United States v. Rita Shaba — Plea Agreement, Eastern District of Michigan (ECF No. 65)
Summary
A plea agreement between the United States and Rita Shaba, Case No. 23-CR-20296, filed August 26, 2025 as ECF No. 65 in the U.S. District Court for the Eastern District of Michigan before Hon. Jonathan J.C. Grey. Rita Shaba agrees to plead guilty to Count 1 of the Indictment, conspiracy to commit wire fraud and bank fraud under 18 U.S.C. § 1349, which carries up to 30 years' imprisonment, and the government will move to dismiss any remaining charges. In the factual basis the defendant admits conspiring with others, including Samer Kammo, from about April 2020 through December 2020 to obtain Paycheck Protection Program loans with false applications and fictitious records, and obtaining additional PPP loans in her own name. The parties recommend guideline provisions including an actual loss of $1.5 Million-$3.5 Million, and there is no agreement on restitution.
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“United States v. Rita Shaba — Plea Agreement, Eastern District of Michigan (ECF No. 65).”
Original at ecf.mied.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-shaba-et-al-dkt-65-e-d-mich-e13ed20a14/
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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.394 Filed 08/26/25 Page 1 of 25
United States District Court
Eastern District of Michigan
Southern Division
United States of America,
Plaintiff,
Case No. 23-CR-20296
V.
Hon. Jonathan J.C. Grey
D-1 Rita Shaba,
Defendant.
I
Plea Agreement
The United States of America and the defendant, Rita Shaba, have
reached a plea agreement under Federal Rule of Criminal Procedure 11.
The plea agreement's terms are:
1. Count of Conviction
The defendant will plead guilty to Count 1 of the Indictment. Count
1 charges the defendant with Conspiracy to Commit Wire Fraud and
Bank Fraud under 18 U.S .C § 1349.
2. Statutory Maximum Penalties
The defendant understands that the count to which she is pleading
guilty carries the following maximum statutory penalties:
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Count 1 Term of imprisonment: Up to 30 Years '
Imprisonment
Fine: Up to $1,000,000 or twice
the pecuniary gain or loss;
18 U.S.C. § 3571(d)
Term of supervised release: Up to 5 years
3. Agreement to Dismiss Remaining Charges
If the Court accepts this agreement and imposes sentence
consistent with its terms, the United States Attorney's Office for the
Eastern District of Michigan will move to dismiss any remaining charges
in the indictment (ECF No. 1) against the defendant, Rita Shaba, in this
case.
4. Elements of Count of Conviction
The elements of Count 1 (Conspiracy to Commit Wire Fraud and
Bank Fraud) are:
(l)First, that or more persons conspired, or agreed, to commit
the crime of wire fraud, in violation of 18 U.S.C. § 1343,
and the crime of bank fraud, in violation of 18 U.S.C.
§ 1344(2); and
(2)Second, that the defendant knowingly and voluntarily
joined the conspiracy.
The elements of the crime of wire fraud, in violation of 18 U.S.C.
§ 1343, are:
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(l)First, that the defendant knowingly participated in,
devised, or intended to devise, a scheme to defraud in order
to deprive another of money or property;
(2)Second, that the scheme included a material
misrepresentation or concealment of a material fact;
(3)Third, that the defendant had the intent to defraud; and
(4)Fourth, that the defendant used wire , radio or television
communications or caused another to use wire , radio or
television communications in interstate commerce in
furtherance of the scheme.
The elements of the crime of bank fraud, in violation of 18 U.S.C.
§ 1344(2), are:
(l)First, that the defendant knowingly executed or attempted
to execute a scheme to obtain any of the money, funds, or
property owned by, or under the control of, a bank or
financial institution by means of false or fraudulent
pretenses, representations or promises;
(2) Second, that the scheme included a material
misrepresentation or concealment of a material fact;
(3)Third, that the defendant had the intent to deceive or cheat
someone for the purpose of either causing a financial loss
to another or bringing about a financial gain to herself or
to another person; and
(4)Fourth, that the bank or financial institution was federally
insured.
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5. Factual Basis
The parties agree that the following facts are true , accurately
describe the defendant's role in the offense, and provide a sufficient
factual basis for the defendant's guilty plea:
From at least in or around April 2020, through at least in or around
December 2020, in the Eastern District of Michigan and elsewhere, RITA
SHABA conspired and agreed with others, including SAMER KAMMO
and CHRISTINA ANASI, to commit the crime of wire fraud , in violation
of 18 U.S.C. § 1343, and the crime of bank fraud, in violation of 18 U.S.C.
§ 1344(2). SHABA knowingly and voluntarily joined the conspiracy.
The object of the conspiracy was for SHABA and her co-conspirators
to obtain money and enrich themselves by, among other things, inducing
federally insured financial institutions and other third-party lenders,
through materially false and fraudulent representations and pretenses,
to issue improper Paycheck Protection Program ("PPP") loans and then
divert those loan proceeds to impermissible uses.
As part of the conspiracy, the co-conspirators caused materially
false and fraudulent representations to be made to federally insured
financial institutions and other third-party lenders, including materially
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false and fraudulent representations relating to the purported
entitlement of various business entities to PPP loan assistance. PPP loan
assistance funds issued because of the materially false and fraudulent
representations were then received by the conspirators and used for
impermissible purposes.
As part of the conspiracy, the co-conspirators caused:
a. Misrepresentations to be made regarding purported payroll
expenditures by various business entities;
b. Misrepresentations to be made regarding the purported
number of employees of various business entities;
c. Misrepresentations to be made regarding the purported
nature of business activity for various business entities;
d. Misrepresentations to be made regarding the purported
purpose of PPP loan requests for various business entities;
e. False certifications to be made indicating that PPP loan
proceeds would only be used for permissible business-related
purposes;
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f. False certifications to be made indicating that various non-
operational business entities were operational and that those
entities paid employee salaries;
g. Fictitious payroll records to be created and submitted to
financial institutions and other third-party lenders;
h. Fictitious health insurance records to be created and
submitted to federally insured financial institutions and other
third-party lenders;
1. Fictious bank records to be created and submitted to financial
institutions and other third-party lenders; and
J. Fictitious tax records to be created and submitted to financial
institutions and other third-party lenders.
SHABA acknowledges that as part of the conspiracy, she personally
submitted PPP loan applications knowing the applications were
fraudulent and also generated fictious records for submission in
connection with fraudulent PPP loan applications. SHABA also
acknowledges that she worked with co-conspirators, including
CHRISTINA ANASI , to generate fictious records for submission as part
of fraudulent PPP loan applications.
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SHABA acknowledges causing the transfer of fraudulent PPP loan
proceeds into bank accounts controlled by the co-conspirators knowing
both that those proceeds were fraudulently obtained and that the
proceeds would not be used for permissible purposes.
In furtherance of the conspiracy, the co-conspirators caused
interstate wire transfers to be made, including interstate wire transfers
of PPP assistance funds.
6. Relevant Conduct
SHABA acknowledges that in addition to participating in the
conspiracy detailed above, she also fraudulently obtained additional PPP
loans in her own name. SHABA acknowledges that this conduct is
relevant to her offense of conviction under U.S.S.G. § lBl.3.
7. Advice of Rights
The defendant has read the Indictment, has discussed the charges
and possible defenses with her attorney, and understands the crime(s)
charged. The defendant understands that, by pleading guilty, she is
waiving many important rights, including the following:
A. The right to plead not guilty and to persist in that plea;
B. The right to a speedy and public trial by jury;
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C. The right to be represented by counsel-and, if necessary,
have the court appoint counsel-at trial;
D. The right to be presumed innocent and to require the
government to prove the defendant guilty beyond a reasonable
doubt at trial;
E. The right to confront and cross-examine adverse witnesses at
trial;
F. The right to testify or not to testify at trial, whichever the
defendant chooses;
G. If the defendant chooses not to testify at trial, the right to
have the jury informed that it may not treat that choice as evidence
of guilt;
H. The right to present evidence or not to present evidence at
trial, whichever the defendant chooses; and
I. The right to compel the attendance of witnesses at trial.
8. Collateral Consequences of Conviction
The defendant understands that her conviction here may carry
additional consequences under federal or state law. The defendant
understands that, if she is not a United States citizen, her conviction here
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may require him to be removed from the United States, denied
citizenship, and denied admission to the United States in the future. The
defendant further understands that the additional consequences of her
conviction here may include, but are not limited to, adverse effects on the
defendant's immigration status, naturalized citizenship, right to vote ,
right to carry a firearm , right to serve on a jury, and ability to hold certain
licenses or to be employed in certain fields. The defendant understands
that no one, including the defendant's attorney or the Court, can predict
to a certainty what the additional consequences of the defendant's
conviction might be. The defendant nevertheless affirms that the
defendant chooses to plead guilty regardless of any immigration or other
consequences from her conviction.
9. Defendant's Guideline Range
A. Court's Determination
The Court will determine the defendant's guideline range at
sentencing.
B. Acceptance of Responsibility
The government recommends under Federal Rule of Criminal
Procedure l l(c)(l)(B) that the defendant receive a two-level reduction for
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acceptance of responsibility under USSG § 3El. l(a) Further, if the
defendant's offense level is 16 or greater and the defendant is awarded
the two-level reduction under USSG § 3El.l(a), the government
recommends that the defendant receive an additional one-level reduction
for acceptance of responsibility under USSG § 3El.l(b). If, however, the
government learns that the defendant has engaged in any conduct
inconsistent with acceptance of responsibility-including, but not limited
to, making any false statement to, or withholding information from , her
probation officer; obstructing justice in any way; denying her guilt on the
offense(s) to which she is pleading guilty; committing additional crimes
after pleading guilty; or otherwise demonstrating a lack of acceptance of
responsibility as defined in USSG § 3E 1.1-the government will be
released from its obligations under this paragraph, will be free to argue
that the defendant not receive any reduction for acceptance of
responsibility under USSG § 3El.1 , and will be free to argue that the
defendant receive an enhancement for obstruction of justice under USSG
§ 3Cl.1.
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C. Other Guideline Recommendations
The parties also recommend under Federal Rule of Criminal
Procedure 1 l(c)(l)(B) that the following guideline provisions apply:
Guideline Section Offense Level
Base Offense Level: § 2Bl.l(a)(l) 7
Actual Loss of +16
$1.5 Million-$3.5 Million:
& 2B 1.1 (b )(l)(I)
Sophisticated Means: +2
§ 2B 1.1 (b )(1 0)(C)
Zero-Point Offender:§ 4Cl.l(a) -2
The parties have no other joint recommendations as to the
defendant's guideline calculation.
E. Parties' Obligations
Both the defendant and the government agree not to take any
position or make any statement that is inconsistent with any of the
guideline recommendations or factual stipulations in paragraphs 9.B or
9.C. Neither party is otherwise restricted in what it may argue or present
to the Court as to the defendant's guideline calculation.
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F. Not a Basis to Withdraw
The defendant understands that she will have no right to withdraw
from this agreement or withdraw her guilty plea if she disagrees, in any
way, with the guideline range determined by the Court, even if that
guideline range does not incorporate the parties' recommendations or
factual stipulations in paragraphs 9.B or 9.C. The government likewise
has no right to withdraw from this agreement if it disagrees with the
guideline range determined by the Court.
10. Imposition of Sentence
A. Court's Obligation
The defendant understands that in determining her sentence, the
Court must calculate the applicable guideline range at sentencing and
must consider that range, any possible departures under the sentencing
guidelines, and the sentencing factors listed in 18 U.S.C. § 3553(a), and
apply any applicable mandatory minimums.
B. Imprisonment
1. Recommendation
Under Federal Rule of Criminal Procedure 1 l(c)(l)(B), the
government recommends that the defendant's sentence of imprisonment
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not exceed the top of the defendant's guideline range as determined by
the Court.
2. No Right to Withdraw
The government's recommendation 1n paragraph 10.B. l is not
binding on the Court. The defendant understands that she will have no
right to withdraw from this agreement or withdraw her guilty plea if the
Court decides not to follow the government's recommendation. The
government likewise has no right to withdraw from this agreement if the
Court decides not to follow the government's recommendation. If,
however, the Court rejects or purports to reject any other term or terms
of this plea agreement, the government will be permitted to withdraw
from the agreement.
C. Supervised Release
1. Recommendation
The parties have no agreement as to supervised release.
2. No Right to Withdraw
Any recommendation regarding the imposition of a term of
supervised release made by either party is not binding on the Court. The
defendant understands that she will have no right to withdraw from this
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agreement or withdraw her guilty plea if the Court decides not to follow
the recommendation of either party.
D. Fines
The parties have no recommendation or agreement as to a fine.
E. Restitution
Notwithstanding the offense of conviction, the defendant
understands the Court must order restitution to every identifiable victim
of the defendant's scheme. There is no recommendation or agreement on
restitution. The Court will determine at sentencing who the victims are
and the amounts of restitution they are owed.
The defendant agrees that restitution 1s due and payable
immediately after the judgment is entered and is subject to immediate
enforcement, in full , by the United States. 18 U.S.C. §§ 3612(c) and 3613.
If the Court imposes a schedule of payments, the defendant agrees that
the schedule of payments is a schedule of the minimum payment due,
and that the payment schedule does not prohibit or limit the methods by
which the United States may immediately enforce the judgment in full.
The defendant agrees to make a full presentence disclosure of her
financial status to the United States Attorney's Office by completing a
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Financial Disclosure Form and the accompanying releases for the
purpose of determining her ability to pay restitution. The defendant
agrees to complete and return the Financial Disclosure Form within
three weeks of receiving it from government counsel. The defendant
agrees to participate in a presentencing debtor's examination if requested
to do so by government counsel.
F. Forfeiture
The defendant agrees, pursuant to Fed. R. Crim. P. 32.2., 18 U.S.C.
§ 981(a)(l)(C) with 28 U.S.C. § 2461(c), to forfeit to the United States any
and all property, real or personal, which constitutes or is derived from
proceeds traceable to the defendant's violation of 18 U.S.C. § 1349, as
charged in the Indictment, including but not limited to the following:
Descriotion CATS
1. $8,900.00 U.S. Currency 21-CBP-
000095
2. $761,414.32 ln funds from Bank 21-FBI-
Account Number 761261221 held in 001467
the name of Rita A. Shaba at
JPMorgan Chase Bank, Clinton
Township, MI
3. $74,367.15 ln funds from Bank 21-FBI-
Account Number 517597115 held in 001547
the name of Forever Beauty, LLC at
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Description CATS
JPMorgan Chase Bank, Clinton
Township, MI
4. $50,247.23 In funds from Bank 21-FBI-
Account Number 0080543967 in the 001548
name of Rita A. Shaba at Michigan
Schools and Government Credit
Union, Clinton Township, MI
5. $9,835.58 In funds from Bank 21-FBI-
Account Number 517597115 held in 004468
the name of Forever Beauty, LLC at
JPMorgan Chase Bank, Clinton
Township, MI
6. $498,027.99 In funds from Bank 21-FBI-
Account Number 1852899267 in the 001039
name of C&S Detroit Property LLC
and/or Samer Kammo and/or
Christina Anasi at Comerica Bank in
Macomb, MI
7. $205,898.76 In funds from Bank 21-FBI-
Account Number 1852899259 held in 001040
the name of C & S Liquor and/or
Samer Kammo and/or Christina
Anasi at Comerica Bank, Macomb,
MI
8. $55,000.00 In funds from Bank 21-FBI-
Account Number 6826004936 held in 002551
the name of Christina Anasi, in trust
for Samer Kammo at Comerica Bank,
Macomb, MI
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Description CATS
9. $125,500.00 1n funds from Bank 21-FBI-
Account No. 9417715175 in the name 002566
of Christina Anasi, in trust for Samer
Kammo at Comerica Bank 1n
Macomb, MI
10. $53,083.08 in funds from Account No. 21-FBI-
200999370 in the name of Anasi 002677
Detroit Property, LLC at JPMorgan
Chase in Clinton Township, MI
11. $67,029.74 1n funds from Bank 20-FBI-
Account Number 842340622 in the 006526
name of Slewai S. Allos at JP Morgan
Chase, Troy, MI; and
12. $201,656.48 1n funds from Bank 21-FBI-
Account Number 1853452405 held in 002284
the name of W Shallal LLC DBA
Mound Express at Comerica Bank,
Macomb, MI
(the "Subject Property").
In entering into this agreement, defendant hereby withdraws any
and all prior claims filed with the FBI, the United States Attorney's
Office, or the Court, concerning the forfeiture of the Subject Property, or
any other property filed on or about January 28, 2025, and agrees not to
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contest the forfeiture of any of the Subject Property in any proceeding,
whether administrative or judicial.
The defendant agrees to the entry of one or more orders of
forfeiture , including a Preliminary Order of Forfeiture, containing the
above referenced forfeiture , upon application by the United States at, or
any time before, her sentencing in this case . The defendant agrees to sign
such an order, indicating she consents to its entry if requested to do so by
the government. The defendant agrees that the forfeiture order will be
final and effective as to her upon entry by the Court.
The defendant will cooperate with in the government as requested
by the government in connection with the government's efforts to
identify, locate , seize, and forfeit property that is subject to forfeiture
under this agreement. The defendant agrees that she will cooperate with
the United States by taking whatever steps are necessary to deliver
possession of, and clear title to, property that is forfeitable to the United
States under this agreement and will execute such legal documents as
may be required to transfer title to the United States and by taking
whatever steps are necessary to ensure that the property is not sold,
disbursed, hidden, wasted or otherwise made unavailable for forfeiture.
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If any other person or entity has any interest in such property, the
defendant will provide the government with the name and address of the
person or entity that has an interest in, and/or possession of, the asset,
and assist the government in obtaining a release of interest from any
such other person or entity.
The defendant waives her right to have a jury determine the
forfeitability of her interest in the Subject Property as provided by Fed.
R. Crim. P. 32.2(b)(5).
The defendant waives the requirements of Fed. R. Crim. P. 32.2 and
43(a) regarding notice of the forfeiture in the charging instrument,
pronouncement of the forfeiture at sentencing, and incorporation of the
forfeiture in the judgment. The defendant acknowledges that she
understands that the forfeiture of property is part of the sentence that
may be imposed in this case and waives any failure by the Court to advise
her of this, pursuant to Fed. R. Crim. P. ll(b)(l)(J), at the time her guilty
plea is accepted.
The defendant agrees to hold the United States, its agents and
employees harmless from any claims whatsoever in connection with the
seizure and/or forfeiture of property covered by this Plea Agreement.
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The defendant knowingly, voluntarily, and intelligently waives any
statutory and constitutional challenge to the above-described forfeiture
including any challenge based upon the Excessive Fines Clause of the
Eighth Amendment to the United States Constitution.
G. Special Assessment
The defendant understands that she will be required to pay a
special assessment of $100, due immediately upon sentencing.
11. Appeal Waiver
The defendant waives any right she may have to appeal her
conviction on any grounds. The defendant also waives any right she may
have to appeal her sentence on any grounds, unless her sentence of
imprisonment exceeds the top of the guideline range as determined by
the Court.
12. Collateral Review Waiver
The defendant retains the right to raise claims alleging ineffective
assistance of counsel or prosecutorial misconduct, as long as the
defendant properly raises those claims by collateral review under 28
U.S.C. § 2255. The defendant also retains the right to pursue any relief
permitted under 18 U.S.C. § 3582(c), as long as the defendant properly
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files a motion under that section. The defendant, however, waives any
other right she may have to challenge her conviction or sentence by
collateral review, including, but not limited to, any right she may have to
challenge her conviction or sentence on any grounds under 28 U .S .C.
§ 2255 (except for properly raised ineffective assistance of counsel or
prosecutorial misconduct claims, as described above), 28 U.S.C . § 2241 ,
or Federal Rule of Civil Procedure 59 or 60.
13. Remedies for Withdrawal, Breach, Rejection, or Vacatur
If the defendant is allowed to withdraw her guilty plea or breaches
this agreement, or if the Court rejects this agreement, or if the
defendant's conviction or sentence under this agreement is vacated, the
government may reinstate any charges against the defendant that were
dismissed as part of this agreement and may file additional charges
against the defendant relating, directly or indirectly, to any of the
conduct underlying the defendant's guilty plea or any relevant conduct.
If the defendant has been permitted to plead guilty to a lesser-included
offense, the government may also reinstate any charges or file any
additional charges against the defendant for the greater offense, and the
defendant waives her double-jeopardy rights with respect to the greater
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offense. If the government reinstates any charges or files any additional
charges as permitted by this paragraph, the defendant waives her right
to challenge those charges on the ground that they were not filed in a
timely manner, including any claim that they were filed after the
limitations period expired.
14. Use ofWithdrawn Guilty Plea
The defendant agrees that if she is permitted to withdraw her guilty
plea for any reason, she waives all of her rights under Federal Rule of
Evidence 410, and the government may use her guilty plea, any
statement that the defendant made at her guilty plea hearing, and the
factual basis set forth in this agreement, against the defendant in any
proceeding.
15. Parties to Plea Agreement
This agreement does not bind any government agency except the
United States Attorney's Office for the Eastern District of Michigan.
16. Scope of Plea Agreement
This plea agreement is the complete agreement between the parties
and supersedes any other promises, representations, understandings, or
agreements between the parties concerning the subject matter of this
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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.416 Filed 08/26/25 Page 23 of 25
agreement that were made at any time before the guilty plea is entered
in court. Thus, no oral or written promises made by the government to
the defendant or to the attorney for the defendant at any time before the
defendant pleads guilty are binding except to the extent they have been
explicitly incorporated into this plea agreement. If the parties have
entered, or subsequently enter, into a written proffer or cooperation
agreement, though, this plea agreement does not supersede or abrogate
the terms of that agreement. This plea agreement also does not prevent
any civil or administrative actions against the defendant, or any
forfeiture claim against any property, by the United States or any other
party.
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Case 2:23-cr-20296-JJCG-APP ECF No. 65, PageID.417 Filed 08/26/25 Page 24 of 25
17. Acceptance of Agreement by Defendant
This plea offer expires unless it has been received, fully signed, in
the United States Attorney's Office by 5:00pm on August 18, 2025. The
government may withdraw from this agreement at any time before the
defendant pleads guilty.
JEROME F . GORGON JR.
United States Attorney
John K. Neal Andrew J. Y ahkind
Chief, Anti-Corruption Unit Assistant United States
Assistant United States Attorney
Attorney
Dated: 8/1/25
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