Government's Motion to Dismiss the Indictment and the Remaining Counts of the Superseding Indictment — United States v. Ryan Macaulay (Dkt. 136)

Summary

The Government's Motion to Dismiss the Indictment and the Remaining Counts of the Superseding Indictment, filed September 25, 2025 as Document 136 in United States of America v. Raymond Rahbar Jr. and Ryan Macaulay, Case No. 1:24-CR-180, in the United States District Court for the Eastern District of Virginia. The United States asks for an order dismissing Counts 1–11 of the Indictment (Dkt. 1) and Counts 2–11, 13–14 of the Superseding Indictment (Dkt. 38) as to Rahbar, and Counts 1, 3, 5, and 8 of the Indictment as to Macaulay. The motion states that on September 25, 2025, the Court sentenced Rahbar to a total of 54 months incarceration and Macaulay to 24 months incarceration. A form of order follows.

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“Government's Motion to Dismiss the Indictment and the Remaining Counts of the Superseding Indictment — United States v. Ryan Macaulay (Dkt. 136).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-vaed-558615-136-0-8ff8d726cc/, SHA-256 1dc869d3de1290e39b536c1ce5c7223fe6410ec354a5d2c0fb7c33e73347abfc.

Full text

Case 1:24-cr-00180-PTG           Document 136       Filed 09/25/25     Page 1 of 4 PageID# 927




                     IN THE UNITED STATES DISTRICT COURT FOR THE
                             EASTERN DISTRICT OF VIRGINIA

                                        Alexandria Division

 UNITED STATES OF AMERICA

        v.                                             Case No. 1:24-CR-180

 RAYMOND RAHBAR JR.,

 RYAN MACAULAY,

        Defendants.


         GOVERNMENT’S MOTION TO DISMISS THE INDICTMENT AND
         THE REMAINING COUNTS OF THE SUPERSEDING INDICTMENT

       The United States, by and through undersigned counsel, hereby moves this Honorable

Court for an Order dismissing:

             •   As to defendant Raymond Rahbar, Jr.: Counts 1–11 of the Indictment, Dkt. 1; and

                 Counts 2–11, 13–14 of the Superseding Indictment, Dkt. 38; and

             •   As to defendant Ryan Macaulay: Counts 1, 3, 5, and 8 of the Indictment, Dkt. 1.

       On April 10, 2025, Defendant Rahbar pled guilty to Counts 1 and 12 of the Superseding

Indictment. Dkts. 108, 109. Per the terms of the Plea Agreement, the Government agreed to

dismiss the Indictment and the remaining counts of the Superseding Indictment at the conclusion

of the defendant’s sentencing hearing. Dkt. 109 at ¶ 7. On September 25, 2025, this Court

sentenced the defendant to a total of 54 months incarceration. As such, the Government now

moves this Court for an order dismissing Counts 1–11 of the Indictment, Dkt. 1; and Counts 2–

11, 13–14 of the Superseding Indictment, Dkt. 38, as to Defendant Rahbar.

       On April 15, 2025, Defendant Macaulay pled guilty to Counts 1, 5, 7, and 11 of the

Superseding Indictment without a plea agreement. Dkts. 112, 113. On September 25, 2025, this

Court sentenced the defendant to 24 months incarceration. The Government now moves this
Case 1:24-cr-00180-PTG         Document 136        Filed 09/25/25     Page 2 of 4 PageID# 928




Court for an order dismissing Counts 1, 3, 5, and 8 of the Indictment, Dkt. 1, as to Defendant

Macaulay.

                                                            Respectfully submitted,


                                                     Lindsey Halligan
                                                     United States Attorney


                                             By:                   /s/
                                                     Kristin S. Starr
                                                     Assistant United States Attorney




                                                    2
Case 1:24-cr-00180-PTG         Document 136      Filed 09/25/25     Page 3 of 4 PageID# 929




                   IN THE UNITED STATES DISTRICT COURT FOR THE
                           EASTERN DISTRICT OF VIRGINIA

                                      Alexandria Division

 UNITED STATES OF AMERICA

        v.                                              Case No. 1:24-CR-180

 RAYMOND RAHBAR JR.,

 RYAN MACAULAY,

        Defendants.


                                           ORDER

       This matter having come before the Court on the government’s Motion to Dismiss the

Indictment and the Remaining Counts of the Superseding Indictment and the Court having

considered the motion, it is hereby

       ORDERED that Counts 1–11 of the Indictment, Dkt. 1; and Counts 2–11, 13–14 of the

Superseding Indictment, Dkt. 38; are dismissed as to defendant Raymond Rahbar, Jr., and

       ORDERED that Counts 1, 3, 5, and 8 of the Indictment, Dkt. 1, are dismissed as to

defendant Ryan Macaulay.




Date: ___________________                          _________________________________
      Alexandria, Virginia
Case 1:24-cr-00180-PTG          Document 136       Filed 09/25/25      Page 4 of 4 PageID# 930




                                 CERTIFICATE OF SERVICE

       I hereby certify that, on September 25, 2025, I electronically filed the foregoing with the

Clerk of Court using the CM/ECF system, which automatically generated a Notice of Electronic

Filing to counsel of record in this case.

                                                         /s/
                                                     Kristin S. Starr
                                                     Assistant United States Attorney

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