Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charge contained in the information. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt:
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts One and Two of the information. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct under Guideline § 1B1.3:
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts One and Two of the superseding indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline § 1B1.3, and establish a basis for forfeiture of the property described elsewhere in this Plea Agreement:
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charges contained in Counts One and Count Two of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt: On or about September 19, 2010, XXXX XXXXX XXXXXXX, attempted, without lawful authority, to use a weapon of mass destruction against people and property in a manner that would have affected interstate and foreign commerce in violation of Title 18, United States Code, Section 2332a(a)(2)(D), and attempted to damage and destroy, by means of an explosive, real property affecting interstate and foreign commerce in violation of Title 18, United States Code, Section 844(i). In early June 2010, XXXXXXX told a law enforcement cooperating source (hereinafter, the “CS”) that he wanted to commit acts of violence in Chicago for monetary gain and to cause political instability. The CS asked XXXXXXX about his ideas for a terrorist attack. XXXXXXX suggested bombing the commercial area surrounding Wrigley Field as one option. XXXXXXX explained that an attack against an entertainment center like the one near Wrigley Field could “paralyze” Chicago commerce. In response, the CS told XXXXXXX that he/she had “friends” who might be willing to pay XXXXXXX to perpetrate such an attack. Over the following weeks, the CS and XXXXXXX continued to discuss XXXXXXX’x ideas for perpetrating a terrorist act. XXXXXXX indicated that he wanted to meet with the CS’s contacts and was anxious to act against Chicago. The CS arranged a meeting between XXXXXXX and an individual the CS represented to be one of his/her purported contacts on July 8, 2010. Then unbeknownst to XXXXXXX, the contact was an undercover FBI task force officer (hereinafter “UC-1”). During their initial meeting, XXXXXXX told UC-1 that he had been contemplating how to perpetrate terrorist attacks in Chicago. XXXXXXX stated that he believed that a series of escalating violent acts could be used to undermine the city’s political establishment. When asked by UC-1 what XXXXXXX was personally willing to do, XXXXXXX indicated that he would be willing to facilitate a car bombing or the assassination of Chicago police officers. XXXXXXX assured UC-1 that he wanted to participate in some violent act. When asked if he was concerned about those who would be hurt by such violence, XXXXXXX stated that casualties were the inevitable result of what he termed “revolution.” XXXXXXX met with U...
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charge contained in Count One of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt, and establish a basis for forfeiture of the property described elsewhere in this Plea Agreement: Beginning no later than 2007 and continuing through August 2013, in the Northern District of Illinois, Eastern Division, and elsewhere, DIKE AJIRI did participate in a scheme to defraud a health care benefit program affecting commerce, as defined by Title 18, United States Code, Section 24(b), namely Medicare, and to obtain, by means of materially false and fraudulent pretenses, representations, and promises, money under the custody and control of that program in connection with the delivery of and payment for health care benefits and services. XXXXX was the chief executive officer of Mobile Doctors, a company that arranged with physicians to provide home visits to patients in Illinois, Michigan, Indiana, and other states, among other things. Mobile Doctors used the entity “Lake MI Mobile Doctors” as its billing arm. Physician visits to a patient’s home were billed to Medicare using codes established by the American Medical Association, referred to as “CPT codes.” Physician visits with established patients were billed using CPT codes 99347 through 99350, with the higher codes representing visits of a more complicated nature. Medicare was a Federal health care benefit program, as defined in Title 18, United States Code, Section 24(b), that provided free and below-cost health care benefits, including, among other things, medically necessary physician visits to patients’ homes and in-home health care services for persons who were confined to their homes. Medicare payments for claims submitted using CPT codes 99350 were more than the payments for claims submitted using CPT codes 99349. XXXXX knew that for a home visit with an established patient to be billed properly using CPT code 99350, it was required to have at least two of the following key components as defined by the American Medical Association: a comprehensive interval history, a comprehensive examination, and/or medical decision making of moderate to high complexity. According to the American Medical Association, such a visit usually involved a problem or problems of moderate to high severity, and a physician typically spent 60 minutes face-to-face with the patient and...
Factual Basis. 6. Defendant will plead guilty because she is in fact guilty of the charge contained in the indictment. In pleading guilty, defendant admits the following facts and that those facts establish her guilt beyond a reasonable doubt: Beginning in at least January 2003 and continuing through on or about June 30, 2011, in the Northern District of Illinois, Eastern Division, and elsewhere, defendant Xxxxxx, did conspire with Individuals A and B, Xxxx Xxxxx, Xxxxxx X’Xxxxxx and others to corruptly give, offer, and agree to give things of value, namely cash payments and other personal financial benefits for the benefit of Bills and X’Xxxxxx, with intent to influence and reward Xxxxx, an agent of the City of Chicago, a local government that received in excess of $10,000 in federal funding during each of the twelve-month calendar years from 2003 through 2011, in connection with any business, transaction, and series of transactions of $5,000 or more of the City of Chicago, namely contracts for the Digital Automated Red Light Enforcement Program. Specifically, in early 2003, Xxxxx Xxxxxx was the Vice President of Operations at Redflex Traffic Systems, Inc., at a time when Redflex was competing with another company for a red light camera contract with the City of Chicago. In the course of the competition, Xxxxxx learned that Xxxx Xxxxx, who was the City official in charge of Chicago’s red light camera program, was assisting and championing Redflex by providing pointers and inside information to Redflex. In approximately late May 2003, Xxxxxxx was awarded Chicago’s contract. In return for Xxxxx’ assistance to Redflex, and in an effort to ensure that Bills would continue to provide such assistance, Xxxxxx agreed with Individual B that Redflex would hire Xxxxxx X’Xxxxxx as an independent contractor. Xxxxxx understood that X’Xxxxxx was a friend of Bills and that it was important to Bills that Redflex hire X’Xxxxxx. Xxxxxx interviewed X’Xxxxxx before Xxxxxxx offered him a position, but at the time she interviewed him, Xxxxxx understood that Xxxxxxx would in fact hire X’Xxxxxx in exchange for Xxxxx’ help in getting Redflex the Chicago contract and in order to ensure Xxxxx’ assistance to Redflex in the future. In the fall of 2003, Xxxxxx and Individual B finalized X’Xxxxxx’x contract with Redflex, which included provisions for lucrative increases in X’Xxxxxx’x compensation as new red light cameras were added. The addition of such provisions were out of the ordinary, as the cust...
Factual Basis. 14. The Defendant is pleading guilty because it is guilty of the charges contained in the Information. The Defendant admits, agrees, and stipulates that the factual allegations set forth in the Information and Attachment A are true and correct, that it is responsible for the acts of its officers, employees, and agents described in the Information and Attachment A, and that the Information and Attachment A accurately reflect the Defendant’s criminal conduct.
Factual Basis. 6. Defendant will plead guilty because she is in fact guilty of the charges contained in the information. In pleading guilty, defendant admits the following facts and that those facts establish her guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline ' 1B1.3: From at least 2010 through 2012, defendant was a tax preparer and the owner of a tax preparation business operating under the name Taxes Etc., Inc., located at 0000 Xxxx 00xx Xxxxxx, Xxxxxxx, Xxxxxxxx. Defendant=s services included preparing federal income tax returns and filing those returns on behalf of individual taxpayers. In return for her tax return preparation services, defendant=s clients paid a fee of between approximately $25 to $400 per tax return prepared and filed. The majority of defendant=s clients paid approximately $125 per tax return. While preparing tax returns at Taxes Etc., Inc., defendant held herself out to clients as a person trained in and knowledgeable about the preparation and filing of federal income tax returns. For calendar years 2009 through 2011, and in her capacity as a tax preparer and in return for a fee, defendant prepared and caused to be filed with the IRS a total of approximately 3,193 U.S. Individual Income Tax Return Form 1040 and Form 1040A on behalf of numerous tax clients, and in each of these returns, defendant knowingly included false statements and representations. Specifically, for each of these returns, defendant created a false Form 8863 that misrepresented that the taxpayer or a dependent attended an institution of higher education and was entitled to a refundable education credit. The vast majority of these taxpayer clients never indicated to defendant that a family member attended an institution of higher education. A small number of the tax clients indicated to defendant that a family member attended an institution of higher education but none of this small number of clients provided any documents to support the suggestion. Nonetheless, for all of these clients defendant prepared a false Form 8863. Further, defendant claimed the false refundable education credit on all these taxpayers= Form 1040 or Form 1040A and submitted the false returns and false Forms 8863 to the IRS. Defendant knew that the named taxpayer did not incur the claimed education expense at the institution of higher education and thus knew the taxpayer was not entitled to the refundable education credit. By making these false statements, defendant f...
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charge contained in Count Two of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt and constitute relevant conduct pursuant to Guideline § 1B1.3: Beginning no later than on or about March 17, 2010, and continuing until at least March 23, 2010, at Chicago, in the Northern District of Illinois, and elsewhere, defendant, a citizen of the United States, did knowingly attempt to provide material support and resources, namely, property (funds) and currency, as those terms are defined in Title 18, United States Code, Section 2339A(b) and 2339B(g), to a foreign terrorist organization, namely al Qaeda, which was designated by the United States Secretary of State as a foreign terrorist organization on October 8, 1999, and redesignated on October 5, 2001, October 2, 2003, and January 22, 2009, knowing that al Qaeda had engaged and was engaging in terrorist activity (as defined in Section 212(a)(3)(B) of the Immigration and Nationality Act), and that al Qaeda had engaged and was engaging in terrorism (as defined in Section 140(d)(2) of the Foreign Relations Authorization Act, Fiscal Years 1988 and 1989); in violation of Title 18, United States Code, Section 2339B(a)(1). Specifically, on October 8, 1999, the U.S. Secretary of State designated al Qaeda as a foreign terrorist organization. The Secretary of State redesignated al Qaeda as a foreign terrorist organization on October 5, 2001, October 2, 2003, and January 22, 2009. Defendant, who became a naturalized U.S. citizen in 1988, was born and resided in the Azad Kashmir region of Pakistan prior to immigrating to the United States in the late 1970's. Although he maintained a permanent residence in the United States, defendant usually traveled to Pakistan annually, for months at a time, to visit with family and tend to other affairs. During one such trip, in or around the early to mid-2000s, defendant was contacted by several individuals seeking monetary donations for Xxxxx Xxxxxxxx, who, as defendant knew, was a leader of the Kashmir independence movement and was involved in, among other things, leading, participating in, coordinating, and training others for attacks against the Indian government in an effort to force India out of the portions of the Kashmir region it controlled. Defendant supported Kashmir independence from India. Defendant and the individuals tr...
Factual Basis. 6. Defendant will plead guilty because he is in fact guilty of the charge contained in Count One of the indictment. In pleading guilty, defendant admits the following facts and that those facts establish his guilt beyond a reasonable doubt: Beginning in approximately October 1999, and continuing through approximately September 2003, XXXXXX XXXXXXXXX and co-defendant Xxxxx Xxxxxx knowingly executed a scheme to defraud Central Illinois Bank, a financial institution, and to obtain moneys and funds owned by and under the custody and control of CIB, by means of materially false and fraudulent pretenses and representations. Specifically, between approximately October 1999 and September 2003, XXXXXXXXX, together with Xxxxxx, caused and attempted to cause CIB, a financial institution, the deposits of which were insured by the Federal Deposit Insurance Corporation, to lend money for the acquisition and development of properties located at 0 Xxxxx Xxxxxxxx Xxxxxx xxx 00 X. Xxx Xxxxx Street in Chicago, Illinois, by falsely representing the sales price of the properties, their equity in the projects, and the use of the loan proceeds.