Stipulation and Order — United States v. Ameet Goyal (Dkt. 122, S.D.N.Y.)

Summary

Stipulation and Order, Document 122, filed 01/19/23, in Case 7:19-cr-00844-CS, S1 19 Cr. 844 (CS), between the United States Attorney for the Southern District of New York, Ameet Goyal, and Alka Goyal. It recites that the Court entered a Consent Preliminary Order of Forfeiture/Money Judgment (D.E. 97) imposing a Money Judgment of $3,600,000, of which $1,809,146.08 remains unpaid, and that the Government located a property jointly owned by the Defendant and Alka Goyal. Under the stipulation, Alka Goyal agrees to make a payment of $700,000, which the Government applies toward the Money Judgment, the Government will not seek forfeiture of the Defendant's interest in the property as a substitute asset, and the Government consents to the transfer of that interest to Alka Goyal.

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

Full text

Text recognized from a scanned document; may contain errors.

Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 1 of 7

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA :
AMEET GOYAL, > $119 Cr. 844 (CS)
Defendant.

WHEREAS, on or about June 26, 2020, AMEET GOYAL (the.“Defendant”) was
charged in a six-count Superseding Indictment, $1 19 Cr. 844 (CS) (the “Indictment”), with health
care fraud, in violation of Title 18, United States Code, Sections 1347 and 2 (Count One); wire
fraud, in violation of Title 18, United States Code, Sections 1343 and 2 (Count Two); false
statements relating to health care matters, in violation of Title 18, United States Code, Sections
1035 and 2 (Count Three); bank fraud, in violation of Title 18, United States Code, Sections 1344,
3147(1) and 2 (Count Four); making false statements to a bank, in violation of Title 18, United
States Code, Sections 1014, 3147(1) and 2 (Count Five); and making false statements, in violation
of Title 18, United States Code, Sections 1001, 3147(1) and 2 (Count Six);

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

offenses charged in Counts One through Three of the Indictment;
Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 2 of 7

WHEREAS, the Indictment included a second forfeiture allegation with respect to
Counts Four and Five of the Indictment, seeking forfeiture to the United States, pursuant to Title
18, United States Code, Section 982(a)(2)(A), of any and all property, real and personal,
constituting or derived from proceeds obtained, directly or indirectly, as a result of the commission
of the offenses alleged in Counts Four and Five of the Indictment, including but not limited to a
sum of money in United States currency, representing the proceeds traceable to the commission of
the offenses charged in Counts Four and Five of the Indictment;

WHEREAS, the Indictment included a third forfeiture allegation with respect to
Count Six of the Indictment, seeking forfeiture to the United States, pursuant to Title 18, United
States Code, Section 982(a)(3), of any and all property, constituting or derived from proceeds
obtained, directly or indirectly, as a result of the commission of the offense alleged in Count Six
of the Indictment, including but not limited to a sum of money in United States currency,
representing the proceeds traceable to the commission of the offense charged in Count Six of the
Indictment;

WHEREAS, on or about September 13, 2021, the Defendant pled guilty to Counts
One through Six of the Indictment, pursuant to a plea agreement with the Government;

WHEREAS, on or about September 15, 2021, this Court entered a Consent
Preliminary Order of Forfeiture/Money Judgment (the “Forfeiture Order”) (D.E. 97) against the
Defendant, imposing a Money Judgment in the amount of $3,600,000 in United States currency
(the “Money Judgment”), representing the amount of proceeds traceable to the offenses charged

in Counts One through Six of the Indictment that the Defendant personally obtained;
Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 3 of 7

WHEREAS, the Forfeiture Order authorized the Government, pursuant to Title 21,
United States Code, Section 853(p), to seek forfeiture of substitute assets of the Defendant up to
the uncollected amount of the Money Judgment.

WHEREAS, to date, $1,809,146.08 of the Money Judgment entered against the
Defendant remains unpaid;

WHEREAS, the Government has located the following asset of the Defendant:

a. 5 Mount Holly Drive, Rye, New York 10580, Map No. 20670, Lot 25, Town
and Village of Harrison, County of Westchester, State of New York,

(the “Subject Property”);

WHEREAS, the Subject Property is jointly owned by the Defendant and his wife,
Alka Goyal;

WHEREAS, the Government asserts that Defendant’s interest in the Subject
Property is forfeitable as a substitute asset; and

WHEREAS, the Government has agreed to accept the sum of $700,000 in United
States currency from Alka Goyal, representing the value of the Defendant’s interest in the Subject
Property.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and
between Damian Williams, United States Attorney for the Southern District of New York,
Assistant United States Attorneys Vlad S. Vainberg, David Felton, and Margery Feinzig, of
counsel, and the Defendant and his counsel, Marc Mukasey, Esq., Torrey K. Young, Esq., and
Stephanie Guaba, Esq., and Alka Goyal and her counsel Evan T. Barr, Esq. and Linda Imes, Esq.,

that:
Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 4 of 7

Ls Upon entry of this Stipulation and Order, Alka Goyal agrees to make a
payment to the Government in the amount of $700,000 in United States currency (the “Payment”)
which shall be made by bank or certified check payable to the United States Marshals Service and
delivered by mail to the United States Attorney’s Office, Southern District of New York, Attn:
Money Laundering and Transnational Criminal Enterprises Unit, One St. Andrew’s Plaza, New
York, New York 10007 and shall indicate the Defendant’s name and case number.

2. Upon receipt, the Government shall apply the Payment towards the
satisfaction of the Money Judgment.

3: Upon receipt of the Payment, the Government shall not seek the forfeiture
of the Defendant’s interest in the Subject Property as a substitute asset. The Payment shall be in
full satisfaction and settlement of all claims, civil or criminal, that the Government may have to
the Subject Property arising from the offenses described in the Indictment.

4, The Government hereby consents to the transfer of the Defendant’s
ownership interest in the Subject Property to Alka Goyal under the terms and conditions set forth
in this Stipulation and Order.

S. The Government agrees to execute any such documents as necessary to
ensure that it has released any and all claims it may have to the Subject Property.

6. This Stipulation and Order constitutes the entire agreement between the
Government, the Defendant, and Alka Goyal (the “Parties”) on the matters raised herein, and no
other statement, promise or agreement, either written or oral, made by any party or agents of any
party that is not contained in this Stipulation and Order shall be enforceable.

Ts Each party agrees to bear their own costs and attorneys fees.
Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 5 of 7

8. The Parties hereby waive all rights to challenge or contest the validity of

this Stipulation and Order.

9. The Court shall have exclusive jurisdiction over the interpretation and

enforcement of this Stipulation and Order.

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
Case 7:19-cr-00844-CS Document 122 Filed 01/19/23 Page 6 of 7

10. The signature page of this Stipulation and Order 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 same instrument.

AGREED AND CONSENTED TO:

DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York

By:

VLAD S. VAINBERG

DAVID FELTON

MARGERY FEINZIG

Assistant United States Attorneys
One St. Andrew’s Plaza

New York, NY 10007

(212) 637-1029/-2299

ALKA GOYAL

By:

By:

EVAN T. a ESQ.
One New York Plaza
New York, NY 10004

LINDA IMES, ESQ.
51 Madison Avenue
New York, NY 10010

Attorneys for Alka Goyal

1/18/2023
DATE
Case 7:19-cr-00844-CS Document 122

By: {

AMEEBT GOYAL

By:

Q.
TORREY K. YOUNG, ESQ.
STEPHANIE GUABA, ESQ.
570 Lexington Ave, Suite 3500
New York, NY 10022

Attorneys for Defendant

SO ORDERED:

HONORABLE CATHY SEIBEL
UNITED STATES DISTRICT JUDGE

Filed 01/19/23 Page 7 of 7

DATE

1/19/23
DATE


File and source

File

122.pdf

Size

1,352,727 bytes

SHA-256

07d2af68ec83ed116732b6f79ec40c671095d2b219f400a057e1024fbd14b1af

Our copy

122.pdf

Original

No public link identified.