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Indictment — United States v. Mihir Patel et al., Northern District of Texas (Document 1)

Summary

A sealed indictment against Mihir Patel, Kinjal Patel, Prateek Desai, Wajahat Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel, Dharmesh Patel, Mitra Bhattarai and Bhargav Bhatt, Case No. 3:23-cr-00252-K, in the U.S. District Court for the Northern District of Texas, filed June 21, 2023 as Document 1. The indictment alleges that the defendants submitted loan applications to financial institutions seeking over $53 million in the aggregate, including PPP loans for purported metal recycling companies and individuals with inflated payroll, false IRS documents and altered bank statements. It lists at least 24 false and fraudulent PPP applications. The 16 Counts include conspiracy to commit bank fraud under 18 U.S.C. § 1349, bank fraud, conspiracy to commit money laundering under 18 U.S.C. § 1956(h), and a false statement to the FDIC under 18 U.S.C. § 1007.

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

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“Indictment — United States v. Mihir Patel et al., Northern District of Texas (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-3-23-cr-00252-dkt-1-n-d-tex-094a81739e/, SHA-256 5540f8ecba55dcfabcda65a5cd58deb3b6dc383e02086f7c14b601c843a372a0.

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Case 3:23-cr-00252-K S Cat Ip Fi 1/23. Pagelof23 PagelD1
EAL DISTRICT COUR

IN THE UNITED STATES DISTRICT] COURT

FOR THE NORTHERN DISTRICT OF TEXAS os
DALLAS DIVISION JUN 21 2623

a
aS

UNITED STATES OF AMERICA CASE NO CLERK, ULS. DISTRICT COURT

MIHIR PATEL (01)

KINJAL PATEL (02) FILED UNDER SEAL
PRATEEK DESAI (03)
WAJAHAT KHAN (04)
a/k/a Ray Khan
IMRAN KHAN (05)
a/k/a Ron Khan
CHIRAG GANDHI (06)
a/k/a Chris Gandhi
BHAVESH PATEL (07)
a/k/a Bobby Patel
DHARMESH PATEL (08)
a/k/a Danny Patel
MITRA BHATTARAI (09)
| BHARGAV BHATT (10)
| a/k/a Brad Bhatt

V.

INDICTMENT

The Grand Jury charges:
At all times material to this indictment:

General Allegations

Summary of the Scheme

1. From on or about July 1, 2019, through on or about April 1, 2023, in the
Northern District of Texas and elsewhere, defendants Mihir Patel, Kinjal Patel, Prateek
Desai, Wajahat Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel, Dharmesh
Patel, Mitra Bhattarai, Bhargav Bhatt, and others both known and unknown to the

Grand Jury, sought to unlawfully enrich themselves and others by submitting, and

Indictment—Page 1
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causing to be submitted, loan applications to financial institutions seeking, in the
aggregate, over $53 million in loan proceeds, including under the coronavirus pandemic
relief initiative known as the Paycheck Protection Program.

2. In particular, the defendants prepared and submitted, and caused to be
prepared and submitted, loan applications on behalf of themselves, purported metal
recycling companies that the defendants owned and controlled (“recycling companies’),
and others, in which the defendants made, and caused to be made, materially false and
fraudulent representations.

3. The defendants further sought to conceal their unlawful conduct by
laundering the proceeds of the fraudulently obtained loans.

Relevant Entities and Defendants

4. The recycling companies consisted of a loosely affiliated group of
purported metal recycling companies primarily operating in and around Dallas and
Houston, Texas. The recycling companies included, but were not limited to, the
following:

a. 4G Metals, Inc. (“4G Metals”);

b. 4G Plastics, Inc. (“4G Plastics”);

Cc. 5G Metals, Inc. (“5G Metals”);

d. ARA Global Industries Inc. (““ARA Global”);

e. Elephant Recycling, Inc. (“Elephant Recycling”);
f. Gulf Coast Scrap, Inc. (“Gulf Coast Scrap”);

g. Level Eight, Inc. (“Level Eight’);

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h. L.K. Industries, Inc. (“L.K. Industries”);

i. NTC Industries, Inc. (“NTC Industries”);

j. R.A. Industries, Inc. (“R.A. Industries”);

k. Sunshine Recycling;

1. West Texas Equipment Company, Inc. (“West Texas Equipment”);
and

m. West Texas Scrap, Inc. (“West Texas Scrap”).

5. The recycling companies also included a group of purported metal
recycling companies whose names generally included the word “Mammoth” (“Mammoth
Group”). The Mammoth Group included, but was not limited to, the following:

a. Mammoth Metal Recycling Dallas Land Co 1, LLC;
b. Mammoth Metal Recycling Dallas Land Co 2, LLC;
Cc. Mammoth Metal Recycling Dallas Land Co 3, LLC;
d. Mammoth Metal Recycling Equipment Co, LLC;

e. Mammoth Metal Recycling Houston Land Co, LLC;
f. Mammoth Metal Recycling Operations, LLC; and

g. On The Path Trucking, LLC.

6. Defendant Mihir Patel was Sunshine Recycling’s Chief Financial Officer.
Further, Mihir Patel owned ARA Global, R.A. Industries, L.K. Industries, and the
Mammoth Group. S.P. and C.P., individuals known to the Grand Jury, were close

relatives of Mihir Patel.
|
|
|
|

Indictment—Page 3
7. Defendant Kinjal Patel was Sunshine Recycling’s Controller. J.P., an
individual known to the Grand Jury, was a close relative of Kinjal Patel.

8. Defendant Prateek Desai owned West Texas Scrap. A.Q., an individual
known to the Grand Jury, was a close relative of Desai.

9. Defendant Wajahat Khan was the President and owner of Gulf Coast
Scrap.

10. Defendant Imran Khan was the Operations Director and owner of 4G
Metals and West Texas Equipment.

11. Defendant Chirag Gandhi was the Controller of NTC Industries, and the
President and owner of 5G Metals and Sunshine Recycling.

12. Defendant Bhavesh Patel was Sunshine Recycling’s Chief Business
Development Officer and the owner of Level Eight.

13. Defendants Dharmesh Patel and Mitra Bhattarai were Co-Presidents and
co-owners of Elephant Recycling. Bhattarai resided with U.C., an individual known to
the Grand Jury.

14. Defendant Bhargav Bhatt was employed by NTC Industries.

15. “Equipment Company-1,” an entity known to the Grand Jury, was a
purported recycling equipment company located in Plano, Texas.

Paycheck Protection Program

16. The Paycheck Protection Program (“PPP”), implemented by the United
States Small Business Administration, was a COVID-19 pandemic relief program that,

among other things, provided small businesses with forgivable loans to pay payroll and

Indictment—Page 4
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certain other expenses. Under the PPP, participating third-party lenders approved loan
applications and disbursed PPP loans to qualifying businesses. To obtain a PPP loan, a
business was required to submit a PPP loan application to a lender. In the PPP loan
application, the business was required to state, among other things, the business’s average
monthly payroll expenses and its number of employees. This payroll information was
used to calculate the amount of funds that the business was eligible to receive as a PPP
loan.

Financial Institutions

17. | The following banks were financial institutions as defined in 18 U.S.C.

§ 20, and were insured by the Federal Deposit Insurance Corporation (“FDIC”): -

a. American Bank, National Association (“American Bank’’);

b. Bank of America, National Association (“Bank of America”);

Cc. Celtic Bank;

d. Dominion Bank;

e. First United Bank and Trust Company (“First United Bank’);

f. Happy State Bank;

g. IncredibleBank;

h. International Bank of Commerce (“IBC Bank’’)

1. Midwest Regional Bank;

j. One World Bank; and

k. Spectra Bank.

Indictment—-Page 5
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18. Carter Federal Credit Union, also known as Carter Credit Union (“Carter
FCU”), was a financial institution as defined in 18 U.S.C. § 20, whose accounts were
insured by the National Credit Union Share Insurance Fund.

19. American Bank, Bank of America, Carter FCU, Celtic Bank, Dominion
Bank, Happy State Bank, Midwest Regional Bank, and One World Bank participated in

the PPP as third-party lenders.

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Count One
Conspiracy to Commit Bank Fraud
[Violation of 18 U.S.C. § 1349 (18 U.S.C. § 1344(a)(2)]

20. Paragraphs 1 through 19 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

21. From in or about March 2020, through in or about April 2023, in the
Northern District of Texas and elsewhere, defendants Mihir Patel, Kinjal Patel, Prateek
Desai, Wajahat Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel, Dharmesh
Patel, Mitra Bhattarai, and Bhargav Bhatt, did knowingly and willfully conspire,
combine, confederate, and agree together and with others known and unknown to the
Grand Jury, to knowingly 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, the deposits of which were
insured by the FDIC and the accounts of which were insured by the National Credit

Union Share Insurance Fund, by means of materially false and fraudulent pretenses,

representations, and promises, in violation of 18 U.S.C. § 1344(a)(2).

Indictment—Page 7
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Purpose of the Conspiracy

22. The purpose of the conspiracy was for defendants Mihir Patel, Kinjal
Patel, Prateek Desai, Wajahat Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel,
Dharmesh Patel, Mitra Bhattarai, and Bhargav Bhatt to enrich themselves and others
by fraudulently obtaining PPP loan proceeds from financial institutions.

Manner and Means

23. | The manners and means by which defendants Mihir Patel, Kinjal Patel,
Prateek Desai, Wajahat Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel,
Dharmesh Patel, Mitra Bhattarai, and Bhargav Bhatt sought to accomplish the
purpose of the conspiracy included the following, among other things:

24. Between on or about April 1, 2020, and on or about June 1, 2021,
defendants Mihir Patel, Kinjal Patel, Prateek Desai, Wajahat Khan, Imran Khan,
Chirag Gandhi, Dharmesh Patel, and Mitra Bhattarai, submitted, and caused to be
submitted, to financial institutions PPP loan applications on behalf of various individuals
that fraudulently inflated the individuals’ payroll expenses.

25. Between on or about April 1, 2020, and on or about June 1, 2020,
defendants Mihir Patel and Kinjal Patel created, and caused to be created, an altered
bank statement for submission to Happy State Bank in support of Kinjal Patel’s PPP
loan application. This fraudulent bank statement falsely showed that Kinjal Patel had
business income.

26. Between on or about April 1, 2020, and on or about May 1, 2020,

defendants Mihir Patel, Kinjal Patel, Wajahat Khan, and Mitra Bhattarai prepared,

Indictment—Page 8
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and caused to be prepared, false Internal Revenue Service (“IRS”) documents, such as
IRS Form 1040 Schedule Cs and IRS Form 1099-MISCs, for submission to financial
institutions in support of PPP loan applications for various individuals. These IRS
documents falsely stated that the individuals received business income.

27. | Between on or about April 1, 2020, and on or about May 1, 2020,
defendants Mihir Patel, Kinjal Patel, and Bhavesh Patel provided, and caused to be
provided, false IRS documents and altered bank statements to financial institutions in
support of various PPP loan applications.

28. | Between on or about April 1, 2020, and on or about March 1, 2021,
defendants Mihir Patel, Kinjal Patel, Imran Khan, and Bhavesh Patel submitted, and
caused to be submitted, to financial institutions PPP loan applications on behalf of
various recycling companies that fraudulently inflated the recycling companies’ payroll
expenses.

29. Beginning at least on or about June 12, 2020, after several PPP loans were
funded to various recycling companies, defendants Mihir Patel and Kinjal Patel
directed others, including defendants Wajahat Khan and Bhargav Bhatt, to transfer
PPP loan funds through various bank accounts to create a false paper trail of payroll
expenses for the purpose of concealing how the PPP loan funds would be used.

30. After disguising transfers of PPP loan funds as payroll payments through a
bank account controlled by Wajahat Khan, Bhargav Bhatt, and Chirag Gandhi,

beginning on or about May 1, 2020, defendants Wajahat Khan and Bhargav Bhatt

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transferred, and caused to be transferred, PPP loan proceeds back to a bank account

controlled by Wajahat Khan.

31. During the course of the conspiracy, at least 24 false and fraudulent PPP

loan applications were submitted to financial institutions on behalf of recycling

companies and individuals, on or about the dates shown below seeking the approximate

PPP loan amounts set forth below:

Borrower “|. Date ; Financial Institution Requested || Funded
Level Eight 4/6/2020 Bank of America $12,083 $12,083
Elephant 4/g/2020 | Midwest Regional | 411 993 38 $222,400
Recycling Bank
4G Metals 4/14/2020 | Happy State Bank $307,884.82 $282,200
S.P. 4/20/2020 Dominion Bank $25,625 $20,832.50
J.P. 4/21/2020 Dominion Bank $21,598.96 $20,832.50
Imran Khan 4/22/2020 | Happy State Bank $23,333.33 $20,800
Mihir Patel 4/23/2020 Dominion Bank $20,083.33 $20,832.50
Mitra Bhattarai | 4/23/2020 Midwest Regional $20,833 $20,600
Dharmesh Patel | 4/23/2020 Carter FCU $20,833 $20,799
AQ. 4/29/2020 Dominion Bank $21,197.71 Not Funded
Chirag Gandhi | 4/29/2020 | Happy State Bank $21,041.67 $20,800
CLP. 4/29/2020 Dominion Bank $21,041 $20,832.50
Kinjal Patel 4/29/2020 | Happy State Bank $20,510.42 $20,500
Mihir Patel 4/29/2020 | Happy State Bank $22,083.33 Not Funded
Prateek Desai | 4/29/2020 | Happy State Bank $22,708.33 $20,800
West Texas | 4/99/2020 Celtic Bank $143,593 $143,593
Equipment
crap 4/29/2020 IBC Bank $307,884.82 | Not Funded
scrap 4/29/2020 | One World Bank | $307,884.82 | $307,884.82
UC. 5/13/2020 | Midwest Regional $17,168 $16,800
Bank
O scten 8/1/2020 | AmericanBank | $411,023.38 | $307,000

Indictment—Page 10
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32.

Paragraphs | through 31 of this indictment are realleged and incorporated

Counts Two through Ten

Bank Fraud and
Aiding and Abetting Bank Fraud
[Violations of 18 U.S.C. §§ 1344(2) and 2]

by reference as though fully set forth herein.

33.

Beginning on or about the dates set forth below, in the Northern District of

Texas and elsewhere, defendants Mihir Patel, Kinjal Patel, Prateek Desai, Wajahat

Khan, Imran Khan, Chirag Gandhi, Bhavesh Patel, Dharmesh Patel, and Mitra

Bhattarai aided and abetted by each other and others, and aiding and abetting each other

and others, did knowingly 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, the financial institutions set forth below, by means of

materially false and fraudulent pretenses, representations, and promises, that is, the

defendants submitted, and caused to be submitted, false applications to fraudulently

obtain the PPP loan proceeds that are listed below, each constituting a separate count:

Count’) Pate | Defendant’ | Institution | Requested |. Funded.
Two | 4/6/2020 | Bhavesh Patel Bank of $12,083 $12,083
America
. Happy State
Three | 4/21/2020 Kinjal Patel Bank $20,510.42 $20,500
. . | Happy State
Four | 4/21/2020 | Chirag Gandhi Bank $21,041.67 $20,800
Five | 4/21/2020 | Dharmesh Patel | Carter FCU $20,833 $20,799
. Happy State
Six | 4/22/2020 Imran Khan Bank $23,333.33 $20,800

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Financial Amount Amount
Count | Date Defendant Institution | Requested | Funded
Midwest
Seven | 4/23/2020 | Mitra Bhattarai Regional $20,833 $20,600
Bank
Eight | 4/23/2020| Mihir Patel pominon $20,083.33 | $20,832.50
Nine | 4/29/2020| Prateek Desai Happy State $22,708.33 | $20,800
. American
Ten 8/1/2020 | Wajahat Khan Bank $411,023.38 $307,000

All in violation of 18 U.S.C. §§ 1344(2) and 2.

Indictment—Page 13
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Count Eleven
Conspiracy to Commit Money Laundering
[ Violation of 18 U.S.C. § 1956(h) (18 U.S.C. § 1957)]

34. Paragraphs 1 through 33 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

35. From on or about March 2020, through in or about April 2023, in the
Northern District of Texas and elsewhere, defendants Mihir Patel, Kinjal Patel,
Wajahat Khan, and Bhargav Batt did knowingly and willfully conspire, combine,
confederate, and agree with each other and other persons known and unknown to the
Grand Jury, to knowingly engage and attempt to engage in a monetary transaction
affecting interstate and foreign commerce in criminally derived property of a value
greater than $10,000, such property having been derived from a specified unlawful

activity, that is, bank fraud, in violation of 18 U.S.C. § 1344(2).

All in violation of 18 U.S.C. § 1956(h) (18 U.S.C. § 1957).

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Count Twelve
Bank Fraud
[Violation of 18 U.S.C. § 1344(2)]

The Scheme

36. Paragraphs 1 through 19 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

37. | Between on or about July 1, 2019, and on or about August 1, 2019,
defendant Bhavesh Patel submitted a line of credit application to Spectra Bank on behalf
of Level Eight claiming that Level Eight would use the loan proceeds as working capital.

38. Thereafter, Spectra Bank approved Level Eight’s line of credit for
$500,000.

39. | Between on or about August 1, 2019, and on or about September 1, 2019,
after Spectra Bank funded Level Eight’s line of credit, defendant Bhavesh Patel caused
approximately $495,000 to be withdrawn from the line of credit. Instead of using the
proceeds for Level Eight’s benefit, Bhavesh Patel caused the funds from the line of
credit to be redirected to bank accounts controlled by defendants Mihir Patel, Kinjal
Patel, Prateek Desai, Imran Khan, and Chirag Gandhi.

40. Between on or about September 1, 2019, and on or about September 20,
2019, defendant Bhavesh Patel approached Spectra Bank to increase the amount of
Level Eight’s line of credit. Thereafter, Spectra Bank approved Level Eight’s line of
credit increase for an additional amount of $500,000.

41. Between on or about September 20, 2019, and on or about November 1,

2019, defendant Bhavesh Patel caused approximately $501,000 to be withdrawn from

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the line of credit. Instead of using the proceeds for Level Eight’s benefit, Bhavesh Patel
caused funds from the line of credit to be redirected to bank accounts controlled by
defendants Mihir Patel, Kinja] Patel, Prateek Desai, and Chirag Gandhi.
The Charge

42. Fromon or about July 1, 2019, through on or about November 1, 2019, in
the Northern District of Texas and elsewhere, defendant Bhavesh Patel did knowingly
and willfully execute a scheme and artifice to obtain moneys, funds, credits, assets,
securities, and other property owned by, and under the custody and control of, a financial
institution, Spectra Bank, by means of materially false and fraudulent pretenses,
representations, and promises, that is, Bhavesh Patel submitted, and caused to be

submitted, a false line of credit application to fraudulently obtain loan proceeds.

All in violation of 18 U.S.C. § 1344(2).

Indictment—Page 16
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Counts Thirteen through Fifteen
Bank Fraud
[Violation of 18 U.S.C. § 1344(2)]

The Scheme

43. Paragraphs 1 through 19 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

44. Beginning on or about June 1, 2021, defendant Mihir Patel submitted, and
caused to be submitted, applications to IncredibleBank, Dominion Bank, and First United
Bank, seeking several loans on behalf of various recycling companies purportedly for
business purposes, such as, to purchase recycling equipment from Equipment Company-
1. The total amount of loan proceeds requested from these financial institutions was
approximately $46,359,900.

45. Beginning on or about July 1, 2021, defendant Mihir Patel submitted, and
caused to be submitted, false documents to IncredibleBank, Dominion Bank, and First
United Bank in support of these fraudulent loan applications. The documents included
false estimate and payoff documentation from Equipment Company-1, as well as a
personal financial statement that falsely described Mihir Patel’s financial obligations and

his ownership of certain recycling companies.
The Charge

46. From on or about June 1, 2021, and continuing through on or about April 1,
2023, in the Northern District of Texas and elsewhere, defendant Mihir Patel did
knowingly and willfully execute a scheme and artifice to obtain moneys, funds, credits,

assets, securities, and other property owned by, and under the custody and control of, the

Indictment—Page 17
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financial institutions listed below, by means of materially false and fraudulent pretenses,

representations, and promises, that is, Mihir Patel submitted, and caused to be submitted,

false applications to fraudulently obtain loan proceeds on or about the dates, and in the

approximate amounts listed below, each constituting a separate count:

Thirteen R.A. Industries 7/22/2021 | Dominion Bank | $3,969,000 | $3,969,000
Fourteen | West Texas Scrap | 12/31/2021] IncredibleBank | $4,050,000 | $4,050,000
Fifteen Mammoth Group | 12/29/2022 | First United Bank | $38,340,900 | $38,340,900

All in violation of 18 U.S.C. § 1344(2).

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Count Sixteen
Making a False Statement to the FDIC
[Violation of 18 U.S.C. § 1007]

47. Paragraphs 1 through 19 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

48. Onor about March 30, 2022, in the Northern District of Texas and
elsewhere, defendant Bhavesh Patel did knowingly make and invite reliance on a false,
forged, and counterfeit statement, document, or thing for the purpose of influencing the
action of the FDIC, that is, Bhavesh Patel submitted, and caused to be submitted, to the
FDIC a statement in which Bhavesh Patel falsely claimed that he did not know Mihir
Patel, Wajahat Khan, Imran Khan, Chirag Gandhi, and Dharmesh Patel.

In violation of 18 U.S.C. § 1007.

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Forfeiture Notice
[18 U.S.C. § 982(a)(2) and 18 U.S.C. § 982(a)(1)]

49, Paragraphs 1 through 48 of this indictment are realleged and incorporated
by reference as though fully set forth herein.

50. Upon conviction for any of the offenses alleged in Counts One through
Fifteen of this indictment and pursuant to 18 U.S.C. § 982(a)(2), each of defendants
Mihir Patel, Kinjal Patel, Prateek Desai, Wajahat Khan, Imran Khan, Chirag
Gandhi, Bhavesh Patel, Dharmesh Patel, Mitra Bhattarai, Bhargav Bhatt, as
applicable, shall forfeit to the United States of America any property constituting, or
derived from, proceeds obtained directly or indirectly as a result of the offense.

51. | Uponconviction for the offense alleged in Count Sixteen of this indictment
and pursuant to 18 U.S.C. § 982(a)(1), defendant Bhargav Bhatt shall forfeit to the
United States of America any property, real or personal, involved in, or traceable to
property involved in, the offense.

52. The above-referenced property subject to forfeiture includes, but is not

limited to, a “money judgment” constituting the gross proceeds traceable to the offense.

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A TRUE BILL:

FOREPERSON

LEIGHA SIMONTON
UNITED STATES ATTORNEY

FABIO LEONARDI

Assistant United States Attorney
New York State Bar No. 4902938
1100 Commerce Street, Third Floor
Dallas, Texas 75242-1699
Telephone: 214-659-8600
Facsimile: 214-659-8809

Email: fabio.leonardi@usdoj.gov

Indictment—Page 21
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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

THE UNITED STATES OF AMERICA

MIHIR PATEL (01)
KINJAL PATEL (02)
PRATEEK DESAI (03)
WAJAHAT KHAN (04)
a/k/a Ray Khan
IMRAN KHAN (05)
a/k/a Ron Khan
CHIRAG GANDHI (06)
a/k/a Chris Gandhi
BHAVESH PATEL (07)
a/k/a Bobby Patel
DHARMESH PATEL (08)
a/k/a Danny Patel
MITRA BHATTARAI (09)
BHARGAV BHATT (10)
a/k/a Brad Bhatt

SEALED INDICTMENT

18 USC. § 1349 (18 US.C. § 1344(a)(2))

Conspiracy to Commit Bank Fraud
(Count 1)

18 U.S.C. §§ 1344(2) and 2
Bank Fraud and Aiding and Abetting Bank Fraud
(Counts 2 through 10)

18 U.S.C. § 1956(h) (18 U.S.C. § 1957)
Conspiracy to Commit Money Laundering
(Count 11)

18 U.S.C. § 1344(2)
Bank Fraud
(Counts 12 through 15)

he ap
Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 23 of 23 PagelD 23

18 U.S.C. § 1007
Making a False Statement to the FDIC
(Count 16)

18 U.S.C. § 982(a)(2) and 18 U.S.C. § 982(a)(1)
Forfeiture Notice

16 Counts

A true bill rendered 1V) (

DALLAS FOREPERSON

Filed in open court this 7 | day of June, 2023.

Warrant to be Issued for all Defendants

UNITED STATES MAGISTRATE JUDGE
No Criminal Matter Pending


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File
1-indictment-5540f8ec.pdf
Size
679,032 bytes
SHA-256
5540f8ecba55dcfabcda65a5cd58deb3b6dc383e02086f7c14b601c843a372a0
Our copy
1-indictment-5540f8ec.pdf
Original
archive.org
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