Bill of Indictment — United States v. Izzat Freitekh and Tarik Freitekh (Dkt. 3, W.D.N.C.)
Summary
A grand jury in the Western District of North Carolina charged Izzat Freitekh and Tarik Freitekh with conspiracy to commit wire fraud and with bank fraud over Paycheck Protection Program loans, and Izzat Freitekh alone with false statements, in a bill of indictment filed December 16, 2020. It alleges PPP applications for Green Apple Catering LLC, Aroma Packaging Systems, La Shish Catering and La Shish Kabob that overstated payroll and attached IRS Forms 940 and 941 that were never filed. Bank 1 disbursed $1 million to Green Apple on or about May 14, 2020, on an application claiming an average monthly payroll of $400,000; the account had held approximately $48.25 on May 1, 2020. Aroma Packaging and La Shish Catering each received $300,000, and La Shish Kabob $150,000. The forfeiture notice seeks at least $1,750,000 and seized funds including approximately $977,607.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
FILED
UN CHARLOTTE, NC
DEC 1 6 2020
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA us DISTRICT COURT
CHARLOTTE DIVISION WESTERN DISTRICT OF NC
UNITED STATES of AMERICA, ) 18 U.S.C. § 1349
) 18 u.s.c. § 1343
v. ) 18 U.S.C. § 1344(1) and (2)
) 18 U.S.C. § 1001
(1) IZZAT FREITEKH and ) 18 u.s.c. § 2
(2) T ARIK FREITEKH )
a/k/a Tareq Freitekh ) 3 .'10 L\2Jlt3S:;'
)
THE GRAND JURY CHARGES:
At all times relevant to this Indictment:
Background
Defendant and Related Entities and Individuals
1. IZZAT FREITEKH was a resident of the Western District of North Carolina.
2. TARIK FREITEKH, also ]mown as Tareq Freitekh, was the son of IZZAT
FREITEKH and a resident of California.
3. Individual A was married to IZZAT FREITEKH and was a resident of the Western
District of North Carolina.
4. Bank 1 was a federally insured financial institution headquartered in Charlotte, North
Carolina within the Western District of North Carolina. Bank 2 was a federally insured financial
institution that was a subsidiary of a bank holding company located in Wyomissing, Pennsylvania.
5. Green Apple Catering LLC (hereinafter, "Green Apple") was a limited liability
corporation formed in the State ofNorth Carolina on or about March 18, 2020. IZZAT FREITEKH
was the company's registered agent.
6. Aroma Packaging Systems (hereinafter, "Aroma Packaging") was a sole
proprietorship. IZZAT FREITEKH identified himself on bank records as the purported owner of
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Aroma Packaging.
7. La Shish Catering was a sole proprietorship. IZZAT FREITEKH identified himself
on bank records as the purported owner of La Shish Catering.
8. La Shish Kabob Restaurant was a restaurant located in Charlotte, No1ih Carolina,
within the Western District of North Carolina. IZZAT FREITEKH and Individual A were the
owners of La Shish Kabob Restaurant. At various times, La Shish Kabob was the business name
used by IMS Food and Restaurants, LLC.
9. FinTech 1 was a financial technology company based in Florida and New Jersey.
FinTech 1 was a Merchant Cash Advance (MCA) company that provided assistance to small
businesses seeking funding, including the businesses owned by IZZAT FREITEKH.
10. FinTech 2 was a financial technology company based in Utah that matched
businesses seeking funding with financing opportunities, including opportunities through the
Paycheck Protection Program.
Tlte Paycheck Protection Program
11. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal
law enacted in or around March 2020 designed to provide emergency financial assistance to the
millions of Americans suffering the economic effects caused by the COVID-19 pandemic. One
source of relief provided by the CARES Act was the authorization of forgivable loans to small
businesses for job retention and ce1iain other expenses, through a program referred to as the
Paycheck Protection Program ("PPP").
12. In order to obtain a PPP loan, a qualifying business submitted a PPP loan application,
which was signed by an authorized representative of the business. The PPP loan application
required the business (through its authorized representative) to acknowledge the program rules and
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make certain affirmative certifications in order to be eligible to obtain the PPP loan. In the PPP
loan application (Small Business Administration ("SBA") Form 2483), the small business (through
its authorized representative) was required to provide, among other things, its: (a) average monthly
payroll expenses; and (b) number of employees. These figures were used to calculate the amount
of money the small business was eligible to receive under the PPP. In addition, businesses
applying for a PPP loan were required to provide documentation showing their payroll expenses.
13. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
While the lender issued the PPP loan, the SBA provided a guarantee that the financial institution
would be reimbursed. Data from the application, including info1mation about the bon·ower, 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.
14. PPP loan proceeds were required to be used by the business on certain permissible
expenses such as payroll costs, interest on mortgages, rent, and utilities. 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 and used a defined portion of the PPP
loan proceeds on payroll expenses.
Overview of the Fraud
15. As described further below, beginning on or about March 17, 2020, IZZAT
FREITEKH and TARUC FREITEKH submitted, and caused to be submitted, fraudulent loan
applications to Bank 1 and FinTech 1 in order to obtain funds through PPP.
16. After receiving the PPP loan proceeds, IZZAT FREITEKH and TARIK FREITEKH
used the funds for improper expenses and caused the funds to be tr·ansferred among various bank
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accounts in the name ofIZZAT FREITEKH and associated entities.
Purpose of the Conspiracy
17. It was the purpose of the scheme for IZZAT FREITEKH and T ARIK FREITEKH to
unjustly emich themselves and others by obtaining PPP loan proceeds under false and misleading
pretenses, including by making false statements about the number of employees and by providing
false documentation.
Manner and Means
The Green Apple PPP Application
18. Banlc 1 accepted PPP applications through an electronic p01ial which applicants used
to upload documents and information. On or about May 1, 2020, an application for a $1 million
PPP loan for Green Apple was transmitted tln·ough Bank 1's electronic portal. The application
represented that Green Apple had an average monthly payroll of $400,000.
19. As paii of the application, IZZAT FREITEKH electronically signed, or caused to be
signed, an Application Addendum on which he identified himself as Green Apple's authorized
representative. The Application ce1iified that "the applicant was in operation on Febrnary 15, 2020
and had employees for whom it paid salaries and payroll taxes or paid independent contractors, as
reported on Forms 1099-MISC."
20. IZZAT FREITEKH signed, or caused to be signed, a Bank 1 promissory note, which
attested: "Borrower certifies that the information provided in the Application and the inf01mation
that Borrower provided in all supp01iing documents and forms is true and accurate in all material
respects. Borrower aclmowledges that lmowingly making a false statement to obtain a guaranteed
loan from SBA is punishable under the law, including under 18 USC 1001 and 3571."
21. The Green Apple PPP application included false and fraudulent information about
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its purported payroll, as well as fraudulent documentation purporting to establish that Green Apple
made substantial monthly payroll disbursements.
a. The Green Apple PPP application included a document entitled "Green
Apple Catering Payroll Smmnary 2019," which represented that Green Apple had an Employer
Identification Number (EIN) of xx-xxx7219. The docmnent provided that Green Apple disbursed
$4,800,000 in "gross pay" in 2019 to 23 employees. The document further represented that Green
Apple took the following deductions in 2019: $1,740,320.50 for federal tax; $275,568.75 for
North Carolina State Tax; and $128,400 for Social Security. In fact, Green Apple did not receive
its EIN until March 17, 2020. Moreover, at the time the PPP application was submitted to Bank
1, neither Green Apple nor IZZAT FREITEKH had filed federal taxes with the Internal Revenue
Service ("IRS") for tax year 2019.
b. The Green Apple PPP application included an IRS Form 940 electronically
signed by IZZAT FREITEKH purporting to show that, in 2019, Green Apple made $4,800,000
in payments to employees. In fact, no such Form 940 was ever filed with the IRS on behalf of
Green Apple.
c. The Green Apple PPP application included an IRS Form 941 electronically
signed by IZZAT FREITEKH purporting to show that Green Apple paid $1,200,000 in wages to
employees during the first quarter of 2020. In fact, no such Form 941 was ever filed with the IRS
on behalf of Green Apple.
22. On or about May 14, 2020, Bank 1 funded the loan by disbursing $1 million to Ban!,
1 checking account x-1388 for Green Apple ("the Green Apple Account"). Account opening
documents for the Green Apple Account were submitted to Ban!, 1 on or about March 18, 2020.
IZZAT FREITEKH was listed as the sole authorized person on the account opening documents.
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As of May 1, 2020, prior to the receipt of the PPP loan funds, the Green Apple Account had a
balance of approximately $48.25.
23. On or about May 14, 2020, a tax preparer sent a message to the email account for
TARIK FREITEKH (hereinafter, "the TARIK FREITEKH Email Account") stating, in relevant
part, "Greetings Tarik! It was a pleasure working with you. Please provide the breakdown for
Green Apple with 23 employees and monthly payroll $400,000." The TARIK FREITEKH Email
Account responded with a list of salaries for the various positions at Green Apple.
24. On or about May 16, 2020, the TARIK FREITEKH Email Account sent a message
to the tax preparer regarding Green Apple. The message stated, in relevant part, "I just spoke with
the company that is preparing our loan applications. They informed me that [t]he SBA just
released an 11 page application for the loan forgiveness." In addition, the message contained a list
of salaries for various positions at Green Apple.
25. On or about May 30, 2020, the email account for IZZAT FREITEKH (hereinafter,
"the IZZAT FREITEKH Email Account") forwarded a message to the TARIK FREITEKH Email
Account. The message contained "important tax information for GREEN APPLE LLC" and
provided infonnation for accessing tax forms electronically.
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The Aroma Packaging PPP Application
26. On or about April 22, 2020, an application for a $380,000 PPP loan was submitted
to FinTech 2. The application was never finalized or funded.
27. On or about April 30, 2020, an application for a $350,000 PPP loan for Aroma
Packaging was transmitted through Bank l's electronic portal. The application represented that
Aroma Packaging had an average monthly payroll of $120,000.
28. As part of the application, IZZAT FREITEKH electronically signed, or caused to be
signed, an Application Addendum, on which he identified himself as Aroma Packaging's
authorized representative. The Application Addendum certified that "the applicant was in
operation on February 15, 2020 and had employees for whom it paid salaries and payroll taxes or
paid independent contractors, as reported on Forms 1099-MISC."
29. IZZAT FREITEKH signed, or caused to be signed, a Bank 1 promissory note, which
attested: "Borrower ce1iifies that the information provided in the Application and the information
that Bonower provided in all supporting documents and forms is true and accurate in all material
respects. Borrower acknowledges that knowingly making a false statement to obtain a guaranteed
loan from SBA is punishable under the law, including under 18 USC 1001 and 3571."
30. The Aroma Packaging PPP application included false and fraudulent information
about its purported payroll, as well as fraudulent documentation purpmiing to establish that Aroma
Packaging made substantial monthly payroll disbursements.
a. The Aroma Packaging PPP application included a document entitled "2019
Payroll Processor Records," which represented that Aroma Packaging disbursed $1,440,000 in
"gross salaries" to 11 employees in 2019. The document further represented that Aroma
Packaging took the following deductions in 2019: $512,750.30 for federal tax; $82,800 for North
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Carolina State Tax; and $89,280 for Social Security. In fact, Aroma Packaging never filed federal
taxes with the IRS for tax year 2019.
b. The Aroma Packaging PPP application included an IRS Fonn 940
electronically signed by IZZAT FREITEKH purporting to show that in 2019 Aroma Packaging
made $1,440,000 in payments to employees. In fact, no such Form 940 was ever filed with the
IRS on behalf of Aroma Packaging.
c. The Aroma Packaging PPP application included an IRS Form 941
electronically signed by IZZAT FREITEKH purporting to show that Aroma Packaging paid
$360,000 in wages during the first quatier of 2020. In fact, no such Form 941 was ever filed with
the IRS on behalf of Aroma Packaging.
31. On or about May 6, 2020, Bank 1 funded the loan by disbursing $300,000 to Bank 1
account x-4239 in the name of IZZAT FREITEKH Sole Prop DBA Aroma Packaging Systems
(the "Aroma Account"). IZZAT FREITEKH and TARIK FREITEKH were listed among the five
authorized persons for the Aroma Account. As of May 1, 2020, prior to the receipt of the PPP
funds, the Aroma Account had a balance of $200.14.
32. On or about May 13, 2020, the TARlK FREITEKH Email Account received a
message from the tax preparer verifying the spelling for Green Apple, Aroma Packaging, and La
Shish Catering. On or about May 14, 2020, the T ARlK FREITEKH Email Account replied to that
message, stating, in relevant pati, "I just wanted to check if all is going well regarding the tln·ee
companies filing. Thank you. Kind Regards, Tarik Freitekh."
33. Following the receipt of the PPP funds in the Aroma Account, multiple large
transfers were made from the Aroma Account to other accounts in the name ofIZZAT FREITEKH
and associated entities, including the following transfers on or about May 7, 2020:
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a. Approximately $150,000 to Bank 1 checking account x-5182 in the name ofIZZAT
FREITEKH;
b. Approximately $70,000 to Bank 1 checking account x-6067 in the name of "Izzat
Freitekh Sole Prop DBA Izzat Freitekh La Shish Catering"; and
c. Approximately $149,000 to a Bank 1 checking account x-4803 in the name of
"DBA Freitekh Ente1iainment Izzat Freitekh Sole Prop."
The La Shislt Kabob, La Sltish Catering and IMS Food and Restaurants PPP Applications
34. Beginning on or about April 7, 2020, and continuing through May 2020, IZZAT
FREITEKH, and TARIK FREITEKH submitted, and caused to be submitted, multiple PPP
applications to Bank 1 and FinTech 1 for IMS Food and Restaurants; IMS Food and Restaurants
LLC; La Shish Catering; and La Shish Kabob.
35. These applications included an application on or about April 7, 2020, for a $150,000
PPP loan for La Shish Kabob ("La Shish Kabob Application") that was submitted to FinTech 1
through FinTech 2.
36. The La Shish Kabob Application stated that La Shish Kabob had an average monthly
payroll of $6,000 and 12 employees. IZZAT FREITEKH and Individual A were each listed on
the application as cofounders with 50% ownership of La Shish Kabob. The La Shish Kabob
Application included an electronic signature purpotiedly made by Individual A.
37. The La Shish Kabob Application included a ce1iification, purpmiedly signed by
Individual A, that "the applicant was in operation on February 15, 2020 and had employees for
whom it paid salaries and payroll taxes or paid independent contractors, as reported on Form(s)
1099-MISC."
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38. Additionally, the La Shish Kabob Application included a certification, purportedly
signed by Individual A, "that the information provided in this application and the information
provided in all supporting documents and forms is true and accurate in all material respects. I
understand that knowingly making a false statement to obtain a guaranteed loan from [the United
States Small Business Administration] is punishable under the law, including under 18 USC 1001
and 3571."
39. The La Shish Kabob Application included a 2019 IRS Form 1040, which indicated
that the form had been filed jointly by IZZAT FREITEKH and Individual A. However, no such
IRS Form 1040 was ever filed with the IRS.
40. On or about April 8, 2020, a FinTech 2 representative received an email from the
IZZAT FREITEKH Email Account on which the T ARIK FREITEKH Email Account and the
email account for Individual A (hereinafter, "the Individual A Email Account") were copied. The
email read, in relevant part, "Thank you for helping us getting [sic] a loan, please find a copy of
my DL as requested, our Restaurant is considered one of the best restaurants in Charlotte and
surrounding areas." A copy of the driver's license for IZZAT FREITEKH was attached to the
message.
41. On or about April 22, 2020, a FinTech 2 representative received an email from the
IZZAT FREITEKH Email Account, which read:
Other than La shish we own two more business [sic], IMS food and Aroma Packaging
systems. We have 9 employees in aroma and 12 in IMS food. Can we apply for another
SBA loan for each business? Also we have not heard back from [FinTech I]. But we got
the email that they hired 200 more employees because how busy they are.
Thank you.
Izzat Freitekh
42. On or about April 28, 2020, FinTech 1 received a message from the Individual A
Email Account, with copy to the IZZAT FREITEKH Email Account. The email read:
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Thank you so much for your help. My husband and I are very thankful. We were
wondering how long it may take for the loan amount to be deposited into our [Bank 1] La
shish kabob business account. Our Restaurant is considered one of the best restaurants in
Charlotte and surrounding areas. We have to take care of our employees and clients as
they have been with us since we started in 2008. . . . I hope you will be able to expedite
depositing the amount.
Thank you so much. We really appreciate it.
Kind regards,
[Individual A]
43. On or about April 30, 2020, FinTech I sent an email to the Individual A Email
Account, stating, in relevant part: "Your application was completed and is currently in our funded
queue. There is a slight delay due to the amount of applications in the queue." FinTech 1 received
the following response:
... Roughly how many days do you think it might take us to be on top of the Queue. That
will help us plan our scheduled payments. If you are ever in Charlotte NC[, yJou are invited
to our restaurant anytime to enjoy our food on us. Thank again and I hope you have a great
day.
Kind Regards,
[Individual A]
La Shish kabob
44. In addition to the La Shish Kabob Application, on or about April 14, 2020, an
application for a $300,000 PPP loan for La Shish Catering (the "La Shish Catering Application")
was transmitted through Bank 1's electronic portal. The La Shish Catering Application included
the same false and fraudulent IRS Form 1040 for IZZAT FREITEKH and Individual A included
with the La Shish Kabob Application.
45. The La Shish Catering Application included false and fraudulent payroll summaries
for thirteen purported employees of La Shish Catering.
46. On or about May 5, 2020, Bank 1 checking account x-6067 in the name of "Izzat
Freitekh Sole Prop DBA Izzat Freitekh La Shish Catering" was funded with $300,000 based on
the La Shish Catering Application.
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47. On or about May 6, 2020, Bank 2 funded the PPP loan based on the La Shish Kabob
Application with a payment of$150,000 to Bank I checking account x-6067 in the name of"Izzat
Freitekh Sole Prop DBA Izzat Freitekh La Shish Catering."
48. IZZAT FREITEKH was listed as the sole authorized person on the account opening
documents for checking account x-6067 in the name of "Izzat Freitekh Sole Prop DBA Izzat
Freitekh La Shish Catering." As of May I, 2020, prior to the receipt of the PPP loan funds, the
account had a balance of $9,883.08.
49. Following the receipt of the PPP funds, there were multiple large transfers to other
accounts in the name ofIZZAT FREITEKH and associated entities, including two transfers, on or
about May 6, 2020, of approximately $150,000 to the Bank 1 checking account x-5182 in the name
of IZZAT FREITEKH and approximately $200,000 to Bank 1 checking account x-4803 in the
name of"DBA Freitekh Entertainment Izzat Freitekh Sole Prop."
50. The PPP applications submitted to Bank I beginning on or about April 14, 2020
and continuing until on or about May 1, 2020, in the name of IMS Food and Restaurants, IMS
Food and Restaurants LLC, and La Shish Catering listed an EIN ofxx-xxx2365. In fact, this EIN
belonged to a different, unrelated entity located in Florida, Entity 1. After IZZAT FREITEKH
and T ARIK FREITEKH submitted and caused to be submitted applications to Bank 1 using EIN
xx-xxx2365, Entity 1 also applied for a PPP loan. Entity l's request was rejected because La Shish
Catering had already been granted a PPP loan using that same EIN.
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COUNT ONE
(CONSPIRACY TO COMMIT WIRE FRAUD)
51. The Grand Jury re-alleges and incorporates by reference paragraphs 1 through 50 of
this Indictment.
52. From March 2020 through July 2020, the exact dates to the Grand Jurors unknown,
in the Western District of North Carolina and elsewhere, the defendants,
(1) IZZAT FREITEKH and
(2) TARIK FREITEKH, also known as TAREQ FREITEKH,
lmowingly and intentionally, that is, with the intent to advance the conspiracy, did combine,
conspire, and agree with each other and with others known and unknown to the Grand Ju1y to
commit wire fraud, that is, to knowingly and 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 meij,ns of materially false and fraudulent pretenses, representations, and promises, !mowing
such pretenses, representations, and promises were false and fraudulent when made, transmitted
and caused to be transmitted, by means of wire communications in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds, for the purposes of executing such
scheme and artifice, in violation of Title 18, United States Code, Section 1343.
Pm-poses of the Conspiracy
53. The Grand Jury realleges and incorporates by reference paragraph 17 of this
Indictment as a description of the purposes of the conspiracy.
Manner and Means of the Conspiracy
54. The Grand Jury realleges and incorporates by reference paragraphs 18 to 44 of this
Indictment as a description of the manner and means of the conspiracy.
All in violation of Title 18, United States Code, Section 1349.
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COUNT TWO
(Bank Fraud Scheme)
55. Paragraphs 1 through 50 of the Indictment are incorporated by reference as if fully
set forth herein.
56. From in or around March 2020 through July 2020, the exact dates to the Grand Jurors
unknown, in the Western District of North Carolina, and elsewhere, the defendants,
(1) IZZAT FREITEKH and
(2) TARIK FREITEKH, also known as TAREQ FREITEKH,
aided and abetted by each other and others known and unknown to the Grand Jury, knowingly
executed and attempted to execute a scheme and artifice (1) to defraud financial institutions and
(2) to obtain moneys, funds, credits, assets, securities, or other property owned by, or under the
custody or control of, financial institutions, by means of false and fraudulent pretenses,
representations, and promises.
All in violation of Title 18, United States Code, Sections 1344(1) and (2) and 2.
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COUNT THREE
(FALSE STATEMENTS)
57. Paragraphs 1 through 50 are incorporated by reference as if fully set forth herein.
58. On or about July 27, 2020, defendant IZZAT FREITEKH, in a matter within the
jurisdiction of the executive branch of the Government of the United States, knowingly and
willfully made the following materially false, fictitious, or fraudulent statement or representations,
including that:
a. A representative from a company called "Kyber Capital" contacted him and offered
to apply for SBA loans on IZZAT FREITEKH's behalf in exchange for a portion
of the loan proceeds.
b. Kyber Capital completed and submitted the loan applications purportedly
submitted by IZZAT FREITEKH and Individual A.
c. Neither IZZAT FREITEKH nor Individual A used the Individual A Email Account
or the IZZAT FREITEKH Email Account.
d. IZZAT FREITEKH provided Kyber Capital with the login information for the
IZZAT FREITEKH Email Account and the Individual A Email Account.
All in violation of Title 18, United States Code, Section 100l(a)(2).
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NOTICE OF FORFEITURE AND FINDING OF PROBABLE CAUSE
Notice is hereby given of 18 U.S.C. § 982 and 28 U.S.C. § 2461(c). Under Section 246l(c),
criminal forfeiture is applicable to any offenses for which forfeiture is authorized by any other
statute, including but not limited to 18 U.S.C. § 981 and all specified unlawful activities listed or
referenced in 18 U.S.C. § 1956(c)(7), which are incorporated as to proceeds by Section
981 (a)(l )(C). The following prope1ty is subject to forfeiture in accordance with Section 982 and/or
246l(c):
a. All prope1ty which constitutes or is derived from proceeds of the violations set forth
in this bill of indictment; and
b. If, as set forth in 21 U.S.C. § 853(p), any property described in (a) cannot be located
upon the exercise of due diligence, has been h·ansferred or sold to, or deposited
with, a third party, has been placed beyond the jurisdiction of the court, has been
substantially diminished in value, or has been commingled with other prope1ty
which cam10t be divided without difficulty, all other property of the defendant/s to
the extent of the value of the property described in (a).
The Grand Jury finds probable cause to believe that the following property is subject to
forfeiture on one or more of the grounds stated above:
a. A forfeiture money judgment in the amount of at least $1,750,000, such amount
constituting the proceeds of the violations set forth in this bill of indictment;
b. Approximately $977,607 in funds seized by law enforcement in or around July
2020 from Bank of America Account x-1388, such account held in the name of
Green Apple Catering LLC;
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c. Approximately $36,600 in funds seized by law enforcement in or around July 2020
from Bank of America Account x-4239, such account held in the name of Izzat
Freitekh Sole Prop DBA Aroma Packaging Systems;
d. Approximately $7,863 in funds seized by law enforcement in or around July 2020
from Bank of America Account x-6067, such account held in the name of Izzat
Freitekh Sole Prop DBA lzzat Freitekh La Shish Catering;
e. Approximately $78,217 in funds seized by law enforcement in or amund July 2020
from Bank of America Account x-4803, such account held in the name of DBA
Freitekh Entertainment Izzat Freitekh Sole Prop; and
f. Approximately $200,020 in funds seized by law enforcement in or around July
2020 from Bank of America Account x-5182, such account held in the name of
Izzat Freitekh.
A.TRUE BILL:
GRAND JURY FOR~PEH.~UN -
R. ANDREW MURRAY
UNITED STATES ATTORNEY
( .,. b1-t1({J,
J Y US SUGAR
SSITANT UNITED STATES ATTORNEY
DANIEL S. KAHN
ACTING CHIEF, FRAUD SECTION, CRIMINAL DIVISION
U.S. DEPARTMENT OF JUSTICE
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OSHUA DEBOLD
TRIAL ATTORNEY
FRAUD SECTION, CRIMINAL DIVISION
17
Case: 3:20-cr-00435-FDW-DCK *SEALED* Document 3 Filed 12/16/2020 Page 17 of 17
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