C. §§ 924(d), 981(a)(1)(C) and 
982(a)(2)(A), 21 U.S.C. § 853(p), and 28 U.S.C. § 2461(c), upon conviction of the Defendant of 
the offense alleged in Count One of the Information. 
3. 
On April 9, 2024, the Defendant pleaded guilty to the offense alleged in Count 
One of the Information.  ECF No. 54.  As part of his guilty plea, the Defendant agreed to entry 
of an order of forfeiture to include a money judgment in the amount of $250,723.00 in U.S. 
Case 1:22-cr-00330-JKB     Document 62     Filed 09/03/24     Page 1 of 3

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currency equal to the value of the property derived from, or otherwise involved in, the 
Defendant’s offense.  Id. ¶¶ 12-13. 
4. 
In support of his guilty plea, the Defendant executed a Stipulation of Facts in 
which the Defendant admitted that he and a co-conspirator obtained a fraudulent loan for Yazee, 
Inc., Qureshi’s purported business, under the Paycheck Protection Program (PPP), part of the 
Coronavirus Aid, Relief, and Economic Security (CARES) Act.  Ultimately, Qureshi 
fraudulently obtained $250,723 as part of this scheme. ECF No. 54. 
5. 
Pursuant to 18 U.S.C. § 982(a)(2)(A) and (b), 21 U.S.C. § 853(p) and Rule 
32.2(b)(2) of the Federal Rules of Criminal Procedure, the United States is now entitled to a 
forfeiture money judgment in the amount of $250,723.00 in U.S. currency against the Defendant. 
6.
Further, the United States may move at any time, pursuant to Rule 32.2(e)(1)(B)
of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(p), to forfeit any property of the 
defendant up to the value of the forfeiture money judgment included in the Preliminary Order of 
Forfeiture. Upon issuance of any order forfeiting specific property, the United States will 
publish notice in accordance with 21 U.S.C. § 853(n)(1) and Rule 32.2(b)(6) of the Federal Rules 
of Criminal Procedure. 
7.
The United States also seeks permission to conduct any discovery that might be
necessary to identify, locate, or dispose of forfeited property, pursuant to Rule 32.2(b)(3) of the 
Federal Rules of Criminal Procedure and 21 U.S.C. § 853(m). 
WHEREFORE, the United States requests that this Court: 
(a)
enter the Preliminary Order of Forfeiture in the form submitted herewith;
(b)
include the forfeiture, as set forth in the Preliminary Order of Forfeiture, in the
oral pronouncement of the Defendant’s sentence; 
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(c)
retain jurisdiction for the purpose of enforcing the forfeiture; and
(d)
incorporate the Preliminary Order of Forfeiture in the criminal judgment entered
against the Defendant, pursuant to Federal Rule of Criminal Procedure 32.2(b)(4). 
Respectfully submitted, 
Erek L. Barron 
United States Attorney 
By: 
/s/
Jared M. Beim
Assistant United States Attorney 
Case 1:22-cr-00330-JKB     Document 62     Filed 09/03/24     Page 3 of 3

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