Addendum to Plea Agreement — United States v. Dinesh Sah (N.D. Tex., Dkt. 52, July 28, 2021)

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Addendum to Plea Agreement in United States v. Dinesh Sah, No. 3:20-CR-484-S, in the U.S. District Court for the Northern District of Texas, Dallas Division, Document 52, filed July 28, 2021. It adds to the February 16, 2021 Plea Agreement (Dkt. 30) on forfeiture, in which the defendant agrees to forfeit proceeds of the offense and lists funds seized from financial institutions, including $26,106.68, $250,000.00 and $200,064.30, along with funds transferred to other accounts and a payment toward a residential property. The defendant agrees not to claim the property, waives claims relating to its seizure and forfeiture, and waives notice requirements under Rule 32.2(a) and challenges to the forfeiture as an excessive fine. The signature blocks name prosecutors and defense counsel.

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Case BPN AS Document 52 Filed 07/28/21 Page1of4 PagelD 299

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS 2021 JUL 28 AM 9: 10
DALLAS DIVISION

DEPUTY

UNITED STATES OF AMERICA cLerkK__Wlo
v. NO. 3:20-CR-484-S

DINESH SAH

ADDENDUM TO PLEA AGREEMENT

The United States of America and the Defendant hereby agree to the following
addendum to their February 16, 2021 Plea Agreement (Dkt. 30) as follows:

Regarding the forfeiture, Sah agrees:

l. I agree to forfeit all property constituting, or derived from, any proceeds I
obtained, directly or indirectly, as the result of my crime and all property used, or
intended to be used, in any manner or part, to commit, or to facilitate the commission of,
such violation. I admit and agree that each of the following properties constitute
proceeds of my offense and/or facilitated the same:

a. $26,106.68 in funds seized from Neighborhood Credit Union account
ending in -9614 on or about May 14, 2021, maintained in the name of
Dinesh Sah;

b. $250,000.00 in funds seized from JP Morgan Chase general ledger from
wire reversal to closed account ending in -0206 on or about June 9, 2021,

maintained in the name of Dinesh Sah;

Plea Agreement Addendum — Page |
Case 3:20-cr-00484-S Document 52 Filed 07/28/21 Page 2of4 PagelD 300

. $200,064.30 in funds seized from Citibank general ledger from closed

account ending in -0591 on or about June 25, 2021, maintained in the name

of Dinesh Sah;

. The $50,000.00 transferred on June 1, 2020 to account ending -0583 in the

name of Dinesh Sah at Citibank, which may or may not still be contained in

the account;

. The $50,000 transferred on June 5, 2021 to account ending in -1107 in the

name of Dinesh Sah at State Bank of India, which may or may not still be
contained in the account;
The $130,000.00 in U.S. dollars transferred on August 27, 2020 to account

9864905790 in the name of Sagar Gohill at Wells Fargo Bank, and

. The $120,000 in U.S. dollars transferred on August 24, 2020 to First

Integrity Title Westminster CO for the purchase of the residential property
located at 18856 W. 93rd Road, Arvada, Colorado 80007;

Regarding this property, I agree: a) I obtained or retained it as a result of

my offense(s); b) it may be forfeited administratively, civilly, or criminally; c) I will not

make a claim to it or oppose its forfeiture, or help anyone else do so; d) to withdraw any

previous claims made to the property; e) to sign any necessary documents to ensure that

clear title passes to the United States; and f) to testify truthfully regarding this property in

any forfeiture proceeding. I also agree not to make or cause anyone else to make a claim

to property forfeited by any other defendant in this case.

Plea Agreement Addendum — Page 2
Case 3:20-cr-00484-S Document 52 Filed 07/28/21 Page3of4 PagelD 301

3. I waive any claims I may have against the United States regarding the

seizure and/or forfeiture of the property covered by this agreement.

4. I waive the requirements regarding notice of the forfeiture in the charging

instrument (Rule 32.2(a)), announcement of the forfeiture at sentencing, and

incorporation of the forfeiture in the judgment (Rule 32.2(b)(4)(B)).

5. I waive any constitutional or statutory challenges to the forfeiture covered

by this agreement, including that the forfeiture is an excessive fine or punishment.

DATED this 2% ~ day of July 2021.

Plea Agreement Addendum — Page 3

PRERAK SHAH
Acting United States Attorney

ANNA G. KAMINSKA
Assistant Deputy Chief

Fraud Section, Criminal Division
New York Bar No. 4202958

KATHERINE MILLER
Section Chief
Texas Bar No. 00789107

ERICA HILLIARD
Assistant United States Attorney
Mississippi Bar No. 104224

DIMITRI ROCHA
Assistant United States Attorney
Florida Bar No. 693332
| f 2 Case 3:20-cr-00484-S Document 52 Filed 07/28/21 Page 4of4 PagelD 302

I have read or had read to me this plea agreement addendum and have carefully
reviewed every part of it with my attorney. I fully understand it and voluntarily agree to

7 [28 (2

Date

I am the defendant’s attorney. I have carefully reviewed every part of this plea
agreement addendum with the defendant. To my knowledge and belief, my client’s
decision to enter into this plea agreement addendum is an informed and voluntary one.

| | Nad } r € | oA
Reed Prdspere ' | Date
Attorney for Defendant

Plea Agreement Addendum — Page 4


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