United States v. Meelad Dezfooli
2:22-cr-00142-RFB-DJA
| D. Nev. | Jul 16, 2025Background
- Defendant Meelad Dezfooli was convicted by a jury of multiple counts of bank fraud, money laundering, and monetary transactions with unlawfully derived property related to fraudulent PPP (Paycheck Protection Program) loan applications.
- Dezfooli submitted materially false PPP loan applications to three banks, fraudulently securing $11,231,186.52 in loans across three companies he controlled.
- The court entered a preliminary order of forfeiture for specific vehicles and real properties per the jury’s special verdict, based on evidence the assets were traceable to the crimes.
- Documentary and testimonial evidence showed Dezfooli’s companies never employed the number of staff or paid the payroll stated in the applications; the applications included fictitious IRS forms and altered business documents.
- The government moved for a money judgment forfeiture in the same amount as the total fraudulent loan proceeds. Dezfooli opposed, raising several procedural and substantive objections.
- The court considered the legal standard for such forfeitures and entered a preliminary order for a personal money judgment equal to the proceeds, pending subsequent credits for sale of forfeited assets.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timing of forfeiture order | Preliminary order is needed before sentencing | Motion is premature due to pending motion for acquittal/sentencing | Granted for plaintiff; order is preliminary |
| Requirement of ancillary proceedings for property | No need for ancillary proceedings for a money judgment | Ancillary proceedings needed if unlisted property targeted for forfeiture | No ancillary needed for money judgment |
| Credits against money judgment | Credits after, not before, sale of forfeited property | Judgment should be reduced immediately by value of forfeited properties | Credits only after property sold |
| Stay pending appeal | No stay unless order is entered | Intends to move for stay if convictions appealed | Stay not addressed, order needed first |
Key Cases Cited
- United States v. Nejad, 933 F.3d 1162 (9th Cir. 2019) (upholding the entry of personal money judgments in criminal forfeiture cases)
- United States v. Lo, 839 F.3d 777 (9th Cir. 2016) (affirming forfeiture money judgment for proceeds of fraud)
- United States v. Casey, 444 F.3d 1071 (9th Cir. 2006) (forfeiture statutes require disgorgement of all criminal proceeds, even if already spent)
- United States v. Christensen, 828 F.3d 763 (9th Cir. 2016) (jury not required to decide amount of forfeiture money judgment)