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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA ) 

 ) No. 20 CR 362

v. ) 

 ) Judge Jorge L. Alonso 

AHMAD al-SHAHMAN ) 

 

UNOPPOSED MOTION FOR BOND AND PRE-SENTENCE PAYMENT

The United States of America, by its attorney, John R. Lausch, Jr., United 

States Attorney for the Northern District of Illinois, pursuant to 28 U.S.C. '' 2041 

and 2042, moves this Court for an order directing the Clerk of the Court to accept a 

bond payment to be held pending resolution of this mater, and a pre-sentence 

payment toward the criminal financial obligations to be imposed in the abovecaptioned case, and in support state as follows:

1. The defendant has been charged via superseding indictment with one 

count of tax evasion, in violation of 26 U.S.C. § 7201 and two counts of failing to file 

a tax return, in violation of 26 U.S.C. § 4203 (R. #7). The parties anticipate that the 

defendant will plead guilty, pursuant to a written plea agreement, to tax evasion 

(Count Three) from the Netherlands where he is currently detained pending 

extradition. In order to facilitate the change of plea, the government will withdraw 

the extradition request and the defendant will plead guilty upon release by the Dutch 

authorities. In order to ensure that the defendant does not flee prior to his change of 

plea hearing, the defendant has agreed to post a $150,000 cash bond with the Clerk 

of the Court. The parties have agreed that, upon the filing of the Judgment and 

Case: 1:20-cr-00362 Document #: 19 Filed: 02/09/21 Page 1 of 3 PageID #:52
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Conviction Order, the cash bond will be returned to defendant’s counsel who will in 

turn return the bond to the defendant. 

2. In addition, pursuant to the written plea agreement, the defendant will 

submit his restitution payment to the Clerk of the Court prior to the change of plea 

hearing. 

3. Defendant has further agreed to pay the $100 special assessment prior 

to the change of plea hearing. 

4. Defendant or another representative party may submit payment by 

cash, cashier=s check, or money order made payable to the Clerk of the Court with 20 

CR 362 noted on each payment mailed or delivered to:

Clerk of the Court for the Northern District of Illinois

219 South Dearborn Street, 20th Floor

Chicago, Illinois 60604

5. Pursuant to 28 U.S.C. ' 2041, the defendant or another representative 

party are authorized to pay such funds into the Court Registry, and the Clerk of Court 

is authorized to accept and hold such funds until the time of sentencing. 

6. Further, pursuant to 28 U.S.C. ' 2042, the United States requests an 

order that upon the entry of a criminal judgment in this case, the Clerk of the Court 

is to withdraw and apply the deposited funds to the criminal financial obligations 

imposed against the defendant.

WHEREFORE, the United States moves this court for an order directing the 

Clerk of the Court to: 1) accept payment of a $150,000 cash bond from defendant or 

any other representative party, and to return the bond to counsel for defendant upon 

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entry of the Judgment and Conviction order; and 2) accept a restitution and special 

assessment payment from the defendant, or any other representative party, pending 

entry of the Judgment and Conviction order in this case, and thereafter to withdraw 

and apply the deposited funds to the defendant’s criminal financial obligation. 

Respectfully submitted,

JOHN R. LAUSCH, JR. 

United States Attorney

By: /s/ Barry Jonas

BARRY JONAS

 TIFFANY ARDAM

Assistant U.S. Attorneys

219 South Dearborn St., Rm. 500

Chicago, Illinois 60604

(312) 886-8027

Dated: February 9, 2021 

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