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.
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“Indictment — United States v. Mihir Patel et al., Northern District of Texas (Document 1).”
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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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 2of23 PagelD 2 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’); Indictment—Page 2 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 3of23 PagelD 3 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page5of23 PagelD5 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 6of23 PagelD 6 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. Indictment—Page 6 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 7of23 PagelD 7 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 8of23 PagelD 8 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 9of23 PagelD 9 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 Indictment—Page 9 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 10 of 23 PagelD 10 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 12 of 23 PagelD 12 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 Indictment—Page 12 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 13 of 23 PagelD 13 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 14 of 23 PagelD 14 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). Indictment—Page 14 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 15o0f23 PagelD 15 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 Indictment—Page 15 Case 3:23-cr-00252-K Document 1 Filed 06/21/23 Page 16 of 23 PagelD 16 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 17 of 23 PagelD 17 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 18of23 PagelD 18 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). Indictment—Page 18 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 19 of 23 PagelD 19 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. Indictment—Page 19 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 20 of 23 PagelD 20 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. Indictment—Page 20 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 21 o0f23 PagelD 21 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 Case 3:23-cr-00252-K Document1 Filed 06/21/23 Page 22 of 23 PagelD 22 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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