Indictment — No. 2:23-cr-20296 (Dkt. 1, E.D. Mich.)

Summary

The indictment filed May 24, 2023 in United States v. Rita Shaba and Samer Kammo, Case 2:23-cr-20296, in the U.S. District Court for the Eastern District of Michigan, citing 18 U.S.C. §§ 2, 371, 1014, 1028(A), 1343, 1344 and 1349. It describes the Paycheck Protection Program under the CARES Act. Count One charges conspiracy to commit wire fraud and bank fraud under 18 U.S.C. § 1349 from around April 2020 through around December 2020. The wire counts list transfers of PPP loan funds, including approximately $557,807.00 for Wireless Plus Cellular, LLC and approximately $561,450 for Queen of the Green on May 28, 2020.

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Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.1 Filed 05/24/23 Page 1 of 22

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Case: 2:23-cr-20296
Plaintiff, Judge: Friedman, Bernard A.
MJ: Patti, Anthony P.
Filed: 05-24-2023
Vv. INDI USA VS SEALED MATTER (DP)

D-1 RITA SHABA, Violations:
D-2 SAMER KAMMO, 18 U.S.C. §§ 2, 371, 1014,
1028(A), 1343, 1344, 1349
Defendants.
/

INDICTMENT

THE GRAND JURY CHARGES:

GENERAL ALLEGATIONS

At times relevant to this Indictment:

Paycheck Protection Program

1. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in or around March 2020 and designed to provide emergency
financial assistance to the millions of Americans who were suffering the economic
effects caused by the COVID-19 pandemic. One source of relief provided by the
CARES Act was the authorization of up to $349 billion in forgivable loans to small

businesses for job retention and certain other expenses, through a program referred

a


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.2 Filed 05/24/23 Page 2 of 22

to as the Paycheck Protection Program (“PPP”). In or around April 2020, Congress
authorized over $300 billion in additional PPP funding.

2. In order to obtain a PPP loan, a qualifying business was required to submit a
PPP loan application, which is signed by an authorized representative of the
business. The PPP loan application requires the business (through its authorized
representative) to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain the PPP loan. In the PPP loan
application, the small business (through its authorized representative) must state,
among other things, its: (a) average monthly payroll expenses; and (b) number of
employees. These figures are used to calculate the amount of money the small
business is eligible to receive under the PPP. In addition, businesses applying for a
PPP loan often provided documentation supporting their purported payroll expenses.
3. A PPP loan application had to be processed by a participating lender. If a PPP
loan application was approved, the participating lender funded the PPP loan using
its own monies, which were generally guaranteed by Smal] Business Administration
(“SBA”). Data from the application, including information about the borrower, the
total amount of the loan, and the listed number of employees, was transmitted by the
lender to the SBA in the course of processing the loan.

4. PPP loan proceeds were required to only be used by the business on certain

permissible expenses—generally payroll costs, interest on mortgages, rent, utilities


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.3 Filed 05/24/23 Page 3 of 22

and other explained business expenses. The PPP allowed the interest and principal
on the PPP loan to be entirely forgiven if the business spent the loan proceeds on
these expense items within a designated period of time after receiving the

proceeds.

5. The Defendants

6. Defendant RITA SHABA (“SHABA”) was a resident of the Eastern District
of Michigan.

7. Defendant SAMER KAMMO (“KAMMO”) was a resident of the Eastern
District of Michigan.

Purpose of the Scheme to Defraud and Obtain

8. The purpose of the scheme to defraud and obtain was for the defendants to
obtain money and enrich themselves by, among other things, inducing financial
institutions and other third-party lenders, through materially false and fraudulent
representations and pretenses, to issue improper PPP loans, and then diverting those

loan proceeds to impermissible uses.

The Scheme to Defraud and Obtain

9. As part of the scheme to defraud and obtain, the defendants caused materially
false and fraudulent representations to be made to financial institutions and other
third-party lenders, including materially false and fraudulent representations relating

to the purported entitlement of various business entities to PPP loan assistance. PPP


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.4 Filed 05/24/23 Page 4 of 22

loan assistance funds issued because of the materially false and fraudulent

representations were then received by the defendants and used for impermissible

purposes.

10. As part of the scheme to defraud and obtain, the defendants caused:

a.

Misrepresentations to be made _ regarding purported payroll
expenditures by various business entities;

Misrepresentations to be made regarding the purported number of
employees of various business entities;

Misrepresentations to be made regarding the purported nature of
business activity for various business entities;

Misrepresentations to be made regarding the purported purpose of PPP
loan requests for various business entities;

False certifications to be made indicating that PPP loan proceeds would
only be used for permissible business-related purposes;

False certifications to be made indicating that various non-operational
business entities were operational and that those entities paid employee
salaries; b

Fictitious payroll records to be created and submitted to financial

institutions and other third-party lenders;


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.5 Filed 05/24/23 Page 5 of 22

h. Fictitious health insurance records to be created and submitted to
financial institutions and other third-party lenders;

i. Fictious bank records to be created and submitted to financial
institutions and other third-party lenders; and

j. Fictitious tax records to be created and submitted to financial
institutions and other third-party lenders.

Interstate Wires

11. In furtherance of the scheme to defraud and obtain, the defendants caused
interstate wire transfers to be made, including interstate wire transfers of PPP

assistance funds.

COUNT ONE

(18 U.S.C. § 1349 — Conspiracy to Commit Wire Fraud and Bank Fraud)
12. The allegations in Paragraphs 1 — 10 are hereby realleged and incorporated by
reference as though fully set forth herein.

13. From at least in or around approximately April 2020, through at least in or
around approximately December 2020, in the Eastern District of Michigan, and

elsewhere, the defendants,

D-1 RITA SHABA
D-2 SAMER KAMMO

r

along with others known and unknown, did knowingly, intentionally, and willfully

combine, conspire, confederate, and agree to commit certain offenses, that is,

5


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.6 Filed 05/24/23 Page 6 of 22

a. to violate Title 18, United States Code, Section 1343, that is, to
knowingly and willfully, and with the intent to defraud, devise and
intend to devise a scheme and artifice to defraud, and for obtaining
money and property by means of materially false and fraudulent
pretenses, representations, and promises, and to knowingly transmit
and cause to be transmitted, by means of wire communications in
interstate commerce, writings, signs, signals, pictures, and sounds,
for the purposes of executing such scheme and artifice.

b. to violate Title 18, United States Code, Section 1344(2), that is to
knowingly execute ascheme and artifice to obtain moneys and funds
under the custody and control of financial institutions whose
deposits were insured by the Federal Deposit Insurance Corporation,
by means of materially false and fraudulent _ pretenses,
representations, and promises.

Object of the Conspiracy
14. The object of the conspiracy was the same as the purpose of the scheme to
defraud and obtain set forth in Paragraph 7 of this Indictment, which is realleged and
incorporated by reference as though fully set forth herein.

ey

“Manner and Means of the Conspiracy


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.7 Filed 05/24/23 Page 7 of 22

15. In furtherance of this conspiracy, and to accomplish its object, the methods,
manner, and means that were used are described in Paragraphs | through 10 of this
Indictment and are realleged and incorporated by reference as though fully set forth

herein.

All in violation of Title 18, United States Code, Section 1349.

COUNTS TWO THROUGH FIVE

(18 U.S.C. §§ 1343 and 2—Wire Fraud)

16. The allegations contained in Paragraphs 1 through 14 are hereby realleged and
incorporated by reference as though fully set forth herein.

17. From at least in or around approximately April 2020, through at least in or
around approximately December 2020, in the Eastern District of Michigan, and
elsewhere, the defendants, as specified below, did knowingly, willfully, and with the
intent to defraud, having devised and intending to devise a scheme and artifice to
defraud, and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and promises, knowing such pretenses,
representations, and promises were false and fraudulent when made, transmit and
cause to be transmitted, by means of wire, radio, and television communication,
writings, signals, pictures, and sounds in interstate and foreign commerce for the

purposes of executing such scheme and artifice.

Purpose of the Scheme and Artifice to Defraud
7


18. The Grand Jury realleges and incorporates by reference Paragraph 7 of this
Indictment as though fully set forth herein as a description of the purpose of the

scheme and artifice.

The Scheme and Artifice to Defraud

19. The Grand Jury realleges and incorporates by reference paragraphs 1 through
10 of this Indictment as though fully set forth herein as a description of the scheme

and artifice.

Use of the Wires

20. On or about the dates specified as to each count below, the specified
defendants, in the Eastern District of Michigan and elsewhere, for the purpose of
executing the aforesaid scheme and artifice to defraud, and attempting to do so, did
knowingly transmit and cause to be transmitted, by means of wire, radio, and
television communication, writings, signals, pictures, and sounds in interstate and

foreign commerce for the purposes of executing such scheme and artifice, as set

forth below:
Count Defendant(s) Approximate Description of Wire
Date Communication
2 RITA SHABA May 28, 2020 Transfer of Approximately
SAMER KAMMO $557,807.00 in PPP Loan Funds
for Wireless Plus Cellular, LLC
3 RITA SHABA May 28, 2020 Transfer of Approximately
$561,450 in PPP Loan Funds for
Queen of the Green


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.9 Filed 05/24/23 Page 9 of 22

4 RITA SHABA June 18, 2020 Transfer of Approximately
SAMER KAMMO $388,542.00 in PPP Loan Funds
for W Shallal LLC
5 RITA SHABA June 25, 2020 Transfer of Approximately
SAMER KAMMO $386,667.50 in PPP Loan Funds
for JD Hydro, LLC

All in violation of Title 18, United States Code, Sections 1343 and 2.

COUNTS SIX THROUGH EIGHT

(18 U.S.C. §§ 1344(2) and (2)—Bank Fraud)

21. Paragraphs 1 through 10 of this Indictment are realleged and incorporated by
reference as though fully set forth herein

22. Onor about the dates specified as to each count below, in the Eastern District
of Michigan and elsewhere, the defendants, as specified below, did knowingly
execute a scheme and artifice to obtain moneys and funds under the custody and
control of, financial institutions, by means of materially false and fraudulent
pretenses, representations, and promises.

Purpose of the Scheme and Artifice to Obtain

23. The grand jury realleges and incorporates by reference Paragraph 7 of this
Indictment as though fully set forth herein as a description of the purpose of the

scheme and artifice.


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.10 Filed 05/24/23 Page 10 of 22

The Scheme and Artifice to Obtain

24. The grand jury realleges and incorporates by reference Paragraphs 1! through

10 of this Indictment as though fully set forth herein as a description of the scheme

and artifice.

Execution of the Scheme and Artifice

25. Onor about the dates specified as to each count below, in the Eastern District
of Michigan, and elsewhere, the defendants did execute, and cause the execution of,
the aforesaid scheme and artifice to obtain monies and funds under the custody and
control of the specified financial institutions, as that term is defined in Title 18,

United States Code, Section 20:

10


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.11 Filed 05/24/23 Page 11 of 22

Count

Defendant(s)

Approximate
Date

Financial
Institution

Description of
Execution

RITA SHABA

SAMER KAMMO

May 2020

Celtic Bank

Submission of
False and
Fraudulent PPP
Application and
Supporting
Documents for
D&H Market, Inc.

RITA SHABA

May 2020

Cross River
Bank

Submission of
False and
Fraudulent PPP
Application and
Supporting
Documents for
Green Gold Rush
LLC

RITA SHABA
SAMER KAMMO

July 2020

First Home
Bank

Submission of
False and
Fraudulent PPP
Application and
Supporting
Documents for
Different Flavors
14355, Inc.

All in violation of Title 18, United States Code, Sections 1344(2) and 2.

11


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.12 Filed 05/24/23 Page 12 of 22

COUNT NINE

(18 U.S.C. § 371—Conspiracy to Commit an Offense Against the United
States)

26. From at least in or around May 2020, through at least in or around December
2020, in the Eastern District of Michigan, and elsewhere, the defendants,

D-1 RITA SHABA
D-2 SAMER KAMMO

knowingly and intentionally conspired and agreed together and with each other and
with other individuals known and unknown to the grand jury to commit an offense
against the United States, that is, a violation of Title 18, United States Code, Section
1014, by knowingly making a false statement to a financial institution the accounts
of which were insured by the Federal Deposit Insurance Corporation, for the purpose
of influencing the action of that institution in connection with a loan.
Object of the Conspiracy
27. The object of the conspiracy was the same as the purpose of the scheme to
defraud set forth in Paragraph 7 of this Indictment, which is realleged and
incorporated by reference as though fully set forth herein.
Manner and Means of the Conspiracy
28. In furtherance of this conspiracy, and to accomplish its object, the methods,

manner, and means that were used are described in Paragraphs | through 10 of this

12


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.13 Filed 05/24/23 Page 13 of 22

Indictment and are realleged and incorporated by reference as though fully set forth
herein.

29. In furtherance of the conspiracy and to effect the objects of the conspiracy,
the following over acts, among others, were committed in the Eastern District of
Michigan and elsewhere:

a. In or about May 2020, in the Eastern District of Michigan, the
defendants caused the submission of false statements to Celtic Bank in
connection with a PPP loan application on behalf of D&H Market, Inc.

b. In or about July 2020, in the Eastern District of Michigan, the
defendants caused the submission of false statements to First Home
Bank in connection with a PPP loan application on behalf of Different
Flavors 14355, Inc.

All in violation of Title 18, United States Code, Section 371.

COUNTS TEN THROUGH TWELVE

(18 U.S.C. §§ 1014 and 2— False Statement in Connection with a Bank Loan)

30. The allegations in Paragraphs 1 through 10 are incorporated into this count by
reference.

31. Onor about the dates specified as to each count below, in the Eastern District
of Michigan, and elsewhere, the defendants, as specified below, did knowingly make

a false statement for the purpose of influencing the specified depository institutions

13


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.14 Filed 05/24/23 Page 14 of 22

with accounts insured by the Federal Deposit Insurance Corporation in connection
with a loan, in that the defendants knowingly prepared and presented to the specified
depository institutions PPP loan applications containing false statements as

described below:

Count | Defendant(s) | Approx. | Financial | Application False
Date | Institution Entity Statements
10 RITA May Celtic D&H False average
SHABA 2020 Bank Market, Inc. | monthly payroll;
false number of
SAMER employees; false
KAMMO applicant name

and signature;
false certification
regarding use of
proceeds; false
supporting tax
records; false
supporting health
insurance
records; false
supporting bank
records
11 RITA May Cross Green Gold False average
SHABA 2020 | River Bank} RushLLC | monthly payroll;
false number of
employees; false
certification
regarding use of
proceeds; false

supporting tax
records
12 RITA July | FirstHome; Different False average
SHABA 2020 Bank Flavors monthly payroll;
14355, Inc. | false number of
SAMER employees; false
KAMMO applicant name

14


Case 2:23-cr-20296-BAF-APP ECF No.1, PagelD.15 Filed 05/24/23 Page 15 of 22

and signature;
false certification
regarding use of

proceeds; false

supporting tax

records; false
supporting bank

records

COUNT THIRTEEN

(18 U.S.C. § § 1028(A) and 2—Aggravated Identity Theft)
32. From at least in or around approximately May 2020, through at least in or
around approximately July 2020, in the Eastern District of Michigan, and elsewhere,

the defendants,

D-1 RITA SHABA
D-2 SAMER KAMMO

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, C.B., during and in relation to a felony violation
enumerated in 18 U.S.C. § 1028(A)(C), to wit, Conspiracy to Commit Wire Fraud
and Bank Fraud (18 U.S.C. § 1349), as alleged in Count One of this Indictment,

knowing that the means of identification belonged to another actual person.

15


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.16 Filed 05/24/23 Page 16 of 22

COUNT FOURTEEN

(18 U.S.C. § § 1028(A) and 2—Aggravated Identity Theft)
33. From at least in or around approximately May 2020, through at least in or
around approximately July 2020, in the Eastern District of Michigan, and elsewhere,
the defendants,

D-1 RITA SHABA
D-2 SAMER KAMMO

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, M.F., during and in relation to a felony violation
enumerated in 18 U.S.C. § 1028(A)(C), to wit, Conspiracy to Commit Wire Fraud
and Bank Fraud(18 U.S.C. § 1349), as alleged in Count One of this Indictment,
knowing that the means of identification belonged to another actual person.

COUNT FIFTEEN

(18 U.S.C. § § 1028(A) and 2—Aggravated Identity Theft)
34. In or around approximately July 2020, in the Eastern District of Michigan,

and elsewhere, the defendants,

D-1 RITA SHABA
D-2 SAMER KAMMO

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, B.A, during and in relation to a felony violation

enumerated in 18 U.S.C. § 1028(A)(C), to wit, Conspiracy to Commit Wire Fraud

16


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.17 Filed 05/24/23 Page 17 of 22

and Bank Fraud (18 U.S.C. § 1349), as alleged in Count One of this Indictment,
knowing that the means of identification belonged to another actual person.

FORFEITURE ALLEGATIONS
18 U.S.C. § 981(a)(1)(C) & 28 U.S.C. § 2461(c), 18 U.S.C. 982(a)(2)

35. The allegations contained in Counts One through Eighteen of this Indictment
are incorporated by reference for the purpose of alleging forfeiture pursuant to the
provisions of 18 U.S.C. 981(a)(1)(C) together with 28 U.S.C. § 2461(c), and 18
U.S.C. § 982(a)(2).

36. As aresult of the violation of 18 U.S.C. § 1349 as set forth in Count One of
this Indictment, the defendants shall forfeit to the United States any property, real or
personal, which constitutes or is derived from proceeds traceable to the offense.

37. Asaresult of the violations of 18 U.S.C. § 1343 and 2 as set forth in Counts
Two through Five of this Indictment, the defendants shall forfeit to the United States
any property, real or personal, which constitutes or is derived from proceeds
traceable to the offense.

38. Asa result of the violations of 18 U.S.C. § 1344(2) and 2, as set forth in
Counts Six through Eight of this Indictment, the defendants shall forfeit to the United
States any property constituting, or derived from, proceeds the person obtained

directly or indirectly, as the result of the offense.

17


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.18 Filed 05/24/23 Page 18 of 22

39. Asaresult of the violation of 18 U.S.C. § 371, as set forth in Count Nine of
this Indictment, the defendants shall forfeit to the United States any property, real or
personal, which constitutes or is derived from proceeds traceable to the offense.
40. As aresult of the violation of 18 U.S.C. § 1014 and 2, as set forth in Count
Ten of this Indictment, the defendants shall forfeit to the United States any property
constituting, or derived from, proceeds the person obtained directly or indirectly, as
the result of the offense.
41. Such property includes, but is not limited to:
a. $8,900.00 U.S. Currency;
b. $9,835.58 in funds from Bank Account Number XXXXX7115 held in
the name of Forever Beauty, LLC at JPMorgan Chase Bank, Clinton
Township, MI;
c. $50,247.23 in funds from Bank Account Number XXXXXX3967 in the
name of Rita A. Shaba at Michigan Schools and Government Credit
Union, Clinton Township, MI;
d. $67,029.74 in funds from Bank Account Number XXXXX0622 in the
name of Slewai S. Allos at JP Morgan Chase, Troy, MI; |
e. $498,027.99 in funds from Bank Account Number XXXXXX9267 in
the name of C&S Detroit Property LLC and/or Samer Kammo and/or

Christina Anasi at Comerica Bank in Macomb, MI;

18


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.19 Filed 05/24/23 Page 19 of 22

f. $205,898.76 in funds from Bank Account Number XXXXXX9259 held
in the name of C & S Liquor and/or Samer Kammo and/or Christina
Anasi at Comerica Bank, Macomb, MI;

g. $761,414.32 in funds from Bank Account Number XXXXX1221 held
in the name of Rita A. Shaba at JPMorgan Chase Bank, Clinton
Township, MI;

h. $74,367.15 in funds from Bank Account Number XXXXX7115 held in
the name of Forever Beauty, LLC at JPMorgan Chase Bank, Clinton
Township, MI;

i. $201,656.48 in funds from Bank Account Number XXXXXX2405 held
in the name of W Shallal LLC DBA Mound Express at Comerica Bank,
Macomb, MI;

j. $55,000.00 in funds from Bank Account Number XXXXXX4936 held
in the name of Christina Anasi, in trust for Samer Kammo at Comerica
Bank, Macomb, MI;

k. $125,500.00 in funds from Bank Account No. XXXXXX5175 in the
name of Christina Anasi, in trust for Samer Kammo at Comerica Bank

in Macomb, MI; and

19


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.20 Filed 05/24/23 Page 20 of 22

1. $53,083.08 in funds from Account No. XXXXX9370 in the name of
Anasi Detroit Property, LLC at JPMorgan Chase in Clinton Township,
MI.
42. Money Judgment: Such property further includes, but is not limited to, a
money judgment in an amount to be determined, representing the proceeds the
defendant obtained as a result of such violation.
43. Substitute Assets: Pursuant to 18 U.S.C. § 853(p), as incorporated by 18
U.S.C. § 982(b), each defendant shall forfeit substitute property, up to the value of
the properties identified for forfeiture, if, by any act or omission of the defendant:
the properties identified for forfeiture cannot be located upon the exercise of due
diligence; have been transferred or sold to, or deposited with, a third party; have
been placed beyond the jurisdiction of the court; have been substantially diminished
in value; or have been commingled with other property which cannot be divided

without difficulty.

20


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.21 Filed 05/24/23 Page 21 of 22

THIS IS A TRUE BILL

s/Grand Jury Foreperson

GRAND JURY FOREPERSON

DAWN N. ISON
United States Attorney

s/John K. Neal

JOHN K. NEAL
Chief, White Collar Crimes

s/Andrew J. Yahkind
ANDREW J. YAHKIND
Assistant U.S. Attorney

Dated: May 24, 2023

21


Case 2:23-cr-20296-BAF-APP ECF No. 1, PagelD.22 Filed 05/24/23 Pagan
(Companion Case information MUST be completed by AUSA and i bit

we

Pane VA

United States District Court Criminal Case Cover Sheet Case Number
Eastern District of Michigan

NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to complete it accurately in all respects.

Companion Case Number:

This may be a companion case based upon LCrR 57.10 (b)(4)': Judge Assigned:

[_] Yes No AUSA’s Initials: AJY

Case Title: USAv. D-1 Rita Shaba, D-2 Samer Kammo

County where offense occurred : Macomb

Check One: (X] Felony LJMisdemeanor L\Petty
Y Indictment/ Information --- no prior complaint.
Indictment/ Information --- based upon prior complaint [Case number: ]
Indictment/ Information --- based upon LCrR 57.10 (d) [Complete Superseding section below].

Superseding to Case No: Judge:

[_]Corrects errors; no additional charges or defendants.
Involves, for plea purposes, different charges or adds counts.
[| _]Embraces same subject matter but adds the additional defendants or charges below:

Defendant Ct Prior Complaint (if applicable!

Please take notice that the below listed Assistant United States Attorney is the attorney of record for
the above captioned case.

5-24-23 s/Andrew J. Yahkind
Date Andrew J. Yahkind

Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, Ml 48226-3277
Phone:(313) 226-9565
Fax: (313) 226-2873
E-Mail address: Andrew. yahkind@usdoj.gov
Attorney Bar #:

1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same
related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases

ven though one of them may have already been terminated.
5/1

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