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Plea Agreement — United States v. Mohammad Ribhi Farraj, No. 4:22-cr-00140 (D.S.C.)

Summary

A Plea Agreement, Entry Number 172, filed 12/02/22, Criminal No: 4:22-cr-00140-JD, District of South Carolina, Florence Division, between the United States and Defendant Mohammad Ribhi Farraj. The Defendant agrees to plead guilty to Count I of the Superseding Indictment, which charges a conspiracy to devise and execute a scheme to defraud, and the Government agrees to move to dismiss the remaining counts at sentencing provided the Defendant complies with all the terms. The agreement also covers restitution, cooperation with the Government, and forfeiture, including a money judgment in an amount to be determined by the Court. It lists the Defendant's attorney, Seth Cole Rose, Esquire, and Assistant United States Attorney Derek A. Shoemake.

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

Cite this document

“Plea Agreement — United States v. Mohammad Ribhi Farraj, No. 4:22-cr-00140 (D.S.C.).” Original at storage.courtlistener.com. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-22-cr-00140-dkt-172-d-s-c-705ad417f4/, SHA-256 ac5b791f6f312a7be4429f95624cadcca66ffa6f8d86a30b10dcc41025b1437f.

Full text

4:22-cr-00140-JD        Date Filed 12/02/22         Entry Number 172           Page 1 of 11




                   IN THE DISTRICT COURT OF THE UNITED STATES
                       FOR THE DISTRICT OF SOUTH CAROLINA
                                FLORENCE DIVISION


  LTNITED STATES OF AMERICA                            Criminal No: 4:22-cr-00 140-JD


                                                                 PLEA AGREEMENT
  MOHAMMAD RIBHI FARRAJ


                                      Ceneral Prol'isions


        This PLEA AGREEMENT is made          ,hi, il'? day of L*Mr022, berween the
 Unitcd States of America, as represented by United States Attomey ADAIR F. BOROUGHS,

 Assistant United States Attorney Derek A. Shoemake the Defendant, MOHAMMAD RIBHI

 FARRAJ, and Defendant's attorney, Seth Cole Rose, Esquire.

       IN CONSIDERATION of the mutual promises made herein, the parties agree as follows:

    1. The Defendant agrees to plead guilty to Count I of the Superseding Indictment now
       pending, which charges that beginning approximately in or about January 2020 and

       continuing up and to the date of the Superseding Indictment, in the District of South

       Carolina and else'rvhere, the Defendant, MOHAMMAD RIBHI FARRAJ, did knowingly

       and willfully combine, conspire, confederate, agree and havc a tacit understanding with

       each other and with others known and unknown to the Grand Jury, to devise and execute a

       schenre and artifice to defraud and to obtain money and property by means of false and

       fraudulcnt prctenses, representations, and promises, and during such period, in the coursc

       of executing said scheme and artifice attempted to transmit, transmitted, and caused to be

       tra.nsmitted in interstate commerce, wirc comnrunications, including writings, signs,

       signals, pictures, and sounds, for the purpose of executing the scheme and artifice to



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4:22-cr-00140-JD       Date Filed 12/02/22            Entry Number 172         Page 2 of 11




      defraud, in violation of Title 18, United States Code, Section I343. All in violation of

      United States Code, Section 1349.




      In order to sustain its burden of proof, the Government is required to prove the following:

                                            Count I

      A.     Two or more persons made an agreement to commit an unlawful act, here that
             unlawful act being wire fraud under l8 U.S.C. $ 1343;

             The elernents of l8 U.S,C.   I 1343 are:
                 a. The Defendant devised or intended to devise a scherne to defraud or for
                     obtaining money or properly by means of false or fraudulent pretenses,
                     representations. or promises that were material; and

                 b. That for the purpose of executing the scheme, the Defendant transmitted
                    or caused to be transmitted by means of wirc, radio, or television
                     communication in interstate or foreign con'lrnerce any writings, signs.
                     signals, pictures, or sounds.

      B.     The Defendant knew the unlawful purpose of the agreement; and

      C.     The Defendant joined in the agreement willfully, with the intent to further the
             unlawful purpose.

      The penalty for this offense is:

      Imprisonment for not more than 20 vears (18 U,S.C. $$ 1343 and 1349)
      Fine of $250.000 (l 8 U.S.C. $ 3571)
      Supenised Release of not more than 3 vears (18 U.S.C. S$ 3583, 3559)
      Special Assessment of $100 (18 U.S.C. $ 3013)

 2.   The Defendant understands and agrees that monetary penalties [i.e., special assessments,

      restitution, fines and other paymcnts required under the sentence] imposed by the Court

      are due and payable immediately and subject to enforcement by the United States as civil

      judgments, pursuant to 18 USC S 3613. In the event the Court imposes a schedule for

      payment of restitution, the Defendant also understands that payments made in accordance




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4:22-cr-00140-JD       Date Filed 12/02/22          Entry Number 172            Page 3 of 11




       with installmcnt schedules set by the Court are minimum payments only and do not

      preclude the government from seeking to enlorce the judgment against other assets ofthe

       Defendant at any time, as provided in 1 8 USC $S 3612, 3613 and 3664(m). The Defendant

      further agrees to enter into the Bureau of Prisons Inmate Financial Repayment Program if

      sentenced to a term of incarceration with an unsatisfied monetary penalty. The Defendant

      further understands that any monetary penalty imposed is not dischargeable in bankruptcy.

                     Special Assessment: Pursuant to l8 U.S.C. 93013, the Defendant must pay
                     a special assessment of S 100.00 for each felony count for which he/she is
                     convicted. This special assessment must be paid at or before the time of the
                     guilty plea hearing or during participation in the Bureau of Prisons Inmate
                     Financial Repayment Program ifthis plea results in incarceration.

             R        Restitution: The Defendant agrees to make full restitution under l8 U.S.C.
                      $ 3556 in an amount to be determined by the Court at the time ofsentencing,
                     which amount is not limited to the count(s) to which the Defendant pled
                     guilty, but will include restiturion to oach and every identifiable victim who
                     may have been harmed by his,&er scheme or pattem of criminal activity,
                     pursuant to l8 u.s.c. $$ 2259,366-1, 36634, and f664. The Defendant
                     agrees to cooperate fully with the Govemment in identilying all victims.
                     Upon demand, the Defendant shall submit a personal financial statement
                     under oath and submit to intervicws by the Governmenr and the U.S.
                     Probation Office regarding the Defendant's capacily to satisfy any fines or
                     restitution. The Defendant expressly authorizes the U.S. Attorney,s Office
                     to immediately obtain a crcdit rcport on the Defendant in order to evaluate
                     the Defendant's ability to satisfy any linancial obligation imposed by the
                     Court. The Dcfendant understands that the Defendant has a continuing
                     obligation to pay in full as soon as possible any financial obligation imposed
                     by the Court.

             C      Fines: The Defendant understands that the Coun may impose a fine
                    pursuant to l8 U.S.C. $$ 3571 and 3572.

 3.   Provided the Defendant complies with all the temrs of this Agreernent, tlre united states

      agrees to move to dismiss the remaining counts of (he Superseding indictment
                                                                                         [and any

      odrer indictm€nts under this number] at senlencing. Thc Defendant understands that the




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4:22-cr-00140-JD           Date Filed 12/02/22           Entry Number 172            Page 4 of 11




           court may considcr these dismisscd counts as rerevant conduct pursuant to
                                                                                           $ r B L3 of thc

           United States Sentencing Cuidelines.

    4      Defendant understands that if Defendant is not a united States citizen,
                                                                                                thc ferony
           conviction in this case may subject Defendant to removar, arso known as
                                                                                            deportation,

           which may, under some circumstances, be mandatory. The court cannot, and
                                                                                            Defendant,s

           attomey also may not be able to, advise Defcndant fully regarding the immigration

           conscquenccs ofthe felony conviction in this casc. Defendant understands
                                                                                        that by entering

           a guilty plea defendant waives any craim that unexpected immigration
                                                                                     consequences may

           render Defendant's guilty plea invalid.

 5         The Defendant understands that the obligations of the Government within
                                                                                                 the prca
          Agreement are expressly contingent upon the Defendant's abiding by federal
                                                                                          and state raws

          and complying with any bond executed in this case. In the event that the
                                                                                        Defendant fails

          to comply with any of the provisions of this Agreement, either express
                                                                                        or implied, the
          Govemment will havc the right, at its sole erection, to void alr of its obrigations
                                                                                                under this

          Agreement and the Defendant w l not have any right to withdrarv his/her prea
                                                                                            of guilty to

          the olfense(s) enumerated herein,

                                       Coo     tion an d Forfe iturel

6         The Defendant agrees to be fully truthful and forthright with fcderal,
                                                                                   state and local law

          enforcemenr agencies by providing full, complete and truthful infomration
                                                                                                about all
         criminal activities about rvhich he/she has knowledge. The Defendant
                                                                                    nrust provide fu[.



rThe forfeiture in rhis
                          case   d*.
                                  i:,]l:pg..-
    Defendanr: 26.69617j9 ETH, ?.46!.2010     1r"-     !l!*llg cryprocurrency
                                          XR p. 38,234.68;:Z      inp.
                                                                              surrendered by the
                                                                   ur,f 2 i.43 i .,Ji XRp. This
    cryptoc,rency has been surredered ro the Govemnreut via
                                                                united statcs Secret iervice
    Agreements to Sunender property signed by thc Defendant
                                                            o, tutuy t Z, 2022,        and Defendant
    does not contest that the funds may be co,verted and
                                                           are the sore property ofthe Govemment.


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4:22-cr-00140-JD         Date Filed 12/02/22             Entry Number 172              Page 5 of 11




         completc and truthful debriefings about these
                                                             unlawful activities and must fully disclose
         and provide tmthful r'nformation to the Govemment jncluding
                                                                                   any books, papers, or
         documents or any other items of evidentiary
                                                            value to trre investigation. The Defbndant

         must also testiry fuly and truthfully before any
                                                                grand junes and at any trials or
                                                                                                       other
        proceedings ifcalled upon to do so by the
                                                       Government, subject lo prosecution for pe{ury

        for not teslirying truthfury. The fairure of the
                                                           Defendant to be fully truthful and forthright

        at any stagc wiu' at the sole election of the
                                                            Govemment, cause thc obligations of the

        Govemment within this Agreement to become
                                                           null and void. Further, it is expressly agreed

        that ifthe obrigations ofthe Govemment
                                                     within this Agreement become nu, and void
                                                                                                        due
        to the lack of hxthfulness on the part ofthe
                                                         Defendant, rhe Defendant understands
                                                                                                   that:
               A.      the Defendant will not be permitted to
                                                                  withdraw his,trer plca of guilty to the
                       offenses described above;

               B.      all additional charges known to the Govemment
                                                                                   may be filed in the
                       appropriate district;

               C.      the Government will argue for a maximum
                                                                      sentence fbr the offense to which
                       the Defendant has pleaded guilty: and

               D,     the Government will use any and all information
                                                                      and tcstimony provided by
                      the Defendant pursuant to this Ag."..err,
                                                                o, unfprior pruil.er agreements,
                      in the proseculion ofthe Defenda=nt ofufl      .1urg.,...
 7.   The Defendant agrees to submit to such polygraph
                                                               examinations as may be requested
                                                                                                       by
      the Govemment and agrees that any
                                               such examinations shall be performed
                                                                                         by a polygraph
      examincr serected by the Govemment. Defendant
                                                             further agrees that rlis,41er refusar to take
      or his/her failurc to pass any such polygraph
                                                      examination to thc Govemmcnt,s
                                                                                            satistbction
      will result' at thn Govcmment's sore discretion,
                                                         in the obrigations of thc Governmcnt
                                                                                                  within
      the A-greemcnt beconring null and void.




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4:22-cr-00140-JD             Date Filed 12/02/22            Entry Number 172             Page 6 of 11




      8,      The Govcmment agrccs that any self-incriminating information
                                                                                 provided by the Defendant

              as a resurt of the cooperation required by the terms
                                                                     of this Agreement, arthough avairable
             to the Courr, will not be used against the Defendant in determining
                                                                                            the Defendant,s
             applicabJe guideline range for sentencing pursuant to
                                                                         the U.s. Sentencing commission

             Cuidelines. The provisions of this paragraph shall not be applied
                                                                                        to restrict any such
             information:

                     A.     kno\r,n to the Govcmment prior to the date of this Agreement;

                     B.     conceming the existence ofprior convictions and sentences;

                    C.      in a prosecution for perjury or giving a thlse stalementi

                    D.      in the event the Defendant breaches any ofthe terms
                                                                                    ofthe plea Agreement;
                            or

                    E.      used to rebut any.evidence or arguments offered
                                                                                  by or on behalf ofthe
                            Defendant (including arguments made or issues
                                                                               raijed srra         ay tlr"
                            District Court) at any state ofihe criminal prosecution (incluaing
                                                                                           "pont"
                                                                                               bail, tria)-
                            and sentencing).

 9          Provided the Detbndant cooperates pursuant to the provisions
                                                                              ofthis plea Agreement, and
            that cooperation is deemed by the Government as providing
                                                                              substantlal assistance in the

            investigation or prosecution of another person, th€ Govemment
                                                                                agrees to move the court

            for a downward departure or reduction of scntence pursuant
                                                                             to Unjted States Sentencing
           Guidelines {5Kl.l, Title tg, United States Code, g 1553(e)
                                                                            or Federal Rule of Criminal
           Procedure 35(b). Any such motion by the
                                                         Govemment is not binding upon the court, and

           should the Court deny thc motion, the Defendant
                                                                  will have no right to withdraw hisrher
           plea.

10.        The Dcfendant agrees to voluntarily surrender
                                                             to, and not to contest the forfeiture of,
                                                                                                         any
           and all assets and propefiy, or portions
                                                      thereol which are subject to forfeiture pursuanl
                                                                                                          to




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4:22-cr-00140-JD          Date Filed 12/02/22          Entry Number 172                  Page 7 of 11




        any provision of law, including but
                                                nor limitcd to , property in thc possession
                                                                                                or control of
        tlre Defendant or Defendant,s nominees.
                                                     Specifically, the Detendart agrees to
                                                                                                 voluntarily
       surrender and not contest the forfeiture
                                                         of property identified in the Superseding
       Indictment' and any forfeiture BiI of particurars,
                                                              and a money judgment in an amount
                                                                                                            to
       be determined by Cou(, representing the amount
                                                                of gross proceeds of the offense(s) of
       conviction.

                     Procceds/ Forfciture Judement:

                     A sum of money equal to all proceeds the Defendants
                                                                                       obtained directly or
                     indirectly as rhe r€sulr of the offenses
                                                                  ilil;;;;
                     lndictment, and all interesr and proceea. trr""iUf"
                                                                                       Second Superseding
                                                                              ,fr"r"io, and/or that such sum
                                        derived from or haceabte ,o ,t             u.LUor. of 18 U.S.C. $$
                  ;ui*, ffi!*                                                "rr

      With regard to each and every ass€t listed in
                                                         the Superseding Indictment or seized
                                                                                                       in a
      related investigation or administrative,
                                                 state, or rocal action, the Defendant
                                                                                             stipurates and
      agrees

          The Defendant agrees and consents to.the
                                                         forfeiture of these assets pursuant
          federal criminat, civiljudiciai oradminisrrative                                     to anv
          he reby agrees to waive all
                                                              lb.f;;";;;;;l;.;i#;;;iil
                                       constitutjonal. ,,r,r,".y *l p."."#ai
         manner (including direct appeal,.habcas                                  challeng"s rn any
                                                     corpus, .;      ;;;;;;s)      to any forfeiture
         carried our in accordance with thispl.u
                                                    agr"e..nr ";,on,r;;il;j,      including  that the
         forfeiture described herein constitutes_
                                                   an excessive fin", *;; ;;;;roperly
         the charging inshument,                                                          noticed in
                                  addressed by
        announced at sentencing, or incorporated
                                                       il c;;;;;ilil;'j,""- " the guilry plea,
                                                      into the ludgm;.

        To its forfeiture herein, if lecessary as
                                                  substitule property under 2l U.S.C. g53(p),
        made applicabre bv t8 U.s.c                                                   $        as
                                             $ eS.2rb)r I )                      o, in u ."p,,ur.
        administrative or civil judrcial proceeding.        "r';";-;ih;;;;;i.l
        Thatthc Delbndant has or had a posscssory
                                                        in*rcst or other regal interest in each
        or property.                                                                                 itcm

        To assist the United States in thc r

       ffi ?fljt;1ii:f$:i*:",'l*:i:ili:T'.','#JllJi:'ff.i,x1fl T;::::il;
       ;,,"";;;;;;i;;,#;;       ji:l.#  ;;;ll ",j#.Ifi  illi:l:                :ii?;ffi.:f ilf |["j

                                          PageTofll
4:22-cr-00140-JD            Date Filed 12/02/22            Entry Number 172             Page 8 of 11




                Agreem_ent; and (iv) directing all financial institutions
                                                                            to tum ov€r and surrender to the
                United States all funds and records regarding
                                                              "".";;r;
                by the Defendant pursuant to this plel agrei'me
                                                                             li"; i;;nl document signed
                property.
                                                                i,,;;;t;;#;;leeds              or substiture

               The Defendant waives all rights to noticc of
                                                            forfeiture under Rule 32.2 and ofany other
               action or proce_eding regarding such assets. Th.
               nBhts ro compliance by rhe United.srares *irh
                                                                    D.f*;;;; ;."-r,tr.ra waives a
                                  Any retated administrative         -, .pJ;;;le ieuarine, under t8
               *l;!;"lrjrr,r,                                    "r"i. 6r.iiy irr" d"-r.naunt is hereby
                         to._f.ule 32.2(b)(4), the Defendant agrees thar
               l'rr^slart                                                      the preliminary order of
               forfeiturewill satisfo the notice requJrement and will be final
                                                                                as to ttre Oefendant at the
               time it is enrered. In lhe event rhe forfeiture
               Del'endant asrees rhat the forfeiture order may
                                                                  ;   ;il       ;;;;e judgment, the
              judgment at any time pursuant to Rule
                                                                    b. ir";;;;;i          into the wrinen
                                                        J6.

              Ifthe Unired States discov^ers-that the Defendant has
                                                                    not fu,y disclosed all assets, the
              United_ Stares may seek fort'eiture-of.uny
                                                                ,ru..qr"nity_a;i""**a
              Defendant agrees to the immediate forfeiture
                                                                ofany .r"tiurr"ra.         ^..ii"""i,i.i"
               The Defendant furthcr agrees to make a      fu
                                                            and complete disclosure ofall assets oyer
              which Defendant exercises contror and those which
                                                                   ari iiia o,            uy nominees.
              TheDefendant agrees that.Federal Rule of C.i*i,.tpro."ai         "onoort"a
                                                                            re tt and U.S.S.G. ( lgl.g
              will not protect fiom forfeiture, assets disclosed Uy
              coopcration. The Defendant further agrees to .ubmit
                                                                       t" J"Aaunt as part of his,trer
                                                                       to u fotyg.rpt examinalion on
              the issue ofassets if it is deemed necesiary
                                                           by the Uri,.a S,i""r.

              The Defendant agrees to waive any doublejeop_ardy
                                                                      claims the Defendant may have as
              a result ola lbrfeiture proceeding againrt
                                                           ,ny ,f tn.,. prof""i", u, p-uiaJii, ty
             PIea Agreement antr agrees to waive any .r"rn,,                                  ilri.
                                                             ,rruliii-iir.i..iture des,ibed herein
             constitutes an excessive fine.

             Forfeifure of the Defendanl,s assets shall not be
                                                                     treated as satisfaction of any fine,
             restitution, cost of imprisonment, or any other penalty
                                                                         rhe Court may impose upon lhe
             Defcndant in addirion to forfciture. rr,. urit.i
                                                                 ii^iJr'r*]"rr" ,r," varue of forfeited
             property for restitution. but is not required to
                                                              do so.

   I   l The Dcfendant arso agrees to voruntarily transfcr all right, title,
                                                                                rnterest and craim in the
         above-described property and/or assets to the
                                                           united states of America. Furthermore, the
         Dcfendant attests, under penalty ol perjury,
                                                        rhat thc Defcndant owns the above-described




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4:22-cr-00140-JD        Date Filed 12/02/22          Entry Number 172               Page 9 of 11




        property and/or assels free of any liens and encumbrances, and that no
                                                                                       other person o,

        entity has a claim to the above-described property and,/or assets.




                                         ran d Other Provisions

     12. The Defendant and the Governmcnt stipurate and agrec ro the
                                                                         forowing tbr purposes of
        calculating the Defendant's sentence pursuant to the united States Sentencing
                                                                                          commission
        Guidelines

       A.      Pursuant to U.S.S.G. Section 28l.l(bxl), the Defendant wir be herd
                                                                                  accountable
               for a loss of more than $250,000 but not more than $550,000.

       The Dcfendant understands that these stipulations are not binding upon the
                                                                                          court or the
       united states Probation office, and that the D€fendant has no right to withdraw
                                                                                                 his/her
       plea should these stipulations not be accepted, Further, the Defendant
                                                                                     understands and

       acknowledges that these stipurations are binding on the Govemment only
                                                                                      in the event that

       the Defendant complies witir ALL ofthe terms ofthis Agreement and does
                                                                                       not cont€st any

       of the above stipulations or any readily provable relcvant conduct.

    13'Thc Defendant represents to the court that he/she has met with his/her
                                                                                        attomey on a
       sufficient number ofoccasions and for a sufllcient period offine ro discuss
                                                                                     the Defendant,s

       case and receive advice; thal the Defendant has been truthfur
                                                                        with his/her attomey and
      related all information of which the Dcfendant is aware perraining
                                                                                to the caser thar thc
      Defendant and his/her attorney have discussed possible defenses,
                                                                             if any, to the charges in
      the Superseding Indictrncnt including the cxistence of any exculpatory
                                                                                        or favorable
      evidence or witnesses, discussed tbe Defendant.s right
                                                                to a public trial by jury or by the

      Court, the right to the assislalce of ccunsel thrcughout the pioceedings,
                                                                                     tirc right io call
      witnesses in the Dcfendant,s behalf and compel their
                                                             attendance at trial by subpoena, the



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4:22-cr-00140-JD        Date Filed 12/02/22          Entry Number 172            Page 10 of 11




        right to confront and cross-examine the Govemmcnt's witnesses, the Defendant,s right to

        testitr in his/her orvn behalf, or to remain silent and have no adverse infcrcnces drawn from

        his/her silence; and that the Defendant, with the advice ofcounsel,lras weighed the relative

        benefits ofa trial byjury or by the Court versus a plea ofguilty pursuant to this Ageement,

        and has entered this Agreement as a matter ofthe Defendant,s liee and voluntary choice,

        and nol as a resuh ofpressure or intimidation by any person.

     14. The Defcndant is aware that l8 u.s.c. 6 3742 and 28 U.S.c.
                                                                       $ 2255 afford every defendant

        certain rights to contest a conviction and/or sentence. Acknowledging those rights, the

        Defendant, in exchange fbr the concessions made by the Government in this plea

        Agreement, waives the right to contest either the conviction or the sentence in any direct

        appeal or other post-conviction action, including any proceedings under 2g U.S.C.
                                                                                              $ 2255.

        This waiver does not apply to claims of ineffective assistance of counsel, prosecutorial

        misconduct, or future changes in the law that affect the defendant,s sentence. This

        agreement does not afl'ect the rights or obligations ofthe Govemment as set forth in 1g

       u.s.c. $ 3742(b). Nor does it limit the Govemment in its commenrs in or responses r.o any

       post-sentencing matteIs.

    l5' The Defendant waives all rights, whether asserted directly or by a representative, to request

       or receive fiom any deparhnent or agency ofthe united states any records pertaining to

       the investigation or prosecution of this case, including without Iimitation any records that

       nay bc sought under rhe Fr€edon of Information Act, 5 U.S.C. g 552, or the privacy Act

       of 1974, 5 U.S.C. 6 552a.

    16. The parties hcreby agree that this prea Agreemenl contains the entire agree
                                                                                          ent of the

       parties; that this Agreeurent supersedes alr prior promises, representations and
                                                                                          statements




                                          Page 10 of 1l
4:22-cr-00140-JD       Date Filed 12/02/22           Entry Number 172             Page 11 of 11




        of the parties; that this Agreemcnt shall not bc binding on any parry until the Defcndant

       tenders a plea of guilty to the court having jurisdiction over this matter; that flris Agreement

       may be modified only in writing signed by all parties; and that any and all other promises,

       representations and statements, whether made prior to, contemporaneous with or after
                                                                                                  this

       Agreemcnt, are null and void.


         lL- t-?J-
       Datc
                                                 c'/&?
                                              MOHAMMAD RIBHI FARRAJ
                                              Defendant




       Date
              iL -\-1--l-                                 1u/l--
                                              Seth Cole Rose, Esquire
                                              Defense Attorney



                                              ADAIR F. BOROUGHS
                                              UNITED STATES ATTORNEY

          tz- Z- ZZ_
       Date                                          A, Shoemake          Id.#1
                                             Assislant United States Attorncy




                                         Pagellofll


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