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Exhibit B — United States v. James Wessels (District of New Jersey, Document 54-2)

Summary

This is Exhibit B to Document 54-2: an August 8, 2023 letter from Assistant United States Attorney Daniel A. Friedman, District of New Jersey, to Mark W. Catanzaro, counsel for James Wessels. It says the Government is making certain discovery available through the USAfx portal under a Protective Order. The materials include communications between James Wessels and Sieff Robert Sargeant and William Ingram regarding the conspiracy to launder Paycheck Protection Program loan proceeds. The letter states that the pre-indictment disclosure is voluntary and not complete, and that the Government is willing to provide it to facilitate plea negotiations.

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Cite this document

“Exhibit B — United States v. James Wessels (District of New Jersey, Document 54-2).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-adrienne-ponzo-dkt-54-2-d-n-j-81cca3b373/, SHA-256 3c9b3ce9e7ea183480a5e8b5f8ac3fbddffca6c3962233ea6afeb286e67331ef.

Full text

Case 1:24-cr-00267-KMW   Document 54-2   Filed 01/14/25   Page 1 of 3 PageID: 428




               Exhibit B
  Case 1:24-cr-00267-KMW                 Document 54-2       Filed 01/14/25   Page 2 of 3 PageID: 429




                                                                               U.S. Department of Justice
                                                                                     United States Attorney
                                                                                     District of New Jersey

PHILIP R. SELLINGER                                                                401 Market Street, Fourth Floor
United States Attorney                                                             Camden, New Jersey 08101-2098

DANIEL A. FRIEDMAN                                                                 Direct Dial: 856.968.4867
Assistant United States Attorney                                                   Email: Daniel.friedman2@usdoj.gov


August 8, 2023

Via Email Attachment

Mark W. Catanzaro
21 Grant Street
Mt. Holly, NJ 08060

           Re:        U.S. v. James Wessels

Dear Mr. Catanzaro:

        The Government is providing certain discovery relating to the Government’s case against your
client, James Wessels, in the above-referenced matter. The Government is making the discovery
available via the USAfx portal. A link will be provided under separate cover. Please be advised that
these materials are being provided pursuant to a Protective Order that has been entered in this case.

                                           Disclosure by the Government

       The discovery materials include communications between James Wessels and Sieff Robert
Sargeant and William Ingram regarding the conspiracy to launder Paycheck Protection Program loan
proceeds and communications between James Wessels and                      regarding fraudulent tax
forms that James Wessels prepared for              ’s PPP loan application.

                                   This Disclosure Is Voluntary and Not Complete

        Please note that our Office is providing this pre-indictment discovery to you voluntarily. Neither
Federal Rule of Criminal Procedure 16 nor any statute or rule requires that our Office make discovery
to a person unless and until that person has been indicted. Although the Government is under no legal
obligation to provide the enclosed material before the filing of an indictment, see United States v.
Sgarlat, 705 F. Supp. 2d 347, 355 (D.N.J. 2010), we are willing to do so here to facilitate plea
negotiations. Also, please be advised that the disclosure of this evidence does not imply that our Office
has made, or will make, complete pre-indictment discovery to you. Should your client ultimately be
indicted, you will receive all of the discovery to which your client is entitled. However, should you
desire to receive and/or review any other evidence or materials relevant to the investigation and/or
prosecution of your client, please feel free to make a request, and we will consider each such request as
it is made.

                                                       ***
 Case 1:24-cr-00267-KMW          Document 54-2         Filed 01/14/25    Page 3 of 3 PageID: 430


       If you have any questions about the enclosed materials, please do not hesitate to contact me.
Once you have had an opportunity to review the enclosed information with your client, please contact
me regarding disposition of this matter.

                                                     Very truly yours,

                                                     PHILIP R. SELLINGER
                                                     United States Attorney

                                                     /s/ Daniel A. Friedman
                                           By:       DANIEL A. FRIEDMAN
                                                     JASON M. RICHARDSON
                                                     Assistant U.S. Attorneys




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54-att2.pdf
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146,698 bytes
SHA-256
3c9b3ce9e7ea183480a5e8b5f8ac3fbddffca6c3962233ea6afeb286e67331ef
Our copy
54-att2.pdf
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