United States v. Kareem Memon — Information (S.D. Fla., Dkt. 1)
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A Rule 20 transfer packet entered on the docket January 11, 2024 as Document 1 in Case 0:24-cr-60004-RS in the Southern District of Florida, transferring United States v. Kareem Memon from the District of New Jersey, Criminal No. 24-17 (MEF). It contains Memon's consent to transfer the case for plea and sentence under Fed. R. Crim. P. 20, the New Jersey docket for Case 2:24-cr-00017-MEF-1, and the clerk's transmittal letter dated January 10, 2024. The enclosed information charges conspiracy to commit health care fraud under 18 U.S.C. § 1349 in Count 1 and conspiracy to violate the Federal Anti-Kickback Statute under 18 U.S.C. § 371 in Count 2, alleging that from in or around 2017 through in or around 2020 Memon's companies were paid kickbacks for completed doctor's orders for durable medical equipment billed to Medicare.
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“United States v. Kareem Memon — Information (S.D. Fla., Dkt. 1).”
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Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 1 of 21
MP
Jan 11, 2024
Miami
(MEF)
24-17
SDFL Case # 24-cr-60004 Smith/Augustin-Birch
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 2 of 21
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U.S. District Court
District of New Jersey [LIVE] (Newark)
CRIMINAL DOCKET FOR CASE #: 2:24-cr-00017-MEF-1
Case title: USA v. MEMON Date Filed: 01/10/2024
Assigned to: Judge Michael E. Farbiarz
Defendant (1)
KAREEM MEMON represented by BRIAN SILBER
916 SOUTH ANDREWS AVENUE
FORT LAUDERDALE,, FL 33316
1954-462-3636
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: CJA Appointment
Pending Counts Disposition
None
Highest Offense Level (Opening)
None
Terminated Counts Disposition
18-1349 CONSPIRACY TO COMMIT
HEALTH CARE FRAUD (dof- from 2017-
2020)
(1)
18:371 CONSPIRACY TO VIOLATE THE
FEDERAL ANTI-KICKBACK STATUTE
(dof- from 2017-2020)
(2)
Highest Offense Level (Terminated)
Felony
Complaints Disposition
None
Plaintiff
USA represented by MATTHEW SPECHT
DOJ-USAO
DISTRICT OF NEW JERSEY
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 3 of 21
970 BROAD STREET
ROOM 700
NEWARK, NJ 07102
973-353-6061
Email: matthew.specht@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney
Date Filed # Docket Text
01/10/2024 1 CONSENT TO TRANSFER JURISDICTION (Rule 20) to SOUTHERN DISTRICT OF
FLORIDA by KAREEM MEMON. (JB, ) (Main Document 1 replaced on 1/10/2024) (JB, ).
(Additional attachment(s) added on 1/10/2024: # 1 Information) (JB, ). (Additional attachment(s)
added on 1/10/2024: # 3 Cover sheet) (JB, ). Modified on 1/10/2024 (mfr). (Entered: 01/10/2024)
01/10/2024 Notice of Allocation and Assignment setting plea agreement hearing as to KAREEM MEMON for
2/20/2024 at 02:00 PM before Judge Michael E. Farbiarz. (JB, ) Modified on 1/10/2024 (JB, ).
(Entered: 01/10/2024)
01/10/2024 Notice of Allocation and Assignment setting plea agreement hearing as to KAREEM MEMON for
2/6/2024 at 02:00 PM before Judge Michael E. Farbiarz. (JB, ) (Entered: 01/10/2024)
01/10/2024 Please disregard the setting of plea hearing as to KAREEM MEMON this case is a Rule 20
Transfer out to Southern District of Florida: (mfr) (Entered: 01/10/2024)
01/10/2024 2 INFORMATION as to KAREEM MEMON (1) count(s) 1, 2. (JB, ) (Entered: 01/10/2024)
01/10/2024 3 Transmittal Letter re: 1 Rule 20 - Transfer Out to the District of Southern Florida. (JB, ) (Entered:
01/10/2024)
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 4 of 21
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
OFFICE OF THE CLERK CAMDEN OFFICE
M. L. KING JR. FEDERAL BLDG. & U.S. COURTHOUSE ONE JOHN F. GERRY PLAZA
50 WALNUT STREET, P.O. BOX 419 FOURTH & COOPER STREETS
NEWARK, NJ 07101-0419 CAMDEN, NJ 08101
(973) 645-3730
TRENTON OFFICE
402 EAST STATE STREET
Melissa E. Rhoads ROOM 2020
Clerk TRENTON, NJ 08608
REPLY TO:
January 10, 2024
Re: U.S.A. v- KAREEM MEMONOur
Docket No. 24-cr17 (MEF)
Dear Clerk:
A Consent to Transfer Case pursuant to Rule 20 of the Federal Rules of Criminal
Procedure has been filed with this District in the above-captioned case. This District considers
the electronic record to be the original pursuant to Federal Rules of Criminal Procedure 49(d),
Local Civil Rule 5.2 and paragraph 7 of the Court’s Electronic Case Filing Policies and
Procedures. The original records of this Court can be obtained by accessing CM/ECF through
PACER. Certified copies of any document not available through PACER are enclosed. Kindly
acknowledge receipt on the duplicate of this letter, which is provided for your convenience.
Sincerely,
MELISSA E. RHOADS, Clerk
By: JACKELINE BARCO
Deputy Clerk
RECEIPT ACKNOWLEDGED BY:
DATE:
YOUR DOCKET NUMBER: .
DNJ-Crim-001(Rev. 09/06)
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 5 of 21
Instructions for Retrieving Electronic Case Files
1. Access the CM/ECF website for the District of New Jersey at https://ecf.njd.uscourts.gov
2. Click on: Link to Electronic Filing System (Live)
3. At the ECF/PACER Login Screen, enter your Court’s PACER Login and Password
4. On the CM/ECF toolbar, choose:
• Reports
• Docket Sheet
• Enter Case Number in the following format: [06-1234]
• Run Report
< To view a document from the docket sheet, click on the blue “underlined”
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< To download, click on File, Save a Copy and save to your specific
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< If the document does not have an underlined document number, it is
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• The document included an attachment too large for the electronic
case filing system and is enclosed.
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< Camden - 866-726-0726 or 856-757-5285
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Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 6 of 21
MHS/2023R00813
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA : Hon. (MEF)
:
v. : Criminal No. 24-17
:
KAREEM MEMON : 18 U.S.C. § 1349 18
: U.S.C. § 371
INFORMATION
The defendant having waived in open court prosecution by Indictment, the
Attorney for the United States for the District of New Jersey, acting under
authority conferred by 28 U.S.C. § 515, charges:
COUNT 1
(Conspiracy to Commit Health Care Fraud)
1. Unless otherwise indicated, at all times relevant to this Information:
Relevant Individuals and Entities
a. The defendant, KAREEM MEMON (“MEMON”), was a resident
of Florida who owned, operated, and/or had a financial or controlling interest in
entities (the “MEMON Supply Companies”) through which he and his coconspirators
generated information and documents amounting to a guarantee that durable
medical equipment (“DME”) would be reimbursed by Medicare, referred to herein as
a “completed doctor’s order.” As that term was used during MEMON’s scheme, a
completed “doctor’s order” (“DO”) was comprised of a prospective patient’s name,
contact information, insurance information, and a doctor’s order or prescription for a
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 7 of 21
DME orthotic brace, such as a knee, ankle, back, wrist, or shoulder brace for that
particular patient.
b. Aaron Williamsky (“WILLIAMSKY”) and Nadia Levit (“LEVIT”),
coconspirators not charged herein, were residents of New Jersey who owned,
operated, and/or had a financial or controlling interest in several DME supply
companies (the “WILLIAMSKY/LEVIT DME Companies”), which primarily supplied
DME to Medicare beneficiaries. The WILLIAMSKY/LEVIT DME Companies were
enrolled with Medicare as suppliers of DME, and therefore, were authorized to bill
Medicare for the supplying of orthotic braces. Pursuant to the requirements described
above, the WILLIAMSKY/LEVIT DME Companies were also responsible for
acknowledging that any claims made to Medicare complied with the relevant laws,
regulations, and program instructions.
c. Charles Burruss (“BURRUSS”) and Armani Adams (“ADAMS”),
coconspirators not charged herein, were residents of California who owned, operated,
and/or had a financial or controlling interest in several DME supply companies (the
“BURRUSS/ADAMS DME Companies”), which primarily supplied DME to Medicare
beneficiaries. The BURRUSS/ADAMS DME Companies were enrolled with Medicare
as suppliers of DME, and therefore, were authorized to bill Medicare for the supplying
of orthotic braces. Pursuant to the requirements described above, the
BURRUSS/ADAMS DME Companies were also responsible for acknowledging that
any claims made to Medicare complied with the relevant laws, regulations, and
program instructions. The WILLIAMSKY/LEVIT DME Companies and the
2
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 8 of 21
BURRUSS/ADAMS DME Companies will be referred to collectively as the “Subject
DME Companies.”
d. As described more fully below, MEMON entered into
arrangements with WILLIAMSKY, LEVIT, BURRUSS, ADAMS, and others whereby
the Subject DME Companies paid kickbacks and bribes to the MEMON Supply
Companies in exchange for the MEMON Supply Companies providing them with
completed DOs for DME, which the Subject DME Companies would thereafter bill to
and be reimbursed by Medicare and other health care benefit programs, without
regard for medical necessity.
Background on the Medicare Program
e. Medicare was a federally funded program established to provide
medical insurance benefits for individuals aged 65 and older and certain disabled
individuals who qualified under the Social Security Act. Individuals who receive
benefits under Medicare were referred to as “Medicare beneficiaries.”
f. Medicare was administered by the Center for Medicare and
Medicaid Services (“CMS”), a federal agency under the United States Department of
Health and Human Services.
g. Medicare was divided into four parts, which helped cover specific
services: Part A (hospital insurance), Part B (medical insurance), Part C (Medicare
Advantage), and Part D (prescription drug coverage).
3
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 9 of 21
h. Medicare Part B covered non-institutional care that included
physician services and supplies, such as DME that were needed to diagnose or treat
medical conditions and that met accepted standards of medical practice.
i. Medicare was a “health care benefit program,” as defined by 18
U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-
7b(f), that affected commerce.
j. In order for a supplier of DME services to bill Medicare Part B,
that supplier had to enroll with Medicare as a Durable Medical Equipment,
Prosthetics, Orthotics, and Supplies (“DMEPOS”) supplier by completing a Form
CMS-855S.
k. As provided in the Form CMS-855S, to enroll as a DMEPOS
supplier, every DMEPOS supplier had to meet certain standards to obtain and retain
billing privileges to Medicare, such as, but not limited to, the following: (i) provide
complete and accurate information on the Form CMS-855S, with any changes to the
information on the form reported within 30 days; (ii) disclose persons and
organizations with ownership interests or managing control; (iii) abide by applicable
Medicare laws, regulations and program instructions, such as, but not limited to, the
Federal Anti-Kickback Statute (“AKS”) (42 U.S.C. § 1320a-7b(b)); (iv) acknowledge
that the payment of a claim by Medicare was conditioned upon the claim and the
underlying transaction complying with such laws, regulations and program
instructions; and (v) refrain from knowingly presenting or causing to be presented a
4
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 10 of 21
false or fraudulent claim for payment by Medicare and submitting claims with
deliberate ignorance or reckless disregard of their truth or falsity.
TRICARE
l. TRICARE was a health care program of the U.S. Department of
Defense (“DoD”) Military Health System that provided coverage for DoD beneficiaries
worldwide, including active-duty service members, National Guard and Reserve
members, retirees, their families, and survivors. The Defense Health Agency, an
agency of the DoD, was the military entity responsible for overseeing and
administering the TRICARE program.
m. TRICARE was a “health care benefit program,” as defined by 18
U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-
7b(f), that affected commerce.
CHAMPVA
n. The Civilian Health and Medical Program of the Department of
Veterans Affairs (“CHAMPVA”) was a federal health care benefit program within the
Department of Veterans Affairs (“VA”). CHAMPVA was a comprehensive health care
program in which the VA shared the cost of covered health care services and supplies
with eligible beneficiaries. The eligible categories for CHAMPVA beneficiaries were
the spouses or children of veterans who had been rated permanently and totally
disabled for a service-connected disability and the surviving spouse or child of a
veteran who died from a VA-rated service-connected disability.
5
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 11 of 21
o. In general, the CHAMPVA program covered most health care
services and supplies that were medically and psychologically necessary. CHAMPVA
was always the secondary payer to Medicare and reimbursed beneficiaries for costs
that Medicare did not cover. Health care claims had to have first been sent to
Medicare for processing. Medicare electronically forwarded claims to CHAMPVA
after Medicare had processed them.
p. CHAMPVA was a “health care benefit program,” as defined by 18
U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-
7b(f), that affected commerce.
Telemedicine
q. Telemedicine allowed health care providers to evaluate, diagnose,
and treat patients remotely—without the need for an in-person visit—by using
telecommunications technology, such as the internet or telephone, to interact with a
patient.
r. Medicare deemed telemedicine an appropriate means to provide
certain health care related services (“telehealth services”) to beneficiaries, including,
among other services, consultations, and office visits, only when certain requirements
were met. These requirements included, among others, that: (i) the beneficiary was
located in a rural area (outside a metropolitan area or in a rural health professional
shortage area); (ii) the services were delivered via an interactive audio and video
telecommunications system; and (iii) the beneficiary was at a licensed provider’s
6
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 12 of 21
office or a specified medical facility—not at a beneficiary’s home—during the
telehealth service furnished by a remote provider.
s. Telehealth services could be covered by and reimbursable under
Medicare, but only if telemedicine was generally appropriate, as outlined above, and
only if the services were both ordered by a licensed provider and were reasonable and
medically necessary to diagnose and treat a covered illness or condition.
The Conspiracy
2. From in or around 2017 through in or around 2020, in the District of
New Jersey, and elsewhere, defendant
KAREEM MEMON
did knowingly and intentionally conspire and agree with others to knowingly and
willfully execute a scheme and artifice to defraud a health care benefit program and
to obtain, by means of false and fraudulent pretenses, representations, and promises,
money owned by, and under the custody and control of, a health care benefit program,
as defined by 18 U.S.C. § 24(b), namely, Medicare, in connection with the delivery of
and payment for health care benefits, items, and services, contrary to Title 18, United
States Code, Section 1347.
Goal of the Conspiracy
3. The goal of the conspiracy was for MEMON and others to obtain money
by submitting or causing the submission of false and fraudulent claims to Medicare
and other federal and private health care benefit programs.
7
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 13 of 21
Manner and Means
4. The manner and means by which MEMON and others sought to
accomplish the object of the conspiracy included, among other things, the following:
a. From in or around February 2015 through in or around April
2019, WILLIAMSKY, LEVIT, BURRUSS, ADAMS and others began purchasing and
establishing DME companies, including the Subject DME Companies, in New Jersey,
New York, and elsewhere to fraudulently bill health care benefit programs, including
Medicare, for various orthotic braces.
b. Through the Subject DME Companies, and/or other billing
companies, WILLIAMSKY, LEVIT, BURRUSS, ADAMS, and others submitted
and/or caused the submission of false or fraudulent claims to Medicare and other
federal and private health care benefit programs for orthotic braces that were: (i) not
medically necessary; (ii) never requested by a Medicare beneficiary; (iii) never
received by a Medicare beneficiary; and/or (iv) provided based on a DO procured
through the payment of kickbacks and bribes.
c. From in or around 2017 through in or around 2020, the Subject
DME Companies entered into kickback agreements with a number of individuals and
entities who were able to generate completed DOs (the “DME Suppliers”). The Subject
DME Companies paid the DME Suppliers, including MEMON, kickbacks ranging
from approximately $125 to $450 for each completed DO.
d. MEMON and others sold completed DOs from the MEMON
Supply Companies to the Subject DME Companies, and others, located in New Jersey
8
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 14 of 21
and elsewhere.
e. In general, the DME Suppliers obtained completed DOs for DME
for beneficiaries located in the United States and elsewhere through the use of
marketing call centers and telemedicine companies with whom they had
relationships.
f. To conceal the payment of kickbacks, the Subject DME
Companies entered into sham “Marketing, Business Process Outsourcing and Call
Center” agreements (“Marketing Agreements”) with the DME Suppliers. On paper,
the Marketing Agreements called for the DME Suppliers to provide “raw leads”
generated from various advertising campaigns for orthotic braces to the Subject DME
Companies. According to the agreements, these raw leads were to consist only of
information of individuals responding to the advertisements indicating an interest in
orthotic braces. In reality, the DME Suppliers provided WILLIAMSKY, LEVIT,
BURRUSS, ADAMS, and others affiliated with their DME Companies with
completed DOs and not “raw leads.”
g. Once the Subject DME Companies received the completed DOs
from the DME Suppliers, they arranged for the shipping of the ordered orthotic
brace(s) to the beneficiary and electronically submitted and/or caused the electronic
9
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 15 of 21
submission of a claim to Medicare and other federal and private health care benefit
programs for payment.
h. Based on the submission of these claims, the Subject DME
Companies received from Medicare and other federal and private health care benefit
programs payments that they were not entitled to receive.
i. As a result of MEMON’s participation in the health care fraud
kickback scheme, from in or around 2017 through in or around 2020, MEMON and
his coconspirators caused a loss to Medicare of approximately $11,384,001.
In violation of Title 18, United States Code, Section 1349.
10
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 16 of 21
COUNT 2
(Conspiracy to Violate the Federal Anti-Kickback Statute)
1. The allegations in Paragraphs 1 and 3 through 5 of Count 1 are re-
alleged here.
2. From in or around February 2017 through in or around 2020, in the
District of New Jersey, and elsewhere, defendant
KAREEM MEMON
did knowingly and intentionally conspire and agree with others to commit an offense
against the United States, that is, to knowingly and willfully solicit and receive
remuneration, directly and indirectly, overtly and covertly, in cash and in kind, that
is, kickbacks and bribes, from any person in return for purchasing, ordering, and
arranging for, and recommending purchasing and ordering, any good, item, and
service, namely, durable medical equipment, for which payment may be made in
whole and in part under a Federal health care program, as defined by 18 U.S.C. §
24(b), namely, Medicare, TRICARE, and CHAMPVA, contrary to Title 42, United
States Code, Section 1320a-7b(b)(1)(B).
Goal of the Conspiracy
3. The goal of the conspiracy was for MEMON and his coconspirators to
unlawfully enrich themselves by soliciting and receiving kickbacks and bribes for the
referral of Medicare beneficiaries for DME to the Subject DME Companies and
others, for which the DME companies billed to and obtained payments from Medicare
and other federal health care benefit programs.
11
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 17 of 21
Manner and Means
4. The manner and means by which MEMON and others sought to
accomplish the object of the conspiracy included, among other things, the following:
a. As described in Paragraphs 3 through 5 of Count 1, MEMON
entered into kickback arrangements with WILLIAMSKY, LEVIT, BURRUSS,
ADAMS, and others. Pursuant to those arrangements, MEMON and his
coconspirators solicited and received kickbacks for each DO for DME provided to the
Subject DME Companies. To conceal the payment of kickbacks, the Subject DME
Companies entered into sham Marketing Agreements with MEMON and others.
b. As a result of MEMON’s participation in the health care fraud
and kickback scheme, from in or around 2017 through in or around 2020, MEMON
and his coconspirators caused a loss to Medicare and other federal health care benefit
programs of at least approximately $11,384,001.
c. From in or around February 2017 through in or around 2020,
MEMON, through the MEMON Supply Companies) received kickbacks of
approximately $1,486,261.78 for completed DOs provided pursuant to the conspiracy.
Overt Acts
5. In furtherance of the conspiracy and to effect its object, MEMON and
others committed or caused the commission of the following overt acts in the District
of New Jersey and elsewhere:
a. On or about April 9, 2018, WILLIAMSKY and LEVIT, based in
New Jersey, caused a WILLIAMSKY/LEVIT holding company based in New Jersey
12
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 18 of 21
to provide MEMON kickbacks of approximately $36,000 in exchange for completed
DOs for DME.
b. On or about April 10, 2018, WILLIAMSKY and LEVIT, based in
New Jersey, caused a WILLIAMSKY/LEVIT holding company based in New Jersey
to provide MEMON kickbacks of approximately $36,000 in exchange for completed
DOs for DME.
In violation of Title 18, United States Code, Section 371.
13
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 19 of 21
FORFEITURE ALLEGATIONS
1. Upon conviction of the offenses alleged in Counts 1 and 2 of this
Information, defendant KAREEM MEMON shall forfeit to the United States,
pursuant to 18 U.S.C. § 982(a)(7), all property, real or personal, that constitutes or is
derived, directly and indirectly, from gross proceeds traceable to the commission of
the federal health care offenses (as defined by 18 U.S.C. § 24(a)) alleged in this
Information, which was approximately $1,486.261.78.
SUBSTITUTE ASSETS PROVISION
(Applicable to All Forfeiture Allegations)
2. If any of the above-described forfeitable property, as a result of any act
or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be
subdivided without difficulty;
14
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 20 of 21
the United States shall be entitled to forfeiture of substitute property, pursuant to 21
U.S.C. § 853(p), as incorporated by 18 U.S.C. § 982(b).
__________________________
VIKAS KHANNA
Attorney for the United States,
Acting Under Authority Conferred
By 28 U.S.C. § 515
15
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 21 of 21
CASE NUMBER: 24-17(MEF)
═════════════════════════════════
United States District Court
District of New Jersey
═════════════════════════════════
UNITED STATES OF AMERICA
v.
KAREEM MEMON
═════════════════════════════════
INFORMATION FOR
18 U.S.C. § 1349
18 U.S.C. § 371
═════════════════════════════════
VIKAS KHANNA
ATTORNEY FOR THE UNITED STATES
ACTING UNDER AUTHORITY CONFERRED
BY 28 U.S.C. § 515
NEWARK, NEW JERSEY
═════════════════════════════════
MATTHEW SPECHT
ASSISTANT U.S. ATTORNEY
NEWARK, NEW JERSEY
(973) 353-6061
═════════════════════════════════
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