Joint Stipulation Regarding Restitution, United States v. Kareem Memon (S.D. Fla., August 26, 2024)

Summary

A joint stipulation regarding restitution filed August 26, 2024 as Document 84 by the United States and defendant Kareem Memon in Case Nos. 23-CR-80068-AHS(s) and 24-CR-60004-AHS in the U.S. District Court for the Southern District of Florida. The parties stipulate to restitution of $11,384,001 in Case No. 24-CR-60004-AHS and $398,562.62 in Case No. 23-CR-80068-AHS(s), for an aggregate total amount of $11,782,563.62, and state that restitution is mandatory under 18 U.S.C. § 3663A. They ask the court to amend the judgments at ECF No. 42 and ECF No. 74 with standard payment language, including 50% of UNICOR wages or $25.00 per quarter during incarceration and 10% of monthly gross earnings after release. It is signed by Assistant United States Attorney Robin W. Waugh and defense counsel Bradford M. Cohen.

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Cite this document

“Joint Stipulation Regarding Restitution, United States v. Kareem Memon (S.D. Fla., August 26, 2024).” Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-regarding-restitution-usa-v-memon-dkt-84-s-d-fla-db33b23f5e/, SHA-256 d7749a0e05edcd90d2c5cda4efd31427874719c4628002bd473205c36014b8eb.

Full text

Case 9:23-cr-80068-AHS Document 84 Entered on FLSD Docket 08/26/2024 Page 1 of 4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NOs. 23-CR-80068-AHS(s)
24-CR-60004-AHS

UNITED STATES OF AMERICA

vs.

KAREEM MEMON,

Defendant.
________________________________/

JOINT STIPULATION REGARDING RESTITUTION

The United States of America and the defendant, Kareem Memon, by and through

undersigned counsel, hereby file this joint stipulation to the entry of an order requiring the

defendant to pay restitution in the amount of eleven million three hundred eighty-four thousand

and one ($11,384,001) in U.S. currency in connection with Case No: 24-CR-60004-AHS; and

three hundred ninety-eight thousand, five hundred and sixty-two dollars and sixty-two cents

($398,562.62) in U.S. currency in connection with Case No: 23-CR-80068-AHS(s), for an

aggregate total amount of $11,782,563.62. An order of restitution is mandatory under 18 U.S.C.

§ 3663A, in both cases.

The government shall provide the U.S. Probation Office with a list of the victims, their

contact information, and the amount of restitution due (the “Victim List”). Thereafter, the U.S.

Probation Office will provide the Victim List to the Court by separate memorandum.

24-CR-60004-AHS

The parties recommend that the Judgment of Conviction in Case No. 24-CR-60004-AHS

(ECF No. 42) be amended to include the following standard language used in this district:
Case 9:23-cr-80068-AHS Document 84 Entered on FLSD Docket 08/26/2024 Page 2 of 4

It is further ordered that the defendant shall pay restitution in the amount of
$11,384,001. Defendant is jointly and severally liable for the restitution along with
his co-conspirators in the charged scheme, however, the Defendant’s obligation to
pay restitution does not terminate until after the victims are made whole or the
Defendant pays the restitution. During the period of incarceration, payment shall
be made as follows: (1) if the defendant earns wages in a Federal Prison Industries
(UNICOR) job, then the defendant must pay 50% of wages earned toward the
financial obligations imposed by this Judgment in a Criminal Case; (2) if the
defendant does not work in a UNICOR job, then the defendant must pay $25.00 per
quarter toward the financial obligations imposed in this order.

Upon release of incarceration, the defendant shall pay restitution at the rate of 10%
of monthly gross earnings, until such time as the court may alter that payment
schedule in the interests of justice. The U.S. Bureau of Prisons, U.S. Probation
Office and U.S. Attorney’s Office shall monitor the payment of restitution and
report to the court any material change in the defendant’s ability to pay. These
payments do not preclude the government from using other assets or income of the
defendant to satisfy the restitution obligations.

The restitution shall be made payable to the Clerk, United States Courts, and is to
be addressed to:

U.S. CLERK’S OFFICE
ATTN: FINANCIAL SECTION
400 N MIAMI AVENUE, ROOM 08N09
MIAMI, FL 33128-7716

23-CR-80068-AHS(s)

The parties recommend that the Judgment of Conviction in Case No. 23-CR-80068-AHS(s)

(ECF No. 74) be amended to include the following standard language used in this district:

It is further ordered that the defendant shall pay restitution in the amount of
$398,562.62. Defendant is liable for the restitution in the charged scheme. The
Defendant’s obligation to pay restitution does not terminate until after the victims
are made whole or the Defendant pays the restitution. During the period of
incarceration, payment shall be made as follows: (1) if the defendant earns wages
in a Federal Prison Industries (UNICOR) job, then the defendant must pay 50% of
wages earned toward the financial obligations imposed by this Judgment in a
Criminal Case; (2) if the defendant does not work in a UNICOR job, then the
defendant must pay $25.00 per quarter toward the financial obligations imposed in
this order.

Upon release of incarceration, the defendant shall pay restitution at the rate of 10%
of monthly gross earnings, until such time as the court may alter that payment

2
Case 9:23-cr-80068-AHS Document 84 Entered on FLSD Docket 08/26/2024 Page 3 of 4

schedule in the interests of justice. The U.S. Bureau of Prisons, U.S. Probation
Office and U.S. Attorney’s Office shall monitor the payment of restitution and
report to the court any material change in the defendant’s ability to pay. These
payments do not preclude the government from using other assets or income of the
defendant to satisfy the restitution obligations.

The restitution shall be made payable to the Clerk, United States Courts, and is to
be addressed to:

U.S. CLERK’S OFFICE
ATTN: FINANCIAL SECTION
400 N MIAMI AVENUE, ROOM 08N09
MIAMI, FL 33128-7716

WHEREFORE, the parties respectfully request that the Court amend the Judgment and

Conviction in Case No: 24-CR-60004-AHS (ECF No. 42) to set restitution in the amount of

$11,384,001; and in Case No: 23-CR-80068-AHS(s) (ECF No. 74) to set restitution in the amount

of $398,562.62, and order payments to be made to the victims set forth in the Victim List that shall

be provided to the Court by the U.S. Probation Office.

Respectfully submitted,

MARKENZY LAPOINTE
UNITED STATES ATTORENY

By: /s/ Bradford M. Cohen By: /s/ Robin W. Waugh
Cohen & McMullen, P.A. Robin W. Waugh
Attorney for Defendant Assistant United States Attorney
Florida Bar No. 118176 Florida Bar No. 0537837
1132 SE 3rd Avenue 500 S. Australian Avenue, Suite 400
Fort Lauderdale, Florida 33316 West Palm Beach, Florida 33401
Tel.: (954) 523-7774 Tel.: (561) 820-8711
Email: service@floridajusticefirm.com Email: robin.waugh@usdoj.gov

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Case 9:23-cr-80068-AHS Document 84 Entered on FLSD Docket 08/26/2024 Page 4 of 4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 26, 2024, I electronically filed the foregoing

document with the Clerk of Court via the CM/ECF system.

/s/ Robin W.Waugh
Robin W. Waugh

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