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Home Source documents Bill of Particulars — United States v. Fahad H. Shah, Criminal No. 4:20-CR-156 (Dkt. 22, E.D. Tex.)

Bill of Particulars — United States v. Fahad H. Shah, Criminal No. 4:20-CR-156 (Dkt. 22, E.D. Tex.)

Summary

In this bill of particulars in the Eastern District of Texas, the United States lists property it says is subject to forfeiture in Criminal No. 4:20-CR-156 against Fahad H. Shah, under Federal Rule of Criminal Procedure 32.2(a). The list covers five amounts of U.S. currency, the largest $69,480.00, and $7,856.85 from a Wells Fargo account and $43,626.89 from an E-Trade Securities account. It also lists two 2020 Tesla Model 3 cars, two Freightliner M2 106 cabs, a 2014 Mercedes Benz Sprinter van and a 3D printer. The government also seeks a money sum of $1,592,657.00, described as the proceeds the defendant obtained from the offenses alleged in the indictment. The filing says the list includes property newly added through this bill of particulars, and its certificate of service is dated September 25, 2020.

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Full text

                          IN THE UNITED STATES DISTRICT COURT
                           FOR THE EASTERN DISTRICT OF TEXAS
                                   SHERMAN DIVISION

UNITED STATES OF AMERICA                       '
                                               '
V.                                             '   CRIMINAL NO. 4:20-CR-156
                                               '
FAHAD H. SHAH                                  '


                                 BILL OF PARTICULARS

        The United States of America, by and through the undersigned Assistant United

States Attorney, and pursuant to Federal Rule of Criminal Procedure 32.2(a), particularly

alleges that the following property is subject to forfeiture on the basis of the forfeiture

allegations set forth in the indictment filed in the above-styled criminal case:

U.S. Currency:

        (1) $69,480.00 in U.S. currency
        (2) $10,000.00 in U.S. currency
        (3) $1,977.00 in U.S. currency
        (4) $1,127.00 in U.S. currency
        (5) $900.00 in U.S. currency

Bank/Investment Accounts:

        (1) $7,856.85 seized from Wells Fargo Account #XXXX8264
        (2) $43,626.89 seized from E-Trade Securities, LLC Account #XXXX8039

Vehicles:

        (1) 2020 Tesla Model 3, VIN 5YJ3EIEBXLF719969
        (2) 2020 Tesla Model 3, VIN 5YJ3E1EB2LF668077
        (3) 2009 Freightliner M2 106 medium duty conventional cab
            (VIN 1FVACWDT49HAF6849)


Bill of Particulars - Page 1
        (4) 2014 Freightliner M2 106 medium duty conventional cab
            (VIN 3ALACWDT2EDFV8098)
        (5) 2014 Mercedes Benz Sprinter van (VIN WDYPE8DC0E5927890)

Miscellaneous Property:

        5axismaker 5xm 3D printer

Cash Proceeds

        A sum of money equal to $1,592,657.00 in United States currency, and all interest
        and proceeds traceable thereto, representing the amount of proceeds obtained by
        the defendant as a result of the offenses alleged in the indictment, for which the
        defendant is personally liable.

        The above described property that is sought for forfeiture includes property

originally sought for forfeiture within the indictment and newly added property that is

sought for forfeiture solely through this Bill of Particulars.



                                            Respectfully submitted,

                                            JOSEPH D. BROWN
                                            UNITED STATES ATTORNEY


                                             /s/ Robert Austin Wells
                                            ROBERT AUSTIN WELLS
                                            Assistant United States Attorney
                                            Texas Bar No. 24033327
                                            110 N. College, Suite 700
                                            Tyler, Texas 75702
                                            Tel: (903) 590-1400
                                            robert.wells3@usdoj.gov




Bill of Particulars - Page 2
                               CERTIFICATE OF SERVICE

        I hereby certify that the foregoing instrument was served on counsel of record for

defendant via the Court=s CM/ECF filing system on September 25, 2020.



                                          /s/ Robert Austin Wells
                                          ROBERT AUSTIN WELLS




Bill of Particulars - Page 3


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