Plea Agreement & Stipulation of Facts — United States v. Ayaz Qureshi

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. Vv ILED ENTERED P

4:38 pm, Jun 20 2023 _
CLERK, U.S. DISTRICT COURT

United States Attorney DISTRICT OF MARYLAND
District of Maryland BY Cet
Northern Division

Paul A, Riley Mailing Address: Office Location: DIRECT: 410-209-4959

Assistant United States Attorney 36S. Charles Street, 4th Floor 36S. Charles Street, 4th Floor MAIN: 410-209-4800

Paul.Riley@usdoj.gov Baltimore, MD 21201] Baltimore, MD 21201

ITM 06.24.22
September 14, 2022

Thomas J. Maronick Jr., Esq.

Re: United States v. Ayaz Qureshi, Crim.No: KD ~ 22-33 o

Dear Counsel:

This letter, together with the Sealed Supplement, confirms the plea agreement
(this “Agreement”) that has been offered to your client, Ayaz Qureshi (hereinafter “Defendant”),
by the United States Attorney’s Office for the District of Maryland (“this Office”). If the
Defendant accepts this offer, please have the Defendant execute it in the spaces provided below.
If this offer has not been accepted by October 26, 2022, it will be deemed withdrawn. The
terms of the Agreement are as follows:
Offense of Conviction

1. The Defendant agrees to plead guilty to Count One of the Information, which
charges the Defendant with Wire Fraud Conspiracy, in violation of 18 U.S.C. §§ 1349, 1343. The
Defendant admits that the Defendant is, in fact, guilty of the offense and will so advise the Court.

Elements of the Offense

2. The elements of the offense to which the Defendant has agreed to plead guilty, and
which this Office would prove if the case went to trial, are as follows: That on or about the time
alleged in the Information, in the District of Maryland,

Count One (Wire Fraud Conspiracy)

a. Two or more persons, in some way or manner, agreed to try to accomplish a
common and unlawful plan to commit the crime of Wire Fraud, as charged in the Information; and

b. The Defendant knew the unlawful purpose of the plan and willfully joined in it.
Wire Fraud Elements

c. To knowingly devise or intend to devise a scheme or artifice to defraud, or
to obtain money or property by means of false or fraudulent pretenses, representations or promises;

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d. To act with intent to defraud; and

e. That in advancing, furthering, or carrying out the scheme, any writing, signal, or
sound was transmitted by means of a wire, radio, or television communication in interstate
commerce or caused the transmission of any writing, signal, or sound of some kind by means of a
wire, radio, or television communication in interstate commerce.

Penalties

3. The maximum penalties provided by statute for the offense to which the Defendant
is pleading guilty are as follows:

Minimum | Maximum | Supervised | Maximum | Special
Count Statute Prison Prison Release Fine Assessment
18 U.S.C.
1 §§ 1349, N/A 30 years 5 years $1,000,000 $100
1343
a. Prison: If the Court orders a term of imprisonment, the Bureau of Prisons

has sole discretion to designate the institution at which it will be served.

b. Supervised Release: Ifthe Court orders a term of supervised release, and
the Defendant violates the conditions of supervised release, the Court may order the Defendant
returned to custody to serve a term of imprisonment as permitted by statute, followed by an
additional term of supervised release.

c, Restitution: The Court may order the Defendant to pay restitution pursuant
to 18 U.S.C. §§ 3663, 3663A, and 3664.

d. Payment: Ifa fine or restitution is imposed, it shall be payable immediately,
unless the Court orders otherwise under 18 U.S.C. § 3572(d). The Defendant may be required to
pay interest if the fine is not paid when due.

€. Forfeiture: The Court may enter an order of forfeiture of assets directly
traceable to the offense, substitute assets, and/or a money judgment equal to the value of the
property subject to forfeiture.

i Collection of Debts: If the Court imposes a fine or restitution, this Office’s
Financial Litigation Unit will be responsible for collecting the debt. If the Court establishes a
schedule of payments, the Defendant agrees that: (1) the full amount of the fine or restitution is
nonetheless due and owing immediately; (2) the schedule of payments is merely a minimum
schedule of payments and not the only method, nor a limitation on the methods, available to the
United States to enforce the judgment; and (3) the United States may fully employ all powers to
collect on the total amount of the debt as provided by law. Until the debt is paid, the Defendant
agrees to disclose all assets in which the Defendant has any interest or over which the Defendant

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exercises direct or indirect control. Until the money judgment is satisfied, the Defendant
authorizes this Office to obtain a credit report in order to evaluate the Defendant’s ability to pay,
and to request and review the Defendant’s federal and state income tax returns. The Defendant
agrees to complete and sign a copy of IRS Form 8821 (relating to the voluntary disclosure of
federal tax return information) and a financial statement in a form provided by this Office.

‘ Waiver of Rights

4. The Defendant understands that by entering into this Agreement, the Defendant
surrenders certain rights as outlined below:

a. The Defendant has the right to have his case presented to a Grand Jury,
which would decide whether there is probable cause to return an indictment against him. By
agreeing to proceed by way of Information, he is giving up that right, and understands that the
charges will be filed by the United States Attorney without the Grand Jury.

b. If the Defendant had pled not guilty and persisted in that plea, the Defendant
would have had the right to a speedy jury trial with the close assistance of competent counsel.
That trial could be conducted by a judge, without a jury, if the Defendant, this Office, and the
Court all agreed.

1G: If the Defendant elected a jury trial, the jury would be composed of twelve

. individuals selected from the community. Counsel and the Defendant would have the opportunity

to challenge prospective jurors who demonstrated bias or who were otherwise unqualified, and

would have the opportunity to strike a certain number of jurors peremptorily. All twelve jurors

would have to agree unanimously before the Defendant could be found guilty of any count. The

jury would be instructed that the Defendant was presumed to be innocent, and that presumption
could be overcome only by proof beyond a reasonable doubt.

d. If the Defendant went to trial, the Government would have the burden of
proving the Defendant guilty beyond a reasonable doubt. The Defendant would have the right to
confront and cross-examine the Government’s witnesses. The Defendant would not have to
present any defense witnesses or evidence whatsoever. If the Defendant wanted to call witnesses
in defense, however, the Defendant would have the subpoena power of the Court to compel the.

witnesses to attend.

6. The Defendant would have the right to testify in the Defendant’s own
defense if the Defendant so chose, and the Defendant would have the right to refuse to testify. If
the Defendant chose not to testify, the Court could instruct the jury that they could not draw any
adverse inference from the Defendant’s decision not to testify.

f. If the Defendant were found guilty after a trial, the Defendant would have
the right to appeal the verdict and the Court’s pretrial and trial decisions on the admissibility of
evidence to see if any errors were committed which would require a new trial or dismissal of the
charges. By pleading guilty, the Defendant knowingly gives up the right to appeal the verdict and
the Court’s decisions.

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g. By pleading guilty, the Defendant will be giving up all of these rights,
except the right, under the limited circumstances set forth in the “Waiver of Appeal” paragraph
below, to appeal the sentence. By pleading guilty, the Defendant understands that the Defendant
may have to answer the Court’s questions both about the rights being given up and about the facts
of the case. Any statements that the Defendant makes during such a hearing would not be
admissible against the Defendant during a trial except in a criminal proceeding for perjury or false
statement.

h. If the Court accepts the Defendant’s plea of guilty, the Defendant will be
giving up the right to file and have the Court rule on pretrial motions, and there will be no further
trial or proceeding of any kind in the above-referenced criminal case, and the Court will find the
Defendant guilty.

i, By pleading guilty, the Defendant will also be giving up certain valuable
civil rights and may be subject to deportation or other loss of immigration status, including possible
denaturalization. The Defendant recognizes that if the Defendant is not a citizen of the United
States, or is a naturalized citizen, pleading guilty may have consequences with respect to the
Defendant’s immigration status. Under federal law, conviction for a broad range of crimes can
lead to adverse immigration consequences, including automatic removal from the United States.
Removal and other immigration consequences are the subject of a separate proceeding, however,
and the Defendant understands that no one, including the Defendant’s attomey or the Court, can
predict with certainty the effect of a conviction on immigration status. The Defendant is not
relying on any promise or belief about the immigration consequences of pleading guilty. The
Defendant nevertheless affirms that the Defendant wants to plead guilty regardless of any potential
immigration consequences.

Advisory Sentencing Guidelines Apply

5. The Defendant understands that the Court will determine a sentencing guidelines
range for this case (henceforth the “advisory guidelines range”) pursuant to the Sentencing Reform
Act of 1984 at 18 U.S.C. § 3551-3742 (excepting 18 U.S.C. § 3553(b)(1) and 3742(e)) and 28
US.C. §§ 991 through 998. The Defendant further understands that the Court will impose a
sentence pursuant to the Sentencing Reform Act, as excised, and must take into account the
advisory guidelines range in establishing a reasonable sentence.

Factual and Advisory Guidelines Stipulation

6. This Office and the Defendant stipulate and agree to the Statement of Facts set forth
in Attachment A, which is incorporated by reference herein.

Count One

a, This Office and the Defendant further agree that the applicable base offense
level is 7 (seven) pursuant to United States Sentencing Guidelines (“USSG”) § 2B1.1(a)(1).

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b. This Office and the Defendant further agree that there is a 12 (twelve) level
increase pursuant to USSG §2B1.1(b)(1)(G) because the loss amount was more than $250,000 but
less than $550,000.

C. This Office does not oppose a 2 (two) level reduction in the Defendant’s
adjusted offense level pursuant to USSG §3E1.1(a), based upon the Defendant’s apparent prompt
recognition and affirmative acceptance of personal responsibility for the Defendant’s criminal
conduct. This Office agrees to make a motion pursuant to USSG §3E1.1(b) for an additional one
level decrease in recognition of the Defendant’s timely notification of the Defendants intention to
enter a plea of guilty. This Office may oppose any adjustment for acceptance of responsibility
under USSG §3E1.1(a) and may decline to make a motion pursuant to USSG §3E1.1(b), if the
Defendant: (i) fails to admit each and every item in the factual stipulation; (ii) denies involvement
in the offense; (iii) gives conflicting statements about the Defendant’s involvement in the offense;
(iv) is untruthful with the Court, this Office, or the United States Probation Office; (v) obstructs
or attempts to obstruct justice prior to sentencing; (vi) engages in any criminal conduct between
the date of this Agreement and the date of sentencing; (vii) attempts to withdraw the plea of guilty;
or (viii) violates this Agreement in any way.

d. Thus, the final anticipated adjusted offense level 16.

ds There is no agreement as to the Defendant’s criminal history and the Defendant
understands that the Defendant’s criminal history could alter the Defendant’s offense level.
Specifically, the Defendant understands that the Defendant’s criminal history could alter the final
offense level if the Defendant is determined to be a career offender or if the instant offense was a
part of a pattern of criminal conduct from which the Defendant derived a substantial portion of the
Defendant’s income.

8. Other than as set forth above, no other offense characteristics, sentencing guidelines
factors, potential departures or adjustments set forth in the United States Sentencing Guidelines
are in dispute or will be raised in calculating the advisory guidelines range.

Obligations of the Parties

9. At the time of sentencing, this Office and the Defendant reserve the right to
advocate for a reasonable sentence, period of supervised release, and/or fine considering any
appropriate factors under 18 U.S.C. § 3553(a). This Office and the Defendant reserve the right to
bring to the Court’s attention all information with respect to the Defendant’s background,
character, and conduct that this Office or the Defendant deem relevant to sentencing, including the
conduct that is the subject of any counts of the Information. At the time of sentencing, this Office

will move to dismiss any open counts against the Defendant.

Waiver of Appeal

10. In exchange for the concessions made by this Office and the Defendant in this
Agreement, this Office and the Defendant waive their rights to appeal as follows:

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a. The Defendant knowingly waives all right, pursuant to 28 U.S.C. § 1291 or
any other statute or constitutional provision, to appeal the Defendant’s conviction on any ground
whatsoever. This includes a waiver of all right to appeal the Defendant’s conviction on the ground
that the statute(s) to which the Defendant is pleading guilty is unconstitutional, or on the ground
that the admitted conduct does not fall within the scope of the statute(s), to the extent that such
challenges legally can be waived.

b. | The Defendant and this Office knowingly and expressly waive all rights
conferred by 18 U.S.C. § 3742 to appeal whatever sentence is imposed (including any term of
imprisonment, fine, term of supervised release, or order of restitution) for any reason (including
the establishment of the advisory sentencing guidelines range, the determination of the
Defendant’s criminal history, the weighing of the sentencing factors, and any constitutional
challenges to the calculation and imposition of any term of imprisonment, fine, order of forfeiture,
order of restitution, and term or condition of supervised release), except as follows:

i, The Defendant reserves the right to appeal any sentence that exceeds |
the statutory maximum; and

ii. This Office reserves the right to appeal any sentence below a
statutory minimum.

on The Defendant waives any and all rights under the Freedom of Information
Act relating to the investigation and prosecution of the above-captioned matter and agrees not to
file any request for documents from this Office or any investigating agency.

Forfeiture

11. The Defendant understands that the Court may enter an Order of Forfeiture as part
of the Defendant’s sentence, and that the Order of Forfeiture may include assets directly traceable
to the offense(s), substitute assets, and/or a money judgment equal to the value of the property
derived from, or otherwise involved in, the offenses.

12. Specifically, but without limitation on the Government’s right to forfeit all property
subject to forfeiture as permitted by law, the Defendant agrees to forfeit to the United States all of
the Defendant’s right, title, and interest in the following items that the Defendant agrees constitute
money, property, and/or assets derived from or obtained by the Defendant as a result of, or used
to facilitate the commission of, the Defendant’s illegal activities: a money judgment in the amount
of $250,723.00 in U.S. currency.

13. The Defendant agrees to consent to the entry of orders of forfeiture for the property
described herein and waives the requirements of Federal Rules of Criminal Procedure 11(b)(1)(J),
32.2, and 43(a) regarding notice of the forfeiture in the charging instrument, advice regarding
forfeiture during the change of plea hearing, announcement of the forfeiture at sentencing, and
incorporation of the forfeiture in the judgment.

14. The Defendant agrees to assist fully in the forfeiture of the above property. The
Defendant agrees to disclose all assets and sources of income, to consent to all requests for access

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to information related to assets and income, and to take all steps necessary to pass clear title to the
forfeited assets to the United States, including executing all documents necessary to transfer such
title, assisting in bringing any assets located outside of the United States within the jurisdiction of
the United States, and taking whatever steps are necessary to ensure that assets subject to forfeiture
are made available for forfeiture. .

15. The Defendant waives all challenges to any forfeiture carried out in accordance
with this Agreement on any grounds, including any and all constitutional, legal, equitable,
statutory, or administrative grounds brought by any means, including through direct appeal, habeas
corpus petition, or civil complaint. The Defendant will not challenge or seek review of any civil
or administrative forfeiture of any property subject to forfeiture under this Agreement, and will
not assist any third party with any challenge or review or any petition for remission of forfeiture.

Collection of Financial Obligations

16. The Defendant expressly authorizes the U.S. Attomey’s Office to obtain a credit
report in order to evaluate the Defendant’s ability to satisfy any financial obligation imposed by
the Court. If restitution is not paid by the date of sentencing, in order to facilitate the collection
of financial obligations to be imposed in connection with this prosecution, the Defendant agrees
to disclose fully all assets in which the Defendant has any interest or over which the Defendant
exercises control, directly or indirectly, including those held by a spouse, nominee or other third
- party. If restitution is not paid by the date of sentencing, the Defendant will promptly submit a
completed financial statement to the United States Attorney’s Office, in a form this Office
prescribes and as it directs. The Defendant promises that any financial statement and disclosures
the Defendant submits will be complete, accurate and truthful, and understands that any willful
falsehood on the financial statement will be a separate crime and may be punished under 18
U.S.C.§ 1001 by an additional five years’ incarceration and fine.

Defendant’s Conduct Prior to Sentencing and Breach

17. Between now and the date of the sentencing, the Defendant will not engage in
conduct that constitutes obstruction of justice under U.S.S.G. § 3C1.1; will not violate any federal,
state, or local law; will acknowledge guilt to the probation officer and the Court; will be truthful
in any statement to the Court, this Office, law enforcement agents, and probation officers; will
cooperate in the preparation of the presentence report; and will not move to withdraw from the
plea of guilty or from this Agreement.

18. If the Defendant engages in conduct prior to sentencing that violates the above
paragraph of this Agreement, and the Court finds a violation by a preponderance of the evidence,
then: (i) this Office will be free from its obligations under this Agreement; (ii) this Office may
make sentencing arguments and recommendations different from those set out in this Agreement,
even if the Agreement was reached pursuant to Rule 11(c)(1)(C); and (iii) in any criminal or civil
proceeding, this Office will be free to use against the Defendant all statements made by the
Defendant and any of the information or materials provided by the Defendant, including
statements, information, and materials provided pursuant to this Agreement, and statements made
during proceedings before the Court pursuant to Rule 11 of the Federal Rules of Criminal
Procedure. A determination that this Office is released from its obligations under this Agreement

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will not permit the Defendant to withdraw the guilty plea. The Defendant acknowledges that the
Defendant may not withdraw the Defendant’s guilty plea—even if made pursuant to Rule
11(c)(1)(C)—if the Court finds that the Defendant breached the Agreement. In that event, neither
the Court nor the Government will be bound by the specific sentence or sentencing range agreed
and stipulated to herein pursuant to Rule 11(c)(1)(C).

Restitution

19. The Defendant agrees to the entry of a restitution order for the full amount of the
victims’ losses. The Defendant’ agrees that, pursuant to 18 US.C. §§ 3663 and 3663A and
3563(b)(2) and 3583(d), the Court may order restitution of the full amount of the actual, total loss
caused by the offense conduct set forth in the factual stipulation. The total amount of restitution
shall be due immediately and shall be ordered to be paid forthwith. Any payment schedule
imposed by the Court establishes only a minimum obligation. Defendant will make a good
faith effort to pay any restitution, Regardless of Defendant’s compliance, any payment
schedule does not limit the United States’ ability to collect additional amounts from Defendant
through all available collection remedies at any time. The Defendant further agrees that the
Defendant will fully disclose to this Office, the probation officer, and to the Court, subject to the
penalty of perjury, all information (including but not limited to copies of all relevant bank
and financial records) regarding the current location and prior disposition of all funds
obtained as a result of the criminal conduct set forth in the factual stipulation. The
Defendant further agrees to take all reasonable steps to retrieve or repatriate any such funds and
to make them available for restitution. If the Defendant does not fulfill this provision, it will
be considered a material breach of this Agreement, and this Office may seek to be relieved of its
obligations under this Agreement.

Court Not a Party

20. The Court is not a party to this Agreement. The sentence to be imposed is within
the sole discretion of the Court. The Court is not bound by the Sentencing Guidelines stipulation
in this Agreement. The Court will determine the facts relevant to sentencing. The Court is not
required to accept any recommendation or stipulation of the parties. The Court has the power to
impose a sentence up to the maximum penalty allowed by law. If the Court makes sentencing
findings different from those stipulated in this Agreement, or if the Court imposes any sentence up
to the maximum allowed by statute, the Defendant will remain bound to fulfill all of the obligations
under this Agreement. Neither the prosecutor, defense counsel, nor the Court can make a binding
prediction, promise, or representation as to what guidelines range or sentence the Defendant will
receive, The Defendant agrees that no one has made such a binding prediction or promise.

Entire Agreement

21. This letter, together with the Sealed Supplement, constitutes the complete plea
agreement in this case. This letter, together with the Sealed Supplement, supersedes any prior
understandings, promises, or conditions between this Office and the Defendant, There are no other
agreements, promises, undertakings, or understandings between the Defendant and this Office
other than those set forth in this letter and the Sealed Supplement, No changes to this Agreement
will be effective unless in writing, signed by all parties and approved by the Court.

Rev. August 2018
If the Defendant fully accepts each and every term and condition of this Agreement, please
sign and have the Defendant sign the original and return it to me promptly.

Very truly yours,

Erek L. Barron
United States Attorm

Paul A. Riley ‘
Abigail E. Ticse
Assistant United States Attorneys

Ihave read this Agreement, including the Sealed Supplement, and carefully reviewed every
part of it with my attorney. I understand it and I voluntarily agree to it. Specifically, I have
reviewed the Factual and Advisory Guidelines Stipulation with my attorney and I do not wish to
change any part of it. I am completely satisfied with the representation of my attorney.

Date Jo-/ Y- 2 4. | EVA shi

I am the Defendant’s attorney. I have carefully reviewed every part of this Agreement,
including the Sealed Supplement with the Defendant. The Defendant advises me that the
Defendant understands and accepts its terms. To my knowledge, the Defendant’s decision to enter
into this Agreement is an informed and voluntary one.

i

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ATTACHMENT A
STIPULATION OF FACTS

The undersigned parties stipulate and agree that if this case had proceeded to trial, this
Office would have proven the following facts beyond a reasonable doubt. The undersigned parties
also stipulate and agree that the following facts do not encompass all of the evidence that would
have been presented had this matter proceeded to trial.

Defendant Ayaz Qureshi, born June 1969, is a resident of Severna Park, Maryland.
Beginning in March 2021 and continuing through December 2021 in the District of Maryland,
Defendant and his co-conspirator A.S. conspired together and engaged in a scheme to defraud a
financial institution, Bank 1, to obtain 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 enacted in or around March 2020. Ultimately, Qureshi
fraudulently obtained $250,723 as part of this scheme. His offense is described in more detail
below.

PPP Application and Kickback Payments

On March 14, 2021, A.S., with the assistance of Qureshi, submitted a fraudulent PPP loan
application to Bank 1 for Yazee, Inc., a purported business for which Qureshi was the President.
Yazee, Inc. had no employees at the time and was not operating in any legitimate capacity.

The PPP loan application contained multiple material misrepresentations, including that
Yazee, Inc. had 16 employees and an average monthly payroll of $100,289. In support of the loan
application, a fabricated IRS Form 940—Employer’s Annual Federal Unemployment Tax
Return—was submitted, which falsely indicated that Yazee, Inc.’s “[t]otal payments to all
employees” in 2019 was $1,203,471.52. The IRS Form 940 was not legitimate, and the information
within it was false; Yazee, Inc. did not pay any wages to or withhold federal income tax from any
employees during the 2019 tax year.

Additionally, Qureshi gave A.S. documents to be submitted with the PPP loan application,
including photographs of his driver’s license, and a voided check and bank statement from a Wells
Fargo bank account in the name of Yazee, Inc. and controlled by Qureshi.

Based on the false representations and fraudulent submissions made on behalf of Qureshi
as the owner of Yazee, Inc., on March 22, 2021, the PPP loan funded, and approximately
$250,723.00 was distributed by Bank 1 to the Wells Fargo account referenced above.

Qureshi agreed to pay A.S. a kickback for his work in submitting the false application and
obtaining the fraudulent loan. After the PPP loan funds were received by Qureshi, he provided
A.S. with eight checks totaling $75,000, or approximately 30 percent of the PPP loan. On each of
those checks, Qureshi wrote the amount, but left the payee name blank. A.S. and others ultimately
wrote a payee name on each of those checks, deposited the checks, and $75,000—directly traceable
to the fraudulent PPP loan funds—was ultimately drawn on the Wells Fargo account in the name
of Yazee, Inc. and controlled by Qureshi.

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Establishment of Payroll for Purported Employees

Proceeds from a PPP loan were required to be used only for certain permissible business
expenses, including payroll costs, mortgage interest, rent, and utilities. Qureshi and A.S. were
aware that, under the applicable PPP rules, interest and principal on a legitimate PPP loan were
eligible for forgiveness, if the business spent the loan proceeds on permissible items within a
designated period of time and used a certain portion of the loan toward payroll expenses.

Accordingly, in an attempt to make it appear that the PPP loan funds were being used for
legitimate purposes, on June 22, 2021, Qureshi, at the suggestion of A.S., signed an agreement
with Payroll Processor 1 to provide payroll services to purported employees of Yazee, Inc.
Pursuant to the agreement, and at the direction of Qureshi, Payroll Processor 1 withdrew funds
from the Wells Fargo account referenced above, and made payments using the PPP funds to
purported employees of Yazee, Inc., including Qureshi, his wife, and his other associates.

In total, $144,647.21 in sham payroll payments were made using funds traceable to the
PPP loan obtained by Qureshi and his purported business. None of the purported employees were
in fact legitimately employed by Yazee, Inc. In connection with the scheme, Qureshi engaged in
email correspondence with Payroll Processor 1 concerning purported employees to be added and
removed from the payroll and spoke with employees of Payroll Processor 1 on the phone as well.

Qureshi made no payments to Bank 1 in connection with the PPP loan obtained for Yazee,
Inc., and the loan was ultimately forgiven.

Qureshi and A.S. executed the fraud scheme discussed herein, in part, through the use of
mobile phones, the internet, multiple email accounts, and bank deposits and transfers, all of which
used interstate wires, and Qureshi was in Maryland when he transmitted wires to execute his

scheme.

SO STIPULATED: | VWI

Paul A. Riley *
Assistant United States Attorney. - - -

Ayaz Qureshi F 7)

Thomas J. Maronick, BSG.

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