Consent Preliminary Order of Forfeiture/Money Judgment — U.S. v. Ali Rashan, 25 Cr. 283 (PAE), Dkt. 62

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Consent Preliminary Order of Forfeiture/Money Judgment, Document 62, filed 04/17/26, in Case 1:25-cr-00283-PAE, United States of America v. Ali Rashan. It recites a two-count Information charging conspiracy to commit healthcare fraud under Title 18, United States Code, Section 371 (Count One) and making false statements relating to health care matters under Section 1035 (Count Two), and a plea of guilty to both counts under a plea agreement. The Defendant agrees to forfeit a sum of money equal to $24,486,238, and a money judgment of that amount is to be entered against the Defendant. Payments go to the United States Marshals Service, the United States may seek substitute assets under Section 853(p), and the Court retains jurisdiction. The signature block names the Honorable Paul A. Engelmayer.

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Case 1:25-cr-00283-PAE Document62 Filed 04/17/26 Page1of4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
: CONSENT PRELIMINARY ORDER
-V.- OF FORFEITURE/
: MONEY JUDGMENT
ALI RASHAN
Defendant. ‘ $1 25 Cr. 283 (PAE)

WHEREAS, on or about 4/ ( 201] RASHAN (the “Defendant”’), was charged in
a two-count Information, $1 25 Cr. 283 (PAE) (the “Information”), with conspiracy to commit
healthcare fraud, in violation of Title 18, United States Code, Section 371 (Count One); and
making false statements relating to health care matters, in violation of Title 18, United States Code,
Section 1035 (Count Two);

WHEREAS, the Information included a forfeiture allegation as to Counts One and
Two of the Information, seeking forfeiture to the United States, pursuant to Title 18, United States
Code, Section 982(a)(7), any and all property, real or personal, that constitutes or is derived,
directly or indirectly, from gross proceeds traceable to the commission of the offenses charged in
Counts One and Two of the Information, including but not limited to a sum of money in United
States currency representing the amount of proceeds traceable to the commission of the offenses
charged in Counts One and Two of the Information;

WHEREAS, on or about] !#/26 the Defendant pled guilty to Counts One and
Two of the Information, pursuant to a plea agreement with the Government, wherein the Defendant
admitted the forfeiture allegation with respect to Counts One and Two of the Information and

agreed to forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(7),
a sum of money equal to $24,486,238 in United States currency, representing the amount of
proceeds traceable to the commission of the offenses charged in Counts One and Two of the
Information;

WHEREAS, the Defendant consents to the entry of a money judgment in the
amount of $24,486,238 in United States currency, representing the amount of proceeds traceable
to the offenses charged in Counts One and Two of the Information that the Defendant personally
obtained; and

WHEREAS, the Defendant admits that, as a result of acts and/or omissions of the
Defendant, the proceeds traceable to the offenses charged in Counts One and Two of the
Information that the Defendant personally obtained cannot be located upon the exercise of due
diligence.

IT IS HEREBY STIPULATED AND AGREED, by and between the United States
of America, by its attorney Sean S. Buckley, Attorney for the United States, Assistant United States
Attorneys Timothy V. Capozzi, Jaclyn Delligatti, and Qais Ghafary, of counsel, and the Defendant
and his counsel, David M. Eskew Esq., Jarrod L. Schaeffer, Esq., and Anna Skotko, Esq. that:

1. As a result of the offenses charged in Counts One and Two of the
Information, to which the Defendant pled guilty, a money judgment in the amount of $24,486,238
in United States currency (the “Money Judgment”), representing the amount of proceeds traceable
to the offenses charged in Counts One and Two of the Information that the Defendant personally
obtained, shall be entered against the Defendant.

2. Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal Procedure, this

Consent Preliminary Order of Forfeiture/Money Judgment is final as to the Defendant ALI
Case 1:25-cr-00283-PAE Document62_ Filed 04/17/26 Page3of4

RASHAN, and shall be deemed part of the sentence of the Defendant, and shall be included in the
judgment of conviction therewith.

=m All payments on the outstanding money judgment shall be made by postal
money order, bank or certified check, made payable, in this instance, to the United States Marshals
Service, and delivered by mail to the United States Attorney’s Office, Southern District of New
York, Attn: Illicit Finance and Money Laundering Unit, 26 Federal Plaza, 38" Floor, New York,
New York 10278 and shall indicate the Defendant’s name and case number.

4, The United States Marshals Service is authorized to deposit the payments
on the Money Judgment into the Assets Forfeiture Fund, and the United States shall have clear
title to such forfeited property.

3 Pursuant to Title 21, United States Code, Section 853(p), the United States
is authorized to seek forfeiture of substitute assets of the Defendant up to the uncollected amount
of the Money Judgment.

6. Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the
United States Attorney’s Office is authorized to conduct any discovery needed to identify, locate
or dispose of forfeitable property, including depositions, interrogatories, requests for production
of documents and the issuance of subpoenas.

7. The Court shall retain jurisdiction to enforce this Consent Preliminary Order
of Forfeiture/Money Judgment, and to amend it as necessary, pursuant to Rule 32.2 of the Federal

Rules of Criminal Procedure.

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
Case 1:25-cr-00283-PAE Document 62

8.

Filed 04/17/26 Page4of4

The signature page of this Consent Preliminary Order of Forfeiture/Money

Judgment may be executed in one or more counterparts, each of which will be deemed an original

but all of which together will constitute one and the same instrument.

AGREED AND CONSENTED TO:

SEAN S. BUCKLEY
Attorney for the United States
Southern District of New York
Acting under Authority
Conferred by 28 U.S.C. § 515

Timothy Capozzi / Jaclyn Délligatti /Qais Ghafary
Assistant United States Attorneys
26 Federal Plaza
New York, NY 10278
Als

Ali Rashan —_)

David M. Eskew, Esq.
Jarrod L. Schaeffer, Esq.
Abell Eskew Landau LLP
256 5™ Ave., 5" Floor
New York, NY 10001

By:

ALI RASHAN

By:

By:

Anna Skotko, Esq.
SKOTKO LAW PLLC

29 Broadway, Floor 31
New York, NY 10006
Attorneys for the defendant

SO ORDERED:

HONORABLE PAUL A. ENGELMAYER
UNITED STATES DISTRICT JUDGE

4-/\7/26

DA

Ly [17/24

DATE


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