Forfeiture motion concerning Sargis Urumieh

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:24-cr-00424 · Doc. 139 · 2026-08-13 · Docket on CourtListener

Full text

   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 1 of 6 PageID #:1210




                       UNITED STATES DISTRICT COURT
                       NORTHERN DISTRICT OF ILLINOIS
                            EASTERN DIVISION

UNITED STATES OF AMERICA               )
                                       )      No. 24 CR 424-2
             v.                        )
                                       )      Judge Jeremy C. Daniel
SARGIS URUMIEH                         )

             MOTION OF THE UNITED STATES FOR ENTRY OF
                PRELIMINARY ORDER OF FORFEITURE

      The United States of America, through ANDREW S. BOUTROS, United States

Attorney for the Northern District of Illinois, moves for entry of a preliminary order

of forfeiture as to specific property pursuant to the provisions of Title 18, United

States Code, Sections 981(a)(1)(C), Title 28, United States Code, Section 2461(c) and

Fed. R. Crim. P. 32.2, and in support thereof submits the following:

      1.     On December 10, 2024, a second superseding indictment was returned

charging SARGIS URUMIEH with wire fraud, in violation of Title 18, United States

Code, Section 1343 (Counts 1-8).

      2.     The second superseding indictment sought forfeiture to the United

States of any and all right, title and interest defendant SARGIS URUMIEH may have

in any property which constitutes and is derived from proceeds traceable to the

charged wire fraud offenses, as provided in Title 18, United States Code, Section

981(a)(1)(C) and Title 28, United States Code, Section 2461(c).

      3.     On February 12, 2026, defendant SARGIS URUMIEH entered a

voluntary plea of guilty to Count One of the second superseding indictment before the

Court. Pursuant to the terms of the plea agreement and as a result of his violation of
   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 2 of 6 PageID #:1211




Title 18, United States Code, Section 1343 defendant SARGIS URUMIEH agreed

that, among other specified property, the following is subject to forfeiture pursuant

to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code,

Section 2461(c):

             (a)    $312,421.88 that is substitute res held for 29XX East Chevy
                    Chase Drive in Glendale, California (“the $312,421.88 substitute
                    res”).

      4.     Defendant SARGIS URUMIEH has agreed to the entry of a preliminary

order of forfeiture relinquishing any right, title, or interest he has in the foregoing

property pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and Title 28,

United States Code, Section 2461(c) for disposition according to law.

      5.     Defendant SARGIS URUMIEH further agreed to the entry of a personal

money judgment in an amount to be determined by the Court.

      6.     Because of the defendant’s conviction of the above violation, funds in an

amount to be determined by the Court and the foregoing $312,421.88 substitute res

are subject to forfeiture as property which constitutes and is derived from proceeds

traceable to the violation of conviction and are therefore subject to forfeiture pursuant

to the provisions of Title 18, United States Code, Section 981(a)(1)(C) and Title 28,

United States Code, Section 2461(c).

      7.     Pursuant to Fed. R. Crim. P. 32.2(b)(2)(B), unless doing so is impractical,

the court must enter the preliminary order of forfeiture sufficiently in advance of

sentencing to allow the parties to suggest revisions or modifications before the order

becomes final as to the defendant at sentencing.


                                           2
   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 3 of 6 PageID #:1212




      8.     In accordance with this provision, the United States requests that this

Court enter a personal money judgment in an amount to be determined by the Court,

and further enter a preliminary order of forfeiture pursuant to the provisions of Title

18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section

2461(c) forfeiting all right, title and interest defendant SARGIS URUMIEH has in

the funds in an amount to be determined by the Court and              the $312,421.88

substitute res.

      9.     Pursuant to the provisions of Title 21, United States Code, Section

853(g), as incorporated by Title 28, United States Code, Section 2461(c), upon entry

of this preliminary order of forfeiture, the United States Marshals Service, or any

other authorized law enforcement agency, shall seize and take custody of the

$312,421.88 substitute res for disposition according to law.

      10.    Further, pursuant to the provisions of Title 21, United States Code,

Section 853(n)(1), as incorporated by Title 28, United States Code, Section 2461(c),

upon entry of this preliminary order of forfeiture, the United States shall publish

notice of this order and of its intent to dispose of the $312,421.88 substitute res

according to law. The United States may also, to the extent practicable, provide

written notice to any person known to have alleged an interest in the property that is

the subject of the preliminary order of forfeiture, including but not limited to, Reza

Safaeejaved, and Triple S & S LLC, and Triple S & S LLC c/o Sepehr Omrani, Esq.

      11.    Further, pursuant to the provisions of Title 21, United States Code,

Section 853(n)(2), as incorporated by Title 28, United States Code, Section 2461(c), if,



                                           3
   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 4 of 6 PageID #:1213




following notice as directed by this Court and Title 21, United States Code, Section

853(n)(1), any person, other than the defendant, asserts a legal interest in the subject

U.S. currency that has been ordered forfeited to the United States, within 30 days of

the final publication of notice or this receipt of notice under paragraph 10, whichever

is earlier, and petitions the Court for a hearing to adjudicate the validity of this

alleged interest in the property, the government shall request a hearing. The hearing

shall be held before the court alone, without a jury.

      12.    Following the Court’s disposition of all third-party interests, the Court

shall, upon the government’s motion, if appropriate, enter a final order of

forfeiture as to the $312,421.88 substitute res which shall vest clear title in the

United States of America.

      13.     Furthermore, Title 21, United States Code, Section 853(p), as

incorporated by Title 28, United States Code, Section 2461(c), provides that if funds

to satisfy the personal money judgment entered against defendant SARGIS

URUMIEH, as a result of any act or omission of the defendant:

             a.     cannot be located upon the exercise of due diligence;

             b.     have been transferred or sold to, or deposited with, a third-party;

             c.     have been placed beyond the jurisdiction of the Court;

             d.     have been substantially diminished in value, or

             e.     have been commingled with other property which cannot be
                    divided without difficulty;




                                           4
   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 5 of 6 PageID #:1214




the United States shall request that this Court order the forfeiture of any other

property belonging to defendant SARGIS URUMIEH up to the value of the entered

judgment amount, in order to satisfy the money judgment entered by the Court.

      14.      Since funds in the total amount of the outstanding personal money

judgment cannot be located to satisfy the forfeiture judgment, pursuant to the

provisions of Title 21, United States Code, Section 853(p), as incorporated by Title 28,

United States Code, Section 2461(c), and Fed. R. Crim. P. 32.2, the United States,

upon motion before this Court, has the authority to forfeit substitute assets to satisfy

the personal money judgment. Should assets become available to satisfy the forfeiture

judgment in the future, the United States shall, at that time, file a motion for

substitution of assets before this Court requesting permission to seize such assets

and publish notice of the United States’ intent to forfeit the property to satisfy the

forfeiture money judgment according to law.

      15.      Pursuant to Title 18, United States Code, Sections 981(a)(1)(C), Title 28,

United States Code, Section 2461(c), and Fed. R. Crim. P. 32.2, the United States

requests that the terms and conditions of this preliminary order of forfeiture entered

by this Court be made part of the sentence imposed against defendant SARGIS

URUMIEH and included in any judgment and commitment order entered in this case

against him.




                                            5
   Case: 1:24-cr-00424 Document #: 139 Filed: 08/13/26 Page 6 of 6 PageID #:1215




      WHEREFORE, pursuant to the provisions of Title 18, United States Code,

Sections 981(a)(1)(C), Title 28, United States Code, Section 2461(c) and Fed. R. Crim.

P. 32.2, the United States requests that this Court enter a personal money judgment

against defendant SARGIS URUMIEH in an amount to be determined at sentencing,

and further enter a preliminary order of forfeiture against defendant SARGIS

URUMIEH as to the amount of funds comprising the money judgment and as to the

$312,421.88 that is substitute res held for 29XX East Chevy Chase Drive in Glendale,

California, in accordance with the draft preliminary order of forfeiture which is

submitted herewith.

                                              Respectfully submitted,

                                              ANDREW S. BOUTROS
                                              United States Attorney


                                       By:     /s/Jeffrey S. Snell
                                              JEFFREY S. SNELL
                                              Assistant United States Attorney
                                              219 S. Dearborn Street, Suite 500
                                              Chicago, Illinois 60604
                                              (312) 353-5300




                                          6


File and source

File

139-forfeiture-motion-concerning-sargis-urumieh-ordinary-pacer-u.pdf

Size

119,062 bytes

SHA-256

f82d7bf9d4b21fec56bc167b7420c7cd74a818f4cc397e5776cdf3f97ee44487

Our copy

139-forfeiture-motion-concerning-sargis-urumieh-ordinary-pacer-u.pdf

Original

No public link identified.