Haider Bokhari_ Syed Haider Ali Bokhari_ Et Al Plea Agreement

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Haider Bokhari_ Syed Haider Ali Bokhari_ Et Al Plea Agreement Powered By Docstoc
					UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN UNITED STATES OF AMERICA, Plaintiff, v. QASIM BOKHARI, a/k/a SYED QASIM ALI BOKHARI, and a/k/a KASIM BOKHARI, Defendant. PLEA AGREEMENT 1. FILED: October 22, 2004 Case No. 04-CR-56 REDACTED VERSION

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The United States of America, by its attorneys, Steven M. Biskupic, United

States Attorney for the Eastern District of Wisconsin, and R. Hewitt Pate, Assistant Attorney General for the Antitrust Division, and the defendant, Qasim Bokhari, a/k/a Syed Qasim Ali Bokhari and a/k/a Kasim Bokhari, individually and by his attorney Michael J. Steinle, pursuant to Rule 11 of the Federal Rules of Criminal Procedure, enter into the following plea agreement: CHARGES 2. The defendant has been charged in six counts of an eight-count superseding

indictment which alleges violations of Title 18, United States Code, Sections 2, 371, 1341, 1956(h), and 1956(a). 3. The defendant has read and fully understands the charges contained in the

superseding indictment and fully understands the nature and elements of the crimes with which he has been charged. In addition, the charges and the terms and conditions of the plea agreement have been fully explained to him by his attorney.
SOURCED: WWW.BACKGROUNDNOW.COM Page 1 of 26 www.BackgroundNow.com provides background checks to businesses; publishes fraud, corruption, and other criminal and civil case news; and distr butes case complaints, indictments, plea agreements and other court documents to analysts, bloggers, journalists, reporters and interested readers. Always keep in mind that indictments, complaints or informations are not evidence of guilt. These are descriptions of accusations made against defendants. Those accused are presumed innocent until guilt beyond a reasonable doubt is proven or until guilt is admitted or plead.

4.

The defendant voluntarily agrees to plead guilty to counts one through six of the

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superseding indictment which include one count of conspiracy to commit mail fraud in violation of Title 18, United States Code, Section 371 (count one); three counts of mail fraud in violation of Title 18, United States Code, Section 1341 (counts two through four); one count of conspiracy to commit money laundering in violation of Title 18, United States Code, Section 1956(h) (count five); and one count of money laundering in violation of Title 18, United States Code, Section 1956(a) (count six). A copy of the superseding indictment is attached hereto as Exhibit A. 5. The defendant acknowledges, understands, and agrees that he is, in fact, guilty of

the offenses described in paragraph 4 and set forth in Exhibit A. The parties acknowledge and understand that if this case were to proceed to trial, the government would be able to prove the following facts beyond a reasonable doubt. The defendant admits to these facts and that these facts establish his guilt beyond a reasonable doubt: a. At all times relevant to the superseding indictment, Qasim Bokhari was the owner and president of a Virginia limited liability computer consulting company (hereinafter “the consulting company”) operated by him, Raza Bokhari, a/k/a Syed Raza Ali Bokhari, and Haider Bokhari a/k/a Syed Haider Ali Bokhari. Raza Bokhari and Haider Bokhari are the brothers of Qasim Bokhari. At all times relevant to the superseding indictment, Raza Bokhari, Haider Bokhari, and Qasim Bokhari acted as agents of the consulting company. The consulting company was used by defendants for the purpose of defrauding the E-Rate Program. The only activity conducted by the consulting company was the application for, receipt, and subsequent laundering of the fraudulently obtained funds from the E-Rate Program, as described in the superseding indictment. All actions undertaken by the consulting company were at the direction of Raza Bokhari, Haider Bokhari, and Qasim Bokhari. With respect to count one of the superseding indictment, between approximately Fall of 2000 and April 2002, in the State and Eastern District of Wisconsin, and elsewhere, Qasim Bokhari conspired with Raza Bokhari and Haider Bokhari to commit a series of offenses against the United States, namely to defraud and obtain money from the Universal Service Administrative Company (“USAC”) and from a subdivision of USAC called the Schools and Libraries Division (“SLD”), through materially false representations and the concealment of material

b.

SOURCED: WWW.BACKGROUNDNOW.COM Page 2 of 26 2 www.BackgroundNow.com provides background checks to businesses; publishes fraud, corruption, and other criminal and civil case news; and distr butes case complaints, indictments, plea agreements and other court documents to analysts, bloggers, journalists, reporters and interested readers. Always keep in mind that indictments, complaints or informations are not evidence of guilt. These are descriptions of accusations made against defendants. Those accused are presumed innocent until guilt beyond a reasonable doubt is proven or until guilt is admitted or plead.

facts relating to the E-Rate Program, by depositing and causing to be deposited matters and things to be sent to SLD by private and commercial interstate carrier, namely the FedEx Corporation, in violation of Title 18, United States Code, Section 1341. c.

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The objects of the conspiracy were to: (1) violate the r
				
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Founded by Lee Hill and launched August 1st, 2003, BackgroundNow.com provides background checks to businesses; publishes fraud, corruption, and other criminal and civil case news; and distributes case complaints, indictments, plea agreements and other court documents to analysts, bloggers, journalists, reporters and interested readers.