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No. 628-1 Memorandum by USA as to Rishi Shah, Shradha Agarwal, Brad Purdy re Hearing on Defendant's Post-Trial ...

Document USA v. Desai, 1:19-cr-00864, No. 628-1 (N.D.Ill. Dec. 7, 2023)
Exhibit A From: To: Cc: Subject: Date: Richard Finneran Madden, Matthew (USAILN) Johnston, William (CRM) [EXTERNAL] RE: Update Thursday, October 26, 2023 2:24:33 PM Matt, Just got off the phone with Vicki.
But she did share a few things that I believe are directly responsive to your question about whether, as we argued in our reply, the estimates provided by QE in 2020 were “reasonable” (which, again, we don’t concede is relevant), which I detail below.
Mr. Shah did not have the means to pay that amount at the time the representation was initiated, so they accepted a smaller retainer to commence their work with the expectation that the additional monies would be paid as Mr. Shah’s liquidity increased.
In our view, that is sufficient to show that QE’s $14-15 million estimate for both Mr. Shah’s and Ms. Agarwal’s representation was, if anything, an underestimate of the fees and expenses that would actually have been required.
It doesn’t sound like Vicki will be able to get me much more additional information before we are set to be in court tomorrow, but hopefully that gives you what you need in order to be able to assess whether you will continue to challenge the reasonableness of QE’s fee estimate.
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No. 628-2 Memorandum by USA as to Rishi Shah, Shradha Agarwal, Brad Purdy re Hearing on Defendant's Post-Trial ...

Document USA v. Desai, 1:19-cr-00864, No. 628-2 (N.D.Ill. Dec. 7, 2023)
Exhibit B Assets Subject to Forfeiture Attributable to the Loans obtained in 2016 and the Capital Raise in 2017 Source of Funds Funds Transferred To Rishi Shah (Pershing x5573) Rishi Shah (Pershing x5573) Rishi Shah (Pershing x5573) 8VC Fund I Healthx Ventures Fund I, LP 7Wire Ventures Fund, LP Rishi Shah (Pershing x5573) At World Properties, LLC Baroda Trust (Pershing x7793) North American Title Company Asset All right, title, and interest in Eight Partners VC Fund I, LP All right, title, and interest in HealthX Ventures Fund All right, title, and interest in 7Wire Ventures Fund, LP All right, title, and interest in the real property and appurtenances commonly known as 924 N. Clark Street; Chicago, IL 60610 All right, title, and interest in the real property and appurtenances commonly known as 924 N. Clark Street; Chicago, IL 60610 Amount Traceable to Criminal Proceeds 15,000.00$
Page 1 of 3 Assets Subject to Forfeiture Attributable to the Capital Raise in 2017 Source of Funds Funds Transferred To Asset Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) Gravitas Holdings (Pershing x6290) AP 100 W Huron Investors LLC Guild Capital, LLC Guild Capital, LLC Guild Capital, LLC Guild Capital LLC Guild Capital LLC Institutional Venture Partners XVI LP Institutional Venture Partners XVI LP Institutional Venture Partners XVI LP Institutional Venture Partners XVI LP Institutional Venture Partners XVI, LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Management LP L Squared Capital Partners II LLC L Squared Capital Partners II LLC Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Fund I LP Leerink Transformation Partners - LTP BHE LP Monarch Capital Partners IV LP Monarch Capital Partners IV LP Monarch Capital Partners IV LP Monarch Capital Partners IV LP Monarch Capital Partners IV LP Monarch Capital Partners IV LP Gravitas Holdings (Pershing x6290) SwipeSense, Inc Gravitas Holdings (Pershing x6290) Valor Equity Partners IV, LP Gravitas Holdings (Pershing x6290) Funds Remaining in Account Gravitas Holdings (Pershing x6290) Funds Remaining in Account Shradha Agarwal (Pershing x6647) Funds Remaining in Account All right, title, and interest in approximately 17.747958% of AP 100 W Huron Investors, LLC All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in Institutional Venture Partners XVI, LP All right, title, and interest in Institutional Venture Partners XVI, LP All right, title, and interest in Institutional Venture Partners XVI, LP All right, title, and interest in Institutional Venture Partners XVI, LP All right, title, and interest in Institutional Venture Partners XVI, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Management, LP All right, title, and interest in L Squared Capital Partners II, LLC All right, title, and interest in L Squared Capital Partners II, LLC All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Fund I, LP All right, title, and interest in Leerink Transformation Partners - LTP BHE LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in Monarch Capital Partners IV, LP All right, title, and interest in approximately 60,053 shares of Series A2 Preferred Stock of Swipesense, Inc., held in the name of Jumpstart Ventures II, LLC; All right, title, and interest in approximately 90,425 shares of Series B3 Preferred Stock of Swipesense, Inc., held in the name of Gravitas Holdings, LLC; All right, title, and interest in approximately 252,045 shares of Series B4 Preferred Stock of Swipesense, Inc., held in the name of Gravitas Holdings, LLC.
All right, title, and interest in Valor Equity Partners IV, LP All funds and assets held at Pershing, LLC on deposit in account XAZ006290, titled to Gravitas Holdings, LLC, and all linked accounts, including, but not limited to, accounts XEJ006076, XEJ006159, XEJ003123, XA606312, XEJ007090, and XEJ007108 All funds and assets on deposit in account XAZ006647 and all linked accounts at Pershing, LLC, held in the names of Shradha Agarwal and Vandana Agarwal All funds and assets on deposit in account 2312087618 at Kotak Mahinda Bank Amount Traceable to Criminal Proceeds 2,537,695.00$ 25,000.00$
Page 2 of 3 Assets Subject to Forfeiture Attributable to the Loans Obtained in 2016 Source of Funds Rishi Shah (JPMC x9002) Shradha Agarwal (Chase x5964) Funds Transferred To 7Wire Ventures Fund, LP Boom Train Rishi Shah (JPMC x9002) Chicago Ventures Founders Fund, LP Shradha Agarwal (Chase x5964) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Shradha Agarwal (Chase x5964) Rishi Shah (JPMC x9002) Shradha Agarwal (Chase x6297) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Corazon Capital II LP Diversified 321 N Clark, LLC Eight Partners VC Fund I LP Eight Partners VC Fund I LP Eight Partners VC Fund I LP Eight Partners VC Fund I LP Greatpoint Ventures Innovation Fund, LP Greatpoint Ventures Innovation Fund Guild Capital Healthx Ventures Fund I, LP Rishi Shah (JPMC x9002) I2A Ventures SPV Shradha Agarwal (Chase x5964) Shradha Agarwal (Chase x5964) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Rishi Shah (JPMC x9002) Impact Engine IV LLC Institutional Venture Partners XV LP Institutional Venture Apprennet MATH Venture Partners, LP Asset All right, title, and interest in 7Wire Ventures Fund, LP All right, title, and interest in Boom Train All right, title, and interest in Chicago Ventures Founders Fund, LP; formerly known as I2A fund II, LLC All right, title, and interest in Corazon Capital II, LP All right, title, and interest in Diversified 321 N Clark, LLC All right, title, and interest in Eight Partners VC Fund I, LP All right, title, and interest in Eight Partners VC Fund I, LP All right, title, and interest in Eight Partners VC Fund I, LP All right, title, and interest in Eight Partners VC Fund I, LP All right, title, and interest in Greatpoint Ventures Innovation Fund, LP All right, title, and interest in Greatpoint Ventures Innovation Fund, LP All right, title, and interest in investments made with Guild Capital Entities All right, title, and interest in HealthX Ventures Fund All right, title, and interest in Chicago Ventures Founders Fund, LP; formerly known as I2A fund II, LLC All right, title, and interest in Impact Engine IV, LLC All right, title, and interest in Institutional Venture Partners XV, LP All right, title, and interest in Institutional Venture Partners XV, LP 3,291 Shares of Common Stock of Instructure, Inc All right, title, and interest in MATH Venture Partners, LP Amount Traceable to Criminal Proceeds 280,000.00$
200,000.00$ 12/1/2017 Rishi Shah (JPMC x9002) Silvervue Inc Rishi Shah (JPMC x9002) Swipesense, Inc Rishi Shah (JPMC x9002) Shradha Agarwal (Chase x6297) Rishi Shah (JPMC x9002) Wisercare, Inc 1776 Seed Investors, LP Volition Capital Fund II, LP Shradha Agarwal Accounts Funds Remaining in Account Shradha Agarwal Accounts Funds Remaining in Account Shradha Agarwal Accounts Funds Remaining in Account All right, title, and interest in approximately 250,454 shares of Series Preferred AA stock of Silvervue, Inc., held in the name of Jumpstart Ventures II, LLC; All right, title, and interest in approximately 751,362 shares of common stock of Silvervue, Inc., held in the name of Jumpstart Ventures II, LLC All right, title, and interest in approximately 361,702 shares of Series B Preferred Stock of Swipesense, Inc. 705,417 Shrares of Series Seed-3 Preferred Stock All right, title, and interest in 1776 Seed Investors, LP All right, title, and interest in Volition Capital Fund II, LP All funds and assets on deposit in account 309001543517 and 309001543548 at RBL Bank Ltd, held in the name of Shradha Agarwal All funds and assets on deposit in account 309002227836 at RBL Bank Ltd, held in the name of Vandana Agarwal All funds and assets on deposit in account 023455892006 at HSBC, held in the name of Vandana Agarwal
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No. 628-3 Memorandum by USA as to Rishi Shah, Shradha Agarwal, Brad Purdy re Hearing on Defendant's Post-Trial ...

Document USA v. Desai, 1:19-cr-00864, No. 628-3 (N.D.Ill. Dec. 7, 2023)
Exhibit C Harrison Quitman Madden, Matthew (USAILN) Johnston, William (CRM); Patrick Croke Re: Protective Order - Rishi Shah and Monday, January 11, 2021 7:19:24 PM From: To: Cc: Subject: Date: Hi Matt, I hope all is well with you!
Would it be possible to set up a quick call sometime this or next week to discuss this matter?
The Shah funds that we're currently holding in "escrow" are going to increase substantially in the near future, and we'd like guidance on how best to handle them.
Per our conversation, I have attached a copy of a protective order that Judge Durkin entered in this case.
As discussed, the government agrees that it makes sense to put any such capital, including distributions, in an escrow account pending further direction from the court or the government.
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No. 520-2 RESPONSE by USA as to Shradha Agarwal regarding MOTION by Shradha Agarwal for new trial (dismiss ...

Document USA v. Desai, 1:19-cr-00864, No. 520-2 (N.D.Ill. Sep. 7, 2023)
Money Market Savings Summary For: Rishi U Shah Statement Date 11/03/2021 Page 2 CustomerCare Information Toll Free 877-247-ALLY (2559) www.ally.com $28,470.45 $25,164.45 Account Number: xxxxxx4867 Product: Money Market Savings Account Open Date: 12/10/2020 Account Ownership: Single Summary Beginning Balance, as of 10/04/2021 Deposits and Other Credits Interest Paid This Period ATM Fees Reimbursed Withdrawals and Other Debits $48,516.14 $1,378,934,55 $74.72 $0.00 -$1,191,029.92 Ending Balance,as of 11/03/2021 $236,495.49 DaysIn Statement Period Annual Percentage Yield Earned AverageDaily Balance This Period Interest Paid Year to Date 0.50% $176,376.53 $236.28 Overdraft Fee Summary Overdraft Items Paid Overdraft Items Returned Activity Date Description 10/04/2021 Beginning Balance 10/05/2021 10/05/2021 10/05/2021 10/08/2021 ACH Withdrawal THE RESIDENCESA ACH Collec ACH Collec NOW Withdrawal Zelle payment from Rishi U Shah (Ally Money Market Savings Account XXXXXX4867) to FARAH KHAN NOW Withdrawal Zelle payment from Rishi U Shah (Ally Money Market Savings Account XXXXXX4867) to Cornell Mcclellan Wire Transfer 10/08/2021 Wire Fee 10/12/2021 10/13/2021 10/15/2021 ACH Withdrawal
Activity Statement Date 11/03/2021 Page 4 CustomerCare Information Toll Free 877-247-ALLY (2559) www.ally.com $238,850.77 $236,450.77
Debits Date Credits Balance Description 10/28/2021 WEB Funds Transfer Internet transfer to Money Market Savings account XXXXXX6926 10/28/2021 Service Fee Excessive Transactions Fee 10/29/2021 Wire Transfer 10/29/2021 11/01/2021 11/01/2021 11/01/2021 11/01/2021
Refund of Excessive Tran Fee-31 1 NOW Withdrawal Zelle payment from Rishi U Shah (Ally Money Market Savings Account XXXXXX4867) to FARAH KHAN Service Fee Excessive Transactions Fee
Wire Date=WireAmount Wire Type Sending Bank Receiving Bank Case Number Originator Beneficiary ngs Sara IMAD Number Number
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No. 520-1 RESPONSE by USA as to Shradha Agarwal regarding MOTION by Shradha Agarwal for new trial (dismiss ...

Document USA v. Desai, 1:19-cr-00864, No. 520-1 (N.D.Ill. Sep. 7, 2023)
Representatives, Ambassadors, senior White House and Cabinet level officials, U.S. military officers, and senior elected state officials from California, Arizona, Missouri, and Oklahoma in civil and criminal litigation, state and federal grand jury investigations, congressional and other legislative testimony, and US Department of Justice investigations, including matters related to the Foreign Agent Registration Act (FARA), Office of Foreign Assets Control (OFAC) regulations and sanctions, the Presidential Records Act (PRA), and Special Counsel inquiries.
After a 10-month trial, Stephen secured a complete defense verdict for the co- managing partner of a real estate developer, defeating allegations that three county officials took bribes from the client in exchange for their approval for a $102 million settlement of a land dispute.
He was a founding member of the State Department’s Public-Private Partnership for Justice Reform in Afghanistan, and he conducted joint training exercises and investigations with foreign law enforcement agencies in Russia, Kazakhstan, Estonia, Latvia, Poland, Ukraine, and South Korea.
Other noteworthy cases over which he presided include Siegel v. Warner Bros. Entertainment, Inc., which determined the ownership of the copyrights to the iconic comic strip Superman; the United States v. Nazario, a landmark Military Extraterritorial Jurisdiction Act case involving U.S. Marines accused of manslaughter during the Battle of Fallujah; the United States v. Duro, in which Stephen blocked the U.S. Bureau of Indian Affairs’ decade long effort to close down and expel a major migrant worker camp on the Torres Martinez Indian Reservation; and John Doe v. County of San Bernardino, which resulted in systematic reform of educational and therapeutic services for disabled youths within the county juvenile hall system.
Kori is known as a tenacious and creative advocate and has earned praise from judges for her courtroom skill—described as “superb,” “topnotch,” and among “the best I’ve seen.” She has handled high-stakes matters for prominent individuals, public entities, and private companies across a range of industries—from entertainment to finance, technology, pharmaceutical, and sports.
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No. 512-1 RESPONSE by USA as to Rishi Shah regarding MOTION by Rishi Shah to dismiss as to Ashik Desai, ...

Document USA v. Desai, 1:19-cr-00864, No. 512-1 (N.D.Ill. Sep. 1, 2023)
Q. And if there were some like small clean deposits, it was very like minimal to none? Or do you think there were none? A. I believe the only thing would have been interest which would have been interest on the fraudulent proceeds.
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No. 69 FORFEITURE AGREEMENT by Shradha Agarwal

Document USA v. Desai, 1:19-cr-00864, No. 69 (N.D.Ill. Dec. 16, 2019)
JAYANT PREMKUMAR AND SHRADHA AGARWAL agreethat public docket entries and filings in the above-captioned matter constitute adequate notice to the sureties ofall judicial proceedings in the case.
JAYANT PREMKUMAR AND SHRADHA AGARWALunderstand and agree that this forfeiture agreement applies to any modified Order Setting Conditions of Release entered by the Court in the above-captioned matter.
JAYANT PREMKUMAR AND SHRADHA AGARWAL hereby declare under penalty of perjury that they have read the foregoing Forfeiture Agreementin its entirety, and the information contained herein is true and correct.
[a JAYANT PREMKUMAR AND SHRADHA AGARWAL understand and agree that failure to comply with any term or condition of this Forfeiture Agreement will constitute grounds for the United States of America to request that the bond posted for the release of the defendant be revoked.
: ia , Notary ID #128238584 My Commission Expires y PubNey 3, 2022 (date) (name) Prepared by and Returnto: Bissell, US Attorney’s Office 219 S. Dearborn Street, 5th Floor Chicago, Illinois 60604
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No. 14 SUPERSEDING INDICTMENT as to Rishi Shah (1) count(s) 1-2, 4, 5, 9, 10, 11, 12, 13, 14-22, 23, ...

Document USA v. Desai, 1:19-cr-00864, No. 14 (N.D.Ill. Nov. 21, 2019)
... and PURDY knew were false and misleading, including representations (a) that Outcome's 20L5 fi.nancial statements fairly presented, in material respects, the financial positions of Outcome in accordance with GAAP, and (b) that none ...
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No. 14 SUPERSEDING INDICTMENT as to Rishi Shah (1) count(s) 1-2, 4, 5, 9, 10, 11, 12, 13, 14-22, 23, ...

Document USA v. Desai, 1:19-cr-00864, No. 14 (N.D.Ill. Nov. 21, 2019)
... and PURDY knew were false and misleading, including representations (a) that Outcome's 20L5 fi.nancial statements fairly presented, in material respects, the financial positions of Outcome in accordance with GAAP, and (b) that none ...
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No. 1 INFORMATION as to Ashik Desai (1) count(s) 1 (sxb, ) (Entered: 11/14/2019)

Document USA v. Desai, 1:19-cr-00864, No. 1 (N.D.Ill. Nov. 14, 2019)
Outcome placed television screens, tablets and wallboards that displayed educational content into doctor's offices and then sold advertising space on those devices to pharmaceutical ("pharma") companies and other clients.
Defendant ASHIK DESAI started working full-time at Outcome in approximately JuIy 2013 as the Vice President of Business Growth and Analytics.
DESAI, in consultation with Executive C, instructed analysts to fabricate location lists to make it appear to Auditor A that Outcome had satisfied its contractual obligations.
It was further part of the scheme that DESAI concealed the under- delivery and made it appear that Outcome's advertising campaigns were more successful than they actually were by fraudulently altering key performance metrics in Measurement Company A reports prior to sending them to clients.
On os about Febnrary m, 2016, at Chicagp, in the Northem District of Illinois, rmd elsswhorc, deftndant ASIIIK DE8AI, fur the purpose of er*r,rting the gcheme, Luoryingly tranmitted and mussd to be transmitted by nsarc of rrirc mmmtrnic&tiou in intnretfl0s *ry* ,rce eeirtain writinp, sigrs, and gigeals, nanretz, eertain writings, sigrs, and sigp an email messagp from ASHIK DESAI to Executiw C, which was routed t"hrough Google'e computer Bervers loqated outaiile the state of lllinois, asking for Exesufiive Os gxridnnoo on borr to conceal the dsttao on advertisiDg campaigna frou Auditor A; In violatim of fitle 18, Unitod States Coda, Sestion 1848.
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Del Prete v. Thompson

Docket 1:10-cv-05070, Illinois Northern District Court (Aug. 12, 2010)
Honorable Matthew F. Kennelly, presiding
Habeas Corpus
DivisionChicago
FlagsBROWN, HABEAS, PROTO, TERMED
Cause28:2254 Petition for Writ of Habeas Corpus (State)
Case Type530 Habeas Corpus
Tags530 Habeas Corpus, 530 Habeas Corpus
Petitioner Jennifer Del Prete
Respondent Sheryl Thompson
Intervenor Northwestern University
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USA v. Kashmiri et al

Docket 1:09-cr-00830, Illinois Northern District Court (Dec. 7, 2009)

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No. 30

Document USA v. Niggemann, 1:15-cr-00215, No. 30 (N.D.Ill. Jun. 4, 2015)

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USA v. Konjuch et al

Docket 1:07-cr-00794, Illinois Northern District Court (Dec. 4, 2007)
Honorable Matthew F. Kennelly, presiding, Honorable Sidney I. Schenkier

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USA v. Williams et al

Docket 1:07-cr-00614, Illinois Northern District Court (Nov. 29, 2007)
the Honorable Joan B. Gottschall, presiding.

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