Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF IOWA ) ) )

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1 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF IOWA RECEIVED APR CLERkU UNITED STATES OF AMERICA, ) SOUTHERtb~~RTRICTCOURT 1CTOFIOWA ) Plaintiff, ) Criminal No.3 :09-cr-24 ) v. FAZAL MEHMOOD, ) ) ) INFORMATION 18 U.S.C., U.S.C., 1546 a/k/a Fazal Mehmood Awan, ) 18 U.S.c., 1001 VINEET MAHESHWARI, and ) 18 U.S.C., 1957 WORLDWIDE SOFTWARE SERVICES, U\JC., ) 18 U.S.C., 981(a)(l), 981(a)(6) Defendants. ) ) ) 18 U.S.C., 982(a)(2) 21 U.S.C., U.S.C., 2461(c) THE UNITED STATES ATTORNEY CHARGES: At all times material to this Indictment: COUNT 1 (Conspiracy) A. INTRODUCTION 1. The Employment and Training Administration (hereinafter "ETA") was an agency of the United States established within the United States Department of Labor. 2. The "HI-B Specialty (professional) Workers" program allows an employer to temporarily employ a foreign worker for a specific job in the United States on a non-immigrant basis in a "Specialty Occupation". A Specialty Occupation requires the theoretical and practical application of a body of specialized knowledge and a bachelor's degree or the equivalent in the specific specialty. 3. Each employer seeking to employ an non-immigrant for a specific job is required to

2 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 2 of 19 submit a completed Labor Condition Application (LCA) on form ETA9035E to the ETA. The LCA requires the employer to make several attestations regarding the employer's responsibilities, including the wages, working conditions, and benefits to be provided to the non-immigrant. 4. In order to avoid displacing workers within the United States, the employer within the program is required to certify the wage rate, the work location, and the prevailing wage for the work location for the occupation for which the non-immigrant worker is being employed as part of the completion of the LCA on form ETA 9035E. 5. When an employer submits a prevailing wage certification for an employee within the program, the employer is required to submit the certification for the prevailing wage in the State where the employee will work. 6. In order to avoid displacing workers within the United States, the employer within the program must also inform United States workers of the intent to hire a foreign worker by posting the completed LCA for the position at each place of employment where any non-immigrant will be employed as part of the completion of an LCA. 7. Upon submission of the LCA and receipt of the Department of Labor certification, the employer of an non-immigrant worker must also file a form with the U.S. Department of Homeland Security, Bureau of Citizenship and Immigration Services (USCIS) for the specific individual hired in connection with the particular certification and pay a fee associated with the application. 8. An employer is not permitted to assess the foreign worker for any fees associated with (a) the application for a labor certification, (b) the application for a visa, or (c) travel to the place of employment within the United States. 2

3 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 3 of Each employer seeking to relocate a non-immigrant worker under its employ is required to submit a completed LCA on form ETA 9035E to the ETA. The employer must make several attestations on the LCA regarding the employer's responsibilities, including the wages, working conditions, and benefits to be provided to the non-immigrant. 10. In order to avoid displacing workers within the United States, the employer seeking to relocate a non-immigrant worker under its employ is required to certify the wage rate, the work location, and the prevailing wage for the new work location for the occupation for which the non-immigrant worker is being employed as part of the completion of the LCA on form ETA 9035E. 11. In order for a foreign worker present in the United States based upon a visa to secure lawful permanent residence in the United States, a prospective employer first must file an ETA-9089/ETA-750 Application for Alien Employment Certification with the DOL, requesting certification on behalf of the alien employee specified in the application. 12. If the application meets the requirements, the DOL will certify the ETA-9089/ ETA-750, Application for Alien Employment Certification. Following receipt of the certified ETA-9089/ETA-750, Application for Alien Employment Certification, the prospective employer must then submit an Immigrant Petition for Alien Worker to the USCIS requesting that USCIS classify the alien as eligible to apply for designation within a Specialty Occupation. A prospective employer must pay the designated fee and attach the original ETA-9089/ETA-750 Application for Alien Employment to that petition. 13. IfUSCIS grants an employer's Immigrant Petition for Alien Worker, the alien may then seek to obtain his or her "green card" and become a lawful permanent resident in the 3

4 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 4 of 19 United States. 14. Based on immigration regulations, if the ETA 750/ETA 9089 shows that the alien may have an ownership interest in a company, then DOL will issue a Notice of Findings and determine whether a bona fide job existed and whether it was open to U.S. workers. If the ownership interest is tantamount to self-employment, it does not constitute genuine employment under the regulations. In these instances, the labor certification is barred. 15. All non-immigrant workers who obtain employment through an HI-B visa are prohibited from engaging in other employment outside of the work for which the visa is specified. 16. Beginning in 1997 or earlier, Defendants FAZAL MEHMOOD, also known as Fazal Mehmood Awan, and VINEET MAHESHWARl, resided in Clinton, Iowa, and together they operated businesses under the names of Sana Systems and WORLDWIDE SOFTWARE SERVICES, INC. These businesses employed "Hl-B specialty workers" including Defendants FAZAL MEHMOOD, also known as Fazal Mehmood Awan, and VINEET MAHESHWARl. j ~'UA,'. e..:: V\ B. THE. CONSPIRACY I ' I Lll-'t"U From a\;2911t 1997 and continuing tlnoagh on or about February 12,2009, and later, in ~-.r: Clinton County in the Southern District of Iowa, and elsewhere, Defendants FAZAL MEHMOOD, also known as Fazal Mehmood Awan, and VINEET MAHESHWARl, doing business as Sana Systems, and WORLDWIDE SOFTWARE SERVICES, INC., an Iowa corporation, did knowingly combine, conspire, confederate and agree with each other and with other persons known and unknown to the grand jury to defraud the United States and to commit the following offenses against the United States: 4

5 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 5 of To knowingly and willfully falsify by scheme and device a material fact in a matter within the jurisdiction of the United States Department of Labor, in violation of Title 18, United States Code, Section 1001; and, 2. To knowingly make under oath, and as permitted under penalty ofperjury under section 1746 oftitle 28, United States Code, knowingly subscribe as true, false statements with respect to material facts in applications and other documents required by the immigration laws or regulations prescribed thereunder, and knowingly present such applications and other documents which contain such false statements and which fail to contain any reasonable basis in law and fact, in violation of Title 18, United States Code, Section C. MANNER AND MEANS OF THE CONSPIRACY It was part of the conspiracy that: 1. Defendants FAZAL MEHMOOD, also known as Fazal Mehmood Awan, VINEET MAHESHWARl, and WORLDWIDE SOFTWARE SERVICES, INC. (WWSS), and their coconspirators and agents did cause to be submitted to the Employment and Training Administration (hereinafter "ETA"), an agency of the United States established within the United States Department of Labor, numerous Labor Condition Applications (forms ETA 9035 and 9035E) (LCAs) for non-immigrant workers containing false representations as to the existence of such jobs and the work locations and pay for the non-immigrant, foreign workers. 2. Defendants MEHMOOD, MAHESHWARl, and WWSS, and their co-conspirators and agents, did cause to be submitted to the Department of Labor and the U.S. Department of Homeland Security, Bureau of Citizenship and Immigration Services (USCIS), and its predecessor agency, additional false documents, including forms falsely representing the 5

6 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 6 of 19 residential address of numerous non-immigrant, foreign workers. 3. Defendants MEHMOOD, MAHESHWARI, and WWSS, and their co-conspirators and agents, did fail to timely notify immigration officials that certain non-immigrant, foreign workers were no longer employed by Sana Systems and WWSS and no longer employed at the location specified in the forms ETA 9035, 1-129, and previously submitted by them as required by federal regulations. 4. Defendants MEHMOOD, MAHESHWARI, and WWSS, and their co-conspirators and agents, did fail to pay the travel expenses of certain non-immigrant, foreign workers to return them to their country of origin as required by federal regulation after their temporary work assignment was completed. 5. Defendants MEHMOOD, MAHESHWARI, and WWSS, and their co-conspirators and agents, did wrongfully assess one and more non-immigrant foreign worker in connection with filing for and obtaining HIB visas, and for travel expenses, which fees and expenses were, by federal regulation, to be paid by the defendants. D. OVERT ACTS In furtherance of the conspiracy, and to effect the objects thereof, Defendants MEHMOOD, MAHESHWARI, and WWSS, and their co-conspirators and agents, committed and caused to be committed overt acts on or about the following dates in the Southern District of Iowa and elsewhere: 1. From about 2001 through February 2009, FAZAL MEHMOOD, also known as Fazal Mehmood Awan (Mr. Mehmood), VINEET MAHESHWARI (Mr. Maheshwari), and WORLDWIDE SOFTWARE SERVICES, INC. (WWSS), and their co-conspirators and agents, 6

7 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 7 of 19 reached an agreement or came to an understanding to commit crimes in violation of 18 U.S.c and 1546(a). 2. Mr. Mehmood and Mr. Maheshwari voluntarily and intentionally joined in the agreement or understanding, either at the time it was first reached or at some later time while it was still in effect. 3. At the time Mr. Mehmood and Mr. Maheshwari joined in the agreement or understanding, they knew the purpose of the agreement or understanding was to file some false Labor Condition Applications with the Department of Labor in order to apply for H-1B visas for non-immigrant foreign workers. 4. While the agreement or understanding was in effect, a person or persons who had joined in the agreement, or a person or persons acting at the direction ofmr. Mehmood and Mr. Maheshwari, knowingly caused to be submitted to the Employment and Training Administration ("ETA"), an agency of the United States, established within the United States Department of Labor, Labor Condition Applications (forms ETA 9035 and 9035E) for non-immigrant workers which contained false representations and/or statements as to the existence ofjobs and the work locations and pay for the non-immigrant, foreign workers. 5. Some non-immigrant, foreign workers sponsored by defendants and their businesses were required to pay fees associated with the visa applications and travel expenses or asked to pay their own fees and expenses even though Mr. Mehmood and Mr. Maheshwari knew that this was in violation of federal regulations. At times, these fees or expenses were reimbursed, but not all the time. 6. While completing some of the Labor Condition Applications, the Defendants, or a 7

8 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 8 of 19 person or persons who had joined in the agreement, acted with knowledge that statements within the applications were untrue. Within the Labor Condition Applications (forms ETA 9035 and 9035E), there were false statements as to the current existence ofjobs and the work locations and pay for the non-immigrant foreign workers. Likewise, some of the forms 1-129, petitions for non-immigrant foreign workers, filed by Mr. Mehmood, Mr. Maheshwari, and WWSS contained false information about the current existence ofjobs and the work locations for those jobs.. 7. Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Tahir Ali to work as a program analyst. Instead, Mr. Ali worked as a recruiter forwwss. 8. Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Farrukh Ashan to work in the United States as a program analyst at a specific job for WWSS when there as was no suchjob. Mr. Ashan worked for WWSS as a recruiter, prepared prospective immigrant workers for interviews, and had other miscellaneous duties. 9. Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Melanie Agatep to work for WWSS in the United States as a computer programmer, and this was the representation in her immigration documents. When she arrived in the United States, this job was not available to her. Instead, she worked at WWSS as a secretary. 10. Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Vasanta Amin to work for WWSS in the United States as a computer programmer, and this was the representation in his immigration documents. When he arrived in the United States, this job was not available to him. He was without employment for a period of time and was not paid a salary by WWSS while he looked for a job. 8

9 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 9 of Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Munwar Soomro to work for WWSS in the United States as a software developer, and this was the representation in his immigration documents. When he arrived in the United States, there was no such job. He was without employment for a period oftime and was not paid a salary by WWSS while he looked for a job. 12. Mr. Mehmood, Mr. Maheshwari, and WWSS applied through the United States government for Hiten Shah to work for WWSS in the United States as a consultant, and this was the representation in his immigration documents. When he arrived in the United States, this job was not available to him. He was without employment for a period of time and was not paid a salary by WWSS while he looked for a job. This is a violation of Title 18, United States Code, Section

10 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 10 of 19 THE UNITED STATES ATTORNEY FURTHER CHARGES: COUNT 2 (Engaging in illegal monetary transaction) On or about December 31, 2008, in and about Clinton County in the Southern District of Iowa and elsewhere, the defendants, FAZAL MEHMOOD, also known as Fazal Mehmood Awan, and VINEET MAHESHWARI, knowingly and intentionally engage and attempt to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and derived from the specified unlawful activities as set forth in Count 1, and while conducting and attempting to conduct such financial and monetary transaction the defendants knew that the property involved in the transaction represented the proceeds of some form of unlawful activity. This is a violation of Title 18, United States Code, Section 1957 and 2. THE UNITED STATES ATTORNEY FURTHER CHARGES: ALLEGATION OF FORFEITURE (18 U.S.C. 982(a)(I)) A. INTRODUCTION. Pursuant to Title 18, United States Code, Section 982(a)(I), upon conviction of the offense set forth in Count 1, Defendants FAZAL MEHMOOD, also known as Fazal Mehmood Awan, and VINEET MAHESHWARI, and WORLDWIDE SOFTWARE SERVICES, INC., forfeit to the United States the following property: 1. OVERVIEW - ASSETS To BE FORFEITED. All right, title, and interest in any and all property involved in the offenses in violation of Title 18, United States Code, Sections 371, 1001, 1546, and 1957, for which the defendants were convicted and all property traceable to 10

11 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 11 of 19 such property, including the following: (a) all money and other property that was the subject of each financial and monetary transaction that the defendants conducted or conspired to conduct in violation of Sections 1956 and 1957; (b) all commissions, fees and other property constituting proceeds obtained as a result of those violations; and (c) all property used in any manner or part to commit or facilitate the commission of those violations. 2. MONEY JUDGMENT. A sum of money equal to the total amount of money involved in each offense for which the defendants were convicted. The defendants shall be jointly and severally liable for the amount involved in each such offense. B. SUBSTITUTE ASSETS. Pursuant to Title 21, United States Code, Section 853(p) as incorporated by Title 18, United States Code, Section 982(b), each defendant shall forfeit substitute property, up to the value described in paragraph A, if, by any act or omission, or any portion thereof, cannot be located upon the exercise of due diligence, has been transferred, sold to, or deposited with a third party, has been placed beyond the jurisdiction of the court, has been substantially diminished in value, or has been commingled with other property which cannot be divided without difficulty. C. SPECIFIC ASSETS SUBJECT To FORFEITURE. The property subject to forfeiture as property traceable to, and property involved in, the money laundering offenses, or as substitute assets, includes but is not limited to the following: 1. The interest(s) of Fazal Mehmood, also known as Fazal Mehmood Awan, and Uzma Amin, in the real property, and buildings and appurtenances thereto, located at 258 Cragmor Drive, Clinton, Iowa; 2. The interest(s) ofvineet Maheshwari and Shelly Maheshwari, in the real 11

12 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 12 of 19 property, and buildings and appurtenances thereto, located at 1001 Second Avenue North, Clinton, Iowa; 3. Accounts at Clinton National Bank located at th Avenue, Clinton, Iowa and any account that received funds from these accounts: a. Account No Certificate of Deposit; b. Account No Certificate of Deposit; c. Account No Certificate of Deposit; d. Account No Certificate of Deposit; e. Account No Certificate of Deposit; f. Account No Certificate of Deposit; g. Account No Commercial Checking Account for Sana Systems; h. Account No Commercial Checking Account for Worldwide Software Service; 1. Account No E-Vantage (checking) NOW Acct; J. Account No E-Vantage (checking) NOW Acct; k. Account No E-Vantage (checking) NOW Acct; 1. Account No E-Vantage (checking) NOW Acct; m. Account No E-Vantage (checking) NOW Acct; n. Account No E-Vantage (checking) NOW Account; o. Account No E-Vantage (checking) NOW Account; p. Account No Worldwide Software Trust Account; q. Account in the name of Worldwide Investment Co. LLC. r. Account No Certificate of Deposit; 12

13 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 13 of 19 s. Account No Certificate of Deposit; 1. Account No Certificate of Deposit;; u. Account No Certificate of Deposit; 4. All accounts at First Gateway Credit Union in Clinton, Iowa in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 5. All accounts at US Bank in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 6. All accounts at Members Choice Community Credit Union, Clinton, Iowa in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 7. All accounts at American Bank & Trust Company in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 8. Any and all accounts at the Wells Fargo Bank in the names of Fazal Awan, Fazal Mehmood, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 9. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC., in the Shahana Hospitality Group. 13

14 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 14 of The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in Mava Enterprises. 11. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in 53 rd Street Real Estate, LLC. 12. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in New Age Technology Group. 13. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in Worldwide Investment Co. LLC. 14. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in the real property identified as 25 Kingsbridge Garden Circle, Unit 1518, Mississauga, Ontario, Canada. All in accordance with Title 18, United States Code, Section 982(a)(6), and Rule 32.2(a) of the Federal Rules of Criminal Procedure. THE UNITED STATES ATTORNEY FURTHER CHARGES: SECOND ALLEGATION OF FORFEITURE (18 U.S.c. 981(a)(1) & 28 U.S.c. 2461(c» A. INTRODUCTION. Pursuant to Title 18, United States Code, Section 981(a)(l), and Title 28, United States Code, 2461(c), upon conviction of the offenses set forth in Counts 1 and 2, defendants, FAZAL MEHMOOD, also known as Fazal Mehmood Awan, VINEET MAHESHWARI, and WORLDWIDE SOFTWARE SERVICES, INC., shall, respectively, forfeit to the United States the following property: 14

15 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 15 of OVERVIEW - ASSETS To BE FORFEITED. All right, title, and interest in any and all property involved in each offense in violation of Title 18, United States Code, Section 371, 1001, and 1546, for which the defendants were convicted including all property traceable to such property, and all property traceable to such violations, including the following: (a) all money and other property that was the subject of each of the transactions that the defendants conducted or conspired to conduct in violation of Sections 371, 1001 and 1546; (b) all commissions, fees and other property constituting proceeds obtained as a result of those violations; and (c) all property used in any manner or part to commit or facilitate the commission ofthose violations. 2. MONEY JUDGMENT. A sum of money equal to the total amount of money involved in each offense for which the defendants were convicted. If more than one defendant is convicted of a violation of Sections 371, 1001, and 1546, the defendants so convicted shall be jointly and severally liable for the amount involved in each such offense. B. SUBSTITUTE ASSETS. Pursuant to Title 21, United States Code, Section 853(p) as incorporated by Title 18, United States Code, Section 981 and Title 28, United States Code, 2461, each defendant shall forfeit substitute property, up to the value described in paragraph A, if, by any act or omission, or any portion thereof, cannot be located upon the exercise of due diligence, has been transferred, sold to, or deposited with a third party, has been placed beyond the jurisdiction of the court, has been substantially diminished in value, or has been commingled with other property which cannot be divided without difficulty. C. SPECIFIC ASSETS SUBJECT To FORFEITURE. The property subject to forfeiture as property traceable to, and property involved in, the mail fraud and conspiracy offenses, or as 15

16 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 16 of 19 substitute assets, includes but is not limited to the following: 1. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood Awan, and Uzma Amin in the real property, and buildings and appurtenances thereto, located at 258 Cragmor Drive in Clinton, Iowa; 2. The interest(s) ofvineet Maheshwari and Shelly Maheshwari, in the real property, and buildings and appurtenances thereto, located at 1001 Second Avenue North, Clinton, Iowa; 3. Accounts at Clinton National Bank located at th Avenue, Clinton, Iowa and any account that receives funds from these accounts: a. Account No Certificate of Deposit; b. Account No Certificate of Deposit; c. Account No Certificate of Deposit; d. Account No Certificate of Deposit; e. Account No Certificate of Deposit; f. Account No Certificate of Deposit; g. Account No Commercial Checking Account for Sana Systems; h. Account No Commercial Checking Account for Worldwide Software Service; 1. Account No E-Vantage (checking) NOW Acct; J. Account No E-Vantage (checking) NOW Acct; k. Account No E-Vantage (checking) NOW Acct; 1. Account No E-Vantage (checking) NOW Acct; m. Account No E-Vantage (checking) NOW Acct; n. Account No E-Vantage (checking) NOW Account; 16

17 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 17 of 19 o. Account No E-Vantage (checking) NOW Account; p. Account No Worldwide Software Trust Account; q. Account in the name of Worldwide Investment Co. LLC. r. Account No Certificate of Deposit; s. Account No Certificate of Deposit; t. Account No Certificate of Deposit; u. Account No Certificate of Deposit; All accounts at First Gateway Credit Union in Clinton, Iowa in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. All accounts at US Bank in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53 rd Street Real Estate, LLC, and/or New Age Technology Group. All accounts at Members Choice Community Credit Union, Clinton, Iowa in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. All accounts at American Bank & Trust Company in the names of or accessed by Fazal Mehmood also known as Fazal Mehmood Awan, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Inc., Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 17

18 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 18 of Any and all accounts at the Wells Fargo Bank in the names of Fazal Awan, Fazal Mehmood, Vineet Maheshwari, Uzma Amin, Shelly Maheshwari, Worldwide Software Services, Sana Systems, Worldwide Investment Co. LLC, Shahana Hospitality Group, Mava Enterprises, 53rd Street Real Estate, LLC, and/or New Age Technology Group. 9. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC., in the Shahana Hospitality Group. 10. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in Mava Enterprises. 11. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in 53rd Street Real Estate, LLC. 12. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in New Age Technology Group. 13. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in Worldwide Investment Co. LLC. 14. The interest(s) offazal MEHMOOD, also known as Fazal Mehmood SERVICES, INC. in the real property identified as 25 Kingsbridge Garden Circle, Unit 1518, Mississauga, Ontario, Canada. All in accordance with Title 18, United States Code, Section 981(a)(l), Title 28 United States Code, Section 2461(c), Title 21, United States Code, Section 853, and Rule 32.2(a) of the Federal Rules of Criminal Procedure. 18

19 Case 3:09-cr JAJ-TJS Document 192 Filed 04/30/10 Page 19 of 19 By: Nicholas A. Klinefeldt United States Attorney. / /5'1/ l i -. Cronk III nited States Attorney 19