Pandemic Darlings The pandemic economy, in original documents
Home Indictment — United States v. Rodney Rosenstein, District of Arizona (Document 3)Search ⌕

Indictment — United States v. Rodney Rosenstein, District of Arizona (Document 3)

Summary

A sealed grand jury indictment against Rodney Rosenstein, Case 4:26-cr-04213-RM-EJM, filed August 12, 2026 as Document 3 in the U.S. District Court for the District of Arizona. It charges conspiracy to commit bank fraud under 18 U.S.C. § 1349 (Count 1-2) and conspiracy to commit false statement to influence a mortgage lending business under 18 U.S.C. § 371 (Count 3). It alleges that between approximately May 2020 and April 2021 Rosenstein, through companies he owned and controlled, obtained approximately $2,904,091 in 15 PPP loans using fake IRS Forms 941 and W-2's created by an unindicted co-conspirator, and later sought loan forgiveness with fake payroll documents. It also alleges fake rent rolls overstated occupancy to obtain cash-back refinance loans, including an approximately $11.4 million loan from M&T Realty Capital Corporation on or about June 30, 2023.

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. Rodney Rosenstein, District of Arizona (Document 3).” Original at ecf.azd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-usa-v-rosenstein-dkt-3-d-ariz-1f34c7d62e/, SHA-256 df0309d72f6bede8ebe483d03aeb057d6cb28d6eecf1bfdba0fcabd6bb0664f3.

Full text

     Case 4:26-cr-04213-RM-EJM        Document 3      Filed 08/12/26     Page 1 of 12



 1    TIMOTHY COURCHAINE
      United States Attorney
 2    District of Arizona
      Jonathan B. Grano ff
 3    David P. Petermann
      Assistant U.S. Attorneys
 4    United States Courthouse
      405 W. Congress Street, Suite 4800
 5    Tucson, Arizona 85701
      Telephone: 520-620-7300
 6    Email: Jonathan.Granoff@usdoj.gov
             David.Petermann@usdoJ.gov                   CR26-04213 TUC-RM(LLP)
 7    Attorneys for Plaintiff
 8                         IN THE UNITED STATES DISTRICT COURT
 9                               FOR THE DISTRICT OF ARIZONA
10
       United States of America,
11                                                                  INDICTMENT
                              Plaintiff,
12                                                    Violations:
               vs.
13                                                       18 U.S.C. § 1349
                                                         Conspiracy to Commit Bank Fraud
14     Rodney Rosenstein,                                (Count 1-2)
15                            Defendant.
                                                        18 U.S.C. § 371
16                                                      Conspiracy to Commit False Statement to
                                                        Influence a Mortgage Lending Business
17                                                      (Count 3)
18
                                                        18 U.S.C. §§ 98l(a)(l)(C) and
19                                                      982(a)(2)(A); 28 O.S.C. § 246l(c)
                                                        (Forfeiture Allegation)
20
                                                                    (UNDER SEAL)
21
22     THE GRAND JURY CHARGES:
23                                         INTRODUCTION
24           At all relevant times in this indictment, the following facts are alleged:
25            1. The defendant, Rodney Rosenstein ("ROSENSTEIN"), was a resident of
26     California. Rosenstein owned and controlled the following companies: Red Ocean Inc. ;
27     Ocean Structures LP; 9919 Canoga LLC ; 2450 Colorado Blvd. LLC; Helpful Housing;
28     Storage Depot Inc. ; Pacific Coast Alarms Inc. ; and Ocean Structure Inc.
     Case 4:26-cr-04213-RM-EJM                Document 3   Filed 08/12/26   Page 2 of 12



 1             2. ROSENSTEIN also owned and controlled the following additional companies:
 2     4098 E. 29th Street LLC ; 4141 E. 29th Street LLC ; 314 E. Benson LLC ; and 1025 E.
 3     Benson LLC. Helpful Housing is the principal member for each of these entities.
 4     ROSENSTEIN incorporated and is listed as the CEO of Helpful Housing. Each of these
 5     entities was formed in Arizona.
 6              3. Pacific Western Bank (now known as Banc of California, N.A); Pacific Enterprise
 7     Bank (now known as United Business Bank); Zions Bancorporation dba California Bank
 8     & Trust; Zions Bancorporation dba Zions First National Bank; Farmers & Merchants Bank
 9     of Long Beach; and Bank of Southern California (now known as California Bank of
10     Commerce) were all financial institutions insured by the Federal Deposit Insurance
11     Corporation (FDIC).
12             4. These "financial institutions" were all Small Business Administration (SBA)
13     participating lenders for the Paycheck Protection Program described below.
14             5. The SBA is an agency of the United States. The purpose of the SBA is to help
15     and support small businesses in the United States.
16             6. Pacific Premier Bank (now known as Columbia Bank), M&T Realty Capital
17     Corporation, and ReadyCap Commercial LLC were financial institutions and mortgage
18     lending businesses.
19                                      The Paycheck Protection Program
20             7. In March 2020, the Coronavirus Aid Relief, and Economic Security ("CARES")
21    Act was enacted and provided emergency financial assistance to Americans suffering
22     economic harm because of the COVID-19 pandemic. The CARES Act authorized the SBA
23     to create the Paycheck Protection Program (PPP), which permitted the SBA to use billions
24     of dollars in United States taxpayer funds to provide guaranteed loans to small businesses
25     for job retention and certain other expenses. PPP loans were 100% guaranteed by the SBA,
26     and the full principal amount of the loans qualified for loan forgiveness if the terms of the
27    program were satisfied.
28

       United States of America v. Rodn ey Rosenstein
       Indictment Page 2 of I 2
     Case 4:26-cr-04213-RM-EJM              Document 3   Filed 08/12/26    Page 3 of 12



 1            8. To provide relief to America's small businesses expeditiously, the CARES Act
 2     streamlined the loan process and allowed SBA participating lenders (the financial
 3     institutions) to rely on certifications of the borrowers to determine eligibility for the loans.
 4     The Act also allowed these financial institutions to rely on specified documents provided
 5     by borrowers to detennine the qualifying loan amount and eligibility for loan forgiveness.
 6     Some of the documents the lenders relied on for their loan approval process were United
 7     States tax forms to include Forms 941 (quarterly payroll tax forms) and W-2 's. These
 8     documents were material to the lending decisions and provided by the loan applicant as
 9     proof of the monthly payroll expenses to support the loan amounts issued by the
10     participating lenders.
11            9. To obtain approval for the loan, the loan applicant was required to state, among
12     other things, their average monthly payroll expenses. These figures were used to calculate
13     the amount of money the small business was eligible to receive. Under the Program,
14     businesses were generally eligible for loans 2.5 times that of their average monthly payroll.
15     The loan funding amount under the SBA program therefore generally increased depending
16     on the stated monthly payroll in the loan application.
17            10. In the application for PPP loan ("SBA Form 2483 "), the applicant certified that
18    "the information provided in all supporting documents and forms [was] true and accurate
19     in all material respects. " The application further informed the applicant that making a false
20    statement to obtain a guaranteed loan from the SBA was punishable under various federal
21     criminal statutes.
22                            The PPP Bank Fraud Scheme and Artifice to Defraud
23            11. It was part of the scheme and artifice to defraud that ROSENSTEIN and his co-
24    conspirators, with the intent to defraud, knowingly and intentionally executed and
25    attempted execute a scheme to defraud various federally insured financial institutions
26     identified in paragraph 3 of the indictment. ROSENSTEIN became a member of the
27    conspiracy knowing its object was to commit bank fraud and intended to help accomplish
28     it. Between approximately May 2020 through April 2021, ROSENSTEIN, through his

      United States of America v. Rodney Rosenstein
      Indictment Page 3 of 12
     Case 4:26-cr-04213-RM-EJM               Document 3   Filed 08/12/26   Page 4 of 12



 1     companies identified in paragraph 1, fraudulently obtained a total of approximately
 2     $2,904,091 in 15 PPP loans from these financial institutions. As part of the loan application
 3     process, Co-conspirator A created numerous fake and fraudulent IRS Forms 941 and W-
 4     2's in the names of ROSENSTEIN' s business entities. These phony documents falsely
 5     conveyed that these tax documents had been properly filed with the IRS when that had not
 6     occurred. The fake W-2 forms falsely represented that various employees had been paid
 7     wages and that they had federal income and payroll tax withheld from these wages.
 8     However, none of these W-2 forms were ever issued or filed with the IRS and the listed
 9     individuals were never paid the wages reflected on the forms. Additionally, no such income
10     was ever actually withheld from the phony wages. These tax documents contained personal
11     identifying information of fake individuals purporting to be employees who either did not
12     exist or individuals who did exist but never worked for ROSENSTEIN or his companies.
13     The social security numbers listed on these forms were either not valid or falsely attributed
14     to an individual listed on the tax fonn. After creating these fake tax documents, Co-
15     conspirator A would transfer them to ROSENSTEIN. In certain cases, the transfer of fake
16     documents was directly from Co-conspirator A to ROSENSTEIN. However, in other cases,
17     Co-conspirator A forwarded the fake documents to Co-conspirator B, who would then
18     transfer the fake documents to ROSENSTEIN. 1 ROSENSTEIN and his fellow co-
19     conspirators knowingly and intentionally caused these fake and phony tax documents to be
20     submitted for each fraudulently obtained PPP loan. These fake documents and their filing
21     status with the IRS were material and capable of influencing the lenders' decisions to issue
22    PPP loans.
23             12. As part of the PPP loan program, loan applicants were eligible for loan
24     forgiveness assuming they could demonstrate that they complied with the parameters of
25    the PPP loan program. In furtherance of the bank fraud scheme, between approximately
26    June 2021 through August 2022, ROSENSTEIN submitted or caused to be submitted
27
28             1
                   Co-conspirators "A" and "B" are unindicted co-conspirators.
       United States of America v. Rodney Rosenstein
       Indictment Page 4 of 12
     Case 4:26-cr-04213-RM-EJM             Document 3   Filed 08/12/26   Page 5 of 12



 1     fraudulent and phony payroll tax documents to the financial institutions to unlawfully
 2     obtain "loan forgiveness. " These documents were also created by Co-conspirator A and
 3     provided to ROSENSTEIN through Co-conspirator B. In his "loan forgiveness
 4     applications," ROSENSTEIN further intentionally caused documents to be submitted that
 5     contained materially false representations that he properly used PPP loan funds towards
 6     payroll and other qualified expenses, when in fact ROSENSTEIN had used portions of
 7     fraudulent PPP loan funds to purchase new properties or for other unauthorized expenses.
 8                The Phony "Rent Roll" Bank Fraud Scheme and Artifice to Defraud
 9            13. It was part of the scheme and artifice to defraud that defendant and his co-
10     conspirators, (Co-conspirators B and C and at least one other unnamed Co-conspirator) 2
11     with the intent to defraud, knowingly and intentionally executed and attempted execute a
12     scheme to defraud various financial institutions and mortgage lending businesses in a
13     separate bank fraud scheme as follows. ROSENSTEIN became a member of the
14     conspiracy knowing its object was to commit bank fraud and intended to help accomplish
15     it.
16                                      4098 E. 29th Street, Tucson AZ
17            14. On or about June 30, 2023 , ROSENSTEIN, through his company 4098 E. 29th
18     Street LLC obtained an additional approximately $11.4 million dollar fraudulent "cash
19     back" refinance loan relating to the above property from M&T Realty Capital
20     Corporation, a financial institution and mortgage lending business. From this total,
21    ROSENSTEIN received approximately $3 .5 million dollars after the balance of the
22    previous mortgage had been paid. ROSENSTEIN and his co-conspirators caused to be
23    submitted materially false representations concerning the property ' s rental occupancy.
24    The fake rent roll documents falsely represented the rental occupancy rates for the
25    property at 100% occupied between March through May 2023. In reality, the property
26    during this time-period was 80% occupied.
27
28            2
                  Co-conspirator "C" is also an unindicted Co-conspirator.
      United States ofAmerica v. Rodney Rosenstein
      Indictment Page 5 of 12
     Case 4:26-cr-04213-RM-EJM             Document 3   Filed 08/12/26    Page 6 of 12



 1                                      4141 E. 29th Street, Tucson, AZ
 2            15. On or about March 18, 2022, ROSENSTEIN, through his company 4141 E.
 3     29th Street LLC, obtained an additional approximately $6.2 million "cash back"
 4     refinance loan from ReadyCap Commercial LLC, a financial institution and mortgage
 5     lending business. From this total, ROSENSTEIN received approximately $2.1 million
 6     dollars after the balance of the previous mortgage had been paid. As part of the loan
 7     approval process, the co-conspirators, to include ROSENSTEIN, caused to be submitted
 8     materially false representations to include falsely overstating the "rent roll" occupancy
 9     rate for the property as 100 percent and falsely overstating gross monthly operating
10     income. In reality, during the time-frame submitted for the loan application, the
11     occupancy rate for the property was 56% and 61 %.
12                                   314 E. Benson Highway, Tucson, AZ
13            16. On or about June 30, 2022, ROSENSTEIN, through his company 314 E.
14    Benson LLC, obtained an approximately $2.5 million "cash back" refinance loan from
15    ReadyCap Commercial LLC, a financial institution and mortgage lending business. From
16    this total, ROSENSTEIN received approximately $1.3 million dollars after the balance of
17    the previous mortgage had been paid. As part of the loan approval process, the co-
18    conspirators, to include ROSENSTEIN, caused to be submitted materially false
19    representations to include falsely overstating the "rent roll" occupancy rate as 100 percent
20    and falsely overstating the gross monthly operating income. In reality, during the time-
21    frame submitted for the loan application, the occupancy rate was 76%.
22                                  1025 E. Benson Highway, Tucson, AZ
23            17. On or about January 25, 2023 , ROSENSTEIN, through his company 1025 E.
24    Benson LLC, obtained an approximately $7 .1 million "cash back" refinance loan from
25    ReadyCap Commercial LLC, a financial institution and mortgage lending business. From
26    this total, ROSENSTEIN received approximately $1 .9 million dollars after the balance of
27    the previous mortgage had been paid. As part of the loan approval process, the co-
28    conspirators, to include ROSENSTEIN, caused to be submitted materially false

      United States ofAmerica v. Rodney Rosenstein
      Indictment Page 6 of I 2
     Case 4:26-cr-04213-RM-EJM             Document 3   Filed 08/12/26    Page 7 of 12



 1     representations to include falsely overstating the "rent roll" occupancy rate as 100 percent
 2     and falsely overstating the gross monthly operating income. In reality, the occupancy rate
 3     for the property was between 59% and 66% during the time-period submitted for the loan
 4     application.
 5
               Additional False Statements to Influence Financial Institutions and Mortgage
 6
                                       Lending Businesses
 7
              18. On or about September 16, 2021 , ROSENSTEIN, through his company 4098
 8
       E. 29th Street LLC, obtained an approximately $8 million dollar "cash back" refinance
 9
       loan from Pacific Premier Bank (now known as Columbia Bank), a financial institution
10
       and mortgage lending business. From this total, ROSENSTEIN, through his company,
11
       received approximately $2.2 million dollars after the balance of the previous mortgage
12
       had been paid. To obtain the loan, the Co-conspirators provided fake "rent rolls" to
13
       demonstrate that the property had a rental occupancy rate of 100% when the property
14
       truthfully did not have a full rental occupancy. Co-conspirators further falsely overstated
15
       gross operating income to inflate the profitability of the property. These false
16
       representations were provided to the lender to obtain the loan.
17
              19. Relating to each commercial loan outlined in paragraphs 13-18 of the
18
       indictment, Co-conspirator B, on behalf of ROSENSTEIN, created fake capital
19
       expenditure lists for each loan application. The capital expenditure lists artificially
20
       inflated the true and accurate capital improvement expenses for each property. These
21
       false statements were submitted to the mortgage lending businesses in furtherance of the
22
       conspiracy to influence the lenders ' funding decision.
23
              20. Relating to the commercial loans outlined in paragraphs 13-18 of the
24
       indictment, Co-conspirator B, on behalf ROSENSTEIN, provided additional false
25
      representations concerning the rental occupancy rates after the loans had been approved.
26
      Co-conspirators informed bank inspectors ( after the issuance of the loans) that the
27
28

      United States ofAmerica v. Rodney Rosenstein
      Indictment Page 7 of 12
     Case 4:26-cr-04213-RM-EJM               Document 3          Filed 08/12/26   Page 8 of 12



 1     property had an occupancy rate close to 100 percent when in fact the occupancy rate was
 2     significantly below 100 percent.
 3             21. Relating to the commercial loan for 1025 E. Benson Highway referenced in
 4    paragraph 17 of the indictment, after the loan had been issued, the Co-conspirators
 5     continued to provide the lender' s servicer fake "rent roll" documents and other false
 6     representations about the rental occupancy rates of the property. This property was
 7     condemned by the City in September 2023. After this time-period, the property had no
 8     tenants. Co-conspirator B, on behalf of ROSENSTEIN, falsely "staged" the property to
 9     make it appear that there were tenants on the property during various bank inspections
10     when in fact the property had no tenants at the time.
11                                                           COUNTl
12                                         Conspiracy to Commit Bank Fraud
13                                               (PPP Loan Program)
14                                                     [Title 18 U.S.C. § 1349)
15             22. Paragraphs 1 and 3-5, 7-12 of this indictment are re-alleged and reincorporated
16     as if fully set forth herein.
17             23. On or about April 2020 through August 2022, in the District of Arizona, and
18    elsewhere, the defendant, ROSENSTEIN and his fellow Co-conspirators knowingly and
19    intentionally combined, confederated and agreed with each other to commit an ongoing
20    Conspiracy to Commit Bank Fraud as specified in paragraphs 11-12 of the indictment. The
21    co-conspirators, to include ROSENSTEIN, knowingly and intentionally executed, and
22    attempted to execute, a scheme and artifice to: (1) defraud various federally insured
23    financial institutions; and (2) obtain any money, funds , credits, assets, or other property
24    owned by or under the custody or control of such financial institutions, by means of
25    materially false and fraudulent pretenses, representations, or promises, all in violation of
26    Title 18, United States Code, Sections 1344. Various overt acts in furtherance of the
27    conspiracy occurred in the District of Arizona and elsewhere.
28            All in violation of Title 18, United States Code, Section 1349.

      United States of America v. Rodn ey Rosenstein
      Indictment Page 8 of 12
     Case 4:26-cr-04213-RM-EJM              Document 3          Filed 08/12/26   Page 9 of 12



 1                                                          COUNT2
 2                                         Conspiracy to Commit Bank Fraud
 3                                          (Phony Rent Roll Scheme)
 4                                                    [Title 18 U.S.C. § 1349]
 5            24. Paragraphs 2, 6, and 13-17 of this indictment are re-alleged and reincorporated
 6     as if fully set forth herein.
 7            25. On or about March 2022 through June 2023 , in the District of Arizona, and
 8     elsewhere, the defendant, ROSENSTEIN and his fellow co-conspirators knowingly and
 9     intentionally combined, confederated, and agreed with each other to commit an ongoing
10     Conspiracy to Commit Bank Fraud as specified in paragraphs 13-17 of the indictment. The
11     co-conspirators, to include ROSENSTEIN, knowingly and intentionally executed, and
12     attempted to execute, a scheme and artifice to: (1) defraud various federally insured
13     financial institutions; and (2) obtain any money, funds , credits, assets, or other property
14     owned by or under the custody or control of such financial institutions, by means of
15     materially false and fraudulent pretenses, representations, or promises, all in violation of
16    Title 18, United States Code, Sections 1344. Various overt acts in furtherance of the
17    conspiracy occurred in the District of Arizona and elsewhere.
18            All in violation of Title 18, United States Code, Section 1349.
19
20                                                       COUNT3

21                       Conspiracy to Commit an Offense Against the United States:
                       False Statement to Influence a Mortgage Lending Business
22
                                               [Title 18 U.S.C. § 371]
23
24            26. Paragraphs 2, 6, and 13-21 of this indictment are re-alleged and incorporated as
25    if fully set forth herein.
26            27. On or about September 2021 through December 2025 , in the District of Arizona,
27    and elsewhere, the defendant, ROSENSTEIN and his fellow Co-conspirators knowingly
28    and intentionally combined, confederated, agreed, and conspired with each other to commit

      United States of America v. Rodney Rosenstein
      Indictment Page 9 of 12
     Case 4:26-cr-04213-RM-EJM              Document 3   Filed 08/12/26    Page 10 of 12



       an offense against the United States, that is, false statement for the purpose of influencing
 1
       in any way the action of mortgage lending businesses and an FDIC insured financial
 2
       institution upon and in relation to applications or inspections relating cash-back mortgage
 3
       refinance loans, in violation of Title 18, U.S.C. § 1014. ROSENSTEIN became a member
 4
       of the conspiracy knowing its object was to commit false statement to influence a financial
 5
       institution or mortgage lending business and intended to help accomplish it
 6
 7             28. In furtherance of the conspiracy and to effect the object of the conspiracy, the

 8     following overt acts were committed in the District of Arizona and elsewhere:

 9             a. ROSENSTEIN and his Co-conspirators conspired to falsely inflate various capital

10     expenditures relating to the commercial "cash-back" fraudulently obtained loans. Co-

11     conspirator B, on behalf of ROSENSTEIN, created a phony capital expenditure list that

12     reflected total capital expenses for the 4098 E. 29 th Street Tucson property as

13     approximately $3.7 million dollars. In reality, capital expenses for this property were

14     approximately $2 million to $2.25 million dollars. The false capital expenditure list for this

15     property was submitted to the lenders with the intent to influence the lenders ' decision to

16     obtain the loans. Additionally, false rent rolls reflecting the property had a 100% occupancy

17     rate were also submitted to obtain both cash-back refinance loans for this property. In

18     reality, the truthful rental occupancy rates were between 80% and 92% during the time-

19     period provided in the loan applications for the loans.

20             b. Co-conspirator B, on behalf of ROSENSTEIN, created a phony capital

21     expenditure list that reflected total capital expenses for 4141 E. 29 th Street property as

22     approximately $2.6 million dollars. In reality, capital expenses for this property were

23     approximately $1.2 million dollars. The false capital expenditure list was submitted to the

24     lender, as part of the conspiracy, with the intent to influence the lender' s decision to obtain

25     the loan.

26             c. Co-conspirator B, on behalf of ROSENSTEIN, created a phony capital

27     expenditure list that reflected total capital expenses for 314 E. Benson Street as

28     approximately $ 1.05 million. In reality, capital expenses for this property were

       United States ofAmerica v. Rodney Rosenstein
       indictment Page IO of 12
     Case 4:26-cr-04213-RM-EJM               Document 3   Filed 08/12/26   Page 11 of 12



 1     approximately $250,000 dollars. The false capital expenditure list was submitted to the
 2     lender, as part of the conspiracy, with the intent to influence the lender' s decision to obtain
 3     the loan.
 4             d. Co-conspirator B, on behalf of ROSENSTEIN, created a phony capital
 5     expenditure list that reflected total capital expenses for 1025 E. Benson Highway as
 6     approximately $2 million. In reality, capital expenses for this property were approximately
 7     $200,000 dollars. The false capital expenditure list was submitted to the lender, as part of
 8     the conspiracy, with the intent to influence the lender' s decision to obtain the fraudulent
 9     loan.
10             e. Key Bank Real Estate Capital and Allegiant Community Asset Service Group
11     conducted inspections on behalf of KeyBank, an FDIC insured financial institution and
12     servicer of the 1025 E. Benson Highway loan referenced in paragraph 17 of the indictment.
13     In connection with this loan and during these inspections on or about January 29, 2024 and
14     December 30, 2025, Co-conspirator B, on behalf of ROSENSTEIN, falsely represented
15     that the property was 99% and 100% occupied, when in fact there were no tenants residing
16     on the premises. Co-conspirator B, on behalf of ROSENSTEIN, "staged" the property with
17     fake tenants to make it appear that the property was occupied when in fact no tenants
18     resided there. These false representations were made with intent to influence the loan
19     servicer' s inspections for the property relating to the loan.
20             All in violation of Title 18, U.S.C., Section 371.
21                                        FORFEITURE ALLEGATION
22             Upon conviction of Counts One through Three of this Indictment, the defendant,
23     Rodney Rosenstein, shall forfeit to the United States of America, pursuant to Title 18,
24     United States Code, Sections 98l(a)(l)(C) and 982(a)(2)(A), and Title 28, United States
25     Code, Section 2461 (c), any property, real or personal, constituting or derived from
26     proceeds traceable to the violations, and any property constituting, or derived from ,
27     proceeds obtained, directly or indirectly, as a result of such violations.
28

       United States of America v. Rodney Rosenstein
       Indictment Page I I of 12
     Case 4:26-cr-04213-RM-EJM              Document 3       Filed 08/12/26   Page 12 of 12



 1             If any of the property described above, as a result of any act or omission of the
 2     defendant: a) cannot be located upon the exercise of due diligence; b) has been transferred
 3     or sold to, or deposited with, a third party ; c)has been placed beyond the jurisdiction of the
 4     court; d) has been substantially diminished in value; ore) has been commingled with other
 5     property which cannot be divided without difficulty, it is the intent of the United States,
 6     pursuant to Title 21 , United States Code, Section 853(p ), as incorporated by Title 18,
 7     United States Code, Section 982(b)(l), and Title 28, United States Code, Section 246l(c),
 8     to seek forfeiture of any other property of said defendant up to the value of the above
 9     forfeitable property, including, but not limited to, all property, both real and personal,
10     owned by the defendant.
11             All pursuant to Title 18, United States Code, Sections 98l(a)(l)(C) and
12     982(a)(2)(A), Title 28, United States Code, Section 246l(c), and Rule 32.2(a), Federal
13     Rules of Criminal Procedure.
14
                                                       A TRUE BILL
15
16                                                     ISi
                                                       FOREPERSON OF THE GRAND JURY
17                                                     Dated: August 12, 2026
18     TIMOTHY COURCHAINE
       United States Attorney
19     District of Arizona
20
       ISi
21     JONATHAN B. GRANOFF
       Assistant U.S. Attorney
22
23
24
25
26
27
28

       United States of America v. Rodney Rosenstein
       Indictm ent Page 12 of 12


File and source

File
3-indictment-redacted-for-public-disclosure-as-to-rodney-rosen.pdf
Size
290,020 bytes
SHA-256
df0309d72f6bede8ebe483d03aeb057d6cb28d6eecf1bfdba0fcabd6bb0664f3
Our copy
3-indictment-redacted-for-public-disclosure-as-to-rodney-rosen.pdf
Original
PACER (login required)
Back to top