Stipulation Regarding FDIC Insured Status of Financial Institutions — U.S. v. Bhakta (S.D. Cal.), Dkt. 123

Summary

A Stipulation Regarding FDIC Insured Status of Financial Institutions, filed 10/21/24 as Document 123 in United States v. Denny Bhakta, Case 3:21-cr-03352, Southern District of California. The United States, through United States Attorney Tara K. McGrath and Assistant United States Attorneys P. Kevin Mokhtari and Eric R. Olah, and Defendant Denny Bhakta, through counsel Laura F. Marran and John D. Kirby, stipulate that the stated facts are true and may be read to the jury at trial. The stipulation lists Wells Fargo Bank, N.A.; First Republic Bank; Bank of America, NA; Celtic Bank; WebBank; Customers Bank; Vista Bank; Endeavor Bank; Cache Valley Bank; First Citrus Bank; and others as banks federally insured by the Federal Deposit Insurance Corporation ("FDIC") on the dates of the offenses charged in the indictment.

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     Case 3:21-cr-03352-JLS Document 123 Filed 10/21/24 PageID.943 Page 1 of 2



   TARAK. McGRATH
 1 United States Attorney
   P. KEVIN MOKHTARI
 2 ERIC R. OLAH
   Assistant United States Attorneys
 3 California Bar Nos. 2532831295513
   Office of the U.S. Attorney
 4 880 Front Street, Room 6293
   San Diego, CA 92101
 5 Tel: (619) 546-7540
   Eric.Olah@usdoj.gov
 6
 7 Attorneys for the Plaintiff
   UNITED STATES OF AMERICA
 8
                           UNITED STATES DISTRICT COURT
 9
                        SOUTHERN DISTRICT OF CALIFORNIA
lO UNITED STATES OF AMERICA,                   Case No.: 21-CR-3352-JLS
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            Plaintiff,
                                               STIPULATION REGARDING FDIC
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             V.                                INSURED STATUS OF FINANCIAL
13                                             INSTITUTIONS
      DENNYBHAKTA,
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                    Defendant.
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             Plaintiff, the United States of America, by and through its counsel, Tara K.
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      McGrath, United States Attorney, and P. Kevin Mokhtari and Eric R. Olah, Assistant
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      United States Attorneys, Defendant Denny Bhakta, by and through his counsel Laura F.
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      Marran and John D. Kirby, hereby stipulate that the following facts are true and may be
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      read to the jury at trial:
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      II
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      II
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      II
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      II
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      II
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      II
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      II
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      II
     Case 3:21-cr-03352-JLS Document 123 Filed 10/21/24 PageID.944 Page 2 of 2




 1         All of the financial institutions in this case-including Wells Fargo Bank, N.A.;
 2 First Republic Bank; Bank of America, NA; Celtic Bank; WebBank; Customers Bank;
 3 Vista Bank; Endeavor Bank; Bank of Southern California, N.A. (now California Bank of
 4 Commerce); Cache Valley Bank; First Citrus Bank; and Bank of Whittier, NA-are
 5 banks that are federally insured by the Federal Deposit Insurance Corporation ("FDIC").
 6 All of these financial institutions were federally insured by the FDIC on the dates of the
 7 offenses charged in the indictment and on all dates relevant to this case.
 8         SO STIPULATED AND AGREED.
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     DATED: October1\-, 2024
11                                               P.    VIN MOKHTARI
12                                               ERICR. OLAH
                                                 Assistant U.S. Attorneys
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14 DATED: October2/ , 2024
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18 DATED: October _al, 2024
                                                 DENNY BHAKTA
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                                                 Defendant
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