MICHAEL J. GARCIA 

United States Attorney for the 

Southern District of New York 

BY: ANNA E. ARREOLA 

Assistant United Statea Attorney 

one St. Andrew's Plaza 

New York, New York 10007 

Tel. (212) 637-2218 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YOM 

UNITED STATES OF AMERICh, 

Plaintiff , 

ALL ASSBTS OF ASA DRUGS, INCLUDING 

$207,644.00 IN UNITED STATES 

CURRENCY ON DEPOSIT AT JP MORGAN 

CKASE, 

865; 

IN ACCOUNT NUMBER - 

ALL ASSETS OF NASH PHARMRCY, 

INCLUDING $1,492,892.00 IN UNITED 

STATES CURRENCY ON DEPOSIT AT Je 

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, 

: STIPULATION AND DISMISSAL 

OF CLAIM OF SOBIA SHAHEZN 

: 07 Civ. 3587 (MGC) 

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

SOBIA SHAHEEN, CLAIMANT 

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

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

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

Case 1:07-cv-03587-MGC Document 13 Filed 08/14/2008 Page 1 of 4
WHEREAS, on or about July 6, 2007, Sobia Shaheen 

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

in the Defendant Accounts; 

WHEREAS, on or about December 12, 2006, Muhammad Ejaz 

Ahmad, Muhammad Nawaz Ahnad, and Mohanunad Tanveer were charged in 

a three-count Indictment, 06 Crim. 1135 (JGKI, with conspiracy to 

pay illegal kickbacks, in violation of 18 U.S.C. 5 371; 

conspiracy to commit health care fraud, in violation of 18 U.S.C. 

5 1349, and aggravated identity theft, in violation of 18 U.S.C. 

El l028A and 2; 

WHERERS, the Indictment contained a forfeiture 

allegation providing notice that the Government is seeking 

forfeiture, pursuant to 18 U.S.C. 5 982(a) (71, 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; 

WHERBAS, Claimant's husband, defendant Muhammad Ejaz 

Ahmad, has entered into a plea agreement with the Government; 

WHEREAS, under the tern of the plea agreement, 

defendant Muhammad Ejaz Ahmad has admitted the forfeiture 

allegation in the Indictment and agreed to forfeit to the United 

States all right, title and interest in the Defendant Accounts; 

WHEFC3AS, Claimant has agreed to withdraw her claim to 

the Defendant Accounts; 

Case 1:07-cv-03587-MGC Document 13 Filed 08/14/2008 Page 2 of 4
IT IS HEREBY STIPlJLATED AND AGREGD, by and between 

Plaintiff United States of Amrica, by it8 attorney Assistant 

United States Attorney Anna E. Arreola, and claimant Sobia 

Shaheen, that: 

1. Claimant Sobia Shaheen hereby withdraws her claim 

in this action, and said claim is hereby dismissed with 

prejudice. 

2. Claimant Sobia Shaheen is hereby barred from 

asserting, or assisting others in asserting, any claim against 

the United States of Rmerica ('USA"), the Department of Justice 

('DOJ'), the U.S. Attorney's Office for the Southern District of 

New York ("SDNY-USAO"), the United states Marshals Service 

('OSMSw), and the Federal Bureau of Investigations ("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 Accounts, including, but not limited to, any claim that 

there waa 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. Sobia Shaheen hereby agrees to waive all right6 to 

appeal or otherwise challenge or contest the validity of this 

Stipulation and Order. 

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

Case 1:07-cv-03587-MGC Document 13 Filed 08/14/2008 Page 3 of 4
fees . 

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: 

MIWL J. GARCIA 

United States Attorney for the 

Southern District of New York 

Attorney for Plaintiff 

By: &ALE. QA-Wh 

ANNA E. ARREOLA 

Aaaiatant United States Attorney 

One St. Andrew's Plaza 

New York, NY 10007 

(212) 637-2218 

s& 

SOBIA SHAHEEN 

By: 

&l ~roadwa~, Suite Gb 

New York, NY 10013 

(212) 925-8640 

SO ORDERED: /. 

DATE 

ar-- I DATE 

UNITED STATES DISTRICP JUDGE 

Case 1:07-cv-03587-MGC Document 13 Filed 08/14/2008 Page 4 of 4