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.
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“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/
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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
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 2 of 20
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.
2
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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.
3
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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.
4
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 5 of 20
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.
5
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 6 of 20
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.
6
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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,
7
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 8 of 20
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
8
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 9 of 20
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.
9
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 10 of 20
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
10
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 11 of 20
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
11
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 12 of 20
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.
12
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 13 of 20
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.
13
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 14 of 20
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.
14
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 15 of 20
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:
15
Case 1:22-cr-00034-LJV-MJR Document 14 Filed 03/10/22 Page 16 of 20
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.
16
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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
17
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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;
18
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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
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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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