Stipulation for Settlement Agreement and Release — No. 4:23-cr-00067 (Dkt. 70-3, W.D. Mo.)

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Stipulation for Settlement Agreement and Release in United States v. Mirza Michael Reazuddin, Case No. 23-00067-CR-W-BP (Western District of Missouri), between the United States and Beermann LLP. Beermann LLP filed a third-party ancillary petition over real property the United States sought to forfeit, and it recorded a lien of $28,258.06 against the property on or about July 25, 2024. The United States agrees to pay Beermann LLP $20,000 from the net proceeds of the sale after a Final Order of Forfeiture is entered and the property is sold. Beermann LLP agrees to release its lien within ten (10) business days of full execution, and payment is conditioned upon the United States prevailing against competing claims and upon net proceeds from the sale.

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IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v. Case No. 23-00067-CR-W-BP
MIRZA MICHAEL REAZUDDIN,
Defendant.

STIPULATION FOR
SETTLEMENT AGREEMENT AND RELEASE

It is hereby stipulated by and between the United States of America, by and through the
United States Attorney for the Western District of Missouri, and Beermann LLP, by and through
its attorney, Matthew D. Elster, as follows:

L. On April 4, 2023, Defendant Mirza Michael Reazuddin (hereinafter “Defendant”)
was charged in an Indictment with four counts of wire fraud, in violation of 18 U.S.C. § 1343, and
seven counts of money laundering, in violation of 18 U.S.C. § 1957. (Doe. 1.)

Ze The Forfeiture Allegation of the Indictment sought forfeiture, pursuant to 18 U.S.C.
§ 981(a)(1)(C) and 28 U.S.C. § 2461, of any property, real or personal, constituting or derived
from proceeds traceable to the wire fraud. Jd. The Forfeiture Allegation further sought forfeiture,
pursuant to 18 U.S.C. § 982(a)(1), of any property, real or personal, involved in money laundering
activity, and any property traceable to such property. Id.

3. On December 21, 2023, the United States filed a Notice and Bill of Particulars for
Forfeiture of Property, giving notice that it was seeking forfeiture of the real property located at

1925 Severbrook Place, Lawrenceville, Georgia, more fully described as:
All that tract or parcel of land lying and being in Land Lot 83, of the
7th District, Gwinnett County, Georgia, being Lot 71, Block A,
Clairemont F.K.A. Sever Creek, as per plat recorded in Plat Book
107, Page 300, and 108, Page 1, Gwinnett County, Georgia records,
said plat being incorporated herein and made a part hereof by
reference.

(hereinafter the “Property’”). (Doc. 36.) The Bill of Particulars advised that the United States was
seeking forfeiture of the Property as constituting or derived from proceeds Defendant obtained
directly and indirectly as a result of wire fraud, and/or as property involved in money laundering
activity or property traceable to such property. Id.

4. On December 21, 2023, the United States filed a Lis Pendens as to the Property,
giving notice that the United States is seeking forfeiture of the Property in the above-captioned
action. (Doc. 37.) The Lis Pendens was recorded with the Clerk of the Superior Court of Gwinnett
County, Georgia on or about December 26, 2023.

5. On February 5, 2024, Defendant entered into a plea agreement with the United
States, pursuant to which he agreed to plead guilty to one count of wire fraud and one count of
money laundering. (Doc. 42.) In the plea agreement, Defendant agreed to forfeit his interest in the
Property. Id.

6. On July 24, 2024, the Court entered a Preliminary Order of Forfeiture, which
included the Property. (Doc. 63.)

he On or about July 25, 2024, Beermann LLP recorded a lien against the Property in
the amount of $28,258.06 with the Clerk of the Superior Court of Gwinnett County, Georgia.

8. Beermann LLP subsequently submitted a third-party ancillary petition to determine
the validity of its interest in the Property (hereinafter the “Petition’”), which is attached hereto as

Exhibit A.
9. To avoid the delay, uncertainty, inconvenience, and expense of litigation,
Beermann LLP and the United States agree to settle and compromise the Petition pursuant to the
terms set forth herein.

10. The United States agrees that after a Final Order of Forfeiture is entered by the
Court and the Property has been sold, the United States shall pay Beermann LLP the sum of
$20,000 from the net proceeds of the sale. In exchange, Beermann LLP agrees that it will release
its lien against the Property within ten (10) business days of the date of full execution of this
Agreement.

11. | Beermann LLP understands and agrees that the United States shall incur costs
associated with sale of the Property. Beermann LLP agrees that it will not contest or object to the
United States’ costs to dispose of the Property and further agrees that all costs of sale will be paid
in full first from gross proceeds of the sale.

12. | Beermann LLP agrees that payment to Beermann LLP is conditioned upon the
United States prevailing against any competing claims and conditioned upon net proceeds resulting
from the sale. In the event the net proceeds from the sale are not sufficient to satisfy the payment
contemplated by Paragraph 10 of this Agreement, and any other payment(s) to resolve any other
claim(s) made to the Property in connection with the above-captioned action, the Parties agree that
this Agreement will be void and will have no force or effect.

13. | Beermann LLP agrees that payment pursuant to Paragraph 10 of this Agreement
shall be in full settlement and satisfaction of all claims by Beermann LLP arising from and
resulting from the seizure, detention, and forfeiture of the Property. Beermann LLP agrees that by
entering into this Agreement, Beermann LLP waives any right to further litigate against the United

States its interest in the Property and understands and agrees that this waiver includes, but is not
limited to, litigation regarding the Property in the above-captioned case.

14. | Beermann LLP hereby releases and forever discharges the United States; its
officers, agents, servants, and employees; and its heirs, successors, or assigns; from any and all
actions, causes of action, suits, proceedings, debts, dues, contracts, judgments, damages, claims,
and/or demands whatsoever in law or in equity which they, their heirs, successors, or assigns ever
had, now have, or may have in the future in connection with the seizure, detention, and forfeiture
of the Property.

15. This Agreement does not bind any agency of the United States on any matters not
directly related to the seizure, detention, and forfeiture of the Property.

16. |The United States and Beermann LLP each agree to bear their own costs and
attorney’s fees incurred in connection with the forfeiture and disposition of the Property.
Beermann LLP further waives any and all claims or rights it has or may have pursuant to 28 U.S.C.
§ 2412 (the Equal Access to Justice Act) for attorney’s fees or other costs involving the Property,
arising out of the above-captioned criminal investigation and case and the forfeiture of the
Property.

17. This Agreement, and any dispute arising therefrom, shall be governed by the laws
of the United States. The Parties agree that, should any judicial action be required to enforce or
interpret this Agreement, or to resolve any dispute hereunder, the exclusive venue for such an
action shall be in the United States District Court for the Western District of Missouri.

18. For purposes of construction, this Agreement shall be deemed to have been drafted
by both the Government and Beermann LLP and shall not be construed against any party for that
reason in any subsequent dispute.

19. It is contemplated that this Agreement may be executed in several counterparts,

4
with a separate signature page for each party. All such counterparts and signature pages together
shall be deemed one document.

20. This Agreement comprises all the provisions stipulated by and between the Parties
in full and complete settlement of the Petition in the above-captioned action.

21. This Agreement cannot be modified or amended except by an instrument in writing,
agreed to and signed by the parties, nor shall any of its provisions be waived other than by a written
waiver, signed by the Parties.

22. The Parties acknowledge that they have: (a) consulted with counsel before
executing this Agreement; (b) have been afforded a reasonable time to consider this Agreement
before executing it; (c) are competent and of sound mind and able to understand the provisions of
this Agreement; (d) have read and understood the Agreement’s provisions; and (e) have executed

the Agreement knowingly, voluntarily, and of their own free will.
For the United States:

Date: November /& , 2025

By:

R. Matthew Price
United States Attorney

/s/ & reel:

Stephanie Bradshaw

Assistant United States Attorney

400 E. 9th Street, Fifth Floor

Kansas City, Missouri 64106
Telephone: (816) 426-3122

E-mail: stephanie.bradshaw@usdoj.gov
Counsel for Plaintiff

United States of America
For Petitioner:

Date: November 14, 2025 SPF CK co - yd
Beermann LLP
Petitioner , yg
Date: November 14, 2025 Matthew D. Elster

Beermann LLP

161 N. Clark Street, Suite 3000
Chicago, IL 60601

Telephone: (312) 621-9700

E-mail: mdelster@beermannlaw.com
Counsel for Petitioner
EXHIBIT A

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
Vv. Case No. 23-00067-CR-W-BP

MIRZA MICHAEL REAZUDDIN,

Defendant.

THIRD-PARTY ANCILLARY PETITION
TO DETERMINE VALIDITY OF INTEREST IN PROPERTY

Third-Party Petitioner, BEERMANN LLP, files this Ancillary Petition to
determine the validity, nature, extent, and priority of its interest in the real
property located at 1925 Severbrook Place, Lawrenceville, Georgia (the “Property”)

as follows:

1. Beermann LLP is an Illinois limited lability partnership with its
principal place of business in Chicago, I]linois.

a Beermann LLP asserts a valid and enforceable interest in the Property,
the nature of which is a judgment lien in the amount of $28,258.06 recorded against
the Property on or about July 25, 2024 with the Clerk of the Superior Court of
Gwinnett County, Georgia.

3. Beermann LLP’s interest was acquired by virtue of a money judgment
entered in its favor and against the Defendant on October 23, 2023 by the Circuit

Court of Cook County, Illinois.
WHEREFOREH, Third-Party Petitioner, Beermann LLP, respectfully requests that

this Honorable Court enter an Order:
a. Adjudicating its interest in the Property;
b. Declaring the validity, nature, extent, and priority of said interest;

c. Requiring that any final judgment or sale of the Property be made subject

its interest in the Property; and

d. Granting it such other and further relief as the Court deems just and
equitable.
Respectfully submitted,

Date: November 14, 2025
/s/ Matthew D. Elster
Attorney for Third-Party Petitioner
Beermann LLP
161 N. Clark Street, Suite 3000
Chicago, IL 60601
Telephone: (312) 621-9700
E-mail: mdelster@beermannlaw.com


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