Amended Preliminary Order of Forfeiture — United States v. Dinesh Sah (N.D. Tex., Dkt. 71, August 24, 2021)

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Amended Preliminary Order of Forfeiture in United States v. Dinesh Sah, Criminal Action No. 3:20-CR-484-S, in the U.S. District Court for the Northern District of Texas, Dallas Division, Document 71, filed August 24, 2021. The Court grants the Government's unopposed Motion for an Amended Preliminary Order of Forfeiture [ECF No. 58]. The order lists property the Government notified the defendant it would seek to forfeit, grouped as bank accounts, vehicles, real property and other property, beginning with $2,848,012.14 in funds seized on or about September 21, 2020. It also sets out the notice and petition procedure for third parties under 21 U.S.C. § 853(n)(2), and the signature block names Karen Gren Scholer, United States District Judge, with the date August 24, 2021.

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Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page1of13 PagelD 397

UNITED STATES OF AMERICA

Vi

DINESH SAH

United States District Court

NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

CRIMINAL ACTION NO. 3:20-CR-484-S

Lr LN 2 OP 2 KN?

AMENDED PRELIMINARY ORDER OF FORFEITURE

Before the Court is the Government’s Motion for an Amended Preliminary Order

of Forfeiture (“Motion”) [ECF No. 58]. Having considered the Motion, which is

unopposed by Defendant Dinesh Sah (“the Defendant’), and the Government’s Amended

Certificate of Conference Regarding Motion for Amended Preliminary Order of Forfeiture

[ECF No. 70], the Court determines the motion should be and is hereby GRANTED.

The Government notified the Defendant that it would seek to forfeit the following:

Bank Accounts

1.

$2,848,012.14 in funds seized from J.P. Morgan Chase account ending in -
0206 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$1,000,026.53 in funds seized from J.P. Morgan Chase account ending in -
4556 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$161,611.65 in funds seized from J.P. Morgan Chase account ending in -

9688 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$50,004.51 in funds seized from J.P. Morgan Chase account ending in -
0259 on or about September 21, 2020, maintained in the name of Unilaxy
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 2of13 PagelD 398

10.

13,

14,

International LLC:

$50,001.49 in funds seized from J.P. Morgan Chase account ending in -
5913 on or about September 21, 2020, maintained in the name of Horizon 5
Lakes LLC;

$50,001.49 in funds seized from J.P. Morgan Chase account ending in -

7047 on or about September 21, 2020, maintained in the name of Relief
Without Borders LLC;

$50,005.33 in funds seized from J.P. Morgan Chase account ending in -
7802 on or about September 21, 2020, maintained in the name of
Convergenz Entertainment LLC;

$50,001.49 in funds seized from J.P. Morgan Chase account ending in -

2501 on or about September 21, 2020, maintained in the name of Symbiont

$43,220.64 in funds seized from J.P. Morgan Chase account ending in -
5588 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$27,128.00 in funds seized from J.P. Morgan Chase account ending in -
5779 on or about September 21, 2020, maintained in the name of Panin

$19,188.22 in funds seized from J.P. Morgan Chase account ending in -
2642 on or about September 21, 2020, maintained in the name of Unilaxy
International LLC;

$10,000.18 in funds seized from J.P. Morgan Chase account ending in -
5102 on or about September 21, 2020, maintained in the name of Panin
LEG

$10,000.16 in funds seized from J.P. Morgan Chase account ending in -
7970 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$10,000.16 in funds seized from J.P. Morgan Chase account ending in -

2
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 3of13 PagelD 399

16.

17.

18.

20.

21,

22,

23,

24.

8854 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$10,000.16 in funds seized from J.P. Morgan Chase account ending in -
8964 on or about September 21, 2020, maintained in the name of Dinesh
Sah;

$10,000.10 in funds seized from J.P. Morgan Chase account ending in -
6921 on or about September 21, 2020, maintained in the name of Gysin
Group LLC;

$10,000.09 in funds seized from J.P. Morgan Chase account ending in -
9980 on or about September 21, 2020, maintained in the name of Quadrant
Clover LLC;

$10,000.00 in funds seized from J.P. Morgan Chase account ending in -
6708 on or about September 21, 2020, maintained in the name of Horizon 5
Lakes LLC;

$9,905.00 in funds seized from J.P. Morgan Chase account ending in -0121
on or about September 21, 2020, maintained in the name of Convergenz
Entertainment LLC;

$9,905.00 in funds seized from J.P. Morgan Chase account ending in -4321
on or about September 21, 2020, maintained in the name of Symbiont LLC
d/b/a Symbiont Retailers;

$9,905.00 in funds seized from J.P. Morgan Chase account ending in -9715
on or about September 21, 2020, maintained in the name of Symbiont LLC;

$9,810.00 in funds seized from J.P. Morgan Chase account ending in -9935
on or about September 21, 2020, maintained in the name of Relief Without
Borders LLC;

$2,500.00 in funds seized from J.P. Morgan Chase account ending in -1252
on or about September 21, 2020, maintained in the name of Gysin Group

$2,500.00 in funds seized from J.P. Morgan Chase account ending in -7773

3
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 4of13 PagelD 400

26.

28.

29.

30.

31.

33:

34.

on or about September 21, 2020, maintained in the name of Quadrant
Clover LLP;

$100,008.57 in funds seized from Bank of America account ending in -
5041 on or about September 21, 2020, maintained in the name of Dinesh
Sah:

$58,203.56 in funds seized from Bank of America account ending in -4437
on or about September 21, 2020, maintained in the name of Dinesh Sah;

$28,441.01 in funds seized from Bank of America account ending in -2798
on or about September 21, 2020, maintained in the name of Unilaxy
Advisors LLC:

$9,997.72 in funds seized from Bank of America account ending in -3028
on or about September 21, 2020, maintained in the name of Unilaxy
Advisors LLC:

$250,032.53 in funds seized from Comerica account ending in -0854 on or
about September 21, 2020, maintained in the name of Symbiont Capital
LEG:

$250,032.53 in funds seized from Comerica account ending in -7885 on or
about September 21, 2020, maintained in the name of Dinesh Sah;

$250,000.00 in funds seized from Comerica account ending in -0839 on or
about September 21, 2020, maintained in the name of Unilaxy International
LLG;

$250,000.00 in funds seized from Comerica account ending in -0847 on or
about September 21, 2020, maintained in the name of Horizon 5 Lakes
LLC:

$5,000.98 in funds seized from Comerica account ending in -7836 on or
about September 21, 2020, maintained in the name of Anju Babbar;

$5,000.35 in funds seized from Comerica account ending in -7968 on or
about September 21, 2020, maintained in the name of Anju Babbar;
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page5of13 PagelD 401

a2.

36.

a7,

38.

40,

Al.

42.

b. Vehicles

le

$250,905.71 in funds seized from Merrill Lynch brokerage account ending
in -7Q11 on or about September 21, 2020, maintained in the name of
Dinesh Sah;

$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;

$794,541.41 in funds seized from Technology Credit Union account ending
in -7530 on or about March 9, 2021, maintained in the name of Chargedge,

$399,062.83 in funds seized from Technology Credit Union account ending
in -5183 on or about May 24, 2021, maintained in the name of Sanjaya
Maniktala and Disha Maniktala;

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;

$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;

$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;

A 2020 Bentley Continental-Convertible (VIN# SCBDB4ZG5LC079786)
seized from 471 Clear Creek Lane, Coppell, TX 75019 on or about
September 18, 2020:
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page6of13 PagelD 402

A 2015 Porsche Macan (VIN# WP1AB2A53FLB63347) seized from 331
Still Forest Drive, Coppell, TX 75019 on or about September 18, 2020:

A 2020 Cadillac XT6 (VIN# 1GYKPHRS8LZ170172) seized from 331
Still Forest Drive, Coppell, TX 75019 on or about September 18, 2020;

A 2020 Chevrolet Corvette (VIN# 1G1Y82D40L5102760) seized from 471
Clear Creek Lane, Coppell, TX 75019 on or about September 18, 2020;

A 2017 Cadillac XT5 (VIN# 1GYKNBRSXHZ101252) seized from the
street on Clear Creek Lane, Coppell, TX 75019 on or about September 18,
2020;

A 2017 Audi A6 vehicle with (VIN# WAUF2AFC8HN 104906) seized
from the street on Clear Creek Lane, Coppell, TX on or about February 5,
2021.

c. Real Property

1.

All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 454 Clear Creek Lane,
Coppell, Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully
described as follows: Lot 36, Block D, Willowood No. 2, an Addition to the
City of Coppell, Dallas, County, Texas, according to the map or plat thereof
recorded in Volume 79095, Page 746, Map Records, Dallas County, Texas;

All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 471 Clear Creek Lane,
Coppell, Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully
described as follows: Lot 12, Block E, Willowood No. 2, an Addition to the
City of Coppell, Dallas, County, Texas, according to the map or plat thereof
recorded in Volume 79095, Page 746, Map Records, Dallas County, Texas;

All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 331 Still Forest Drive,
Coppell, Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully
described as follows: Lot 14, Block 5 of Park Meadow, Section Two, an
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 7of13 PagelD 403

Addition to the City of Coppell, Dallas County, Texas, according to the plat
thereof recorded in volume 86108, page 6974, Map Records, Dallas
County, Texas;

4, All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 208 Bricknell Lane,
Coppell, Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully
described as follows: Lot 9, Block A of Village at Cottonwood Creek
Section V, an Addition to the City of Coppell, Dallas County, Texas,
according to the plat thereof recorded in volume 97061, page 3057, Map
Records, Dallas County, Texas;

v4 All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 318 Buttonwood Court,
Coppell, Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully
described as follows: Lot 19, in Block B of Villages at Cottonwood Creek,
Section IV, an Addition to the City of Coppell, Dallas County, Texas,
according to the plat thereof recorded in volume 93039, page 1542, Map
Records, Dallas County, Texas;

6. All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 631 Beal Lane, Coppell,
Texas 75019 owned by Dinesh Sah and Anju Babbar, more fully described
as follows: Lot No. 3, Block D of Oakbend Addition, an Addition to the
City of Coppell, Dallas County, Texas, according to the plat thereof
recorded in volume 91059, page 1427, Map Records, Dallas County, Texas;

ef All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 22852 Runnymede Street,
West Hills, California 91307 owned by Anju Babbar, more fully described
as follows: Lot 8 of Tract No. 22800, in the City of Los Angeles, County of
Los Angeles, State of California, as per Map recorded in Book 634, Pages
77 and 78 of Maps, in the Office of the County Recorder of said County,
except therein, an undivided one-half interest in and to all oil and mineral
rights, but without the right of entry to the surface or to the subsurface to a
depth of 500 feet of said land, as granted to Bernard Spiegel, a married
man, by deed recorded October 30, 1958 as Instrument No. 2941, in Book
D 261, Page 430 of Official Records; also except therefrom an undivided

7
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 8of13 PagelD 404

one-half interest in and to all oil and mineral rights, but without the right to
entry to the surface or to the subsurface to a depth of 500 feet of said land,
as granted to Home Builders Mortgage Co., a corporation, by deed recorded
October 30, 1958 as Instrument No. 2939 in Book 261, Page 428, Official
Records; also except therefrom all rights to oil and minerals in and under
said land, but without right of entry to the surface or the subsurface to a
depth of 500 feet of said land, as set forth in the Declaration of Restrictions
recorded January 21, 1959 as Instrument No. 2456 in Book M202, Page
240, Official Records, and as excepted in the deed recorded January 13,
1960; and

8. All that lot or parcel of land, together with buildings, improvements,
fixtures, attachments, and easements located at 22107 Cajun Court, Canoga
Hills, California 91303 owned by Anju Babbar, more fully described as
follows: A condominium comprised of Parcel 1: Unit No. 3, as shown and
described on the Condominium Plan for Tract No. 60460, recorded April
17, 2006 as Instrument No. 06-832932 of Official Records of Los Angeles
County; and Parcel 2: An undivided 1/18" interest, as tenant in common, in
Lot 1 of Tract No. 60460, in the City of Los Angeles, County of Los
Angeles, State of California, as per Map recorded in Book 1312, Pages 29
and 30 of Maps, in the Office of the County Recorder of said Count; except
therefrom Units | to 18 inclusive as shown on the Condominium Plan
referred to in Parcel 1.

d. Other Property

1. New York Life Insurance Company Whole Life Insurance Policy seized on or
about February 9, 2021 for Insured Dinesh Sah (Policy # 45 332 755);

2. A timeshare (Unit GMP583217A1Z) seized from Grand Pacific MarBrisa Resort,
1594 MarBrisa Circle, Carlsbad, CA 92008 on or about March 11, 2021,
purchased by Dinesh Sah and Anju Babbar;

3. $50,000.00 in funds seized from American Legend Homes on or about February
23, 2021 for the purchase of the residential property located at 1367 Horsetail
Place, Coppell, Texas 75019, by Dinesh Sah and Anju Babbar;

4. $700,000.00 in funds seized from American Legend Homes on or about February

8
10.

12.

15.

Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 9of13 PagelD 405

23, 2021 for the purchase of residential property located at 1388 Horsetail Place,
Coppell, Texas 75019, by Dinesh Sah and Anju Babbar;

$50,000.00 in funds seized from American Legend Homes on or about February
23, 2021 for the purchase of the residential property located at 1335 Wood Duck
Drive, Coppell, Texas 75019, by Dinesh Sah and Anju Babbar;

$50,000.00 in funds seized from American Legend Homes on or about February
23, 2021 for the purchase of the residential property located at 1324 Otter Way,
Coppell, Texas 75019, by Dinesh Sah and Anju Babbar;

The $1,500,000.00 in U.S. currency transferred on July 14, 2020 to beneficiary
number 91002000807 in the name of Panin Hitech Solutions Pvt. Ltd. at the Axis
Bank Limited, Mumbai India, which may or may not still be contained in that
account;

The $1,500,000.00 in U.S. currency transferred on August 4, 2020 to beneficiary
number 59209820983821 in the name of Panin Hitech Solutions, Pvt. Ltd. at the
HDFC Bank Limited, Kanjur Marg East Mumbai India, which may or may not
still be contained in that account;

$100,000.00 in funds seized from TiE SoCal Angels Fund 2020, LLC on or about
February 23, 2021 for Dinesh Sah's interest in the fund;

Cash in the amount of $1,500 located in a 2017 Cadillac XT5 (VIN#
1GYKNBRSXHZ101252) that was seized on September 18, 2020; and

Cash in the amount of $2,020 located on the person of Dinesh Sah upon his arrest
on September 12, 2020.

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, which may or may
not still be contained in the account;

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;

9
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page 10of13 PagelD 406

14.

16.

18.

19:

20.

ZI

22.

2S.

24.

25.

26.

28.

29.

30.

The following other items were seized from 454 Clear Creek Drive, Coppell,

Texas on or about September 12, 2020;

$17,000.00 U.S. Currency;

Diamond bangle bracelet;

Ring with 3 diamonds (1 big one flanked by 2 smaller ones);

Silver ring with 3 diamonds in a row;

50 gram gold bar - 24 carat;

6 Gold Bracelets with silver accents;

Necklace & Earring set; pendant w/ a goddess; gold w/ black, red, & white beads;
Necklace & Earring set; gold w/ silver accents: long earrings;

4 Diamond stud earrings; 1 single pearl earring w/ green & red stones;
Necklace & Earring set w/ gold chain & pendant in a Nautilus shape;

Necklace & Earring set: gold & silver chain w/ diamonds (bell shaped);
Necklace & Earring set: gold & diamonds; 2 squares:

Necklace & Earring set: gold & silver w/ 3 strands of silver beads:

Necklace & Earring set: gold w/ black beads on necklace: 3 squares w/ dangles;
Necklace & Earring set: gold & diamonds; heart-shaped;

Gold & Diamond Pendant; sun-shaped; 1/2 carat:

3 gold rings;

Earrings: round w/ green, red, & silver;

10
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page11of13 PagelD 407

32. Earrings in flower shape w/ red stone;
33. Gold stud earrings;
34. Matching pendant & earrings: gold & pearl horseshoe shape;
35. 4 gold chains;
36. Gold & diamond earrings in a clover shape;
37. | 2necklaces w/ ampersand shaped diamond pendants: 1 gold & 1 silver;
38. Necklace & earrings w/ gold beads;
39. Necklace & Earring set: gold w/ crystals in a flower shape;
40. 2 strand pearl necklace w/ pearl stud earrings;
41. 2 bracelets w/ gold & diamonds all around;
42. Silver pendant w/ diamond in a flower swirl shape;
43. Necklace & earring set: silver/diamonds in a snowflake shape;
44. Necklace & Earring set; gold w/ red stones & crystals in triangle shape;
45. Diamond Stud earrings;
46. Gold bracelet with diamonds & red stones.
(“the property”) upon the Defendant’s conviction on Counts One and Seven of the
indictment. The Defendant pled guilty to that offense and described in a factual resume
how the property was involved in that offense.
Based on the Defendant’s guilty plea and factual resume, the Court finds the
property is subject to forfeiture to the Government pursuant to 18 U.S.C. §§ 981(a)(1)(C)
and 982(a)(1) and 28 U.S.C. § 2461(c). It is therefore ordered that the property is forfeited

to the Government, subject to the provisions of 21 U.S.C. § 853(n).

11
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page12of13 PagelD 408

It is further ordered that, pursuant to 21 U.S.C. § 853(g) and Fed. R. Crim. P. 32.2,
the Attorney General (or its designee) shall seize the property and hold it in its secure
custody and control pending a final order of forfeiture.

It is further ordered that, pursuant to 21 U.S.C. § 853(n) and Fed. R. Crim. P. 32.2,
the Attorney General shall publish notice of the forfeiture order for at least 30 consecutive
days on an official Government Internet site (www.forfeiture.gov). The notice shall state
the Government’s intent to dispose of the property and state that any person, other than the
Defendant, having or claiming a legal interest in the property must file a petition with the
Court no later than 60 days after the first day of the publication and serve a copy on AUSA
Dimitri N. Rocha, Asset Recovery Unit, United States Attorney’s Office, 1100 Commerce
Street, Third Floor, Dallas, Texas 75242. Pursuant to 21 U.S.C. § 853(n)(2), if direct
written notice is provided to any person known to have alleged an interest in the property
that is the subject of the order of forfeiture, that person must file a petition with the Court
within 30 days of the final publication of notice or receipt of direct written notice,
whichever is earlier, and serve a copy on AUSA Dimitri N. Rocha, Asset Recovery Unit,
United States Attorney’s Office, 1100 Commerce Street, Third Floor, Dallas, Texas 75242.
The petition shall be for a hearing to adjudicate the validity of the petitioner’s alleged
interest in the property; shall be signed by the petitioner under penalty of perjury; and shall
set forth the nature and extent of the petitioner's right, title, or interest in the property, the
time and circumstances of the petitioner’s acquisition of the right, title, or interest in the
property, and any additional facts supporting the petitioner’s claim and the relief sought.

The Government shall send, by means reasonably calculated to reach the person, written

12
Case 3:20-cr-00484-S Document 71 Filed 08/24/21 Page13o0f13 PagelD 409

notice to any person who reasonably appears to be a potential claimant with standing to

contest the forfeiture.
Upon adjudication of all third-party interests, the Court will enter a final order of
forfeiture addressing those interests.

SO ORDERED.

SIGNED August 24, 2021. TS

KAREN GREN SCHOLER
UNITED STATES DISTRICT JUDGE

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