Factual Resume — United States v. Imran Khan (N.D. Tex., Dkt. 425, January 5, 2026)

Summary

Factual Resume in United States v. Imran Khan (05), No. 3:23-CR-252-K, in the U.S. District Court for the Northern District of Texas, Dallas Division, Document 425, filed January 5, 2026, supporting a plea of guilty to Count Six of the indictment. Count Six charges violations of 18 U.S.C. § 1344(2) and 18 U.S.C. § 2, Bank Fraud and Aiding and Abetting Bank Fraud, and the document lists the elements of each. In the stipulated facts, Imran Khan admits that on or about April 22, 2020 an application seeking $23,333 in PPP proceeds was submitted to Happy State Bank and contained materially false representations. It also states that on or about April 29, 2020 an application seeking $21,875 was submitted to Carter Federal Credit Union on behalf of Ambreen Khan.

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
UNITED STATES OF AMERICA
v. NO. 3:23-CR-252-K
IMRAN KHAN (05)
FACTUAL RESUME
In support of Imran Khan’s plea of guilty to the offense in Count Six of the
indictment, imran Khan, the defendant, Stephen Green and Jeff Clark, the defendant’s
attorneys, and the United States of America (the government) stipulate and agree to the
following:
ELEMENTS OF THE OFFENSE
To prove the offense alleged in Count Six of the indictment, charging violations of
18 U.S.C. § 1344(2) and 18 U.S.C, § 2, that is, Bank Fraud and Aiding and Abetting
Bank Fraud, the government must prove each of the following elements beyond a
reasonable doubt: !

First: That the defendant knowingly executed a scheme or artifice;

Second: That the scheme or artifice was executed to obtain monies or other
property from a financial institution, as alleged in the indictment;

Third: That the scheme or artifice was executed by means of false or
fraudulent pretenses, false or fraudulent representations, or false or
fraudulent promises; and

Fourth: That the false or fraudulent pretenses, representations, or promises
were material.

Fifth Circuit Pattern Jury Instruction 2.58B (2024).

Factual Resume—Page 1
Case 3:23-cr-00252-K Document 425 Filed 01/05/26 Page2of4 PagelD 2432

The elements of Aiding and Abetting, a violation of 18 U.S.C. § 2, are as follows:?

First: That the offense of bank fraud was committed by some person;

Second: That the defendant associated with the criminal venture;

Third: That the defendant purposefully participated in the criminal venture;
and

Fourth: That the defendant sought by action to make that venture successful.

STIPULATED FACTS

1. Imran Khan admits and agrees that on or about April 22, 2020, in the
Northern District of Texas and elsewhere, he, aided and abetted by others and aiding and
abetting others, did knowingly execute and attempt to execute a scheme and artifice to
obtain any of the moneys, funds, credits, assets, securities, and other property owned by,
and under the custody and control of, a financial institution, by means of materially false
and fraudulent pretenses, representations, and promises, in violation of 18 U.S.C. §
1344(2) and 18 U.S.C. § 2.

ae Imran Khan agrees that the Paycheck Protection Program (“PPP”),
implemented by the Small Business Administration (“SBA”), was a COVID-19 relief
initiative that, among other things, provided individuals with forgivable loans to pay
for payroll and certain other expenses. Under the PPP, participating third-party lenders
approved loan applications and disbursed PPP loans to qualifying businesses and
individuals. Imran Khan admits that he knew that to obtain a PPP loan, an individual

was required to submit a PPP loan application to a

* Fifth Circuit Pattern Jury Instruction 2.04 (2024).

Factual Resume—Page 2
lender. In the PPP loan application, the individual was required to state,

among other things, the individual’s average monthly payroll. This payroll information
was used to calculate the amount of funds that the individual was eligible to receive as a
PPP loan.

3. Imran Khan agrees that Happy State Bank was a financial institution, as
defined in 18 U.S.C. § 20, whose deposits were insured by the FDIC. He agrees that
Happy State Bank participated in the PPP as a third-party lender located in the Northern
District of Texas.

4. Imran Khan admits that, on or about April 22, 2020, he, with the aid of
others, submitted to Happy State Bank a fraudulent application seeking $23,333 in PPP
proceeds. Khan knew that this application contained materially false representations.
Thereafter, Khan received $20,800 of fraudulently obtained PPP proceeds into his
personal bank account.

5. Imran Khan further admits that, on or about April 29, 2020, he aided the
submission of a fraudulent application to Carter Federal Credit Union on behalf of his
spouse Ambreen Khan seeking $21,875 in PPP proceeds. Imran Khan knew that this
application contained materially false representations. Thereafter, Ambreen Khan
received $21,849 of fraudulently obtained PPP proceeds into her personal bank account.

6. The defendant agrees that the defendant committed all the essential
elements of the offense. This factual resume is not intended to be a complete accounting

of all the facts and events related to the offense charged in this case. The limited purpose

Factual Resume—Page 3
Case 3:23-cr-00252-K Document 425 Filed 01/05/26 Page4of4 PagelD 2434

of this statement of facts is to demonstrate that a factual basis exists to support the

defendant’s guilty plea to Count Six of the indictment.

AGREED TO AND STIPULATED on this 5” day of January, 2026.

RYAN RAYBOULD
y / UNITED STATES ATTORNEY
IMRAN KHAN? 2 RYAN P. NIEDERMAIR
Defendant Assistant United States Attorney
Texas Bar No. 24116828
MADELEINE CASE
Assistant United States Attorney
Texas Bar No. 24125166
KA (- 1100 Commerce Street, Third Floor
4 ¥ iia, Dallas, Texas 75242-1699
STEPHEN GREEN Tel: 214-659-8600
Attorney for Defendant Fax: 214-659-8809
JEFF CLARK
_/Asttomey for Defendant

Factual Resume—Page 4


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