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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

Document USA v. Desai, 1:19-cr-00864, No. 628-2 (N.D.Ill. Dec. 7, 2023)

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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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