Sentencing Memorandum by USA as to Sakiru Olanrewaju Ambali — United States v. Lawal (Dkt. 43, W.D. Wash. No. 3:23-cr-05034)

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U.S. District Court for the Western District of Washington · No. 3:23-cr-05034-RJB · Doc. 43 · 2024-03-07 · Docket on CourtListener

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United States’ Sentencing Memorandum - 1 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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The Honorable Robert J. Bryan 
 
 
 
 
 
 
 
 
 
UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF WASHINGTON 
AT TACOMA 
 
 
UNITED STATES OF AMERICA, 
 
Plaintiff 
 
v. 
SAKIRU OLANREWAJU AMBALI 
       Defendant. 
NO. CR23-5034-RJB-02 
 
UNITED STATES’ SENTENCING  
MEMORANDUM 
 
 
Sakiru Ambali is a Canadian resident and Nigerian citizen who stole over a million 
dollars in pandemic relief funds that should have gone to American workers suffering from 
the devastating economic impacts of the COVID-19 pandemic.  His exploitation of a 
vulnerable time in our nation was the culmination of years of fraudulent activities—
including the use of stolen American identities to submit fraudulent U.S. tax returns 
seeking refunds—while he lived in Nigeria and Canada.  Ambali and Fatiu Lawal, his co-
conspirator and close friend of over 20 years, were well-versed in executing sophisticated 
frauds and had stolen the personal identifying information of more than 14,700 unwitting 
Americans.  At the onset of the pandemic in 2020, the pair used these stolen identities to 
submit more than 1,700 fraudulent claims for COVID-19 unemployment benefits in over 
25 states and to submit fraudulent applications for small business assistance.  Ambali and 
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United States’ Sentencing Memorandum - 2 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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Lawal also used the stolen American identities to submit over 2,300 fraudulent U.S. tax 
returns seeking refunds. 
The United States recommends that the Court sentence Ambali to 36 months of 
imprisonment for wire fraud (Count 5), to run consecutive to the mandatory 24-month 
sentence for aggravated identity theft (Count 15), for a total of 60 months of imprisonment.  
This sentence is necessary to reflect the serious nature of the offense and to deter others—
particularly those who perpetrate fraud from abroad—from engaging in similar conduct.   
The Court should also impose the special conditions proposed by Probation, including that 
upon deportation, he may not reenter the United States without permission of the 
Department of Homeland Security.  The court should further order Ambali to pay 
restitution in the amount of $1,035,107, as agreed upon in the Plea Agreement. 
I. 
BACKGROUND 
A. 
Ambali Has Been Defrauding the United States Since at Least 2018. 
Sakiru Ambali is a seasoned fraudster who maintained multiple email accounts to 
perpetrate various sophisticated fraud schemes.  See, e.g., PSR at ¶¶ 9, 16.  Several of these 
accounts 
used 
variations 
of 
the 
username 
“Larry 
Smith,” 
such 
as 
larrysmith1404@yahoo.com, larrysmith0004@mail.com, larrysmith1404@gmail.com, 
and larrysmith14044@gmail.com.  All of these accounts are linked by a common recovery 
phone number and email addresses belonging to Ambali.  According to subscriber 
information obtained during the course of this investigation, three of these accounts were 
created in 2016 and one in 2017.   
Since at least February 2018, Ambali used two of the Larry Smith accounts to file 
fraudulent U.S. tax returns using stolen American identities and seeking refunds totaling 
approximately $6,000.  See id. at ¶ 21.  During the pandemic, he filed additional returns 
seeking 
refunds 
using 
another 
account 
he 
used 
for 
fraudulent 
purposes, 
seritdavis[@]gmail.com.  Id.  In total, he filed at least eight fraudulent tax returns using 
stolen identities and seeking refunds totaling over $40,000.  Id.   
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United States’ Sentencing Memorandum - 3 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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B. 
Ambali Stole Funds Intended for American Workers Suffering From the 
Economic Impacts of the COVID-19 Pandemic. 
Although Ambali did not appear to reap any monetary benefit from his submission 
of fraudulent tax returns, his perpetration of fraud against the United States and its residents 
culminated at the onset of the COVID-19 pandemic.  In March 2020, following presidential 
declarations of a nationwide emergency and major disasters in every state, the federal 
government enacted measures to mitigate the devasting economic impact the COVID-19 
pandemic was exacting on American workers and businesses.  Id. at ¶ 12.  Among these 
measures was federal funding for expanded and increased unemployment benefits 
administered by state workforce agencies, including the Washington Employment Security 
Department (ESD).  Id. at ¶ 13.   
Between May 7, 2020 and at least until December 12, 2021, Ambali personally used 
his cache of stolen identities to submit over 630 fraudulent claims for pandemic 
unemployment benefits in the names of over 630 American workers to at least 21 state 
workforce agencies across the country, including Washington’s ESD.  Id. at ¶ 11.  Ambali 
used at least four different email accounts to submit the claims, including at least two Gmail 
accounts: onlinefacebookprogs2016@gmail.com and seritdavis@gmail.com.  To 
circumvent fraud safeguards and prevent the state workforce agencies from recognizing 
that a single email account was being used for hundreds of claims, Ambali inserted periods 
at various places in the email addresses, e.g., o.nl.i.ne.f.a.ce.bookprogs2016@gmail.com.  
Id. at ¶ 16-17.  To further evade detection, Ambali used tools that routed his submissions 
through IP addresses located within the United States. 
Washington was one of the first states in the nation to implement federal pandemic 
unemployment benefits, and Ambali directed his earliest efforts in May 2020 to submitting 
fraudulent applications to Washington’s ESD.  At least a dozen of the stolen Washington 
identities Ambali used on these applications belonged to public servants at state and local 
government agencies and entities. Within a month, Ambali filed approximately 35 
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United States’ Sentencing Memorandum - 4 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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fraudulent claims and caused ESD to disburse benefits totaling approximately $131,000 
for about half of them.  Over the next 18 months, Ambali submitted hundreds of fraudulent 
claims in 20 additional states.  In total, Ambali caused state workforce agencies to disburse 
over $1 million in pandemic unemployment benefits.  Id. at ¶ 16. 
Ambali and his co-conspirators directed unemployment benefits to be paid to money 
mules in the United States who then withdrew and transferred the funds according to 
instructions given by Ambali and his co-conspirators.  Id. at ¶ 18. 
C. 
Ambali’s Expenditures Increased Exponentially During Commission of the 
Offenses. 
Because the United States has limited avenues for obtaining financial records 
located abroad, the government does not have a comprehensive analysis of Ambali’s 
finances.  Nevertheless, relying on the contents of Ambali’s personal email account that 
the government lawfully obtained during the course of its investigation, Ambali’s 
expenditures increased dramatically during the commission of the charged offenses while 
his reported annual income from Uber fell to less than $4,000 in 2021.  Therefore, the 
government disputes Ambali’s claim that he only received $6,000 from his criminal 
conduct.  See id. at ¶ 26.   
According to the PSR, Ambali’s employment from 2019 until 2023 was driving for 
Uber, and Ambali reported making up to $5,000 per month.  Id. at ¶ 69.  According to Uber 
statements found in Ambali’s email account, Ambali earned approximately CA$55,000 in 
2019.  Ex. A at 1.  However, his Uber income plummeted to CA$17,842.73, or 
approximately US$13,000, in 2020.  Id. at 2.  For January through November 2021, Ambali 
earned a mere CA$4,408.39, or approximately US$3,261.97.  Id. at 3-7. 
Ambali’s Uber income, particularly during the commission of the charged offenses 
in 2020 and 2021, is inconsistent with expenditures that appear in his inbox.  For instance, 
based on order confirmation emails, Ambali regularly shopped online at YOOX, a retailer 
for clothing and shoes by designers such as Dolce & Gabanna.  During a one-year period 
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United States’ Sentencing Memorandum - 5 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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during which Ambali earned his highest Uber income, between November 2018 and 
September 2019, Ambali placed five YOOX orders that totaled US$1,309.44.  Ex. B at 1-
16.  In contrast, over a three-month period between June and September 2020, Ambali 
placed six YOOX orders for designer clothing and shoes that totaled US$6,641.60, or over 
half of his total Uber income for 2020.  Id. at 16-36.  Additionally, despite Ambali’s 
negligible Uber income in 2021, in April 2022, he financed a 2022 Lexus SUV for 
approximately US$56,000 with monthly payments of approximately US$400.  Ex. C. 
Although Ambali did not earn significant income from Uber in 2020 and had 
minimal earnings in 2021, his spending increased exponentially while he submitted over 
630 fraudulent pandemic unemployment claims to the United States using the stolen 
identities of American workers.  Between May and September 2020 alone, while he bought 
more than US$6,000 worth of designer clothes and shoes, Ambali submitted approximately 
300 fraudulent claims.   
D. 
Ambali Continued His Fraudulent Activities Until His Arrest. 
Incident to Ambali’s arrest, federal agents lawfully seized and searched his personal 
cell phone.  The contents of the phone show that the scope of Ambali’s fraudulent conduct 
was broad, and he continued the criminal activities until his arrest in Frankfurt, Germany 
on February 21, 2023.  See Ex. D, FBI Report re Evidence Item 1B60 – Apple iPhone XR 
(Oct. 13, 2023). 
Ambali was an active user of Telegram and was a participant in at least one channel 
that instructed more than 18,000 followers how to defraud various United States 
government programs.  PSR at ¶¶ 22-23.  The channel, which was administered by a user 
with the handle “@LarryLarry07,” provided step-by-step tutorials for how to make the 
fraudulent submissions, instructions on how to mask IP addresses to evade detection, and 
how to purchase stolen personal identifying information of American residents.  Id.; see, 
e.g., Ex. E.   
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United States’ Sentencing Memorandum - 6 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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Ambali also used the Telegram direct messaging function to communicate with 
other fraudsters.  For instance, in October 2021, Ambali used Telegram’s direct messaging 
function to purchase stolen personal identifying information of New York residents in 
order to defraud the New York Excluded Workers Fund, a pandemic assistance program 
intended to assist workers who did not qualify for unemployment benefits most often due 
to immigration status.  Ex. D at 5-8. 
In January 2023, a month before Ambali’s arrest, in a WhatsApp exchange, Ambali 
received personal identifying information with financial accounts for multiple individuals.  
Although it is difficult to decipher the contours of the scam, Ambali and the other party 
discuss the number of people involved in the fraud and whether or not the information 
should be used.  Ex. D at 20-22. 
Ambali’s web history on his phone included searches for ESD’s login page to access 
unemployment benefit applications.  Amabli first searched for this website on or about 
May 5, 2020, two days before his first fraudulent submission to ESD, and he most recently 
visited the page on February 20, 2023, the day before he was arrested and last had access 
to his devices.  Ex. D at 4.  In other words, it is possible that Ambali—who had never even 
stepped foot in the United States much less worked in Washington State—was defrauding 
ESD until the day before his arrest last year. 
II. 
PROCEDURAL HISTORY 
On January 25, 2023, the Grand Jury returned a 17-count indictment charging 
Ambali and his co-defendant Fatiu Ismalia Lawal with conspiracy (Count 1), in violation 
of 18 U.S.C. § 1349; wire fraud in connection with a presidentially declared emergency or 
major disaster (Counts 2-11), in violation of 18 U.S.C. §§ 1343 and 2; and aggravated 
identity theft (Counts 12-17), in violation of 18 U.S.C. § 1028A.  Dkt. 1. 
On February 21, 2023, German authorities arrested Ambali pursuant to the warrant 
in this case, and Ambali remained in custody until Germany granted the United States’ 
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United States’ Sentencing Memorandum - 7 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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request to extradite him to this district in July 2023.  Ambali made his initial appearance in 
this district on August 18, 2023, and has been detained since then. 
On December 18, 2023, Ambali pled guilty to Counts 5 (wire fraud) and 15 
(aggravated identity theft). 
III. 
SENTENCING GUIDELINES CALCULATIONS 
The United States agrees with the Probation Office on the Sentencing Guidelines 
calculations and has no objections to the facts contained in the PSR. 
 
The following calculation applies for Count 5 (wire fraud):   
Item  
Guideline 
Adjustment  
Base Offense 
2B1.1(a)(1) 
+7 
Intended Loss in Excess 
of $550,000  
2B1.1(b)(1)(H) 
+14 
10 or More Victims 
2B1.1(b)(2) 
+2 
Sophisticated Means  
2B1.1(b)(10) 
+2 
Disaster Benefits 
2B1.1(b)(12) 
+2 
Acceptance  
3E1.1 
-3 
Zero-Point Offender 
4C1.1 
-2 
Total 
 
22 
See PSR at ¶¶ 29-42. 
 
For Count 15 (aggravated identity theft), the Guideline range is the minimum 
required by statute, two years, which must run consecutive to Count 5.  USSG § 2B1.6; 
see PSR at ¶ 28. 
 
The defendant’s criminal history category is I.  PSR at ¶ 45.  The resulting 
Guidelines range is 41 to 51 months for Count 5 (wire fraud) and a mandatory 
consecutive sentence of 24 months imprisonment for Count 15 (aggravated identity 
theft). 
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United States’ Sentencing Memorandum - 8 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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IV. 
FACTORS RELATED TO SENTENCING RECOMMENDATION 
The United States recommends that the Court impose a total term of imprisonment 
of 60 months.   
For the reasons set forth below, this recommendation is appropriate given “the 
nature and circumstances of the offense,” and the need for the sentence “to reflect the 
seriousness of the offense, to promote respect for the law, and to provide just punishment 
for the offense,” to ensure adequate general deterrence, and “to protect the public from 
further crimes of the defendant.” 18 U.S.C. §§ 3553(a)(1), (a)(2)(A), and (a)(2)(C).   
A. 
The Nature and Circumstances of the Offense—Rufai’s Exploitation of Three 
Disaster Periods in the United States is an Aggravating Factor. 
Because four years have lapsed since the onset of the COVID-19 pandemic, it is 
easy to forget the chaotic, desperate, and dire circumstances facing our nation and our 
government’s attempts to stem the catastrophic economic impact of the first six months of 
the COVID-19 pandemic.  In March 2020, schools, businesses, and restaurants abruptly 
shuttered, and hospitals were overwhelmed with patients dying of COVID-19.1  Yet, 
Ambali saw the pandemic and its consequences not as a public health catastrophe but as an 
opportunity to enrich himself through fraud. 
As Ambali began executing his scheme to use stolen identities of American workers 
to file fraudulent unemployment claims in May 2020, approximately 20.6 million 
American were unemployed, far surpassing the Great Recession’s peak of 15.2 million in 
2009.2  American business owners saw their livelihoods vanish overnight.  In fact, a survey 
in April 2020 showed that 43 percent of small businesses in the nation had at least 
 
1 See, e.g., Ariana Cha, “Faced with a crush of patients, besieged NYC hospitals struggle with life-or-death 
decisions,” The Washington Post (Mar. 31, 2020), available at 
https://www.washingtonpost.com/health/2020/03/31/new-york-city-hospitals-coronavirus/. 
2 U.S. Bureau of Labor Statistics, “Unemployment Rises in 2020, as the country battles the COVID-19 pandemic” 
(June 2021), available at https://www.bls.gov/opub/mlr/2021/article/unemployment-rises-in-2020-as-the-country-
battles-the-covid-19-pandemic.htm.  
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United States’ Sentencing Memorandum - 9 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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temporarily closed, which was unprecedented in our nation’s history and a far more severe 
economic impact than the 1918 influenza.3 
During major disasters and nationwide emergencies, it is particularly important for 
the government to be able to disburse aid quickly to real victims to mitigate the impact of 
the crisis. The actual monetary loss to the government comes secondary to the fact that a 
real person or business behind each stolen identity had difficulty accessing assistance 
because a fraudulent claim was already paid in their identity. These difficulties were 
further compounded by the onslaught of fraudulent claims that clogged the infrastructure 
in place distribute the aid.  The estimated loss from these fraudulent pandemic 
unemployment claims is over $100 billion.4 
 
In this case, Ambali used the stolen identities of over 630 real individuals who may 
have qualified for pandemic assistance and may have needed it urgently.  Ambali’s earliest 
submissions to ESD began within two months of the President’s declaration of a national 
emergency.  By then, ESD had been flooded with imposter claims like Ambali’s, and 
approximately a week after his first submissions, on May 13, 2020, ESD was forced to halt 
all benefit payments to more than a million people for three days.6  Ambali had experience 
using stolen American identities to commit fraud before the pandemic, but this time, his 
criminal conduct contributed to victimizing even people whose identities he did not steal and 
urgently needed assistance that could not be disbursed because of criminals like Ambali. 
Notably, both Congress and the Sentencing Commission have endorsed sentencing 
enhancements during national emergencies and major disasters.  See 18 U.S.C 1343 
(increases maximum penalties to 30 years imprisonment and $1 million fine); USSG § 
 
3 Alexander Bartik, et al., “How Are Small Businesses Adjusting to COVID-19? Early Evidence From a Survey,” 
Nat’l Bureau of Economic Research (Apr. 2020), at 3, 8, available at 
https://www.nber.org/system/files/working_papers/w26989/w26989.pdf.  
4 U.S. Gov’t Accountability Ofc, “More Fraud Has Been Found in Federal COVID Funding – How Much Was Lost 
Under Unemployment Insurance Programs” (Sept. 13, 2023), available at https://www.gao.gov/blog/more-fraud-
has-been-found-federal-covid-funding-how-much-was-lost-under-unemployment-insurance-
programs#:~:text=In%20our%20new%20report%2C%20we,paid%20out%20during%20the%20pandemic.  
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United States’ Sentencing Memorandum - 10 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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2B1.1(b)(2)(12) (two-level increase applied for offenses involving disaster fraud).  
Congress enacted the enhanced statutory penalty for wire (and mail) fraud in response to 
reports of widespread fraud and abuse in connection to disaster funds disbursed for 
Hurricanes Katrina and Rita.  The Senate Judiciary Committee report noted: 
We want to help ensure that federal money goes to the right people and 
does not get stolen by criminals posing as victims. Congress wants to 
provide appropriate recovery and relief resources to affected States, and 
also ensure that these resources are protected and distributed only to the 
real victims–not to individuals seeking to take advantage of the disaster. 
Senate Report No. 110-69, 110th Cong., 1st Session (May 22, 2007). 
 
In this case, there are no circumstances under which Ambali—a Canadian citizen 
and Nigerian citizen—was a real victim.  Rather, he was a criminal seeking to take 
advantage of our nation’s crisis.  
B. 
A Substantial Term of Imprisonment is Necessary to Deter and is Just 
Punishment for the Offense. 
The impact the sentence in this case has on general deterrence cannot be overstated.  
Media in Nigeria and Canada have covered the legal developments in this case.  See, e.g., 
Abby O’Brien, “Toronto men defrauded U.S. government of more than $2M using 
‘thousands’ of stolen identities: investigators,” CP24 (Jan. 4, 2024), available at 
https://www.cp24.com/news/toronto-men-defrauded-u-s-government-of-more-than-2m-
using-thousands-of-stolen-identities-investigators-1.6710612?cache=%2F7.323885.  
Kehinde Folarin, “Two Nigerians risk 32 years in jail for allegedly defrauding US of $25m 
COVID 
benefits,” 
Politics 
Nigeria 
(Aug. 
19, 
2023), 
available 
at 
https://politicsnigeria.com/two-nigerians-risk-32-years-in-jail-for-allegedly-defrauding-
us-of-25m-covid-benefits/.  Additionally, in 2022, the Telegram channel Ambali and his 
co-conpsirator participated followed had over 18,000 subscribers.  See, e.g., Ex. E.     
The evidence in this case confirms that there are thousands of individuals around 
the world will steal American identities to perpetrate fraud against the United States.  When 
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United States’ Sentencing Memorandum - 11 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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those criminals read the sentence imposed on Ambali, it must be substantial enough to 
deter them from further illegal activity and underscore that they are not beyond the reach 
of the United States judicial system.   
Moreover, because it is not a secret that extraterritorial monetary judgments are 
difficult to enforce and Probation will not be able to monitor Ambali’s behavior after 
deportation, a significant term of imprisonment may be the only assured punishment 
available to hold Ambali accountable for exploiting a time of crisis in the United States. 
C. 
A 60-Month Term of Imprisonment Would Be Consistent with Sentences 
Imposed for Similar Conduct. 
The crimes Ambali committed and the circumstances under which he committed 
them are nearly identical to Abidemi Rufai, who was sentenced to 60 months in prison by 
the Honorable Benjamin H. Settle in September 2022.  See United States v. Rufai, Dkt. 56, 
Judgment, CR21-5186-BHS (Sept. 26, 2022).  Like Ambali, Rufai is a Nigerian citizen 
who had a history of committing fraud against the United States prior to the pandemic.  Id., 
Dkt. 54, United States’ Sentencing Memorandum at 6-7.  Like Ambali and his co-
conspirator, Rufai was also in possession of thousands of stolen American identities that 
he primarily used to file fraudulent pandemic unemployment claims but also used to file 
applications for small business assistance and U.S. tax returns seeking refunds.  Id. Dkt. 54 
at 7-9.  Although Rufai had aggravating factors in his history and characteristics because 
he was a Nigerian state official, the number of claims he filed and the amount of loss he 
caused was significantly less than Ambali.  Whereas Rufai filed approximately 238 
fraudulent pandemic unemployment claims and caused a total loss of approximately 
$600,000, Ambali filed over 630 fraudulent pandemic unemployment claims and cause 
dover $1 million in loss. 
Accordingly, sentencing Ambali to 60 months of imprisonment would be 
appropriate and avoid a sentencing disparity with a similarly situated defendant.   
 
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United States’ Sentencing Memorandum - 12 
United States v. Sakiru Ambali, CR23-5034-RJB-02 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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V. 
CONCLUSION 
The Court should sentence Ambali to 60 months of imprisonment and the special 
conditions recommended by Probation, including, upon deportation, prohibiting reentry 
into the United States without permission of the Department of Homeland Security.  The 
Court should further order restitution in the amount of $1,035,107, as agreed upon in the 
Plea Agreement.   
Dated: March 7, 2024 
Respectfully submitted, 
 
TESSA M. GORMAN 
United States Attorney 
 
/s/ Cindy Chang 
 
 
 
CINDY CHANG 
Assistant United States Attorney 
United States Attorney’s Office 
700 Stewart Street, Suite 5220 
Seattle, Washington 98101-1271 
Phone: 206-553-7970 
Fax: 206-553-0582 
Email: Cindy.Chang@usdoj.gov 
 
Case 3:23-cr-05034-RJB   Document 43   Filed 03/07/24   Page 12 of 12

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