DeclarationCal. Super. - 6th Dist.August 23, 2019\OOONONU‘&WNt-‘ NNNNNNNNN-I-w-In-nflfl-H_ OONQM#WNHOOOONC\M&WNF‘C Gordon J. Finwall, SB#141 777 FINWALL LAW OFFICES, APC 1056 Lincoln Avenue San Jose, CA 95 125 p (408) 350-4041 (phone) /((408) 350-4042 (fax) ‘5, gGordon@Finwalllaw.com 5:0 I c? Attorneys for Plaintiff 4 ’17 h IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA ”Z2004 IN AND FOR THE COUNTY OF SANTA CLARA AKRIVIS LAW GROUP, PLLC ) NO. l9-CV-35365] ) Plaintiff, ) DECLARATION OF FARHAD R. ALAVI IN ) SUPPORT OF EX PARTE APPLICATION FOR VS. ) RIGHT TO ATTACH ORDER AND ORDER ) FOR ISSUANCE OF WRIT OF ATTACHMENT SADR EMAD-VAEZ, POURAN ) AAZAD and DOES 1 through 20 ) ) Defendants. ) ) I, Farhad R. Alavi, hereby declare and state as follows: 1. I am the managing shareholder in AKRIVIS LAW GROUP, PLLC, the plaintiff herein. The facts set forth herein are personally known by me to be true and correct, except where stated on information and belief, and if called as a witness I could and would competently testify thereto. 2. I have read the complaint filed in this action and know the contents thereof. The matters stated in the complaint are true and correct of my own knowledge, except as to the matters which are stated on information and belief, which matters I believe to be true. 3. I am required to know and, in fact, I am familiar with the records maintained by AKRIVIS LAW GROUP, PLLC with respect to the agreement and services which are the subject of the complaint. AKRIVIS LAW GROUP, PLLC's records regarding the agreement and services were Declaration of Farhad R. Alavi in Support of Ex Pane Application for Right to Attach Order l AWN ©00NO\UI 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 made in the ordinary course of AKRIVIS LAW GROUP, PLLC’S business, at or near the time or occurrence ofthe event ofwhich they are a record, and were made by persons who have a business duty t0 AKRIVIS LAW GROUP, PLLC to make such records. 4. AKRIVIS LAW GROUP, PLLC is a law firm with offices located in Washington, D.C. andNew York City. My office is located in Washington, D.C. Our firm focuses on White Collar & Corporate Investigations & Defense, Sanctions, Export Controls & Trade Regulation, Banking & Finance, and International Business Transactions. 5. In 20 1 6, defendants SADREMAD-VAEZ andPOURAN AAZAD, husband and wife, residents of Los Altos Hills, California and Iranian-Americans (i.e., naturalized U.S. citizens), retained AKRIVIS LAW GROUP, PLLC to provide legal counsel regarding United States sanctions regulations on Iran and potential federal United States investigation of either of them. (A true and correct copy of the signed engagement agreement is attached hereto as Exhibit “A.”) 6. Initially our work was to communicate with the federal agent who was questioning them and searched their laptop and t0 review emails and communications to determine what the agent was searching for and possible violations. 7. In April 201 8, Mr. EMAD-VAEZ and Ms. AAZAD were arrested and, from that point forward, our work drastically changed. (A true and correct copy of a press release issued by the United States Attorney’s Office for the Nonhem District 0f California is attached hereto as Exhibit “B.”) We were defending them before seven federal agencies, doing reviews 0f evidence produced by the government, preparing and representing them at proffers, hiring and managing three different local law firms for themselves and their Iran-based company, and negotiating their civil and criminal plea agreements. Mr. EMAD-VAEZ and Ms. AAZAD were facing several millions ofdollars in fines and several years in jail, and the government was threatening to arrest and prosecute both of their adult children as well. 8. In the end, we successfully negotiated and completed the civil and criminal plea agreements. Mr. EMAD-VAEZ’S criminal plea amount was agreed to be $500,000. Ms. AAZAD’s criminal plea amount (there was a waiver of indictment) was agreed to be $200,000. Mr. EMAD- Declaration of Farhad R. Alavi in Support of Ex Parte Application for Right to Attach Order 2 OOOVONUIAWNt-I NNNNNNNN-fl-flfl-fl-‘flfl gNONUI-th-‘OOOONQUIAQJN-‘O VAEZ’s tax issues were set aside. The penalty for the Department ofCommerce Bureau of Industry & Security was $300,000. Significantly. they were not required to serve any additional jail time. 9. AKRIVISLAW GROUP, PLLC commenced billing Mr. EMAD-VAEZ and Ms. AAZAD for services and costs in 2016 after being retained. 10. Mr. EMAD-VAEZ and Ms. AAZAD paid all of AKRIVIS LAW GROUP, PLLC’s invoices except the last three, true and correct copies ofwhich are attached hereto as Exhibits “C,” “D” and “E.” Pertinent information from these invoices is the following: Invoice N0. Date of Invoice Amount of Invoice Due Date 6865 4/2/2019 $105,498.92 4/17/2019 701 5 5/13/2019 $9,053.00 5/28/2019 7200 7/17/2019 $52,131.12 8/1/2019 Total Principal Amount of Invoices: $166,683.04 1 1 . Mr. EMAD-VAEZ and Ms. AAZAD partially paid invoice number 6865, having made payments on April 3, 2019 and April 29, 2019 in the amounts of $22,924.76 and $9,937.50, respectively. Mr. EMAD-VAEZ and Ms. AAZAD, therefore, owe the following principal amounts on said invoices: Invoice No. Date of Invoice Amount Owed Due Date 6865 4/2/2019 $72,636.66 4/17/2019 7015 5/1 3/2019 $9,053.00 5/28/2019 7200 7/17/2019 $52,131.12 8/1/2019 Total Principal Amount Owed on Invoices: $133,820.78 12. Mr. EMAD-VAEZ and Ms. AAZAD stopped paying only after our work was mostly complete, i.e., they no longer needed our services. We have demanded payment but they have refused to pay the outstanding invoices, with Mr. EMAD-VAEZ only stating cryptically, “Please note that Pouran and I dispute the charges.” l3. Interest accruing at the contract rate of6% per annum (as set forth in Exhibit “A”) on the invoice balances from the dates of breach (i.e., invoice due dates) through November 7, 2019, Declaration of Farhad R. Alavi in Support of Ex Parte Application for Right to Attach Order 3 \OOOVOKU'IAUJNH NNNNNNNNNHH~--H--fl WQ©M$WNHOOWNQMAWN~O the date of the hearing on this application, is calculated as follows: Invoice No. Due Date Amount Owed Accrued Interest 6865 4/17/2019 $72,636.66 $2,435.82 7015 5/28/2019 $9,053.00 $242.57 7200 8/1/2019 $52,13 1.12 $839.81 Total Accrued Interest: $3,518.20 14. AKRIVIS LAW GROUP, PLLC seeks a right to attach order by ex parte application because it may be inferred that there is a danger that the property sought to be attached will be concealed or substantially impaired in value if it must wait for a right to attach order by noticed application. 15. The basis for the concern that Defendants’ property will be concealed or substantially impaired in value relates to the fact Defendants’ criminal sentencing hearing is set for September 25, 20 1 9. While thejudge may honor and make orders consistent with the plea agreements, thejudge may ignore or modify them and impose higher fines and require additional jail and/or prison time. Because ofthe uncertainty ofwhat may happen on September 25, 2019, we believe Defendants are presently a flight risk. When they were arrested in April 20 l 8, bail was set at $8,000,000 as a result of their flight risk and they were fitted with electronic tracking monitors. However, the electronic tracking monitors were removed around the time we reached the plea agreements. Given the fines and potential jail and/or prison time they face at the September 25, 2019 sentencing hearing, we believe there is considerable risk they may leave the country, possibly to their home country of Iran. l6. Likewise, we are concerned that, given the pending sentencing hearing on September 25, 2019, Defendants will transfer their assets out ofCalifomia and, more likely, out ofthe country. Defendants are sophisticated financially and are highly knowledgeable about international transactions. In fact, this sophistication and knowledge led to their arrests and indictments. Note the United States Attomey’s Office press release states, “The indictment alleges the defendants engaged in transactions involving the illegal export of goods and services to Iran and financial transactions designed to evade the Iranian Transactions Sanctions Regulations...They also allegedly used elaborate Declaration of Farhad R. Alavi in Support of Ex Parte Application for Right to Attach Order 4 I«J J. l7. One example ul'Dcl'cndamls hiding assets bramnly occurred q/iw' thc indictments. During lhc pruscculiun, Defendants represented m pmsccutors lhul lhcy nccdcd lu scll a property in Los Allns. (‘ulil'nmiu lo gcncrutc cash lo pay their lcgul cxpcnscs (lo my firm and olhcr law firms). Whilc lhc prosecutors agreed lo allow lhc sulc ol' lhc properly. thcrc was a condition lhau lhc funds remain in [rust and only lac used l'm‘ payment ul'lcgnl expenses. llowcvcr. zll'lcr lhc propcrly was Sold zmd lhc funds wcrc dcpusilcd into a trust crcaucd by Dcl‘cmlauns' rcul cslulc agent. Ihcy violated thc agreement almost innncdiulcly by creating a limited liability cmnpuny and using lhc funds in trust l0 fund lhc LLC.‘ l0 purchase :mulhcr properly. During lhc course ut'lhis transaction. lhcy made blumm misrcprcscnlzuions on sales 21nd tux documcnls lo fucililulc lhc closing of lhc lrunsncliun. ll appears khc violation of thc agreement was fur lhc purpmc ol'thc pulling lhc funds mu ot'lhc reach ol'prosccumrs, which in lurn makes it more difficult l'or Pluinlifi'm suck rucuvcry ul' ils l’ccs and costs. IX. l um informed und hclics'c lluu Dcl'cndunls haw ulsu l'uilcd lo puy ulhcr law firms they cngagcd fur dcl'cnsc ol'lhc criminal und ciVil pmcccdings filed against lhcm. I declare under pcnully of perjury. under thc laws ol’ lhc State ul' California. that lhc [brcguing is lruc and correct and lhul |l1is Dcclurulion was cxcculcd this [fiflday oI'Scplcmbcr 2019 m \Vuslunglom l).(‘. Dccluruuun ul'l’urhml R. Alzwi m Support ul‘ [ix l’zu‘lc Appliculiun I'ur Right m Auuch ()rdur 5 I I I, ,. . L A w AlvvvuIJJ. Grumifhf; ‘ ‘- ‘a r|V|S GROUP ' .I-‘r w :7PLLc E; .w . Farhad R. Alavi 202.686.4859 falavi@Akrivislaw.com June 9, 2016 Via E-Mail (sarasamsom@outlook.com and sadrvaez@yahoo.com) Mr. Sadr Emad-Vaez Ms. Pouran Aazad 1520 Sandhil|s Road Unit 304 Palo Alto, California 94304 RE: EngagementAgreement Dear Mr. Emad-Vaez and Ms. Aazad: | am pleased that you (collectively, the “Client”) have decided to retain Akrivis Law Group, PLLC (“Akrivis”) as legal counsel in connection with the scope of legal services described below. This Engagement Agreement confirms Akrivis' engagement as Client’s legal counsel with respect to such scope of legal services, and sets forth the terms and conditions of such engagement. Scope of Legal Services Akrivis will represent Client as their legal counsel in connection with the provision of general advice and consultation related to current U.S. sanctions regulations on Iran and any potential federal U.S. investigation of either or both individuals comprising the definition of “Client" herein or in which either or both such individuals is/are otherwise involved and ancillary matters reasonably related thereto, grovided, however, that in the event that it is discovered during the course of the representation outlined herein that either or both individuals comprising the definition of “Client" herein is the subject of a U.S. federal or state investigation or otherwise involved therein, Akrivis’ continued representation will be strictly contingent on the execution by Akrivis and Client of a new engagement agreement with a separate retainer payment. ln addition to the foregoing, Akrivis may in the future also represent Client as its legal counsel in connection with other matters that may be mutually agreed upon by Client and Akrivis from time to time. However, any such matter not covered by the scope of the representation provided in this Agreement will require a separate engagement agreement or a written amendment to this Agreement. Moreover, Akrivis reserves the right to require a separate advance payment of fees and costs for each such new matter that Client may request Akrivis to represent it on. So long as either or both of Mr. Sadr Emad-Vaez andlor Ms. Pouran Aazad are ordinarily resident in Iran, all services provided by Akrivis to such individuals will be entirely contingent on the provision of said services being fully authorized under applicable U.S. laws and regulations, including but not limited to those administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Furthermore, we Mr. Sadr Emad-Vaez Ms. Pouran Aazad June 9, 2016 Page 2 of 6 note that the representation of persons in Iran by a U.S. person (as defined in the Iranian Transactions and Sanctions Regulations, 31 CFR Part 560 (the “ITSR”)) 1g authorized under 31 CFR § 560.525(a)(1)-(3) (2015). Responsibilities of Attorney and Client Akrivis will be responsible for performing the legal services provided in this Engagement Agreement, for taking reasonable steps to keep Client informed of progress and developments related thereto, and for responding promptly to Client’s inquiries and communications with respect thereto. Furthermore, I will be responsible for the coordination, quality and timely flow of the legal work to be performed, and addressing legal issues that may arise, in the course of such representation. However, based on the level of experience necessary for the specific tasks involved and with efficiency and cost-effectiveness in mind. Akrivis may utilize the services of other competent and reliable attorneys or paralegals to undertake certain aspects of the work involved in this engagement under my direct and strict supervision. It will be Client's responsibility to cooperate fully with Akrivis in connection with Akrivis’ work by, among other things, providing Akrivis with all relevant information and documents that may be necessary for Akrivis to effectively represent Client or that Akrivis may otherwise request, by confirming the accuracy and completeness of all such information and documents. and by making its management or representatives reasonably available for consultation. Furthermore, it will be Client’s responsibility to communicate with Akrivis as necessary to effectively represent it and to keep Akrivis fully informed of developments that could potentially impact the legal representation provided in this Engagement Agreement. Finally, Client will be responsible for confirming that any document that Akrivis has prepared or received and fonNarded to it for review or approval is, to their knowledge, factually accurate and otherwise consistent with its understandings and expectations. Additionally, Client acknowledges that Akrivis represents both individuals comprising “Client" as defined herein equally irrespective of who pays Akrivis' fees, and that each such individual may contact Akrivis individually; provided, however, that (a) Akrivis will be required to withdraw from the case in the event that any conflict of interest arises among or between any individual(s) comprising “Client" that would result in a non-alignment or conflict in their interests in the matter being represented; (b) decisions by Client with respect to the matter being represented will be by Client's collective consensus; and (c) that Akrivis cannot keep any confidences related to the representation shared by either of Mr. Emad-Vaez and Ms. Aazad with Akrivis from the other individual comprising the Client. Client also acknowledges that communications between Akrivis and any agent appointed by either individual comprising the Client (e.g., another relative) may not be subject to attorney-client privilege. Fees and Billing Akrivis’ fees will be calculated utilizing the “Iodestar” method. The “lodestar” amount reflects the number of hours reasonably worked multiplied by a reasonable hourly rate for the work performed. Although there may be other attorneys and staff that may work on your matter (including outside attorneys hired as contact attorneys andlor co-counsel _), | will have primary responsibility for this matter. The standard hourly billing rates for the attorney and staff likely to engage in work on this matter are as follows: Mr. Sadr Emad-Vaez Ms. Pouran Aazad June 9, 201 6 Page 3 of 6 Farhad Alavi Managing Partner $400 per hour Teresa Taylor Partner $400 per hour Staff Attorney(s) $260 per hour Katerina Roumeliotis Student Associatel Law Clerk $190 per hour In order to cover the legal fees and expenses relating to this engagement, Client will be required to pay an initial retainer in the amount of ten thousand dollars ($10,000.00) (the “Retainer") before the provision of legal services by Akrivis pursuant to this Engagement Agreement is commenced. The Retainer will be deposited in a trust account. the interest on which is payable to the District of Columbia Bar Foundation. The Retainer will be applied to the first seven thousand dollars ($7,000.00) and the remaining three thousand dollars ($3,000.00) will be applied to the final invoice rendered in this matter. If at the end of our engagement if there is any part of the Retainer remaining after payment of all outstanding invoices, we will of course promptly refund any surplus to Client. If, however, the Retainer amount is insufficient to pay all outstanding invoices, Akrivis will expect Client to promptly pay the remaining balance. If Client's balance is not satisfied by the due date of a monthly bill, Akrivis reserves the right to draw down on the Retainer as needed. All payments by Client will be in full accordance with the provisions set forth in the ITSR, including but not limited to 31 CFR § 560.553, which requires, inter alia, a specific license from OFAC to receive payment for the services detailed herein. All receipt of payments for services detailed herein and all provision of services shall be contingent on Akrivis’ compliance with all applicable laws and regulations, including but not limited to U.S. sanctions laws and regulations. Further, in the event that any funds will be owing Client upon the end of Akrivis’ representation, the remittal of such funds to Client or any third party of Client’s choosing is fully contingent on said remittal being authorized under applicable laws and regulations. Client will be provided with detailed monthly billing statements for all time entered, which will track the work done and any expenses incurred on Client's behalf in the previous month. Billing will be calculated on tenth of an hour (1/1 0) increments, with a minimum of two tenths (2/10) of an hour for any work billed on a given day. Upon receipt of each monthly statement from Akrivis, Client will be expected to make prompt payment for legal fees and charges within fifteen (15) calendar days. Interest shall accrue on all bills that are past due at a rate of six percent (6.00%) per annum. compounded monthly and commencing on the 15"“ date of the amount at issue being past due. Furthermore, Akrivis reserves the right to collect any and all attorneys’ fees and related costs from Client in the event of any lawsuit or other form of dispute resolution to collect on services provided to Client that are past due. During the course of this representation, Akrivis may from time to time furnish Client with estimated amounts of legal fees that Akrivis anticipates Client will be charged for certain services to be performed by Akrivis. Such estimates are, however, by their nature imprecise and shall not be binding on either Client or Akrivis. Costs and Expenses In addition to fees for legal services performed pursuant to this Engagement Agreement, Client will be responsible for paying actual and reasonable out-of-pocket costs and expenses outside of the Scope of Services, including but not limited to filing fees, courier service, translation Mr. Sadr Emad-Vaez Ms. Pouran Aazad June 9, 2016 Page 4 of 6 charges, long distance telephone charges or, if necessary, travel expenses that are incurred by us on Client’s behalf in the course of this representation. Such costs and expenses that are incurred and advanced on Client's behalf will be reflected in Akrivis' monthly billing statements that will be furnished to Client. Disclaimer of Guarantees Outcomes in many legal matters are uncertain. As such, Akrivis cannot guarantee a certain result with respect to matters covered in this Engagement Agreement. but will seek to obtain the best result for Client based on the facts of the case and the applicable law. Accordingly, beliefs expressed by Akrivis or others representing Akrivis from time to time during the course of this representation concerning the effectiveness of various strategies and courses of action are not intended and should not be construed as promises or guarantees regarding the outcome of a matter. Termination of Legal Services Either Client, unanimously, or Akrivis may at any time terminate the representation pursuant to this Engagement Agreement by providing the other person or persons with written notice of such termination, and subject on Akrivis’ part to our professional obligations to Client under applicable rules of professional conduct. However, the termination of such representation, whether by Client or by Akrivis. shall not relieve Client of its obligation to pay Akrivis for services rendered and costs advanced prior to such termination. When Akrivis' services conclude, such outstanding charges become immediately due and payable. Unless Client again engages Akrivis after the termination of this matter, we will have no continuing obligation to advise Client with respect to future legal developments. such as changes in the applicable laws or regulations that could have an effect on Client’s future rights and liabilities. Consent to Electronic Communications As is currently prevalent and customary and in order to maximize efficiency in representing Client, in the course of this engagement we intend to use email communications, cellular telephones and facsimile transfers to the fullest extent possible. However, the use of such devices under current technologies may possibly place Client’s confidences and privileges at risk, and by signing this Engagement Agreement, Client consent to the use of such devices by Akrivis. Retention of Files Upon the termination of this engagement, Akrivis will, upon Client’s request and receipt of payment for all outstanding legal costs and expenses, deliver to Client all of their files. If Client does not request such files, we will retain them for a period of three (3) years after the termination of Akrivis' engagement by Client. If Client does not request such files prior to the end of such period, we will have no further obligation to retain them and may, in our sole and absolute discretion, destroy or discard them without further notice. Dispute Resolution This Engagement Agreement shall be, for all purposes, governed by and construed in accordance with the laws of the District of Columbia. Any fee disputes or other legal action or Mr. Sadr Emad-Vaez Ms. Pouran Aazad June 9, 2016 Page 5 of 6 proceeding with respect to this Engagement Agreement and Akrivis' representation of Client pursuant hereto shall be brought before courts or arbitral tribunals located in the District of Columbia. By execution and delivery of this Engagement Agreement, Client hereby irrevocably waives any objection which it may now or hereafter have to the foregoing venue for the resolution of any disputes under this Agreement. Miscellaneous If any term or provision of this Engagement Agreement shall be held invalid, illegal or unenforceable, the validity of all other terms and provisions hereof shall in no way be affected thereby, unless the absence of the omitted term or terms render the rest of the Engagement Agreement manifestly unjust as to either party. This Engagement Agreement contains the entire agreement between Client and Akrivis concerning the subject matter hereof and supersedes all oral statements and prior writings with respect thereto. This Engagement Agreement or any terms thereof may not be amended or modified except by a writing executed by Client and Akrivis. The legal work provided for in this Engagement Agreement shall commence only after Client have executed and returned this Agreement to Akrivis. Accordingly. if Client would like Akrivis to represent them as their legal counsel, please countersign this Engagement Agreement, return a copy to Akrivis and keep another copy for your records. The initial amount of the Retainer, as provided in the paragraph above, can be paid by sending Akrivis a check made out to “Akrivis Law Group, PLLC”, by credit card (we accept Visa, MasterCard, and American Express) calling our office at 202.730.1271 during the office hours of 9:00 a.m. to 7:00 p.m. EDT. Should you wish to wire the Retainer. instructions are provided on page 6 of this Engagement Agreement. Please let me know if you have any questions with respect to this Engagement Agreement. OthenNise, we look fon/vard to working with you and providing you with the legal services contemplated in this Agreement. Sincerely Yours. w Farhad R. Alavi Managing Partner Akrivis Law Group. PLLC [Continued on the following page.] Mr. Sadr Emad-Vaez Ms. Pouran Aazad June 9, 2016 Page 6 of 6 The undersigned has reviewed, understood, and agreed to the terms and conditions of this Engagement Agreement. and represents and warrants that he is authorized to sign on behalf of Client, and funher acknowledges that Akrivis has not acted as Client's counsel with respect to this Agreement. Mr. Sadr Emad-Vaez Signature Date Ms. Pouran Aazad Signature Date Retainer (IOLTA) Wire Instructions: Akrivis Law Group, PLLC Account 9250370040 Citibank, N.A. Connecticut & K 1717 K Street, NW Washington, DC 20036 USA Citibank ABA/Routing Number 2540701 16 SWIFT: CITI US 33 Mr. Sadr Emad-Vm Mn. Poumn Anna Juno 9. 2016 Pngo 6 o! 6 Tho undonlonod has "mm. undom Engngomonl Autumnal. and mpmonln a Cuanl. and lurthor ndnowiodgn that AIuMs lhls Agreement ood. and nursed Io Ina lam ma mm». Mm nd wannnlo that ho h numomod In Mgr! mW (l ha- m! 9cm: n Cllonl'n comm with raw h MW Signature LYM/éQ/é DataW Signature Dale WW: Akrlvls Law Group. PLLc Account 9250370040 Cltlbank. NA Connecticut a K 1717 K Street. NW gzggington. Dc 20036 USA ' nk ABNRouu' Number 2 SWlFr: cm US 33m “0701‘s Mr. Sadr Emad-Vgoz Ms. Pouran Aazad June 9. 2015 Page 6 of 6 The undars ‘[gnad has revuewed. understood. and agreed lo the term. and commons of 1h):Engagement ‘Agreement. Ind represents and warrants that he ts authorized to sign on behaI! o! Client. and furth this Agmemem er acknowledges that Akrlvlu ha: not acted al CIIent‘mm Signature Datemm J/Wv/ Signature U a lo» 23/5 Date W: Akrlvls Law Group, PLLc Account 9250370040 Citibank. NA. Connecticut 8 K 1717 K Street, NW Washington, DC 20036 USA Cltlbank ABNRouflng Number 2540701 16 SWIFT: CITI US 33 a counsel with respect to Executives Of Iranian Auto P: Manufacturer Arrested And Indicted " Violating Irani... Page 1 of 2 f“ L nlrul Smrux Lh-pJnmrm utllmnw THE I'M'rw S'J'A'l‘hs A‘1”I‘()m\'nv‘s (much NORTHERN DIS'l'RIC’I'ro ”CALIFORNIA U.S. Attorneys » Northern District of California » News Department of Justice U.S. Attorney’s Office Northern District of California FOR IMMEDIATE RELEASE Friday, April 27, 2018 Executives OfIranian Auto Parts Manufacturer Arrested And Indicted For Violating Iranian Sanctions Statute U.S. Citizens Provided Services, Materials, and Equipment For Use By Their Company in Tehran, Iran SAN FRANCISCO - Sadr Emad-Vaez, Pouran Aazad, and Hassan Ali Moshir-Fatemi made their initial appearances in district court today after being indicted on April 19, 2018. for violating export control laws under the International Emergency Economic Powers Act (IEEPA), announced Acting United States Attorney Alex G. Tse; Assistant Attorney General for National Security John C. Demers; Department of Commerce, Special Agent in Charge Joseph P. Whitehead; Department of Homeland Security. Special Agent in Charge Ryan L. Spradlin; and Internal Revenue Service, Criminal Investigation, Special Agent in Charge Michael T. Batdorf. The defendants were charged in a three-count indictment with the following crimes: conspiracy to violate the IEEPA, in violation of 50 U.S.C. §§ 1701-1705; a substantive violation of the IEEPA. 50 U.S.C. § 1705; and smuggling, in violation of 18 U.S.C. §§ 554(a) and 2. The indictment alleges the defendants engaged in transactions involving the illegal export of goods and services to Iran and financial transactions designed to evade the Iranian Transactions Sanctions Regulations (ITSR). Under the IEEPA and the ITSR. it is illegal for a United States citizen to, among other things. export, reexport, sell, or supply, directly or indirectly. any goods, technology, or services to Iran or the government of Iran, without a license granted by the Department of Treasury, Office of Foreign Asset Control, or to engage in financial transactions supporting such activities. According to the indictment, the defendants. all naturalized U.S. citizens who lived variously in Tehran and the Northern District of California. participated in the operation of the Ghare Sabz Company, aka GHS Technology, a large manufacturing corporation in Tehran, Iran. Emad-Vaez allegedly has described himself as the “Managing Director," Aazad as the “Chief Financial Officer,” and Moshir-Fatemi as the “Engineering Manager" of the corporation. The defendants https://www.justice.gov/usao-ndca/pr/executives-iranian-auto-parts-manufacturer-arrested-... 9/ 1 0/20 1 9 Executives Of Iranian Auto P: Manufacturer Arrested And Indicted " Violating Irani... Page 2 of 2 are alleged to have acquired and engaged in attempts to acquire components from manufacturers all over the world (including the U.S.), in order to funnel them to GHS in Tehran. They also allegedly used elaborate systems of international wire transfers-including through prohibited financial institutions-to fund the effort. Defendants Emad-Vaez and Aazad were arrested at their residence in Los Altos Hills on April 7, 2018, and were brought before Magistrate Judge Elizabeth D. Laporte for their initial appearance on April 9, 2018. Defendant Moshir-Fatemi was arrested near San Francisco Airport on April 11, 2018, and similarly was brought before Magistrate Laporte. All three defendants have been released on secured bonds. The defendants’ next scheduled appearance is at 10:00 a.m. on July 11, 2018, before the Honorable Charles R. Breyer, U.S. District Judge. The indictment merely alleges that crimes have been committed, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt. If convicted of violating the IEEPA, the defendants face a maximum sentence of 20 years in prison, and a fine of $1 ,000,000. If convicted of smuggling, the defendants face a maximum penalty of 10 years in prison and a $250000 fine. However, any sentence following conviction would be imposed by the Court after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition ofa sentence, 18 U.S.C. § 3553. The case is being prosecuted by Assistant United States Attorney Philip J. Kearney and and the Counter Espionage Section of the National Security Division of the U.S. Department of Justice. The charges are the result of an investigation by agents of the Department of Commerce, Department of Homeland Security, and Internal Revenue Service, Criminal Investigation. Topic(s): National Security Component(s): USAO - California Northern Updated May 30. 2018 https://www.justice.gov/usao-ndca/pr/executives-iranian-auto-parts-manufacturer-arrested-... 9/ 1 0/201 9 I I I L A w , . v a I’IVISE [ P L L C ; c c e Statement of Servnces Statement No. 6865 Date: 04/02/2019 Due On: 04/17/2019 Mr. Sadr Emad-Vaez 27333 Ursula Lane Los Altos Hills, California 94022 10346-Emad-Vaez Defense Matter Client Reference Number: 10346.0001 Services Date Notes Timekeeper Quantity Total 02/01/2019 Review Approval of Stay sent by BIS. Farhad Alavi 0.10 $55.00 02/01/2019 Review drafts of BIS report; review BIS stay or Teresa Taylor 0.60 $330.00 proceedings filings. 02/04/2019 Messages with local counsel re upcoming proffer and Teresa Taylor 0.70 $385.00 case; review draft report to BIS and rules. 02/07/2019 Messages with T. Taylor re matter. Farhad Alavi 0.10 $55.00 02/07/2019 Call with client, T. Taylor and L. Agre. Farhad Alavi 0.50 $275.00 02/07/2019 Review and edit IEEPA case chart to top 25 cases. Joyce Rodriguez 1.50 $427.50 Emails with T. Taylor re same. 02/07/2019 Discuss and review work of J. Rodriguez re IEEPA Teresa Taylor 2.90 $1 595.00 research and case chart, provide edits; emails with local counsel; review messages with client re upcoming proffer; call with client. local counsel, and F. Alavi; discuss with F. Alavi. 02/1 1/2019 Discuss status of matter with T. Taylor. Farhad Alavi 0.20 $1 10.00 Page 1 of 9 Statement N0. 6865 - 04/02/2019 02/1 1/2019 Discuss case with F. Alavi; review case chart analysis re Teresa Taylor 2.20 $1 210.00 IEEPA of J. Rodriguez and provide edits, email to local counsel; emails with AUSA. 02/1 2/2019 Discuss strategy with T. Taylor. Farhad Alavi 0.40 $220.00 02/1 212019 Research and analyze sentencing maximum and Joyce Rodriguez 2.20 $627.00 minimum re tax violations. Draft and edit email summary re same. Email local counsel re sunset provision research. 02/1 2/201 9 Instruct and review work of J. Rodriguez re sentencing Teresa Taonr 3.10 $1 .705.00 and other tax violations, and related laws, edit, research. 02/1 4/2019 Emails with local counsel and AUSA. Teresa Taylor 0.50 $275.00 02l1 5/2019 Call and messages with AUSA; review draft plea Teresa Taylor 1.40 $770.00 agreement; research sentencing guidelines; review case law research and charts. 02/1 9/2019 Review Update/Driven invoices. Messages with T. Taylor. Farhad Alavi 0.20 $1 10.00 Correspondence with Lynn Agra & T. Taylor. Discuss with T. Taylor. 02/1 9/2019 Discuss Update Legal invoices of client and status; Teresa Taylor 2.50 $1 375.00 prepare for call with company and same with client; discuss same with F. Alavi; review draft email of call re case proffer issues re proffer preparation with client re call F. Alavi and client; review messages with AUSA and local counsel; call with local counsel and F. Alavi. 02/20/2019 Review plea agreement. Discuss with T. Taylor. Farhad Alavi 1.70 $935.00 Conference call with Lynn Agre and T. Taylor. Messages with S. Emad-Vaez. Call with client. 02/20/2019 Emails with local counsel and AUSA; review draft plea Teresa Taylor 3.00 $1,650.00 agreement from AUSA; call with AUSA; emails and call with Update Legal, document company re client bills and files, discuss with F. Alavi; discuss with client; review sentencing analysis and case chart analysis of J. Rodriguez and law clerks, and edit. 02/21/2019 Message with client. Correspondence with Lyn Agre re Farhad Alavi 0.20 $1 10.00 proffer. 02/21/2019 Messages with local counsel and F. Alavi; emails with all Teresa Taylor 1.70 $935.00 local counsel; emails with AUSA; review fines laws and draft BIS repon; messages with F. Alavi and client. 02/22/2019 Discuss proffer prep with T. Taylor and S. Emad-Vaez. Farhad Alavi 0.40 $220.00 Review correspondence by Assistant US Attorney. Correspondence with L. Agre. 02/22/2019 Messages and calls with local counsel; Messages and call Teresa Taylor 2.50 $1 ,375.00 with AUSA and local counsel; messages with local counsel, F. Alavi, and the court separately; review filings, fine analysis for both cases. and preparation for proffer. Page 2 of 9 Statement No. 6865 - 04/02/2019 02/24/2019 Messages with local counsel; review stipulation of travel; Teresa Taylor 1.20 $660.00 discuss with F. Alavi; review messages with client and F. Alavi. 02/25/2019 Review correspondence by Lyn Agre. Message with Farhad Alavi 0.50 $275.00 client. Call with client. Review proffer topics. Draft additional notes. Correspondence with T. Taylor. 02l25/2019 Review and analyze client files and papers in preparation Joyce Rodriguez 1.00 $285.00 of proffer preparation meetings. Review and process stipulation filing re travel permission for Sadr and related order. Review and process proffer topic outlines. 02l25/2019 Prepare for proffer preparation of client; calls and Teresa Taylor 4.50 $2,475.00 messages with local counsel; review messages re client and F. Alavi; review court filings; review case material, laws. and research; instruct staff and review work; review drafts from AUSA; review draft to BIS. 02/26/2019 Prepare for meeting with client. Messages with T. Taylor Farhad Alavi 6.90 $3,795.00 and S. Emad-Vaez. Meeting with T. Taylor, L. Agre (via teleconference). J. Rodriguez and client. 02/26/2019 Assist T. Taylor with printing of documents. Oliver Koppany 0.20 $33.00 02126/2019 Assist F. Alavi wtih research regarding the property Oliver Koppany 0.50 $82.50 located 2130-2136 Jones St. in San Francisco. 02/26/2019 Managing logistics and documents for day one proffer Joyce Rodriguez 12.00 $3,420.00 preparation of Sadr. Proffer preparation of Sadr. Reviewing and analyzing reports of investigation re previous proffers. Reviewing and analyzing plea agreement draft. 02/26/2019 Prepare for proffer preparation of client; review Teresa Taylor 13.20 $7,260.00 documents and case file; review and conduct research; calls and messages with local counsel; proffer preparation of client; assign and review work of staff; prepare for next day re meeting with client; prepare for trip re upcoming proffer. 02/27/2019 Proffer prep with client. Messages with T. Taylor. Farhad Alavi 7.70 $4,235.00 02/27/2019 Managing logistics and documents for day one proffer Joyce Rodriguez 9.00 $2,565.00 preparation of Sadr. Researching re sentencing for conspiracy count. Proffer preparation of Sadr. 0227/2019 Attend and take notes during second day of proffer Heather Duncan 4.00 $660.00 preparation. 02/27/2019 Proffer preparation. proffer preparation of client; instruct Teresa Taylor 12.00 $6,600.00 staff and review work; discuss with F. Alavi; review case files; texts and calls with local counsel; emails with AUSA; review proffer notes. 02/28/201 9 Review correspondence by A. Frazier (Commerce) re Farhad Alavi 0.10 $55.00 sentencing. Correspondence with T. Taylor. Review response by T. Taylor. Page 3 of 9 02/28/201 9 02/28/201 9 02/28/20 1 9 03/01/201 9 03/01/201 9 03/01/201 9 03/01 l201 9 03/02/201 9 03/03/201 9 03/04/201 9 03/04/201 9 03/04/20 1 9 Editing proffer preparation notes for scanning and printing. Instructing O. Koppany re Reviewing and analyzing proffer preparation notes for Sadr in preparation of outline for proffer. Drafting and editing outline. Processing J. Rodriguez hand-written notes re day two of proffer preparation of S. Emad-Vaez. Instruct and review work of staff; discuss cases with F. Alavi; emails with BIS counsel; review draft report to BIS and research; review sentencing guidelines and research; review fines analysis and laws; review proffer preparation materials and case files; calls and messages with local counsel re case and loan documents new purchase. Emails with AUSA. Analyzing, editing and processing hand-written notes from proffer preparation of Sadr day one in preparation for proffer. Review correspondence by US Depanment of Commerce counsel and T. Taylor. Call with Department of Commerce. Discuss with T. Taylor. Call with client to discuss plea agreement and penalties. Discuss with Update Legal. Processing J. Rodriguez hand-written notes re day two of proffer preparation of S. Emad-Vaez. Emails and call with local counsel and AUSA; view loan documents and discuss with F. Alavi and L. Agre; view follow-up with court and probation re new property purchase and court rescheduling; supervise work of J. Rodriguez and H. Duncan re proffer preparation outline for client, and review notes from same; emails with client; call with BIS. Emails with client re sale of property and loan specifics, probation follow-up; emails with local counsel re same; emails with AUSA re draft plea agreement issues, and call re same; emails and call with Update Legal re client bills; discuss issues with F. Alavi; direct and review work of J. Rodriguez and H. Duncan re proffer preparation tasks and BIS case issues; emails and calls with BIS counsel re settlement discussions; prepare for upcoming proffer. Review Economic Enforcement Guidelines and prepare analysis. Send same to T. Taylor. Process J. Rodriguez hand-written notes re day two of proffer preparation of S. Emad-Vaez. Review correspondence by T. Taylor and. J. Rodn'guez re mitigation. Messages with T. Taylor re same. Analyze. edit. and processing hand-written notes re proffer preparation day one. Reviewing and edit O. Page 4 of 9 Statement No. 6865 - 04/02/2019 Joyce Rodriguez Oliver Koppany Teresa Taylor Joyce Rodriguez Farhad Alavi Oliver Koppany Teresa Taylor Teresa Taylor Farhad Alavi Oliver Koppany Farhad Alavi Joyce Rodriguez 6.00 4.50 4.70 7.00 1.50 5.80 3.00 5.90 1.00 4.00 0.10 8.00 $1,710.00 $742.50 $2,585.00 $1 £95.00 $825.00 $957.00 $1 £50.00 $3,245.00 $550.00 $660.00 $55.00 $2,280.00 Statement No. 6865 - 04/02/2019 Koppany typed up notes re proffer preparation for day two. Research and analyze BIS enforcement factors to compare with OFAC factors, and maximum BIS civil penalty for T. Taylor. Draft and edit email to T. Taylor re BIS enforcement factors to compare with OFAC factors, and maximum BIS civil penalty for T. Taylor. 03/04/2019 Review emails from A. Frazier. BIS. re fines analysis; Teresa Taylor 3.10 $1 .705.00 review fines analysis. Call with AUSA and local counsel re plea agreement issues and upcoming proffer; call with local counsel re same; discuss with F. Alavi; review cases and sentencing guidelines, and draft plea agreement. 03/05/2019 Processing J. Rodriguez hand-written notes re day two of Oliver Koppany 3.70 $610.50 proffer preparation of S. Emad-Vaez. 03/05/2019 Researching and analyzing facts and BIS factors to derive Joyce Rodriguez 7.00 $1,995.00 the best possible outcome re administrative proceeding. Drafting and editing memorandum re analysis of BIS factors and civil fine argument. Reviewing and editing all typed up notes re proffer preparation. Reviewing and editing proffer preparation outline for S. Emad Vaez and creating exhibits. Emails to L. Agre re typed notes re proffer preparation and proffer preparation outline. 03/05/2019 Trip to San Francisco; review case files and proffer Teresa Taylor 13.70 $7,535.00 preparation materials re proffer preparation; texts with client and local counsel; meeting with local counsel and client re proffer. 03/06I2019 Review proffer outline. Messages with T. Taylor. Make Farhad Alavi 0.40 $220.00 edits to outline. Send same to T. Taylor and J. Rodriguez. 03/06/2019 Profier with AUSA, DOJ NSD. BIS, OFAC, FBI, IRS, Teresa Tayior 15.40 $8,470.00 client, and local counsel; discuss with F. Alavi; travel to Washington, DC. 03/07/2019 Texts with local counsel; discuss case with F. Alavi; Teresa Taylor 2.60 $1 .430.00 emails with counsel, BIS. re case; review draft case law chart and BIS report. and resume edits. 03/1 1/201 9 Review emails from Update Legal; review emails from Teresa Taylor 0.20 $1 10.00 local counsel. 03l1 2/2019 Review emails from Update Legal, and client; review Teresa Taylor 0.30 $165.00 emails from local counsels. 03/1 3/2019 Messages with T. Taylor. Review memorandum on Farhad Alavi 1.90 $1 ,045.00 penalties. Review BIS regulations. Discuss with T. Taylor. 03/1 3/2019 Emails with S. Moeel re IEEPA case chart and update re Joyce Rodriguez 0.50 $142.50 P. Aazad laptop documents. Call with T. Taylor re same and BIS civil penalty memorandum. 03/13/2019 Manage and instruct J. Rodn'guez re case files and edits Teresa Taylor 2.20 $1 210.00 to drafts re BIS and case charts, review work; emails with local counsel re applicable laws in case. Page 5 of 9 Statement No. 6865 - 04/02/2019 03/14/2019 Make edits to memorandum. Review regulations. Send Farhad Alavi 1.90 $1,045.00 revised memo to T. Taylor. Discuss and make additional edits with T. Taylor. 03/14/2019 Emails with local counsel; texts with client; discuss with F. Teresa Taylor 2.10 $1,155.00 Alavi; review edits and comments of F. Alavi re BIS fines analysis. and review and edit fines analysis; reviews applicable laws. 03/1 5/2019 Continue edits on civil penalty memo to Assistant U.S. Farhad Alavi 1.50 $825.00 attorney. Review regulations. Send same to T. Taylor. Discuss with T. Taylor. 03/1 5/2019 Texts with local counsel; texts with client; continue review Teresa Taylor 3.40 $1 £70.00 and edit of BIS fines analysis; review emails and edits of J. Rodriguez re BIS fines analysis memo; emails with local counsel and AUSA; review email from Update Legal; review court filings emails. 03/1 6/2019 Review edits of BIS fines analysis and continue to edit; Teresa Taylor 0.90 $495.00 emails re same with F. Alavi. 03/1 7/2019 Finalize edits to BIS fines analysis memo. review laws Teresa Taylor 3.40 $1 .870.00 and case files; discuss with F. Alavi. 03/1 8/2019 Review memorandum and changes by T. Taylor. Make Farhad Alavi 0.40 $220.00 additional proofing edits. Send same to client. Messages with T. Taylor and client re same. Discuss with T. Taylor. 03I1 8/2019 Final review and edits of BIS fines analysis memo; review Teresa Taylor 2.20 $1 210.00 draft email to clients; review emails re F. Alavi and clients. 03/1 9/2019 Review correspondence by T. Taylor to Assistant US Farhad Alavi 0.20 $1 10.00 Attorney and to Department of Commerce counsel re penalty memo. Resend memorandum to Dept. of Commerce. 03/1 9/2019 Emails with A. Frazier, BIS. and share fines analysis re Teresa Taylor 0.40 $220.00 case; emails with AUSA re same; emails re F. Alavi and A. Frazier. 03/1 9/2019 Messages with local counsel re status re redline of draft Teresa Taylor 0.20 $1 10.00 plea agreement. 03/21/2019 Correspondence with Adrienne Frazier, Department of Farhad Alavi 0.10 $55.00 Commerce. 03/21/2019 Emails with A. Frazier. BIS, and F. Alavi. Teresa Taylor 0.20 $1 10.00 03/25/201 9 Emails with A. Frazier. BIS, and F. Alavi. Teresa Taylor 0.20 $1 10.00 03l26/2019 Correspondence with Department of Commerce counsel. Farhad Alavi 1.60 $880.00 Call with same and T. Taylor regarding penalty memorandum and proposed fine. Discuss with T. Taylor. 03/26/2019 Emails and call with A. Frazier and C. Walls, counsel to Teresa Taylor 3.00 $1 £50.00 BIS, and F. Alavi re fines analysis memo and settlement discussions; calls with F. Alavi re same; draft follow-up Page 6 of 9 Statement No. 6865 - 04/02/2019 draft email with F. Alavi to same; review draft plea agreement and case information re impact on global resolution options. 03/27/2019 Review OFAC penalty information. Correspondence with Farhad Alavi 0.40 $220.00 T. Taylor. Instruct J. Rosenberg. Review research by same. 03/27/2019 Researched and drafted a summary of individuals and Jaime Rosenberg 2.70 $445.50 small companies that were fined by BIS in the past two years. 03/27/2019 Review email from A. Frazier. BIS; review emails re F. Teresa Taylor 1.80 $990.00 Alavi and J. Rosenberg re BIS and OFAC penalties research; discuss with F. Alavi; review research and analyze against clients' case. Services Subtotal $102,633.00 Expenses Date Notes Quantity Rate Tow 02/27/201 9 Lyft after proffer preparation. 1.00 $1 6.35 $16.35 02/27/2019 Meals during proffer preparation meetings. 1.00 $186.36 $1 86.36 03/05/2019 Transportation expenses for San Francisco travel. 1.00 $2,663.21 $2,663.21 Expenses Subtotal $2,865.92 Time Keeper Posltlon Quantity Rate Total Farhad Alavi Partner 30.0 $550.00 $16,500.00 Joyce Rodriguez Associate 54.2 $285.00 $15,447.00 Teresa Taylor Partner 120.9 $550.00 $66,495.00 Heather Duncan Paralegal 4.0 $1 65.00 $660.00 Oliver Koppany Law Clerk 18.7 $1 65.00 $3,085.50 Jaime Rosenberg Law Clerk 2.7 $165.00 $445.50 Subtotal $1 05,498.92 Interest Type Date Description Total Page 7 of 9 Statement No. 6865 - 04/02/2019 Interest 04/1 8/201 9 Interest on overdue invoice #6865 $203.61 Interest 05/1 8/201 9 Interest on overdue invoice #6865 $359.21 Interest 06/1 7/201 9 Interest on overdue invoice #6865 $360.98 Interest Subtotal $923.80 Subtotal $105,498.92 Interest $923.80 Total $1 06,422.72 Payment (04I03I201 9) $22,924.76 Payment (0412912019) $9,937.50 Balance Owlng $73,560.46 Detailed Statement of Account Other Invoices Invoice Number Due 0n Amount Due Payments Received Balance Duo 701 5 05/28/201 9 $9.053.00 $0.00 $9,053.00 Interest 0n Other Invoices Original Invoice Due On Amount Due Payments Received Balance Duo 7015 06I28/2019 $22.32 $0.00 $22.32 Current Invoice Invoice Number Duo On Amount Due Payments Received Balance Duo 6865 04/1 7/201 9 $1 06,422.72 $32,862.26 $73,560.46 Outstanding Balance $82,635.78 Total Amount Outstanding $82,635.78 Account Balance Citibank IOLTA Balance $0.00 Page 8 of 9 Statement No. 6865 - 04/02/2019 Total Account Balance $0.00 Please make all amounts payable to Akrivls Law Group, PLLC Payment must be received within 15 days. 5% annual interest will be charged every 30 days. Page 9 of 9 “DOI- Fm> [-02 0C ‘0akrivis . Mr. Sadr Emad-Vaez 27333 Ursula Lane Los Altos Hills, California 94022 10346-Emad-Vaez Defense Matter Client Reference Number: 10346.0001 Date Notes 04/02/2019 Compiled a BIS case chart. 04/02/2019 Instruct O. Koppany on research re BIS fines. Correspondence re same. 04/02/2019 Compiled chart with OFAC and BIS cases. 04/03/2019 Researched and compiled BlS/OFAC case chart. u’ 1: 9 Statement of Services Statement No. 7015 Date: 05/ 1 3/201 9 Due On: 05l28/201 9 Timokeepor Quantity Total Jaime Rosenberg 2.00 $430.00 Farhad Alavi 0.20 $120.00 Jaime Rosenberg 2.50 $537.50 Jaime Rosenberg 1.50 $322.50 04/03/2019 Assist F. Alavi with compiling compliance information from Oliver Koppany 0.60 $129.00 BIS and OFAC. 04/03/2019 Review work of J. Rosenberg and O. Koppany re BIS Teresa Taylor 0.70 $420.00 research chart re cases; review research re BIS cases and fines, elements. 04/04/2019 Emails with local counsel; review draft plea agreement; Teresa Taylor 0.90 $540.00 review emails with Phil. 04/08/2019 Research penalty case involving BIS and DOJ. Instruct J. Farhad Alavi 0.20 $120.00 Rodriguez re same. 04/08/2019 Review and analyze Rinko indictment, BIS settlement. Joyce Rodriguez 1.50 $487.50 and reIated press released. Draft summary analysis of Rinko case. Review emails from F. Alavi and T. Taylor re same. Page 1 of 4 Statement No. 701 5 - 05/1 3/201 9 04/08/201 9 Review work of J. Rodriguez and instruct further; review Teresa Taylor 2.20 $1 320.00 case law and draft re fines analysis and mitigating factors. 04/09/2019 Messages with L. Agre. Teresa Taylor 0.10 $60.00 04/1 0/2019 Messages with F. Alavi and client. Teresa Taylor 0.10 $60.00 04/1 0/201 9 Messages with F. Alavi. Farhad Alavi 0.20 $1 20.00 04/1 2/201 9 Messages with L. Agre. Teresa Taylor 0.1 0 $60.00 04/1 3/201 9 Messages with L. Agre. Teresa Taylor O. 1 0 $60.00 04/1 6/2019 Emails with local counsel re status of case and Teresa Taylor 0.50 $300.00 negotiations re plea agreement drafts; same with F. Alavi. 04/1 7/2019 Review regulations and plea agreement. Discuss with T. Farhad Alavi 0.40 $240.00 Taylor. Instruct J. Rosenberg and O. Koppany. 04/1 7/2019 Assist T. Taylor and F. Alavi with research regarding DOJ Oliver Koppany 1.10 $236.50 statutory penalties. 04/1 7/2019 Emails with local counsel, P. Kearney AUSA; review Teresa Taylor 1.00 $600.00 research and work of J. Rosenberg and O. Koppany re analysis for plea agreement and negotiations with BIS; discuss with F. Alavi; messages with L. Agre. 04/1 8/2019 Go through the IEEPA case chart and look for cases that Jaime Rosenberg 2.00 $430.00 have large fines to compare to. 04/1 8/2019 Review emails re all local counsel and AUSA; review new Teresa Taylor 1.50 $900.00 work of J. Rosenberg re BIS cases and fines comparison; prepare for strategy and next steps with BIS and DOJ; messages with L. Agre. 04/1 9/2019 Review emails with all local counsel and AUSA; review Teresa Taylor 0.90 $540.00 research and analysis re final plea agreement and negotiations with BIS and DOJ; messages with L. Agre. 04/20/2019 Review email from S. Moeel. Teresa Taylor 0.10 $60.00 04/22/201 9 Review emails with all local counsel and AUSA; review Teresa Taylor 0.50 $300.00 plea agreement and charts; Email to L. Agre. 04/23/2019 Review emails with local counsel and AUSA, and client. Teresa Taylor 0.30 $180.00 04/25/2019 Messages with F. Alavi and client. Teresa Taylor 0.10 $60.00 04/25/2019 Messages with T. Taylor. Farhad Alavi 0.20 $120.00 04/26/201 9 Discuss status and next steps with T. Taylor. Farhad Alavi 0.1 0 $60.00 04/26/2019 Discuss status and next steps with F. Alavi. 0.10 $60.00 04/29/2019 Review email from L. Agre. Teresa Taylor 0.1 O $60.00 04/30/2019 Emails with L. Agra and F. Alavi. Teresa Taylor 0.20 $120.00 Page 2 of 4 Time Keeper Farhad Alavi Joyce Rodriguez Teresa Taylor Oliver Koppany Jaime Rosenberg Interest Type Date Interest 05/29/201 9 Detailed Statement of Account Other Invoices Invoice Number 6865 Interest On Other Invoices Original Invoice 6865 6865 6865 Statement No. 7015 - 05/13/2019 Position Quantity Rate Partner 1.3 $600.00 Associate 1 .5 $325.00 Partner 9.4 $600.00 Law Clerk 1.7 $215.00 Law Clerk 8.0 $215.00 Subtotal Description Interest on overdue invoice #701 5 Interest Subtotal Subtotal Interest Total Duo On Amount Due Payments Received 04/1 7/2019 $1 05,498.92 $32,862.26 Due On Amount Due Payments Received 05/18/2019 $203.61 $0.00 06/1 7/201 9 $359.21 $0.00 07/1 7/201 9 $360.98 $0.00 Page 3 of 4 Total $780.00 $487.50 $5,640.00 $365.50 $1 ,720.00 $9,053.00 Total $22.32 $22.32 $9,053.00 $22.32 $9,075.32 Balance Duo $72,636.66 Balance Duo $203.61 $359.21 $360.98 Statement No. 7015 - 05/1 3/2019 Current Invoice Invoice Number Duo On Amount Duo Payments Received Balance Duo 701 5 05/28/2019 $9,075.32 $0.00 $9,075.32 Outstanding Balance $82,635.78 Total Amount Outstanding $82,635.78 Account Balance Citibank IOLTA Balance $0.00 Total Account Balance $0.00 Please make all amounts payable to Akrivis Law Group, PLLC Payment must be received within 15 days. 5% annual interest will be charged every 30 days. Page 4 of 4 I I i i L A W :i n a rIVISr‘ P L L C i t: c 6 Statement of Servnces Statement No. 7200 Date: 07/1 7/2019 Due On: 08/01/2019 Mr. Sadr Emad-Vaez Ms. Pouran Aazad 27333 Ursula Lane Los Altos Hills, California 94022 10346-Emad-Vaez Defense Matter Client Reference Number: 10346.0001 Services Date Notes Timekoeper Quantlty Ton! 05/02/2019 Review status with T. Taylor. Messages with S. Emad- Farhad Alavi 0.1 0 $60.00 Vaez. 05/03/2019 Conference call with T. Taylor and Sadr Emad-Vaez. Farhad Alavi 0.50 $300.00 05/03/2019 Review email from L. Agre re AUSA status re draft plea Teresa Taylor 0.50 $300.00 agreements; review draft plea agreements re edits. 05/06/2019 Review message by T. Taylor. Correspondence with L. Farhad Alavi 0.70 $420.00 Agre re plea agreement. Call with Lyn Agre to discuss sentencing and fine issues. Correspondence with T. Taylor. 05/06/2019 Follow-up on status and discuss with F. Alavi. review Teresa Tayior 1.30 $780.00 emails re L. Agre and F. Alavi. Review email from F. Alavi re call with L. Agre re settlement options and negotiations status, strategy for global resolution; research various plea options and review, devise proposals to government. 05/07/2019 Correspondence with Lyn Agre re plea. Review Farhad Alavi 0.20 $120.00 correspondence by AUSA re same. Page 1 of 6 05/07/201 9 05/08/201 9 05/08/201 9 05/09/201 9 05/1 0/201 9 05/1 0/201 9 05/1 1/2019 05/1 2/2019 05/1 2/2019 05/1 3/201 9 05/1 3/201 9 05/14l201 9 05/1 4/201 9 Discuss case with F. Alavi, strategize and assess resolution options. review cases files and draft agreements. emails with local counsel and F. Alavi. Emails with AUSA. P. Kearney. and L. Agre re plea status and outstanding issues. review draft agreements and global resolutions agreements; discuss with F. Alavi. Call with clients and T. Taylor. Call with clients. Discuss case with F. Alavi; review draft agreements. Review emails with Update Legal re client's outstanding document review matter and bill; discuss with F. Alavi. Discuss status of case and final agreements with government with clients and F. Alavi. Emails with L. Agre re court appearances and communications with AUSA re status and schedule. Review correspondence by Phil Kearney and T. Taylor. Emails and call with AUSA re plea status and trial. negotiations. options forward. draft plea agreements. and upcoming status conference; communication with client re settlement and pleas; edit plea agreements. Discuss plea and draft plea agreements with F. Alavi; review edits of F. Alavi; enter further edits; emails with AUSA. Review emails from AUSA. discuss fines range with F. Alavi and review research of cases and BIS regulations; review and edit responses to AUSA. Review correspondence by Phil Kearney. Messages with T. Taylor. Draft response and send. Review exchange with P. Kearney and L. Agre. Emails with AUSA, F. Alavi. and L. Agre re fines arguments. draft plea agreements, and final resolutions language, review all material, final edits, confirm with clients. Review correspondence by Lyn Agre. Discuss with T. Taylor. Emails with AUSA re further negotiations on plea agreements terms and fines, scheduling, and discuss strategy with F. Alavi; emails with L. Agre re scheduling. Messages with T. Taylor. Correspondence to Adrienne Frazier re proposed penalty. Review correspondence with clients. Review Plea Agreement seht by Phil Kearney. Discuss with T. Taylor. Call with Lyn Agre. Review emails with Update Legal; emails and call with AUSA and DOJ, NSD re negotiate fines and terms of plea agreements re global settlement including with BIS and for all defendants; call with clients and emails re plea agreements and negotiations and options; edit draft plea agreements, discuss with F. Alavi; emails with L. Agre; Page 2 of 6 Statement No. 7200 - 07/1 7/2019 Teresa Taylor Farhad Alavi Teresa Taylor Teresa Taylor Farhad Alavi Teresa Taylor Teresa Taylor Farhad Alavi Teresa Taylor Farhad Alavi Teresa Taylor Farhad Alavi Teresa Taylor 1.50 0.40 1.50 0.30 0.20 3.40 2.50 0.50 1.90 0.20 0.90 0.80 4.00 $900.00 $240.00 $900.00 $180.00 $12000 $2,040.00 $1 500.00 $300.00 $1,140.00 $120.00 $540.00 $480.00 $2,400.00 05/1 5/201 9 05/1 5/201 9 05/1 6/201 9 05l1 6/201 9 05/1 7/201 9 05/2 1 I20 1 9 05/21/2019 05/22/201 9 05/22/201 9 05/23/201 9 05/24/201 9 05/24/201 9 05/31/201 9 emails with BIS counsel re fines and terms of plea agreements with BIS and DOJ global settlements; calls again with clients; edit final plea agreements further; review all material and research. Discuss with T. Taylor. Review correspondence. Calls with client. Review all research and files and discuss with F. Alavi; Calls and emails with F. Alavi and counsel, BIS, and F. Alavi re civil fines and terms negotiations re civil plea agreements and global resolution; call and emails with AUSA and DOJ and DOJ. NSD. re criminal fines and terms global resolution and cn'minal plea agreements edits; communicate with clients re final agreements and terms; edit final edits to civil and criminal plea agreements and share with BIS and DOJ attorneys; emails and updates to L. Agre. Discuss with T. Taylor. Review emails by AUSA and Department of Commerce counsel. Continued negotiations with BIS and DOJ and F. Alavi re terms and fines amount for clients re civil and cn‘minal cases, and negotiation final fines re global resolution re Pouran's penalties in exchange for no incarceration; confirm with clients and local counsel; finalize civil and criminal plea agreements and enter final edits. Emails with L. Agre; emails with AUSA re change of plea hearings status and final plea agreements re global resolution and status; review all new court docket notifications and filings. Review email from T. Taylor with instructions and respond regarding same. Emails with L. Agre. Review email from T. Taylor and respond re same. Emails with BIS counsel re logistics of filing final plea agreements re ALJ re BIS civil case and global resolution; instruct staff and F. Alavi. Review and Check file for addresses to send to A. Frazier. Email to T. Taylor and F. Alavi re: mail and physical addresses. Follow up email regarding addresses to T. Taylor and F. Alavi. Review emails from F. Alavi and T. Taylor re addresses. Send email to A. Frazier with addresses. Emails with BIS counsel re civil case re follow-up re logistics re filing final plea agreement. Review email from T. Taylor; review email from A. Frazier. review messages from T. Taylor. draft Motion to Extend Page 3 of 6 Statement No. 7200 - 07/17/2019 Farhad Alavi Teresa Taylor Farhad Alavi Teresa Taylor Teresa Taylor Heather Duncan Teresa Taylor Heather Duncan Teresa Taytor Heather Duncan Heather Duncan Teresa Taylor Heather Duncan 0.50 $300.00 4.50 $2,700.00 0.50 $300.00 2.50 $1 500.00 0.60 $360.00 0.60 $171 .00 0.1 0 $60.00 0.50 $142.50 0.20 $120.00 0.10 $28.50 0.30 $85.50 0.10 $60.00 1.50 $427.50 Statement No. 7200 - 07/1 7/2019 Stay and send same to T. Taylor for review; Respond to emails from A. Frazier; finalize and file Motion to Extend Stay; draft correspondence to parties on Certificate of Service; review email from L. Muess re: Order granting stay. message T. Taylor re: same. 05/31/2019 Emails with BIS counsel re follow-up logistics re filings of Teresa Taylor 0.80 $480.00 final plea agreements with ALJ for clients. Instruct and review work of H. Duncan re Motion to Stay re ALJ re BIS case re draft and filing re request of BIS for approval of final plea agreements for ciients in civil BIS case. 06/07/2019 Emails with BIS counsel re civil matter final agreements Teresa Taylor 0.30 $180.00 and draft order for ALJ re final logistics and review. 06/1 0/2019 Review correspondence by A. Frazier. Correspondence Farhad Alavi 0.20 $120.00 with client. 06/1 3/201 9 Assign research to Walker Livingston. Emails and Farhad Alavi 0.30 $180.00 voicemails to client re Settlement Agreement. Messages with T. Taylor. 06/1 3/2019 Review email re F. Alavi to clients re follow~up re final Teresa Taylor 0.50 $300.00 agreements re BIS case. Review further emails with F. Alavi and BIS counsel re final logistics re BIS case and emails from clients; review signatures and emails from clients re final plea agreements to filed. 06I1 3/2019 Assist F. Alavi and T. Taylor on research. Draft. Walker Livingston 1.70 $365.50 06/1 4/2019 Review correspondence by Adrienne Frazier and T. Farhad Alavi 0.20 $120.00 Tayior. Sign BIS Settlement Agreement and send same to BIS. 06/14/2019 Review emails from BIS counsel and F. Alavi. Teresa Taonr 0.20 $120.00 06l1 7/2019 Correspondence with Adrienne Frazier and Update. Farhad Alavi 0.20 $120.00 Discuss with T. Taylor. 06/1 7/2019 Emails from BIS counsel and F. Alavi status of filing of Teresa Taylor 0.30 $180.00 final resolution plea agreements re BIS case. 07/01/2019 Review Order re case. Teresa Taylor 0.10 $60.00 07/1 7/2019 Follow-up with BIS counsel re Order withdrawing case. Teresa Taylor 0.10 $60.00 07/1 7/201 9 Review file. Review status wtih T. Taylor. Farhad Alavi 0.20 $1 20.00 Correspondence with Adrienne Frazier. Services Subtotal $21 500.50 Expenses Date Nob: Quanflty Rate Tohl Page 4 of 6 Statement No. 7200 - 07/1 7/2019 05/1 5/201 9 Document Preparation: Update Legal - Document hosting & 1.00 $30,407.14 $30,407.14 review services 05/31/2019 FedEx charges for sending BIS extension of time request. 1.00 $44.38 $44.38 05/31/201 9 Gather court records using Pacer. 1.00 $1 79. 1 0 $1 79. 1 0 Expenses Subtotal $30,630.82 Time Keep“ Posltlon Quantity Rate Total Farhad Alavi Partner 5.7 $600.00 $3,420.00 Teresa Taylor Partner 28.1 $600.00 $16,860.00 Heather Duncan Paralegal 3.0 $285.00 $855.00 Walker Livingston Law Clerk 1.7 $21 5.00 $365.50 Subtotal $52.1 31 .1 2 Interest Typo Date Ducflpflon Total Interest 08/02/201 9 Interest on overdue invoice #7200 $128.54 Interest Subtotal $128.54 Subtotal 352,1 31 .12 Interest $1 28.54 Total $52,259.66 Detailed Statement of Account Other Invoices Invoice Number Duo On Amount Duo Payments Received Balance Duo 6865 04/1 7/2019 $1 05,498.92 $32,862.26 572.636.66 7015 05/28/2019 $9,053.00 $0.00 $9,053.00 Page 5 of 6 Interest On Other Invoices Original Invoice 6865 6865 70 1 5 6865 761 5 6865 70 1 5 Current Invoice Invoice Number 7200 Citibank IOLTA Balance Due On 05/1 8/20 1 9 06/1 7/201 9 06/28/201 9 07/1 7/201 9 07I28/201 9 08/1 6/201 9 08/27/201 9 Duo On 08/01 /20 1 9 Amount Due $203.61 $359.21 $22.32 $360.98 $44.76 $362.76 $44.98 Amount Due $52,259.66 Account Please make all amounts payable to Akrivls Law Group, PLLC Statement No. 7200 - 07/17/2019 Payments Received $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Payments Rooslvod $0.00 Outstanding Balance Total Amount Outstandlng Total Account Balance Payment must be received within 15 days. 5% annual interest will be charged every 30 days. Page 6 of 6 Balance Due $203.61 $359.21 $22.32 $360.98 $44.76 $362.76 $44.98 Balance Due $52,259.66 $135,347.94 $1 35,347.94 Balance $0.00 $0.00
