Declaration of Hanni M. Fakhoury in Support of Amended Petition for Ancillary Proceeding (Will-Darnall)

Summary

In this declaration supporting the amended petition for an ancillary proceeding, attorney Hanni M. Fakhoury states that he represents Sandra Will in United States v. Cassie Will-Darnall. It lists Exhibits A and B as property detail reports for the two Los Gatos properties, Exhibit C as a petition for divorce filed by Cassie Will-Darnall in Santa Clara County Superior Court, Exhibit D as a judgment of dissolution, and Exhibit E as a Bank of America custodian declaration with records of an account in the name of Sandra Will. The declaration states the documents came from Assistant Federal Public Defender Varell Fuller, who is informed they were obtained from the government in discovery. It also describes home value estimates from Zillow and Redfin and is executed November 11, 2025.

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Full text

          Case 5:24-cr-00292-PCP               Document 104-2      Filed 11/11/25   Page 1 of 2



 1   MOEEL LAH FAKHOURY LLP
     Hanni M. Fakhoury (State Bar No. 252629)
 2   2006 Kala Bagai Way, Suite 16
     Berkeley, CA 94704
 3   Telephone: (510) 500-9994
     Email:      hanni@mlf-llp.com
 4

 5   Attorneys for Third Party Claimant Sandra Will

 6

 7                                   IN THE UNITED STATES DISTRICT COURT
 8                              FOR THE NORTHERN DISTRICT OF CALIFORNIA
 9                                                 SAN JOSE DIVISION
10

11     UNITED STATES OF AMERICA,                               Case No.: 5:24-CR-00292-PCP

12                      Plaintiff,                             DECLARATION OF HANNI M.
                                                               FAKHOURY IN SUPPORT OF
13             v.                                              AMENDED PETITION FOR
                                                               ANCILLARY PROCEEDING
14     CASSIE WILL-DARNALL,

15                      Defendant.

16

17     SANDRA WILL,

18                      Third Party Claimant.

19

20          I, Hanni M. Fakhoury, hereby declare as follows:
21          1. I am an attorney licensed to practice in California and admitted in the Northern District of
22               California. I represent Sandra Will in this matter.
23          2. Attached as Exhibit A is a property detail report for 306 Los Gatos Almaden Road, Los
24               Gatos, California 95032-4006. I obtained this document from Assistant Federal Public
25               Defender Varell Fuller, who represents defendant Cassie Will-Darnall, and who, I am
26               informed, obtained this document from the government in discovery.
27

28

     AMENDED DECLARATION OF HANNI M. FAKHOURY
     United States v. Will-Darnall, 5:24-CR-00292-PCP
                                                           1
          Case 5:24-cr-00292-PCP               Document 104-2    Filed 11/11/25      Page 2 of 2



 1          3.   Attached as Exhibit B is a property detail report for 111 Belwood Gateway, Los Gatos,
 2               California 95032-5138. I obtained this document from Mr. Fuller, who I am informed,
 3               obtained this document from the government in discovery.
 4          4. Attached as Exhibit C is a petition for divorce filed by Cassie Will-Darnall in Santa Clara
 5               County Superior Court. I obtained this document from Mr. Fuller, who I am informed,
 6               obtained this document from the government in discovery.
 7          5. Attached as Exhibit D is a judgment of dissolution in the divorce case brought by Cassie
 8               Will-Darnall in the Santa Clara County Superior Court. I obtained this document from Mr.
 9               Fuller, who I am informed, obtained this document from the government in discovery.
10          6. Attached as Exhibit E is a declaration of custodian of records from Bank of America, as
11               well as records from Bank of America, concerning a bank account in the name of Sandra
12               Will. I obtained this document from Mr. Fuller, who I am informed, obtained this document
13               from the government in discovery.
14          7. I calculated that the home at 306 Los Gatos Almaden is worth $2 million by approximating
15               the average of the estimates from the property websites Zillow ($1,986,300.00) and Redfin
16               ($2,035,113.00), which totaled $2,010,706.50 as of November 11, 2025.
17          8. I calculated that the home at 111 Belwood Gateway is worth $2.5 million by approximating
18               the estimate from the property website Redfin, which estimates a value of $2,540,120 for
19               the house as of November 11, 2025. I could not find an estimate of the property on Zillow.
20

21          I declare under penalty of perjury that the foregoing is true and correct to the best of my
22   knowledge.
23          Executed on November 11, 2025, in Clayton, California.
24
                                                                  s/ Hanni M. Fakhoury
25
                                                                  HANNI M. FAKHOURY
26

27

28

     AMENDED DECLARATION OF HANNI M. FAKHOURY
     United States v. Will-Darnall, 5:24-CR-00292-PCP
                                                         2


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