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Plea Agreement with Azhar Rana — United States v. Rana (D.N.J., Document 17, February 18, 2021)

Summary

A plea agreement letter dated February 18, 2021 from the U.S. Attorney's Office for the District of New Jersey to William Purpura, Esq., counsel for Azhar Rana, filed 07/01/21 as Document 17 in Case 2:21-cr-00527-ES. The letter states that the Government will accept a guilty plea to a two-count Information charging bank fraud in Count One and money laundering in violation of 18 U.S.C. § 1957 in Count Two, and that the offer expires on March 5, 2021 if a signed copy is not received. It describes sentencing, stipulations, waiver of appeal rights and forfeiture, and states that Rana agrees the aggregate value of the property was $5,677,473 and to a Money Judgment in that amount.

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 with Azhar Rana — United States v. Rana (D.N.J., Document 17, February 18, 2021).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-rana-dkt-17-d-n-j-2b1ae29b32/, SHA-256 2de5311492990396171c7946732027ce6ffae21fc55391a39dc7933797dc3e91.

Full text

 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 1 of 12 PageID: 48




                                           U.S. Government of Justice

                                           Un/ted Seawc Aetw’wy
                                           District c/New Jersey


                                           970 thnad Seruct                    (973) 297-2020
                                           Win,, kNew Mxcv 07)02



                                            February 18, 2021

William Purpura, Esq.
                                                                   C r. 21 527 ES
8 East Mulben-y Street
                                                                        -




Baltimore, Maryland 21202

            Re: Plea Agreement with Azhar Rana

Dear Mr. Purpura:

             This letter sets forth the plea agreement between your client, Azhar
Rana, and the United States Attorney for the District of New Jersey (“the
Government”). The Government’s offer to enter into this plea agreement will
expire on March 5, 2021, if a signed copy is not received by the Government on
or before that date.

Charge

            Conditioned on the understar.dings specified below, the
Government will accept a guilty plea from Azhar Rana to a two-count
Information, which charges him in Count One with bank fraud in violation of
18 U.S.C. § 1244, and in Count Two with money laundering in violation of 18
U.S.C. § 1957. If Azhar Rana enters a guilty plea and is sentenced on these
charges, and o’ ‘erwise fully complies with all of the terms of this agreement,
the Governmeia will not initiate any furth’r criminal charges against Azhar
Rana for his scheme to fraudulently obtain government stimulus loans meant
for small businesses occurring in or around April 2020.

             However, in the event that a guilty plea in this matter is not
entered for any reason or the judgment of conviction entered as a result of this
guilty plea does not remain in full force and effect, Azhar Rana agrees that any
dismissed cha. :.;es and any other charges that are not time-barred by the
applicable stan te of limitations on the date this agreement is signed by Azhar
Rana may be commenced against him, notwithstanding the expiration of the
limitations pr d after Azhar Rana signs the agreement.
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 2 of 12 PageID: 49




Sentencing

              The violation of 15 U.S.C. § 1344 to which Azhar Rana agrees to
plead guilty in Count One carries a statutory muedmum penalty of 30 years’
imprisonment and a statutory maximum fine equal to the greatest of: (1) $1
million, or (2) twice the gross amount of arty pecuniary gain that any persons
derived from ti offense, or (3) twice the gioss amount of any pecuniary loss
sustained by nit victims of the offense.

             Tie violation of 18 U.S.C. § 1957 to which Azhar Rana agrees to
plead guilty in aunt Two carries a statutory maximum penalty of 10 years’
imprisonment Lad a statutory maximum fi::e equal to the greater of: (1)
$250,000; or (1 twice the gross amount of any pecuniary gain that any
persons derivec from the offense, or (3) twice the gross amount of any
pecuniary loss sustained by any victims of the offense.

            Fines imposed by the sentencing judge may be subject to the
payment of interest.

             TIc sentence to be imposed LinDa :\zhar Rana is within the sole
discretion of ti   sentencing judge, subject to the provisions of the Sentencing
Reform Act, IS U.S.C. § 355 1-3742, and he sentencing judge’s consideration
of the United    .ttes Sentencing Guidelines. The United States Sentencing
Guidelines  ar    (Ivisoty, not mandatory. The sentencing judge may impose any
reasonable sci erice up to ad inciLiding the suitutory maximum term of
               ..




imprisonment      id the maximum statutor\ fine. The Government cannot and
does not make my representation or promise as to what guideline range may
be found by the sentencing judge, or as to what sentence Azhar Rana
ultimately vill receive.

             Further, in addition to imposing any other penalty on Azhar Rana,
the sentencing pudge: (1) will order Azhar nn:m to pay an assessment of $100
per Count (SZ’) here) pursuant to 18 USC. § 3013, which assessment must
be paid by thm ate of sertv:ncing; (2) may oicicr Azhar Rana to pay restitution
pursuant to N U.S.C. § 3U63 et seq.; (3) r:iust order forfeiture pursuant to
18 U.S.C. § 9 cl) and 21 LS.C. § S53; and (4) pursuant to is u.s.c. § 3583,
may require       ar Rana to serve a term 0: supervised release of not more than
5 years, whic. 411 begin rt che expiration of any term of imprisonment
imposed. Sin ,!. I Azhar l\an in be placed on a term of supervised release and
subsequently ulate any of the conditions (ii supervised release before the
expiration of its tei-m, Azhnr Rana nay be sunteieed to not more than 3 years’
imprisonment in addition to any prison term previously imposed, regardless of
the statutory maximum term of imprisonirtnt set forth above and without

                                      -0-
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 3 of 12 PageID: 50




credit for time reviously served on post-reieasc supervision, and may be
sentenced to an additional term of supen’i ed release.

Rkhts of the C’   emmentk:garding_Sentcu         itz


               E-   pt as oth cv:ise provided iii this agreement, the Government
reserves its ri .1 to take any position with respect to the appropriate sentence
to be imposed a Azhar PLain by the sentencing judge, to correct any
misstatements IL-Iatmg to I1C sentencing proceedings, and to provide the
sentencing judc and tlfl: United States Probation Office all law and
information rclcvant to sentencing, favorable or othenvise. In addition, the
Government may inform the sentencing judge and the United States Probation
Office of: (1) this agreement; and (2) the full nature and extent ofAzhar Rana’s
activities and       vant conduct with respe to this ease.

Stipulations

               T Govcrnrn e:ii and Azhar Rina agree to stipulate at sentencing
to the states     s set foL    a the attached S.i:edule A, which hereby is made a
part of this pl     nreemiit     [his agreement to stipulate, however, cannot and
does not bind     c senten’ inL judge, who may make independent factual
findings and III.    reject nay or all of the stipulations entered into by the
parties. To lit atent JiLl he parties do ut stipulate to a particular fact or
legal conclusb:t, zitch reserves the right U. argue the existence of and the effect
of any such ft     or conclLls:un upon the seri:enee. Moreover, this agreement to
stipulate on J part of the Government is based on the information and
evdanee tba       c Governnici a possesses as of the dale of this agreement.
Thus, if the G \tjrnrnent obtains or receiv s additional evidence or information
prior to sentencing that it determines to he credible and to be materially in
conflict with a     stipulation in the attach U Schedule A, the Government shall
not be bound        my so i si ipulation. A determination that any stipulation is
not binding          not rt      either the Government or Azhar Rana from any
other portiot       his nr :nent, including toy other stipulation. If the
sentencing (         -ejects oH ipulation, both: parties reserve the right to argue on
appeal or at       —set tom      proceedings that the sentencing court was within
its discret mi    LI nut hon: to do so. These stipulations do not restrict the
                             -




 Government ‘a richt to respot i1 to questiot s from the Court and to correct
misinformati ‘a hat has been provided to the Court.

Wai’.er ci A; a    ;acl Pos’-Sntencing Rir:its

             A    ct (briN in Schedule A, tIme (loverament and Azhar Rana waive
certain rights    die an a cal, collateral attack, writ, or motion after

                                         -3
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 4 of 12 PageID: 51




sentencing, in’              Jing h tt i t limited to an appeal under 18 U.S.C. § 3742 or a
motion under                  U.S.C.   .255.

Forf@it.ti re

               As part of his acceptance of responsibility, and (1) pursuant to 18
U.S.C. § 982(:c2), Azhar ‘ana agrees to forfeit to the United States all of his
right, title, an interest in all property, real or personal, that constitutes or is
derived from         rends traceable to the bank fraud charged in Count One of the
Information, l (2) pursi.iant to 18 U.S.( . § 9S2(a)(1), Azhar Rana agrees to
forfeit to the       ted Stairs, any and all prIpert involved in, or traceable to, the
money launcl       n; offense charged in COLIt it Two of the Information. Azhar
Rana furthe      rites        that he aggregate value of such property was $5,677,473;
that one or ii            I the c      lii ions set forth in 21 U.S.C. § 853(p) exists; and
that the Uiii’     States i             nibre entitled to forfeit substitute assets equal to
the value of tI a pro teects ‘ tamed by the defendant (the “Forfeiture Amount”),
in an amount         .1 tI eNrol l $5,677,473 (the “Money Judgment”).
                     .                                                            The
defendant cci        :ats to tb: entry of an order requiring the defendant to pay the
Forfeiture An               in I ho lijanner described below (the “Order”), and that the
Order will lx          .1 as to t I te defendant pri r to sentencing, pursuant to Rule
32.2(b)(4) of I:         eleral ules of Criminal Procedure, and which may be
satiafied iii v.           r in p: rt with substitute assets. The defendant further
agrees that u            entry of the Order, the I. nited States Attorney’s Office is
authorized to               nt any discovery need ci to identify, locate, or dispose of
property soil.             to r’ the Lorfeiture Aiiount in full or in connection with
any petition:             with a ard to proceecla or substitute assets, including
depositions,        .1                  aod requests for procloiction of documents, and the
                                               ,


issuance of        p

                 A            .   ,vtneni      ide in full or partial satisfaction of the Forfeiture
Arnou in shal1           .        (all        nostal money ot dir, bank, or certified check, made
payable in U                                he United States Marshals Service, indicating the
defendant’s 0:.                 ai id    e nn nber on the thee of the check; and shall be
delivered h\                   t° the t. nited States AtnrIle\’’s Office, District of New Jersey,
Att i: Asset F                    ic and Moi cy Launcle ing Unit, 970 Broad Street, 7th Floor,
Newark, Ncu                  rs’ v 071 2.

                                         iither agrees to forfeit all of his right, title, and interest
in the prop’r                    led Ufl ie attached Schedule B, and which Defendant admits
have the icqi                 i   ‘‘x!e      th offenses charged in Counts One and Two of the
Information                  I i    a ic
                                     .
                                            c are forfeitable to the United States of America
pursuant to                   1]H.C. & 1d2(a)(1) and 982(a)(2) (the “Specific Property”). The
Defendant aw                            :.
                                              perifle Property is subject to forfeiture as property,
real or pers                      a   cit i.ites or is der*ed, directly and indirectly, from
  Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 5 of 12 PageID: 52




proceeds trac                    H             nmission of tli otTo nses in violation of 18 U.S.C. §
1344, and pr                                 3 in, or traceable to, the money laundering offense
charsed in C                 \VC) ol        le In:lrnitition. \nv forfeited money and the net
proceeds fror’i                             he Specific Proper:’ will be applied to the Money
Judszme III,                                action taereof.


              f-)        .     it ft I ther consents to time administrative and/or civil
judicial forfeit               i!        ecifle Property pursuant to 18 U.S.C. § 981(a)(1)(C).
Defc-nclant her               ,ec-Qp        to the entry of Preliminary Orders of Forfeiture and
Interlocutory                           in as to the Specific Property pursuant to Rule
32.2(b) of the       -                      of Criminal Pn ct’dure as the United States
Atror nev’s OVh                                  Deki:dant agrees to execute a Preliminary
Order of Porf                                 tenon mtory Order of Sale as to the Specific
Property by                                  i-ti hen ing ii. Ins ease. Defendant agrees that he
 vil not Ide a                            I [loll tbr erniss om i or mitigation in any forfeiture
proceeding in                            pecile’ I toperty timid will not cause or assist anyone
else in doing                          tent [ )eferidant ins filed a claim or petition in any
ad iii n is [tat i                      cial f riciture proceeding involving the Specific
Property, stic                           etitinns are henby deemed withdrawn. Defendant
further agre                         H ‘leces rv steps in pass clear title to the Specific
Prc’riertv to                             es, including, but not limited to, the surrender of
sun     ar’;pel:                          l St [es MarshIs Service and the execution of all
flt   uSS3F\’ Ct


                Ar                      v vets the -equir inents of Rules 32.2 and 43(a) of the
Federal   Rule                         I     ncedtire regal limig notice of the forfeiture in the
Charging ins                            u     in-melt of [lu forfeiture at sentencing, and
in    1)0 J t hr                       it re iii the judu,iient. The defendant understands
that clai:in:                             naiL of je seiterne that may b-c imposed in this case
ann \\‘ai\’cS                             the no t to ocR se him of this ptirstiant to Rule
1 (b)(1)(J) o:                           Rules it Ci-imitintil ‘roeecltire at the guilty plea
pro reed i ng.                          mit waives any ni nfl constitutional, statutory, and
other challen                             leiture on any am il all grounds, including that the
forfeit ore C                              ces iv, fine, or )iiflishmnt.Iit under the Eighth
Amend neni                                tmnd rst.ood that tiny forfeilure of the defendant’s
as-cts shall                               as satisfaction of any fine, restitution, cost of
irfllJrSOnlTiec                              oeitaltv the C’ urt may mposc upon him in
acl(l]tl(,la LO

                                       ft   Per tiemees dit.: mini 1ater than the date he enters
his plea of                            p1   ide a compl 00 and ic-curate Financial Disclosure
St i,nient o                           rovide I y the Government. If Azhar Rana fails to
pt-i )\2(lt’ a cc’                     ICUITh e    inaneitil Disc losLire Stmiterncnt by the date he
emtei—s his I                          or if tac ‘lovc-rinent determines that Azhar Rana has
                                                        -5
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 6 of 12 PageID: 53




intentionally filled to disclose assets on his Financial Disclosure Statement,
Azhar Rana atrecs hat that failure constit LUCS a material breach of this
agreement, aud tao Government reserves the right, regardless of any agreement
or stipulation that mht othenvse apply, to oppose any downward adjustment
for acceptance of :sponL:Hlity pursuant to U.S.S.Q. § 3E1.l, and to seek leave
of the Court H wi hdraw rum this agreement or seek other relief.

Immigration Cons ‘ucnces

              A:utr Pana understands that, if he is not a citizen of the United
States, his g: a u:t to the charged offen e will likely result in his being
subject to inn :ii:ioa proceedings and n moved from the United States by
making him dicer r:abe, excludble, or in;±nissible, or ending his
naturalizatie      ..:i ar Fana uncerstands hat the immigration consequences of
this plea will be i!u1)ced in a sparate prtccecling before the immigration
authorities. A: lair ha ia wants and agrees to plead guilty to the charged
offense regai ic:ss ut any itrirnigration consequences of this plea, even if this
plea vi1l cause hi      emu at from the Unite] States. Azhar Rana understands
that he is ho    d       his     ilty plea i-cgardless of any immigration consequences
of the plea. A.eo: ingly, .a:har Rana waives any and all challenges to his guilty
plea and to ha s.              based on any immigration consequences, and agrees
not to seek ta ‘vi: idraw his auilty plea, or to file a direct appeal or any kind of
collateral an               i:gim4 his guilty plea, convicLion, or sentence, based on
                               .




any immigni’                cjueiicc’S of his guilty plea.


Other Provi&

                                   a   ‘                     to tIu. United States Attorney’s Office for
                                            reolent is Lriiited
the District o                             siv and iiC United States Government of Justice
                                             .




Criminal Div                             .iu    ectiori, and cannot bind other federal, state, or local
authorities.          )\\              or, ti   iovefl)iuent will bring this agreement to the
attention of          ret              rose t ing offices, if requested to do so.

                       5                  was reached without regard to any civil or
                                           reer ret
administrati\’         a     ats that may be pending or eohimencecl in the future
against Azh,                       1115    I reitint clues not prohibit the United States, any
agency thor                .
                               a: itig I te Internal Revenue Service and Immigration and
Customs Liii      .       a.v: it) or any third party       cmi initiating or prosecuting any
civil or arIa:.         .‘,i:i\’: pt-oceed:iig against \zhar Rana.


                                             inn of thi agreement shall vecludle Azhar Rana from
pursuing in                            :      )flac fort ill, when   ormitted by law, an appeal, collateral
attack, writ.                                i r   fling I hat Azhtrr Rana received constitutionally
inellcc’tive as       at                   e of    insel.
                                                                  -6-
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 7 of 12 PageID: 54




No Other Pro! :“s

                       iiwnt ronstit utes th plea agreement between Azhar
Rana and the       i:   rut ad supersedes any previous agreements between
them. No ad ‘u’auI promises, aureernems. or conditions have been made or
will be macic u:J s sri hrth in \vnctng an signed by the parties.

                                          Very truly yours,

                                          Rachaci A. Honig
                                          Acting United States Attorney

                                               J       47
                                                   /
                                          By: ANDREW MACURDY
                                          Assistant U.S. Attorney




APPROVED:

     /
                      /       1’7
 (       C   —   .‘  y    .




COURTIcEYA :!u VARU
Chief, Econur I :jmcs Unit

U.S. Attorne:    re For tie District of New Jersey
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 8 of 12 PageID: 55




             I hvr rcviv(cl this letter from my attorney, William Purpura, Esq.
I have read it... N’ aLtorlu\ and I have discussed it and all of its provisions,
including tho      Icl(Iressll g the charge, sentencing, stipulations, waiver,
forfeiture and tnnitrati cii ‘onsequences. I understand this letter fully. I
hereby accepi c terms alit conditions and acknowledge that it constitutes the
plea agreetra ifi between th’ Parties. I understand that no additional promises,
agreements, or e id ii ions have been made or ‘tIl be made unless set forth in
writing and sig      I lv he parties. I want to plead guilty’ pLirsuant to this plea
agreement.

AGREED AND AC CVI’TLD:




                                              Date:D      \I-2°\
Azar Rana



             I h    ‘   ausse with my cheat this plea agreement and all of its
provisIons, tne           use   Zressing the charge. sentencing, stipulations,
waiver, forfeitur    ii iininhration conseqt ences. My client understands this
plea agrecrncnl     lv and wants to plead gi iltv pursuant to it.



          /                 --                Date:   0—\t0             \
William Rirp




                                        -8-
 Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 9 of 12 PageID: 56
                           A




                                               Agreement Wi h Azhar Rana

                                                     Schedule A

             1. i’hc Govern!nent and Azhar Rana recognize that the United
States Sente:        CLIide!i,as arc not binding upon the Court. The Government
and Azhar R.y,c nvrthc!.ss agree to the stipulations set forth herein, and
agree that tN (.         should sentence Azhur Rana within the Guidelines range
that results Lou:         total uicicljnes offense level set forth below. The
Government an-   i.;\; !i:ir Ru:  fttrtl’.cr agree that neither party will argue for the
imposition of a :utnce ouish Ic the Guidelines range that results from the
agreed total Cu     i: us oft nsc level.

           2. 1. a v rv-: of the United Slates Sentencing Guidelines effective
November 1, 2(- N a-’ s in this case.

                                                     Count One
                                                     (l3anh Fraud)

                               ii              a guideline rcg:ircling Count One is U.S.S.G.

§ 2R1.i(aflli.                      H            aHase Offef.se Level of7.

              —        -                ( :   nsa Characteristic U.S.S.G. § 2131 .1 (b)(l)(J) applies
becausc Azh. :1            --:-                  I a )nnl( Irnul scheme in which the intended loss
amount was at                                 nil on. This Spec iflc Offense Characteristic results
in an increase o.c

             5.   ci     ftnse Characteristic U.S.S.G. § 231.1(bfll7)(A) applies
because Azha:     a. -u ‘.ed more than Si 000,000 in gross receipts from one
or more fina:-ri: nsTh’1!on5 as a result o: his hank fraud. This Specific
Offense Char:. -rst c results iii an increase 012 levels.

                                              hvC for Count One is 27.

                                                      Count Two
                                                 (Mmcv Laundering)

              7 .     .;                       DIv guidcline re arding Count rl\vo is U.S.S.G.
§ 2Sl.l(a)(i),    ..                           es a base olfense level of 27, based on the offense
level for the a or lv                         a Ic fraud.

              N                       ènse Ch;racteristc U.S.S.G. § 2S1 l(b)(2)(A) applies
                                                                                  .



because the d              ii: .t uc: s convicted und r 18 U.S.C. § 1957. This Specific
Offense Cha:                           di s in an incre::se of 1 level.

                                                          -9-.
Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 10 of 12 PageID: 57




                                              o i\’el for Count Two is 28.

                                                                  Grouping

                                                   o U.S.S.G. § 3D 1.2(b), Counts One and Two group.

                                                  offense level, after grouping, is 28.

                                              t neeptance of Responsibility

              12 .\e of he late of this letter, Azhar Rana has clearly
demonstrated:ii’        nit ii and affirmative acceptance of personal
responsiailji        a a .  s• ciiarged. Th1rufore, a downward adjustment of 2
levels for ac    *ECO of r      nshihty is aporonriate if his acceptance of
responsibiln                     i.’i the date ui sentencing. See U.S.S.G. §
3E1.l(a).

                     •                m  ate of this letter, Axhar Rana has assisted
authorities ii1          iv              Lion or lirosecLitiuLi of his own misconduct by timely
notifying aut’                            intent on to enter a plea of guilty, thereby permitting
the Governii                           preparing for trial rind permitting the Government and
the court to                      HI    rcsnt roes efficiently. At sentencing, the Government
                                              -




will move for                        -e iii1 reduction iii Azhar Rana’s offense level pursuant
to U.S.S.G.                           .UL    o.o’ving (-(Ittlitlons arc met: (a) Azhar Rana enters
a plea purs’.            )    t   •s        •m”nt, (b) the Government in its discretion
de:crtnines              xl       -     n’s a      -pLi:ce of responsibility has continued
through the                                 no i;cl Azha: Rana therefore qualifies for a 2—point
reduction Lb                                     ni jjjjIjt\’ JLIrSLLC(iI[ Lu U.S.S.G. § 3E1. 1(a), and

(c) Azhar Ran:                                  der the C .tidelines prior to the operation of §
3E1. 1(a) is IS
                 1
                                          u        nce ‘itIi the al’ive, the parties agree that the total
Guidelines e                                       pl:h!e to Axhir Rana is 25 (the “agreed total
Gui U eli n us

                                                                e not :o seek or argue for any upward or
downward d                   .
                                                             .‘nt or vriri:. ice not set forth herein. The parties
furhernnr                  a      et              ‘ni       ‘s’ithn the Guidelines range that results from the
ago (U tea               cli      ‘s              rfe            vel a; 25 is reasonable.

                                                            I e has and, except as noted below in
                                                                us I hot
this paragr:                                     es. the rirhi to tile am’ appeal, any collateral
                                                        .




attack, or iii                            F V         inelLiclilig but not titrated to an appeal
                                                            L)t;OU,


under 18 U.                           -2 r a motion under 28 U.S.C. § 2255, which challenges
the sentene                            h’ he sc-i t’iieing nirt if that sentence falls within or
                                                                      -   10   -
Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 11 of 12 PageID: 58




below the C                      t hni    .esult s fr m the agreed total Guidelines
offense level    a     ‘   e C ov ri a alit will iot file an’ appeal, motion, or writ
which cha!I       :h       SC ICC      ifl:jiOSC(l h\ the sentcncing court if that sentence
falls within      Vt       hr iU Via ts range hat results from the agreed total
GuideLnes o        I             2’i.      a pan us :‘eservea’av right they may have
under 18 U                            “:J he sentencing CoLirt’s determination of the
criminal hia                                  isions oF this paragraph are binding on the
parties even                    mpk’vs a Guidelines analysis different from that
stipulated Ii               ilr ernot    ,    if the sentencing court accepts a stipulation,
both parties u               ri it to lie an appeal, collateral attack, writ, or motion
claiming thn’                    ig (         erred i:t doing so.

                                   es i’e:’ve the right to oppose or move to dismiss
any apoenl.                              ,   or :i!ot.aii barred by the preceding
paragraph         Hi        ir 1,3 ua;a se in apical, collateral attack, writ or motion
not barred        pt       ‘u’ nu.      r.T,ialJli.




                                             -   II   -
Case 2:21-cr-00527-ES Document 17 Filed 07/01/21 Page 12 of 12 PageID: 59




                                     Schedule B


An account at ‘eIIs lrr’n ending in 5779 in the name Azhar Rana;

An account at ‘e]ls Pawn ending in 8284 in the name Azhar Rana;

An account       a.                 ending in 9370 in the name of Meal to Live
LLC;

An account a                        ending in 8857 in the name of Manhattan
Realty LLC;

An account             --   J       ending in 7502 in the name of Azhar Sanvar
Rana LLC;

A brokerage a               T:) Ar vntrade ending in 8065 in the name of Azhar
Sanvar Rant

A brokerage aceot n’ •t I      A     ti ado   en ing in 8062 in the name of Azhar
Sarwar Rana


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2de5311492990396171c7946732027ce6ffae21fc55391a39dc7933797dc3e91
Our copy
17.pdf
Original
archive.org
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