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Declaration of Hanni M. Fakhoury (Document 65-2)

Summary

Document 65-2, filed 06/06/25, is a declaration by the attorney for Sandra Will in United States v. Cassie Will-Darnall. He lists Exhibits A through E: property detail reports for the Almaden and Belwood properties, a petition for divorce and a judgment of dissolution from Santa Clara County Superior Court, and Bank of America records for an account in the name of Sandra Will. He says the documents came from Assistant Federal Public Defender Varell Fuller, who obtained them from the government in discovery. He estimates the Almaden home at $2.1 million and the Belwood home at $2.6 million from Zillow and Redfin estimates as of June 6, 2025.

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Cite this document

“Declaration of Hanni M. Fakhoury (Document 65-2).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-65-2-92b49c56c7/, SHA-256 4647fc3b0cfb183010119446e419d0cb9fee24286fe03b855ef26417a15a1472.

Full text

             Case 5:24-cr-00292-PCP                     Document 65-2     Filed 06/06/25   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
13                 v.

14     CASSIE WILL-DARNALL,

15                          Defendant.

16

17            I, Hanni M. Fakhoury, hereby declare as follows:
18            1. I am an attorney licensed to practice in California and admitted in the Northern District of
19                  California. I represent Sandra Will in this matter.
20            2. Attached as Exhibit A is a property detail report for 306 Los Gatos Almaden Road, Los
21                  Gatos, California 95032-4006. I obtained this document from Assistant Federal Public
22                  Defender Varell Fuller, who represents defendant Cassie Will-Darnall, and who, I am
23                  informed, obtained this document from the government in discovery.
24            3.    Attached as Exhibit B is a property detail report for 111 Belwood Gateway, Los Gatos,
25                  California 95032-5138. I obtained this document from Mr. Fuller, who I am informed,
26                  obtained this document from the government in discovery.
27

28

     DECLARATION OF HANNI M. FAKHOURY
     United States v. Will-Darnall, 5:24-CR-00292-PCP
                                                                  1
             Case 5:24-cr-00292-PCP                     Document 65-2   Filed 06/06/25   Page 2 of 2



 1            4. Attached as Exhibit C is a petition for divorce filed by Cassie Will-Darnall in Santa Clara
 2                 County Superior Court. I obtained this document from Mr. Fuller, who I am informed,
 3                 obtained this document from the government in discovery.
 4            5. Attached as Exhibit D is a judgment of dissolution in the divorce case brought by Cassie
 5                 Will-Darnall in the Santa Clara County Superior Court. I obtained this document from Mr.
 6                 Fuller, who I am informed, obtained this document from the government in discovery.
 7            6. Attached as Exhibit E is a declaration of custodian of records from Bank of America, as
 8                 well as records from Bank of America, concerning a bank account in the name of Sandra
 9                 Will. I obtained this document from Mr. Fuller, who I am informed, obtained this document
10                 from the government in discovery.
11            7. I calculated that the home at 306 Los Gatos Almaden is worth $2.1 million by
12                 approximating the average of the estimates from the property websites Zillow
13                 ($1,990,900.00) and Redfin ($2,152,433.00), which totaled $2,071,666.50 as of June 6,
14                 2025.
15            8. I calculated that the home at 111 Belwood Gateway is worth $2.6 million by approximating
16                 the estimate from the property website Redfin, which estimates a value of $2,521,477 for
17                 the house as of June 6, 2025. I could not find an estimate of the property on Zillow.
18

19            I declare under penalty of perjury that the foregoing is true and correct to the best of my
20   knowledge.
21            Executed on June 6, 2025, in Clayton, California.
22
                                                                         s/ Hanni M. Fakhoury
23
                                                                         HANNI M. FAKHOURY
24

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

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