United States v. Meelad Dezfooli
2:22-cr-00142-RFB-DJA
| D. Nev. | Jul 14, 2025Background
- Defendant Meelad Dezfooli was convicted by a jury of multiple counts of bank fraud, concealment money laundering, and conducting monetary transactions with criminally derived property.
- The property at issue, 176 Glen Falls Avenue in Henderson, Nevada, was purchased using proceeds from fraudulently obtained PPP loans and is held in the name of "Sanam Limited."
- The property is subject to criminal forfeiture as established in the superseding indictment and a preliminary order of forfeiture.
- The United States sought an interlocutory (pre-final judgment) sale of the property due to declining value, unpaid taxes, fees, and risks from squatters and deterioration.
- Dezfooli opposed the motion, arguing it was premature while his appeal was pending, but did not dispute the forfeiture status of the property.
- The Court granted the government’s motion, authorizing the sale by a court-designated real estate agent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the court allow an interlocutory sale of the property pending final forfeiture? | Property's equity is at risk due to financial burdens and decline in value, so immediate sale is necessary to preserve value. | Sale is premature; should wait until appellate process is complete and/or request for a stay is considered. | Motion granted: interlocutory sale is warranted to preserve equity. |
| Appointment of real estate agent for the sale | Court should designate Doug Sawyer as agent to comply with rules. | Defendant requests Juan Rubio as agent. | Doug Sawyer appointed, per supplemental rules. |
| Applicability of Supplemental Rule G(7) factors | Property meets multiple factors: excessive expense, risk of deterioration, etc. | Not directly contested. | Court finds all factors met. |
| Effect of pending appeal/stay on sale | No stay requested or granted; process should proceed. | Sale should be delayed pending any appeal/stay moot. | Appeal/stay not sufficient basis to deny motion. |
Key Cases Cited
- United States v. One Parcel of Real Prop. Described as Lot 41, Berryhill Farm Ests., 128 F.3d 1386 (10th Cir. 1997) (interlocutory sale of property is appropriate when subject to deterioration)
- United States v. Gianelli, 594 F. Supp. 2d 148 (D. Mass. 2009) (court may order interlocutory sale to preserve equity when mortgages, taxes, or insurance go unpaid)