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Indictment — United States v. Hormoz Mansouri, Western District of New York (Document 14)

Summary

A grand jury indictment in United States v. Hormoz Mansouri, No. 1:22-cr-00034, in the U.S. District Court for the Western District of New York, filed March 10, 2022 as Document 14, listing 40 counts and 2 forfeiture allegations. Count 1 charges conspiracy to commit wire fraud and bank fraud from around April 2020 to February 2021 through PPP and EIDL applications that, the indictment alleges, misstated payroll, employees and revenues for entities including EI Team Inc., NPTS, Inc. and HLM Holding, LLC. Counts 2 through 13 charge bank fraud over PPP loans funded by M&T Bank, Cross River Bank, Celtic Bank and Customers Bank, including $238,757 on April 20, 2020. Counts 14 through 32 charge wire fraud over EIDL and PPP applications. The 20-page indictment seeks forfeiture of funds seized from M&T Bank accounts and a 2017 Lexus LX570.

Summary drafted by a model from the text of the original file linked on this page 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

“Indictment — United States v. Hormoz Mansouri, Western District of New York (Document 14).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-22-cr-00034-dkt-14-w-d-n-y-681bbe9e0d/, SHA-256 af4ae0cf785fb2ae60f7e2cc54dfa6c9d7dcb652526a72dc52ba426c0fd0e3e6.

Full text

      Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 1 of 20




   IN THE DISTRICT COURT OF THE UNITED STATES

                    for the Western District of New York
                                  ____________________

                                                     MARCH 2021 GRAND JURY
                                                     (Impaneled March 26, 2021)

 THE UNITED STATES OF AMERICA                        INDICTMENT

        -vs-                                         Violations:
                                                     Title 18, United States Code,
 HORMOZ MANSOURI                                     Sections 1349, 1344, 1343, and 1957
                                                     (40 Counts and 2 Forfeiture Allegations)


                                    INTRODUCTION

                              The Grand Jury Charges That:

      At all times relevant to this Indictment:

      The Defendant

      1.       Defendant, HORMOZ MANSOURI, (“MANSOURI”), was a resident of

Amherst, New York.



      Related Entities

      2.       HLM Holding LLC (herein after HLM) was a limited liability company with a

listed address of 2060 Sheridan Drive, Buffalo, New York 14223. In loan applications and

bank records, MANSOURI was listed as the owner/managing partner.



      3.       2060 Sheridan Drive, LLC (hereinafter 2060 Sheridan Drive) was a limited

liability company with a listed address of 2060 Sheridan Drive, Buffalo, New York 14223. In
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loan applications and bank records, MANSOURI was listed as the owner/managing sole

member.

      4.     212 Holden Avenue LLC (hereinafter 212 Holden) was a limited liability

company, with a listed address of 2060 Sheridan Drive, Buffalo, New York 14223. In loan

applications and bank records MANSOURI was listed as the owner/managing partner.



      5.     350 Old Niagara Falls Boulevard LLC (hereinafter 350 Old NFB) was a limited

liability company, with a listed address of 2060 Sheridan Drive, Buffalo, New York 14223.

In loan applications and bank records MANSOURI was listed as the owner/sole member.



      6.     47 East Amherst LLC (hereinafter 47 E. Amherst) was a limited liability

company, with a listed address of 2060 Sheridan Drive, Buffalo, New York 14223. In loan

applications and bank records, MANSOURI was listed as the majority owner/managing

member.



      7.     3600 Harlem Road LLC (hereinafter 3600 Harlem) was a limited liability

company, with a listed address of 2060 Sheridan Drive, Buffalo, New York 14223. In loan

applications and bank records, MANSOURI was listed as the majority owner/managing sole

member.



      8.     EI Team Inc. (hereinafter EI Team) was a corporation, with an address of 2060

Sheridan Drive, Buffalo, New York 14223. In loan applications and bank records,

MANSOURI was listed as the owner.




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       9.     NPTS Inc. (hereinafter NPTS) was a corporation with an address of 2060

Sheridan Drive, Buffalo, New York 14223. In loan applications, MANSOURI was listed as

the owner.



       The Small Business Administration

       10.    The United States Small Business Administration (“SBA”) was an agency of

the United States government that provided support to entrepreneurs and small businesses.



       The Paycheck Protection Program

       11.    The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a

federal law, enacted on or about March 27, 2020, designed to provide emergency financial

assistance to the millions of Americans who were suffering the economic effects caused by

the COVID-19 pandemic.        One source of relief provided by the CARES Act was the

authorization of forgivable loans to small businesses for job retention and certain other

expenses, through a program referred to as the Paycheck Protection Program (“PPP”).



       12.    To obtain a PPP loan, a qualifying business was required to submit a PPP loan

Application. The loan application required that it be signed by an authorized representative

of the business.    The loan application required the business (through its authorized

representative) to acknowledge the program rules and make certain affirmative certifications

in order to be eligible to obtain the PPP loan. In the PPP loan application, the small business

(through its authorized representative) was required to state, among other things, its: (a)

average monthly payroll expenses; and (b) number of employees. These figures were used to

calculate the amount of money the small business was eligible to receive under the PPP.

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       13.    PPP loan applications were processed by a participating lender. The loan

application and any supporting documentation was transmitted to the lender. If a PPP loan

application was approved, the participating lender funded the PPP loan using its own monies,

which were 100 percent guaranteed by the SBA.



       14.    PPP loan proceeds were required to be used on certain permissible expenses,

including payroll costs, mortgage interest, rent, and utilities. Under the applicable PPP rules

and guidance, the interest and principal on the PPP loan were eligible for forgiveness if the

business spent the loan proceeds on these expense items within a designated period of time

and used a certain portion of the loan for payroll expenses.



       Economic Injury Disaster Loan (EIDL)

       15.    A second source of relief provided by the CARES Act was funding to the SBA

for the Economic Injury Disaster Loan (“EIDL”) Program. The EIDL program was designed

to provide economic relief to businesses experiencing a temporary loss of revenue due to

COVID-19.



       16.    The program provided low interest loans to pay for expenses that could have

been met had the pandemic not occurred. Eligible expenses included payroll, paid sick leave

for employees, increased production costs due to supply chain disruptions, and business

obligations such as debts, rent, and mortgage payments.



       17.    In addition to the EIDL program loans, small businesses could request an

EIDL Advance, based on the number of employees stated on the EIDL application.

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       Relevant Financial Institutions and Other Lending Institutions

       18.    M&T Bank was a federally insured financial institution based in Buffalo, New

York. M&T Bank was authorized by the SBA to participate as a PPP lender.



       19.    Funding Circle was a financial service company based in California. Funding

Circle was authorized by the SBA to participate as a PPP lender.



       20.    Cross River Bank was a federally insured financial institution based in New

Jersey. Cross River Bank was authorized by the SBA to participate as a PPP lender.



       21.     Celtic Bank was a federally insured financial institution based in Utah. Celtic

Bank was authorized by the SBA to participate as a PPP lender.



       22.    Customers Bank was a federally insured financial institution based in

Pennsylvania. Customers Bank was authorized by the SBA to participate as a PPP lender.



       23.    Fundbox was a financial service company based in California. Fundbox was

authorized by the SBA to participate as a PPP lender.



                                         COUNT 1

                   (Conspiracy to Commit Wire Fraud and Bank Fraud)

                          The Grand Jury Further Charges That:

       24.    The allegations in the Introduction of this Indictment are re-alleged and

incorporated by reference as though fully set forth herein.

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       25.      Beginning in or around April 2020, and continuing to in or around February

2021, in the Western District of New York, and elsewhere, the defendant, MANSOURI, did

knowingly, willfully, and unlawfully combine, conspire, and agree with others, known and

unknown to the Grand Jury, including unindicted coconspirators, to:

             i. devise and intend to devise a scheme and artifice to defraud financial
                institutions, financial service companies, and the SBA and to obtain
                money and property from financial institutions, financial service
                companies and the SBA by means of materially false and fraudulent
                pretenses, representations, and promises, and for the purpose of
                executing such scheme and artifice, did transmit, and cause to be
                transmitted by means of wire communication in interstate and foreign
                commerce, writings, signs, signals, pictures, and sounds, in violation of
                Title 18, United States Code, Section 1343; and

             ii. execute a scheme and artifice to defraud financial institutions and to
                 obtain money, funds, credits, assets, securities, and other property
                 owned by, and under the custody and control of, financial institutions
                 by means of materially false and fraudulent pretenses, representations,
                 and promises, in violation of Title 18, United States Code, Section
                 1344.


       26.      Beginning in or around April 2020, and continuing until in or around February

2021, the defendant, MANSOURI, conspired to execute, executed, and attempted to execute,

a scheme and artifice to defraud financial institutions, financial service companies, and the

SBA in connection with funds available through the PPP and EIDL programs.



       27.      As part of the conspiracy, the defendant, MANSOURI, submitted, and caused

to be submitted, fraudulent PPP loan applications and fraudulent EIDL applications, by

means of interstate wire communications, in the names of certain entities. The submitted PPP

loan applications and EIDL applications were approved based on materially false and

fraudulent pretenses, representations, and promises contained therein.

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       28.    It was the purpose of the conspiracy for the defendant, MANSOURI, to

unjustly enrich himself and his businesses by fraudulently obtaining funds available through

the PPP and EIDL programs.


       29.    In furtherance of the conspiracy, the submitted PPP loan applications

contained materially false and fraudulent representations regarding the monthly payroll

expenses and number of employees of the entities for which they were submitted.



       30.    In furtherance of the conspiracy, the defendant, MANSOURI, and others

known to the Grand Jury, submitted, and caused to be submitted, false and fraudulent IRS

Forms 940, IRS Forms 941 and New York State Forms NYS-45.




       31.    In furtherance of the conspiracy, the defendant, MANSOURI, and unindicted

coconspirators known to the Grand Jury, submitted, and caused to be submitted, false and

fraudulent payroll registers.



       32.    Beginning in or around April 2020, and continuing until in or around June

2020, the defendant, MANSOURI, and unindicted coconspirators known to the Grand Jury,

submitted, and caused to be submitted fraudulent EIDL applications.



       33.    In furtherance of the conspiracy, the EIDL applications submitted and caused

to be submitted by the defendant, MANSOURI, and others known to the Grand Jury,




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contained materially false and fraudulent information which misstated revenues, the cost of

goods sold, and/or the number of employees.


       All in violation of Title 18, United States Code, Section 1349.



                                   COUNTS 2 through 13

                                        (Bank Fraud)

                            The Grand Jury Further Charges That:

       34.    The allegations in the Introduction of this Indictment and Count 1 are re-

alleged and incorporated by reference as though set forth herein.



       35.    On or about the dates set forth below, in the Western District of New York,

and elsewhere, the defendant HORMOZ MANSOURI, did knowingly, willfully, and

unlawfully execute, and attempt to execute, a scheme and artifice to obtain any of the moneys,

funds, credits, assets, securities, and other property owned by, and under the custody and

control of a financial institution, by means of materially false and fraudulent pretenses,

representations, and promises.

                                                                     Date        Funded
  COUNT            Entity        Loan type         Funding          Funded       Amount
                                                  Institution

      2        EI Team Inc          PPP           M& T Bank         April 20,    $238,757
                                                                     2020

      3        EI Team Inc          PPP           M&T Bank      January 29,      $274,582
                                                                   2021

      4         NPTS, Inc.          PPP           M&T Bank          April 22,    $141,652
                                                                     2020



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                                                            Date          Funded
COUNT        Entity       Loan type         Funding        Funded         Amount
                                           Institution

  5        NPTS, Inc.        PPP           M&T Bank      January 29,      $274,582
                                                            2021

  6         HLM              PPP           Cross River   February 17,     $274,582
           Holding,                           Bank          2021
             LLC
             2060
  7        Sheridan          PPP           Celtic Bank     June 12,       $83,300
          Drive, LLC                                         2020

  8           2060           PPP           Customers     February 16,     $274,582
            Sheridan                         Bank           2021
           Drive LLC

  9       212 Holden         PPP           Celtic Bank     June 12,       $83,300
          Avenue LLC                                         2020


 10       212 Holden         PPP           Customers     February 16,     $274,582
          Avenue LLC                         Bank           2021


 11         350 Old          PPP           Customers     February 17,     $274,582
          Niagara Falls                      Bank           2021
           Boulevard,
              LLC

 12          47 East         PPP           Customers     February 10,     $274,582
            Amherst,                         Bank           2021
              LLC

 13       3600 Harlem        PPP           Customers     February 25,     $274,582
           Road, LLC                         Bank           2021




  All in violation of Title 18, United States Code, Sections 1344(2) and 2.




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                                  COUNTS 14 through 32
                                      Wire Fraud

                           The Grand Jury Further Charges That:

         36.   The allegations contained in the Introduction of this Indictment and Counts 1

through 13 are re-alleged and incorporated by reference as if fully set forth herein.



         37.   Beginning in or around May 2020, and continuing through in or around

February 2021, in the Western District of New York, and elsewhere, the defendant

HORMOZ MANSOURI, did devise, and intend to devise, a scheme and artifice to defraud

financial institutions, financial service companies and the SBA, and to obtain money and

property from financial institutions, financial service companies and the SBA by means of

materially false and fraudulent pretenses, representations, and promises.



         38.   On or about the dates set forth below, in the Western District of New York,

and elsewhere, for the purpose of executing the scheme and artifice, the defendant

transmitted, and caused to be transmitted, by means of wire communication in interstate and

foreign commerce, writings, signs, signals, pictures and sounds as set forth below:



 COUNT             Date                            Wire Communication


    14         April 6, 2020   EIDL Application for HLM Holding, LLC sent from the
                               Western District of New York to the SBA in Iowa


    15         April 7, 2020   EIDL Application for NPTS sent from the Western
                               District of New York to the SBA in Iowa




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COUNT       Date                           Wire Communication


 16     April 7, 2020   EIDL Application for E.I.Team, Inc., sent from Western
                        District of New York to the SBA in Iowa


 17     May 19, 2020    PPP Loan Application for 2060 Sheridan Drive, LLC sent
                        from the Western District of New York to Celtic Bank in
                        Utah


 18     May 27, 2020    PPP Loan Application for HLM Holding, LLC sent from
                        the Western District of New York to Funding Circle in
                        California

 19     June 4, 2020    PPP Loan Application for 350 Old Niagara Falls
                        Boulevard, LLC sent from the Western District of New
                        York to FundBox in California


 20     June 4, 2020    PPP Loan Application for 47 East Amherst Street sent
                        from the Western District of New York to Fund Box in
                        California


 21     June 5, 2020    PPP Loan Application for 212 Holden Avenue, LLC sent
                        from the Western District of New York to Celtic Bank in
                        Utah


 22     June 15, 2020   PPP Loan Application for 3600 Harlem Road, LLC sent
                        from the Western District of New York to FundBox in
                        California


 23     June 17, 2020   EIDL Application for 2060 Sheridan Drive, LLC sent
                        from the Western District of New York to the SBA in
                        Iowa


 24     June 17, 2020   EIDL Application for 3600 Harlem Road, LLC sent from
                        the Western District of New York to the SBA in Iowa




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COUNT           Date                            Wire Communication


 25        June 18, 2020   EIDL Application for 350 Old Niagara Falls Boulevard,
                           LLC., sent from the Western District of New York to the
                           SBA in Iowa


 26        June 18, 2020   EIDL Application for 47 East Amherst Street, LLC sent
                           from the Western District of New York to the SBA in
                           Iowa

 27         January 15,    PPP Loan Application for 47 East Amherst Street, LLC
               2021        sent from the Western District of New York to Customers
                           Bank in Pennsylvania


 28         January 15,    PPP Loan Application for 3600 Harlem Road, LLC sent
               2021        from the Western District of New York to Customers
                           Bank in Pennsylvania


 29         January 15,    PPP Loan Application for 350 Old Niagara Falls
               2021        Boulevard, LLC sent from the Western District of New
                           York to Customers Bank in Pennsylvania


 30         January 15,    PPP Loan Application for 212 Holden Avenue, LLC sent
               2021        from the Western District of New York to Customers
                           Bank in Pennsylvania


 31         January 15,    PPP Loan Application for 2060 Sheridan Drive, LLC sent
               2021        from the Western District of New York to Customers
                           Bank in Pennsylvania


 32         February 16,   PPP Loan Application for HLM Holden, LLC sent from
               2021        the Western District of New York to Cross River Bank in
                           New Jersey



      All in violation of Title 18, United States Code, Sections 1343 and 2.



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                                  COUNTS 33 through 40

                                    (Money Laundering)

                          The Grand Jury Further Charges That:

       39.    The allegations in the Introduction and Counts 1 through 32 are realleged and

incorporated by reference as though fully set forth herein.



       40.    On or about the dates set forth below, in the Western District of New York,

and elsewhere, the defendant, HORMOZ MANSOURI, did knowingly engage in monetary

transactions, affecting interstate commerce, in criminally derived property of a value greater

than $10,000, that is, the deposit, withdrawal, transfer, and exchange of funds and monetary

instruments by, through, and to financial institutions engaged in, and the activities of which

affected, interstate and foreign commerce, such property having been derived from specified

unlawful activity, that is, bank fraud in violation of Title 18, United States Code, Section

1344, and wire fraud in violation of Title 18, United States Code, Section 1343, and knowing

that the funds and monetary instruments involved in the transactions constituted, and were

derived from, proceeds obtained from a criminal offense.


     COUNT       DATE OF TRANSACTION               AMOUNT          DESCRIPTION OF
                                                                    TRANSACTION

                                                                Check number 26982 in
        33              July 30, 2020              $50,537.56   the amount of $50,537.56,
                                                                drawn on M&T Account
                                                                2928 in the name of
                                                                NPTS made payable to
                                                                Northtown Lexus for the
                                                                purchase a 2017 Lexus
                                                                LX570.




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COUNT    DATE OF TRANSACTION           AMOUNT         DESCRIPTION OF
                                                       TRANSACTION

                                                    Account transfer in the
  34          August 06, 2020          $13,976.35   amount of $13,976.35
                                                    from M&T Account 0135
                                                    in the name of 212
                                                    Holden Avenue to M&T
                                                    Account 2928 in the name
                                                    of NPTS.

                                                    Account transfer in the
  35           August 20, 2020         $13,977.15   amount of $13,977.15
                                                    from M&T Account 5884
                                                    in the name HLM to
                                                    M&T Account 2678 in the
                                                    name of EI Team.

                                                    Account transfer in the
  36         September 03, 2020        $16,513.55   amount of $16,513.55
                                                    from M&T Account 3470
                                                    in the name of 47 E
                                                    Amherst to M&T
                                                    Account 2928 in the name
                                                    of NPTS.

                                                    Account transfer in the
  37           October 1, 2020         $16,990.64   amount of $16,990.64
                                                    from M&T Account 3454
                                                    in the name of 2060
                                                    Sheridan Drive to M&T
                                                    Account 2678 in the name
                                                    EI Team.

                                                    Account transfer in the
  38          October 15, 2020         $17,065.52   amount of $17,065.52 from
                                                    M&T Account 2274 in the
                                                    name of 350 Old Niagara
                                                    Falls Boulevard, LLC to
                                                    M&T Account 2678 in the
                                                    name EI Team, Inc.




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     COUNT        DATE OF TRANSACTION              AMOUNT          DESCRIPTION OF
                                                                    TRANSACTION

                                                                Account transfer in the
        39               October 29, 2020          $17,064.17   amount of $17,064.17
                                                                from M&T Account 2720
                                                                in the name 3600 Harlem
                                                                Road LLC to M&T
                                                                Account 2928 in the name
                                                                NPTS.

                                                                Account transfer in the
        40                   May 12, 2021           $200,000    amount of $200,000 from
                                                                M&T Account 2928 in the
                                                                name of NPTS to M&T
                                                                Account 3354 in the name
                                                                of Mansouri for County
                                                                Comptroller.


       All in violation of Title 18, United States Code, Section 1957(a).



                             FIRST FORFEITURE ALLEGATION

                                     (Proceeds Forfeiture)

                                 The Grand Jury Alleges That:

       41.    Upon conviction of one or more of the offenses set forth in Counts 1 through

32 of this Indictment, the defendant, HORMOZ MANSOURI, shall forfeit to the United

States, pursuant to Title 18, United States Code, Section 982(a)(2), Title 18, United States

Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c), any property,

real or personal, constituting, or derived from, proceeds the defendant obtained directly or

indirectly, as the result of such violation. The property to be forfeited includes, but is not

limited to, the following:




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      A. MONETARY SUM

      The approximate sum of three million, five hundred twenty-five thousand, thirty-one

dollars and 70 cents ($3,525,032.70) United States currency, which sum of money is equal to

the total amount of proceeds obtained as a result of the offenses for which the defendant,

HORMOZ MANSOURI, is charged in Counts 1 through 32. In the event that the above

sum is not available, then a money judgment for the same amount will be entered against the

defendant.



      B. BANK ACCOUNTS

         i.   All Funds seized from M&T Bank, Business Checking Account Ending in 2678
              Held in the Name of EI Team, Inc;

        ii.   All funds seized from M&T Bank, Business Checking Account Ending in 2928
              Held in the Name of NPTS;

       iii.   All funds seized from M&T Bank, Business Checking Account Ending in 5884
              Held in the Name of HLM Holding LLC;

        iv.   All funds seized from M&T Bank Business Checking Account Ending in 3454
              Held in the Name of 2060 Sheridan Drive LLC;

        v.    All funds seized from M&T Bank Business Checking Account Ending in 0135
              Held in the Name of 212 Holden Avenue LLC;

        vi.   All funds seized from M&T Bank Business Checking Account Ending in 2274
              Held in the Name of 350 Old Niagara Falls Boulevard LLC;

       vii.   All funds seized from M&T Bank Business Checking Account Ending in 3470
              Held in the Name of 47 East Amherst LLC;

      viii.   All funds seized from M&T Bank Business Checking Account Ending in 2720
              Held in the Name of 3600 Harlem Road LLC; and

       ix.    All funds seized from M&T Bank Business Checking Account Ending in 3354
              Held in the Name of Mansouri for County Comptroller.


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       C. VEHICLE

             i. One 2017 LEXUS LX570, VIN: JTJHY7AX1H4226453
                Titled and Registered to NPTS, Inc, Owned by Hormoz Mansouri.


       If any of the property described above, as a result of any act or omission of the

defendant:

             i.   cannot be located upon the exercise of due diligence;

         ii.      has been transferred or sold to, or deposited with, a third person;

         iii.     has been placed beyond the jurisdiction of the Court;

         iv.      has been substantially diminished in value; or

          v.      has been commingled with other property which cannot be divided without
                  difficulty;

the United States of America shall be entitled to forfeiture of substitute property pursuant to

Title 21, United States Code, Section 853(p).



       All pursuant to Title 18, United States Code, Section 982(a)(2), Title 18, United

States Code, Section 981(a)(1)(C), Title 21, United States Code, Section 853(p), and Title

28, United States Code, Section 2461(c).



                            SECOND FORFEITURE ALLEGATION

                                  (Money Laundering Forfeiture)

                              The Grand Jury Further Alleges That:

       42.        Upon conviction of one or more of the offenses set forth in Counts 33 through

40 of this Indictment, the defendant, HORMOZ MANSOURI, shall forfeit to the United

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States, pursuant to Title 18, United States Code, Section 982(a)(1), the following property:



       A.        PROPERTY

       All right, title and interest in any and all property involved in violations of Title 18,

United States Code, Section 1957 for which the defendant is convicted, and all property

traceable to such property, including the following: 1) any property or any property traceable

to such property, that was the subject of each transaction, transmission or transfer in violation

of Section 1957; and 2) any property or any property traceable to such property, used in any

manner or part to commit or to facilitate the commission of those violations.



       B.        MONETARY AMOUNT

       The sum of approximately three hundred forty-six thousand, one hundred twenty-four

dollars and 94 cents ($346,124.94) United States currency, which sum of money is equal to

the total amount of money involved in the money laundering offenses for which the

defendant, HORMOZ MANSOURI is charged. In the event that the above sum is not

available, then a money judgment for the same amount will be entered against the defendant.



       C.        SPECIFIC ASSETS

       The following specific assets which have been identified as property involved in a

money laundering transaction or transactions:


            1.     BANK ACCOUNTS

                  i.   All funds seized from M&T Bank, Business Checking Account Ending
                       in 2678 Held in the Name of EI Team, Inc;




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                 ii.   All funds seized from M&T Bank, Business Checking Account Ending
                       in 2928 Held in the Name of NPTS;

                iii.   All funds seized from M&T Bank, Business Checking Account Ending
                       in 5884 Held in the Name of HLM Holding LLC;

                iv.    All funds seized from M&T Bank Business Checking Account Ending
                       in 3454 Held in the Name of 2060 Sheridan Drive LLC;

                 v.    All funds seized from M&T Bank Business Checking Account Ending
                       in 0135 Held in the Name of 212 Holden Avenue LLC;

                vi.    All funds seized from M&T Bank Business Checking Account Ending
                       in 2274 Held in the Name of 350 Old Niagara Falls Boulevard LLC;

               vii.    All funds seized from M&T Bank Business Checking Account Ending
                       in 3470 Held in the Name of 47 East Amherst LLC;

               viii.   All funds seized from M&T Bank Business Checking Account Ending
                       in 2720 Held in the Name of 3600 Harlem Road LLC; and

                ix.    All funds seized from M&T Bank Business Checking Account Ending
                       in 3354 Held in the Name Of Mansouri For County Comptroller.


          2.       VEHICLE

                   i. One 2017 LEXUS LX570, VIN: JTJHY7AX1H4226453
                      Titled and Registered to NPTS, Inc, Owned by Hormoz Mansouri


       If any of the property described above as being subject to forfeiture, as a result of any

act or omission of the defendant

         i.    cannot be located upon the exercise of due diligence;

        ii.    has been transferred or sold to, or deposited with, a third person;

       iii.    has been placed beyond the jurisdiction of the Court;

        iv.    has been substantially diminished in value; or

        v.     has been commingled with other property which cannot be divided without
               difficulty;



                                              19
     Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 20 of 20




the United States of America shall be entitled to forfeiture of substitute property pursuant to

Title 21, United States Code, Section 853(p).



       All pursuant to Title 18, United States Code, Section 982(a)(1), and Title 21, United

States Code, Section 853(p).




       DATED:        Buffalo, New York, March 10, 2022.



                                                     TRINI E. ROSS
                                                     United States Attorney


                                           BY:       s/Michael Digiacomo
                                                     MICHAEL DIGIACOMO
                                                     Assistant United States Attorney
                                                     United States Attorney’s Office
                                                     Western District of New York
                                                     138 Delaware Avenue
                                                     Buffalo, New York 14202
                                                     716/843-5838
                                                     Michael.Digiacomo@usdoj.gov


A TRUE BILL:

s/Foreperson
FOREPERSON




                                                20


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