MICHAEL J. GARCIA 

United States Attorney for the 

Southern District of New York 

By: ANNA E. ARREOLA 

Assistant United States Attorney 

One St. Andrew's Plaza 

New York, New York 10007 

Tel. (212) 637-2218 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA, 

Plaintiff. 

ALL ASSETS OF ASA DRUGS, INCLUDING : STIPULATION AND DISMISSAL 

$207,644.00 IN UNITED STATES OF CLAIM OF 

CURRENCY ON DEPOSIT AT JP MORGAN : pUHAMbfADam 

m1 

CHASE, 

865; 

IN ACCOUNT NUMBER - 

: 07 Civ. 3587 (MGC) 

ALL ASSETS OF NASH PHARMACY, 

INCLUDING $1,492,892.00 IN UNITED 

STATES CURRENCY ON DEPOSIT AT JP 

MORGAN CHASE, IN ACCOUNT NUMBER 

4 365; and 

ALL ASSETS OF STAY SLIM PHARMACY, 

INCLUDING $128,534.00 IN UNITED 

STATES CURRENCY ON DEPOSIT AT JP 

MORGAN CHASE, IN ACCOUNT NUMBER = 

6 065, 

------------------ X 

SOBTA SHAHEEN, CLAIMANT 

WHEREAS, on May 4, 2007, the United States commenced 

this civil forfeiture action against the defendants-in-rem (the 

"Defendant Accounts"1 by the filing of a verified complaint; 

Case 1:07-cv-03587-MGC Document 14 Filed 08/14/2008 Page 1 of 4
WHEREAS, on or about July 6, 2007, Muhammad Nawaz Ahr?,ad 

("Claimant") filed a claim in this action asserting an interest 

in the Defendant Accounts: 

WHEREAS, on or about December 12, 2006, the Claimant, 

and others, were charged in a three-count Indictment, 06 Crim. 

1135 (JGKI, with conspiracy to pay illegal kickbacks, in 

violation of 18 U.S.C. § 371; conspiracy to commit health care 

fraud, in violation of 18 U.S.C. § 1349, and aggravated identity 

theft, in violation of 18 U.S.C. §§ 1028A and 2; 

WHEREAS, the Indictment contained a forfeiture 

allegation providing notice that the Government 13 seeking 

forfeiture, pursuant to 16 U.S.C. S 982(a) (7), of all property, 

real and personal, that constitutes or is derived from proceeds 

traceable to the commission of the offenses charged in the 

Indictment, including but not limited to the Defendant Accounts: 

WHEREAS, Claimant has entered into a plea agreement 

with the Government; and 

WHEREAS, under the terms of the plea agreement, 

Claimant has admitted the forfeiture allegations in the 

Indictment and agreed to forfeit all of his right, title and 

interest in the Defendant Accounts: 

IT IS HEREBY STIPULATED AND AGREED, by and between 

Plaintiff United States of America, by its attorney Assistant 

Case 1:07-cv-03587-MGC Document 14 Filed 08/14/2008 Page 2 of 4
United States Attorney Anna E. Arreola, and claimant Muhammad 

Nawaz Ahmad, that: 

1. Claimant Muha.md Nawaz Ahmad hereby withdraws his 

claim in this action, and said claim is hereby dismissed with 

prejudice. 

2. Claimant Muhammad Nawaz Ahmad is hereby barred 

from asserting, or assisting others in asserting, any claim 

against the United States of America ("USA"), the Department of 

Justice ("30J1'), the U.S. Attorney's Office for the Southern 

District of New York ("SDNY-USAO"], the Unlted States Marshals 

Service ("VSMS"), and the Federal Bureau of Znvestigations 

("FBI") or any agents and employees of the USA, the DOJ, the 

SDNY-USAO, the USMS, and the FBI, in connection with or arising 

out of the seizure, restraint, and/or constructive possession of 

the Defendant Account*, including, but not limited to, any claim 

that there was no probable cause to seize and/or forfeit the 

Defendant Accounts, that the Claimant is a prevailing party, or 

that the Claimant is entitled to attorney's fees or any award of 

interest. 

3. Claimant Muhammad Nawaz Ahmad hereby agrees to 

waive all rights to appeal or otherwise challenge or contest the 

validity of this Stipulation and Order. 

4. Each party shall bear its own costs and attorney's 

fees. 

Case 1:07-cv-03587-MGC Document 14 Filed 08/14/2008 Page 3 of 4
5. The signature pages of this stipulation may be 

executed in one or more counterparts, each of which will be 

deemed an original but all of which together will constitute one 

and the same instrument. 

Agreed and consented to: 

MICHAEL J. GARCIA 

United States Attorney for the 

Southern District of New York 

Attorney for Plaintiff 

By: && t.&L 

ANNA E. ARREOLA DATE 

Assistant United States Attorney 

One St. Andrew's Plaza 

New York, NY 10007 

(212) 637-2218 

~/LZ/O y 

DATE 

By: 

DATE 

Attorney for the Claimant 

27C Madison Avenue, Suite 1500 

New York, NY 10016 

(2121 349-5400 

70 ORDERED: 

slK*zBLE -a- 

- -- 

R V-A DATE 

UNITED STATES DISTRICT JUDGE +4 

Case 1:07-cv-03587-MGC Document 14 Filed 08/14/2008 Page 4 of 4