U.S. V Menendez Et Al Indictment
U.S. V Menendez Et Al Indictment
WAEL HANA, a/k/a “Will Hana,” the defendant, an Egyptian-American businessman, among
others. Among other actions, MENENDEZ provided sensitive U.S. Government information
and took other steps that secretly aided the Government of Egypt. MENENDEZ also improperly
advised and pressured an official at the United States Department of Agriculture for the purpose
of protecting a business monopoly granted to HANA by Egypt and used in part to fund the bribes
and did use his influence and power and breach his official duty to seek to disrupt a criminal
investigation and prosecution undertaken by the New Jersey Attorney General’s Office related to
JOSE URIBE, the defendant, and his associates. Third, MENENDEZ promised to and did use
his influence and power and breach his official duty to recommend that the President nominate
an individual as U.S. Attorney for the District of New Jersey who MENENDEZ believed could
3. In or about June 2022, federal agents executed search warrants on the New Jersey
home and the safe deposit box of ROBERT MENENDEZ and NADINE MENENDEZ, a/k/a
“Nadine Arslanian,” the defendants. In conducting these court-authorized searches, agents found
certain of the fruits of MENENDEZ’s and NADINE MENENDEZ’s corrupt bribery agreement
with WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES, the defendants,
including cash, gold, the luxury vehicle, and home furnishings. Over $480,000 in cash—much
of it stuffed into envelopes and hidden in clothing, closets, and a safe—was discovered in the
home, along with over $70,000 in NADINE MENENDEZ’s safe deposit box. Some of the
envelopes contained the fingerprints and/or DNA of DAIBES or his driver. Other of the
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envelopes were found inside jackets bearing MENENDEZ’s name and hanging in his closet, as
depicted below.
During the same court-authorized search of the home, agents also found home furnishings
provided by HANA and DAIBES, the luxury vehicle paid for by URIBE parked in the garage, as
well as over one hundred thousand dollars’ worth of gold bars in the home, which were provided
by either HANA or DAIBES. Two of the gold bars DAIBES provided are depicted in the
photographs below.
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Relevant Individuals
Senator Robert Menendez and his Wife, Nadine Menendez, a/k/a “Nadine Arslanian”
4. ROBERT MENENDEZ, the defendant, is the senior U.S. Senator from the State
of New Jersey. MENENDEZ served as mayor of Union City, New Jersey, and a member of the
New Jersey state legislature until 1993, when he was elected to the U.S. House of
Representatives representing a New Jersey district. MENENDEZ was appointed to the U.S.
Senate in 2006, subsequently elected in 2006, and reelected in 2012 and 2018. At all times
relevant to this Indictment, MENENDEZ held a leadership position on the Senate Foreign
Relations Committee (the “SFRC”), first as the Ranking Member and then the Chairman, and
therefore possessed influence over, among other things, the Executive Branch’s decisions to
provide foreign military sales, foreign military financing, and other aid or support to or for the
benefit of the Government of Egypt. By virtue of his position as the senior U.S. Senator from
the State of New Jersey, at all times relevant to this Indictment, MENENDEZ had the ability to
recommend to the President that a particular individual be nominated to serve as the U.S.
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Attorney for the District of New Jersey. At all times relevant to this Indictment, the official
public website for MENENDEZ’s Senate office stated that his office could not take certain
actions, including actions to influence private business matters, and actions to intervene with
judicial issues and criminal trials, as detailed in the below excerpt from the website:
ROBERT MENENDEZ, the defendant, in or about early February 2018. They became engaged
in or about early October 2019, and married in or about early October 2020. Before NADINE
6. At all times relevant to this Indictment, WAEL HANA, a/k/a “Will Hana,” the
defendant, who is originally from Egypt, resided principally in New Jersey, and maintained close
connections with Egyptian officials. HANA and NADINE MENENDEZ, a/k/a “Nadine
Arslanian,” the defendant, were friends for many years before she began dating ROBERT
cellphone HANA used revealed thousands of text messages between HANA and NADINE
MENENDEZ, many of which NADINE MENENDEZ deleted from her own cellphone.
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7. JOSE URIBE, the defendant, is a businessman who resides in New Jersey and
works in the trucking and insurance business, after having previously been convicted of fraud
and having his insurance broker’s license revoked. URIBE is a business associate and friend of
WAEL HANA, a/k/a “Will Hana,” the defendant. URIBE developed a relationship with
ROBERT MENENDEZ and NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendants,
8. FRED DAIBES, the defendant, is a New Jersey real estate developer, a founder of
a New Jersey-based bank, and a business associate of WAEL HANA, a/k/a “Will Hana,” the
defendant. On or about October 30, 2018, DAIBES was charged by the United States Attorney’s
Office for the District of New Jersey with obtaining loans under false pretenses from that bank.
MENENDEZ Agrees to Take Actions that Benefit Egypt and HANA in Exchange for
Promises of Things of Value
defendant, informed WAEL HANA, a/k/a “Will Hana,” the defendant, that she was dating
ROBERT MENENDEZ, the defendant. In the following months and years, HANA and
MENENDEZ for the purpose of establishing and solidifying a corrupt agreement in which
HANA, with assistance from FRED DAIBES and JOSE URIBE, the defendants, provided
exchange for MENENDEZ’s acts and breaches of duty to benefit the Government of Egypt,
HANA, and others, including with respect to foreign military sales and foreign military
financing.
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Background on Foreign Military Sales and Foreign Military Financing
10. At all times relevant to this Indictment, Egypt was among the largest recipients in
the world of U.S. military aid. Between approximately 2018 and approximately 2022, the U.S.
Government supplied substantial military aid to Egypt, including in the form of grants of over $1
billion per year (“foreign military financing”), and in the form of direct government-to-
government sales of military equipment (“foreign military sales”), which Egypt typically paid for
with foreign military financing, and which the Executive Branch was required to notify Congress
about under certain circumstances prior to going forward with those sales. The U.S. Department
of State (the “State Department”) played a central role in reviewing and approving foreign
military sales to Egypt and obligating foreign military financing to Egypt, which was conditioned
voluntary practice, the State Department would typically honor so-called “holds” placed by the
Chairman or the Ranking Member of the SFRC on both foreign military financing and foreign
military sales. In other words, the State Department would typically not proceed with a transfer
of foreign military financing grant money to Egypt’s bank account (located at all relevant times
in Manhattan), or with a foreign military sale to Egypt, while the Chairman or the Ranking
Member of the SFRC had not signed off on, and was maintaining a “hold” on, such a transfer or
sale. As a result, at all times relevant to the Indictment, ROBERT MENENDEZ, the defendant,
as the Chairman or the Ranking Member of the SFRC, possessed substantial influence over
11. For at least several years prior to 2018, despite its strategically important
relationship with the U.S. and in the Middle East, Egypt had often faced resistance in obtaining
foreign military financing and foreign military sales. For example, in or about August 2017, the
State Department announced that it was withholding $195 million in foreign military financing
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until Egypt could demonstrate improvements on human rights and democracy, and was canceling
an additional $65.7 million in foreign military financing to Egypt. By in or about early 2018,
multiple U.S. Senators had raised human rights or rule-of-law objections to foreign military
financing to Egypt, and no foreign military sales of offensive military equipment to Egypt
requiring congressional notification had been concluded since in or about March 2016.
MENENDEZ, a/k/a “Nadine Arslanian,” the defendants, began dating, WAEL HANA, a/k/a
“Will Hana,” the defendant, and NADINE MENENDEZ arranged a series of meetings and
dinners with MENENDEZ—paid for by HANA or his associates—at which Egyptian officials
raised, among other things, requests related to foreign military sales and foreign military
MENENDEZ would, among other things, use his power and authority to facilitate such sales and
financing to Egypt, HANA promised, among other things, to put NADINE MENENDEZ on the
official (“Egyptian Official-1”) and other Egyptian military officials at a meeting arranged and
attended by his then-girlfriend NADINE MENENDEZ and her friend HANA. MENENDEZ
allowed NADINE MENENDEZ and HANA to arrange and participate in this meeting, which
took place at MENENDEZ’s Senate office in Washington, D.C. and included discussions of
foreign military financing to Egypt, among other topics, without the involvement of professional
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b. MENENDEZ and NADINE MENENDEZ again met with HANA on or
about May 6, 2018. Later that same day, MENENDEZ sought from the State Department non-
public information regarding the number and nationality of persons serving at the U.S. Embassy
in Cairo, Egypt. Although this information was not classified, it was deemed highly sensitive
government or if made public. Without telling his professional staff, SFRC staff, or the State
Department that he was doing so, on or about May 7, 2018, MENENDEZ texted that sensitive,
c. That same month, in or about May 2018, HANA hosted another dinner at
a high-end restaurant with MENENDEZ, during which MENENDEZ disclosed to HANA non-
public information about the United States’s provision of military aid to Egypt. Shortly after the
dinner, HANA texted Egyptian Official-1, “The ban on small arms and ammunition to Egypt has
been lifted. That means sales can begin. That will include sniper rifles among other articles.”
to MENENDEZ a request from an Egyptian official seeking assistance in editing and drafting a
letter lobbying other U.S. Senators to support U.S. aid to Egypt. NADINE MENENDEZ
explained that she wanted MENENDEZ to prepare the letter because HANA and an Egyptian
official, whom she referred to as the “General” in her communications with MENENDEZ, had
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edited and ghost-wrote the requested letter on behalf of Egypt seeking to convince other U.S.
Senators to release a hold on $300 million in aid to Egypt. MENENDEZ sent this ghost-written
letter to NADINE MENENDEZ from his personal email account. NADINE MENENDEZ
forwarded the ghost-written letter to HANA, facilitating HANA’s conveyance of the revised
draft back to Egyptian officials. Both MENENDEZ and NADINE MENENDEZ deleted the
13. In or about July 2018, ROBERT MENENDEZ, the defendant, met again with
Egyptian Official-1 and multiple other Egyptian military officials to discuss foreign military
financing and foreign military sales during a meeting that was arranged, scheduled, and attended
by NADINE MENENDEZ, a/k/a “Nadine Arslanian,” and WAEL HANA, a/k/a “Will Hana,”
the defendants. In advance of that meeting, the Egyptian Government, through HANA and
foreign policy goals and positions and setting forth Egypt’s requests for the approval of foreign
military financing and foreign military sales to Egypt. The next day, MENENDEZ texted
NADINE MENENDEZ:
Tell Will [HANA] I am going to sign off this sale to Egypt today.
Egypt: 46,000 120MM Target Practice Rounds and 10,000 Rounds
Tank Ammunition: $99 million
NOTE: These tank rounds are for tanks they have had for many
years. They are using these in the Sinai for the counter-terrorism
campaign.
NADINE MENENDEZ forwarded this text to HANA, who forwarded it to Egyptian Official-1
and Egyptian Official-2. Egyptian Official-1 replied with a “thumbs up” emoji.
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MENENDEZ Takes Action to Protect IS EG Halal
14. WAEL HANA, a/k/a “Will Hana,” the defendant, repeatedly promised NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” the defendant, payments, including through a low-or-
no-show job, from IS EG Halal Certified, Inc. (“IS EG Halal”), a New Jersey company that
HANA operated with financial support and backing from FRED DAIBES, the defendant, in
furtherance of the scheme. However, IS EG Halal had little to no revenue between in or about
2018 and in or about early 2019, and HANA did not deliver on his promises to make those
15. After several months of nonpayment following the initial March 2018 meeting
described in paragraph 12.a, above, NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the
defendant, complained to multiple associates of WAEL HANA, a/k/a “Will Hana,” the
defendant, about HANA’s failure to pay her, and caused at least one of them to believe that
ROBERT MENENDEZ, the defendant, would cease acting for HANA’s benefit and at his
request, including with respect to Egypt, unless HANA came through on his promises and paid
her. NADINE MENENDEZ also complained directly to MENENDEZ about HANA’s as-yet-
unfulfilled promises, writing, “I have been so upset all morning. Will left for Egypt yesterday
supposedly and now thinks he’s king of the world and has both countries wrapped around his
16. In or about the spring of 2019, the Government of Egypt granted IS EG Halal an
exclusive monopoly on the certification of U.S. food exports to Egypt as compliant with halal
standards, despite the fact that neither WAEL HANA, a/k/a “Will Hana,” the defendant, nor his
company, had experience with halal certification. Prior to this action, a number of other U.S.
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companies had been licensed to certify U.S. meat exports to Egypt for halal compliance for
years.
17. The monopoly for IS EG Halal allowed WAEL HANA, a/k/a “Will Hana,” the
government official informed HANA that IS EG Halal was likely to become Egypt’s sole halal
certifier for imports from the U.S. market. The next day, NADINE MENENDEZ texted
MENENDEZ, “Seems like halal went through. It might be a fantastic 2019 all the way around.”
18. In or about June 2019, after IS EG Halal obtained its monopoly, NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” the defendant, formed an entity titled Strategic
Jersey, with the assistance of ROBERT MENENDEZ, the defendant. The company was used to
receive bribe payments in furtherance of the crimes charged herein. When sending a relative
information about the formation of her company, NADINE MENENDEZ stated, by text
message, “every time I’m in a middle person for a deal I am asking to get paid and this is my
consulting company.”
19. The IS EG Halal monopoly advanced the scheme by, among other things,
providing a revenue stream from which WAEL HANA, a/k/a “Will Hana,” the defendant, could
make good on the bribe payments he had promised to ROBERT MENENDEZ, the defendant,
through NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendant. The monopoly also
resulted in increased costs for various U.S. meat suppliers and others. As a result, in or about
April and May 2019, multiple U.S. Government officials from the U.S. Department of
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Agriculture (“USDA”) contacted the Government of Egypt objecting to and seeking
reconsideration of its grant of monopoly rights to IS EG Halal, and the USDA prepared a public
report regarding the increased cost for halal certification and the likely disruption to the U.S.
a/k/a “Nadine Arslanian,” and WAEL HANA, a/k/a “Will Hana,” the defendants, met with an
Washington, D.C. During this meeting, the group discussed a human rights matter that had been
affecting aid to Egypt. In the same meeting, HANA also requested MENENDEZ’s assistance to
counter the USDA’s objections to IS EG Halal’s monopoly. Later that evening, the same
21. Over the next two days, on or about May 22 and 23, 2019, WAEL HANA, a/k/a
“Will Hana,” the defendant, provided NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the
monopoly, some of which HANA received from an Egyptian official. NADINE MENENDEZ
then texted certain of those materials to ROBERT MENENDEZ, the defendant, who later
deleted them.
22. On or about May 23, 2019, ROBERT MENENDEZ, the defendant, called a high-
level USDA official (“Official-1”) and insisted, in sum and substance, that the USDA stop
opposing IS EG Halal’s status as sole halal certifier. When Official-1 attempted to explain why
the monopoly was detrimental to U.S. interests, MENENDEZ reiterated his demand, in sum and
substance, that the USDA stop interfering with IS EG Halal’s monopoly. Official-1 did not
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IS EG Halal is Used to Fund Bribe Payments
23. After financially benefitting from IS EG Halal’s monopoly status as the sole halal
certifier, WAEL HANA, a/k/a “Will Hana,” the defendant, at times with the assistance of FRED
DAIBES and JOSE URIBE, the defendants, provided payments in furtherance of the scheme.
24. For example, in or about July 2019, after the mortgage company for the residence
proceedings, WAEL HANA, a/k/a “Will Hana,” the defendant, caused IS EG Halal to pay
approximately $23,000 to bring NADINE MENENDEZ’s mortgage current. HANA made this
payment following a series of discussions with NADINE MENENDEZ, as well as JOSE URIBE
and FRED DAIBES, the defendants, about various options for bringing the mortgage current.
When at one point URIBE responded to NADINE MENENDEZ that HANA might balk at the
amount required to bring the mortgage current, NADINE MENENDEZ replied, in part, “When I
feel comfortable and plan the trip to Egypt he [i.e., HANA] will be more powerful than the
president of Egypt.” Thereafter, URIBE and HANA worked to facilitate the payments, and
MENENDEZ continued taking actions to assist HANA and Egypt, including those discussed
below.
25. A few months later, in or about September 2019, NADINE MENENDEZ, a/k/a
“Nadine Arslanian,” the defendant, texted FRED DAIBES, the defendant, complaining that
HANA had not paid her what he owed her. DAIBES replied to NADINE MENENDEZ,
26. Several days later, NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the
defendant, texted ROBERT MENENDEZ, the defendant, to complain that WAEL HANA, a/k/a
“Will Hana,” and FRED DAIBES, the defendants, had not made payments, writing, “I am
soooooo upset,” stating that HANA had not left her an envelope, and remarking, “I thought Fred
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[DAIBES] would make sure it’s there and the second day in a row there is nothing.” NADINE
MENENDEZ also wrote, “I thought after everything that happened especially last Saturday and
that week [referring to meetings MENENDEZ had with senior Egyptian officials] that at least he
would honor his word one time I don’t know if I should text Fred [DAIBES] or wait what should
I do?” MENENDEZ responded, “No, you should not text or email.” Soon thereafter, NADINE
Business Consultants the next day, on or about September 28, 2019. In total, IS EG Halal issued
three $10,000 checks to Strategic International Business Consultants, dated August 30,
September 28, and November 5, 2019, which DAIBES helped provide or facilitate.
HANA and DAIBES Continue to Seek Action from MENENDEZ for Egypt
27. During the same period when IS EG Halal issued these checks, on or about
September 9, 2019, Egyptian Official-3 texted WAEL HANA, a/k/a “Will Hana,” the defendant,
that “[A State Department employee] told [an Egyptian diplomatic official] today that senator
Menendize [sic] put an [sic] hold on a billion $ of usaid to Egypt before the recess !!!!” and “Is
this true ?” HANA responded to Egyptian Official-3 that HANA would ask. HANA then
attempted to contact NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendant. Several
minutes later, HANA called FRED DAIBES, the defendant, via an encrypted messaging
program, and forwarded Egyptian Official-3’s text message to DAIBES. DAIBES promptly
called ROBERT MENENDEZ, the defendant, and then DAIBES called HANA back via the
same encrypted messaging program. Less than two minutes later, HANA texted Egyptian
Official-3, writing that it was not true and “he” (i.e., MENENDEZ) did not know anything about
28. Also in or about September 2019, ROBERT MENENDEZ, the defendant, offered
to provide his assistance to Egypt and to WAEL HANA, a/k/a “Will Hana,” the defendant,
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during an official trip to India. Following a dinner among HANA, MENENDEZ, and NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” the defendant, HANA texted Egyptian Official-3, “our
man [MENENDEZ] is traveling to India after two weeks and he is asking if there any message
we need or anything for ISEG?” Later that same month, MENENDEZ, HANA, and FRED
29. The meetings between ROBERT MENENDEZ and NADINE MENENDEZ, a/k/a
“Nadine Arslanian,” the defendants, and Egyptian officials, and the receipt of things of value by
actions favorable to Egypt and WAEL HANA, a/k/a “Will Hana,” the defendant, and others,
3, “anytime you need anything you have my number and we will make everything happen.” A
few days later she arranged for MENENDEZ to meet with Egyptian Official-3, whom NADINE
MENENDEZ referred to as “the general,” regarding negotiations between Egypt, Ethiopia, and
Sudan over a dam on the Nile River being built by Ethiopia, known as the Grand Ethiopian
Renaissance Dam (the “Dam”), which was generally regarded as one of the most important
foreign policy issues for Egypt. Within one month, in or about April 2020, MENENDEZ wrote
a letter to the then-Secretary of the Treasury and the then-Secretary of State regarding the Dam,
beginning the letter, “I am writing to express my concern about the stalled negotiations between
Egypt, Ethiopia, and Sudan over [the Dam],” and stating, “I therefore urge you to significantly
for dinner with Egyptian Official-3 and another Egyptian official (“Egyptian Official-4”) at a
restaurant in Edgewater, New Jersey. After this dinner, NADINE MENENDEZ and Egyptian
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Official-4 began texting with each other on an ongoing basis and had additional in-person
meetings, including a dinner they had in or about December 2020 with MENENDEZ and
Egyptian Official-3.
exercise machines and an air purifier, among other items, collectively worth thousands of dollars,
to be purchased online and delivered to the house of MENENDEZ and NADINE MENENDEZ.
4 organized a private meeting between MENENDEZ and a senior Egyptian intelligence official
Official-5 and other U.S. Senators the next day. On the day of the private meeting, MENENDEZ
provided NADINE MENENDEZ with a copy of a news article reporting on questions that other
U.S. Senators intended to ask Egyptian Official-5 regarding a human rights issue. NADINE
MENENDEZ then sent that article to Egyptian Official-4, who responded, “Thanks you so much,
chairman [i.e., MENENDEZ, the Chairman of the SFRC] also raised it today, we appreciate it.”
The next day, NADINE MENENDEZ texted Egyptian Official-4 that she hoped the article she
had sent was helpful, and stated, “I just thought it would be better to know ahead of time what is
being talked about and this way you can prepare your rebuttals.”
e. On or about June 23, 2021—i.e., two days after the private meeting
between MENENDEZ and Egyptian Official-5—HANA purchased 22 one-ounce gold bars, each
with a unique serial number. Two of these one-ounce gold bars were subsequently found during
the court-authorized search in June 2022 of the residence of MENENDEZ and NADINE
MENENDEZ. During the relevant time periods, the spot market price of gold was
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f. In or about the fall of 2021, NADINE MENENDEZ communicated
directly with Egyptian Official-4 to arrange a trip for MENENDEZ and NADINE MENENDEZ
to Egypt, which they took in or about October 2021. NADINE MENENDEZ and Egyptian
Official-4 originally planned the trip as an unofficial visit, and therefore without supervision
from the State Department. When an SFRC staffer contacted the U.S. Embassy in Cairo
regarding the trip, causing the planned trip to become a formal congressional delegation under
the supervision of the State Department, Egyptian Official-4 texted NADINE MENENDEZ “i
will probably loose [sic] my job” and “SOS”. NADINE MENENDEZ forwarded this text to
MENENDEZ. HANA was also in Egypt during MENENDEZ’s and NADINE MENENDEZ’s
trip, and they met for at least one dinner while there. During that trip, MENENDEZ and
NADINE MENENDEZ also met with multiple Egyptian officials, including for a private dinner
to a news article reporting on two pending foreign military sales to Egypt totaling approximately
$2.5 billion dollars. NADINE MENENDEZ forwarded this link to HANA, writing, “Bob had to
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sign off on this.”
30. In exchange for the promises and acts set forth above, WAEL HANA, a/k/a “Will
Hana,” and FRED DAIBES, the defendants, provided multiple things of value to ROBERT
MENENDEZ and NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendants, including
with the assistance of JOSE URIBE, the defendant. Those things of value included hundreds of
thousands of dollars in checks, cash, and gold, some of which was recovered during the June
described above. NADINE MENENDEZ caused some of the gold to be sold in Manhattan prior
to the search and deposited the proceeds into bank accounts she controlled.
31. In or about 2019, WAEL HANA, a/k/a “Will Hana,” and JOSE URIBE, the
defendants, offered and then helped to buy a new Mercedes-Benz C-300 convertible (the
“Mercedes-Benz Convertible”) worth more than $60,000 for NADINE MENENDEZ, a/k/a
agreed and sought to interfere in a New Jersey state criminal prosecution of an associate of
URIBE (the “New Jersey Defendant”) and a state criminal investigation involving an employee
of URIBE (the “New Jersey Investigative Subject”), whom URIBE referred to as a relative in
state prosecutor in the Office of the New Jersey Attorney General who supervised the
prosecution of the New Jersey Defendant and the investigation involving the New Jersey
Investigative Subject (“Official-2”) in an attempt, through advice and pressure, to cause Official-
2 to resolve these matters favorably to the New Jersey Defendant and the New Jersey
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Investigative Subject. Official-2 considered ROBERT MENENDEZ’s actions inappropriate and
32. The first matter that ROBERT MENENDEZ, the defendant, agreed to attempt to
influence concerned the New Jersey Defendant. The New Jersey Defendant was an associate of
JOSE URIBE, the defendant, and was charged with insurance fraud relating to a trucking
controlled by URIBE (the “Insurance Company”). The New Jersey Investigative Subject, an
employee of URIBE who worked at the Insurance Company and whom he referred to as a
relative, allegedly was involved in submitting the insurance applications at issue in the New
Jersey Defendant’s criminal case. URIBE was implicated in the conduct with which the New
Jersey Defendant was charged, and URIBE raised concerns about the case to WAEL HANA,
a/k/a “Will Hana,” the defendant, among others, writing in or about April 2018 about the case
33. NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendant, was involved in
a car accident in or about December 2018 that left her without a car. On multiple occasions up to
and including in or about January 2019, NADINE MENENDEZ sent text messages to WAEL
HANA, a/k/a “Will Hana,” the defendant, about her lack of a car.
MENENDEZ, a/k/a “Nadine Arslanian,” WAEL HANA, a/k/a “Will Hana,” and JOSE URIBE,
the defendants, agreed that MENENDEZ would attempt to intervene with Official-2 to influence
the prosecution of the New Jersey Defendant in exchange for a car. For example:
URIBE to a dinner with her and MENENDEZ. MENENDEZ, NADINE MENENDEZ, and
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HANA had the dinner on or about January 27 without URIBE, who could not attend because of a
scheduling conflict. After the dinner, HANA sent NADINE MENENDEZ a series of text
messages providing facts about the prosecution of the New Jersey Defendant. NADINE
b. On or about January 29, 2019—i.e., two days after the dinner described in
paragraph 34.a, above—MENENDEZ called Official-2 and spoke with him in an attempt,
through advice and pressure, to cause a resolution of the prosecution in the New Jersey
Defendant’s favor. In preparation for this call, MENENDEZ requested and received multiple
text messages from NADINE MENENDEZ about the New Jersey Defendant, including the
charges he was facing, which NADINE MENENDEZ, in turn, requested and received from
HANA. MENENDEZ and NADINE MENENDEZ both subsequently deleted these text
messages.
inappropriate influence in the case, Official-2 did not share with the prosecution team that
MENENDEZ had contacted him about the matter, and did not intervene in the matter.
Nonetheless, in or about April 2019, the New Jersey Defendant resolved his criminal prosecution
with a guilty plea pursuant to a plea agreement that recommended a non-incarceratory sentence.
This resolution was more favorable for the New Jersey Defendant than the prosecutors’ initial
35. After ROBERT MENENDEZ, the defendant, agreed to and did call Official-2
about the New Jersey Defendant’s case in or about January 2019, WAEL HANA, a/k/a “Will
Hana,” and JOSE URIBE, the defendants, worked to provide NADINE MENENDEZ, a/k/a
“Nadine Arslanian,” the defendant, with the Mercedes-Benz Convertible, as HANA had
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previously promised. Only a few days after MENENDEZ’s first call to Official-2, on or about
February 3, 2019, NADINE MENENDEZ texted HANA, “All is GREAT! I’m so excited to get a
car next week. !!” After some delays, URIBE ultimately facilitated NADINE MENENDEZ’s
spoke with him for over 21 minutes. After the call, URIBE texted NADINE MENENDEZ, “I
information for a Mercedes-Benz dealership in Edison, New Jersey. Over the next several days,
URIBE worked to put NADINE MENENDEZ in touch with a salesman at the car dealership.
Once at the dealership, NADINE MENENDEZ sent MENENDEZ photos of two different cars to
Benz car dealership salesperson that URIBE said she would be going to the dealership on April 5
to pick up the car. Later that day, URIBE texted an associate (“Associate-1”), a message roughly
translated from Spanish as, “I did everything on this side. I need 15k cash this afternoon.” Later
that day, NADINE MENENDEZ texted URIBE, “You are a miracle worker who makes dreams
voicemail saying that she was going “to meet Jose for five minutes” and then met URIBE in the
parking lot of a restaurant where URIBE provided NADINE MENENDEZ with approximately
$15,000 in cash.
Convertible, making a $15,000 down payment with a combination of cash, a credit card, and
22
several checks, and taking out an automotive loan to finance the remainder of the approximately
$60,000 purchase price. A number of the statements NADINE MENENDEZ made on the
application in order to secure the loan financing were false, including statements about her
employment and income. After the purchase was complete, NADINE MENENDEZ messaged
MENENDEZ, “Congratulations mon amour de la vie, we are the proud owners of a 2019
Mercedes.�.” Later that day, after URIBE asked her, “are you happy?,” NADINE
MENENDEZ responded, “I will never forget this.” NADINE MENENDEZ later texted
Mercedes Benz Convertible, URIBE subsequently caused monthly financing payments to be paid
for the car, which were routed either through one of his business associates or through a
company he controlled. In order to make the initial payments, in or about early May 2019,
URIBE asked a business associate of his (“Associate-2”) to make a payment for the Mercedes-
23
Benz Convertible from Associate-2’s corporate bank account, which had previously been opened
at a bank branch in the Bronx. URIBE explained to Associate-2, in making this request, that he
did not want his own name to be associated with the payment. URIBE and Associate-2 manually
made each periodic payment from in or about May 2019 through in or about October 2019,
either from Associate-2’s bank account or from an account owned by a trucking company
36. In or about late July 2019, a New Jersey detective sought to interview the New
Jersey Investigative Subject in a criminal investigation related to the prosecution of the New
MENENDEZ, a/k/a “Nadine Arslanian,” and JOSE URIBE, the defendants, agreed that
MENENDEZ and met with her on or about the evening of July 31, 2019. The next morning,
URIBE sent NADINE MENENDEZ a series of texts saying that he did not want anyone to
“bother” the New Jersey Investigative Subject (who as discussed above in paragraph 31 was an
insurance broker at the Insurance Company he controlled), and also saying that “[w]e need to
make things go away,” “[w]e need to move fast,” and “[w]e can still stop this.” That day,
NADINE MENENDEZ wrote to URIBE, among other things, that she would “address it first
thing tomorrow morning or tonight depending on when he [i.e., MENENDEZ] is home,” and
adding, “he will be home first thing tomorrow I will address it first thing tomorrow and have the
phone calls go out.” Later that day, MENENDEZ performed a Google search for the initials of
the state agency employing the insurance fraud investigator who was seeking to interview the
New Jersey Investigative Subject. A few days later NADINE MENENDEZ texted URIBE that
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MENENDEZ had commented about URIBE’s two requests related to these criminal matters, that
making the periodic payments for the Mercedes-Benz Convertible for several months—texted
NADINE MENENDEZ, “Please don’t forget about me. I will never forget about you” and “I
need peace.” The next day, on or about September 4, 2019, MENENDEZ called Official-2 to
schedule an in-person meeting with Official-2 for September 6, 2019, at MENENDEZ’s Senate
office in Newark, New Jersey. The day after that call—i.e., September 5, 2019—URIBE,
MENENDEZ’s Senate office in Newark, New Jersey in an attempt, through advice and pressure,
to cause Official-2 to favorably resolve the investigation involving the New Jersey Investigative
Subject. After the meeting, MENENDEZ met with URIBE at MENENDEZ’s apartment.
URIBE thereafter texted another business associate of his (“Associate-3”) that the meeting
between MENENDEZ and Official-2 had been a “good meeting” and that—while nothing was
final, to URIBE’s understanding—MENENDEZ had informed URIBE that the meeting with
d. Over the next several weeks following the September 6, 2019 meeting
between MENENDEZ and Official-2, URIBE repeatedly texted NADINE MENENDEZ asking
MENENDEZ, “I always text you on Monday in case you have an update. I just need peace.”—
MENENDEZ called URIBE from his Senate office in Washington, D.C. Within minutes of
getting off the phone, URIBE texted NADINE MENENDEZ, writing, “I just got a call and I am
25
a very happy person.” and “GOD bless you and him for ever.” Several nights later,
MENENDEZ, NADINE MENENDEZ, URIBE, and Associate-3 met for a celebratory dinner
from MENENDEZ and meeting for the celebratory champagne dinner—URIBE texted NADINE
MENENDEZ asking for information that would allow him to set up automatic payments for the
payments, URIBE texted NADINE MENENDEZ again, writing, “I have so much peace.
Benz Convertible. Together with the payments URIBE caused Associate-2 to make for the
26
Mercedes-Benz Convertible, URIBE caused more than $30,000 to be paid for the purchase of the
car, not including the cash URIBE had provided in a parking lot to NADINE MENENDEZ to
NADINE MENENDEZ, a/k/a “Nadine Arslanian,” and JOSE URIBE, the defendants, and
places. After those approaches, URIBE ceased making payments on the Mercedes-Benz
Convertible, and later that year, MENENDEZ wrote NADINE MENENDEZ a check for
$23,000, and NADINE MENENDEZ wrote URIBE a check for $21,000 with a memo line
38. From at least in or about December 2020 to at least in or about early 2022,
ROBERT MENENDEZ, the defendant, agreed to attempt to influence and attempted to influence
the pending federal prosecution of FRED DAIBES, the defendant, in exchange for cash,
furniture, and gold bars that DAIBES provided to MENENDEZ and NADINE MENENDEZ,
a/k/a “Nadine Arslanian,” the defendant, including by recommending that the President nominate
a candidate for U.S Attorney for the District of New Jersey who MENENDEZ believed could be
influenced by MENENDEZ with respect to DAIBES’s case, and by attempting to influence the
U.S. Attorney’s Office for the District of New Jersey to act favorably in DAIBES’s case.
39. In or about December 2020, ROBERT MENENDEZ, the defendant, met with an
individual who would later be nominated to be the U.S. Attorney for the District of New Jersey
(referred to herein as the “Candidate” or “Official-3,” the latter after Official-3’s Senate
confirmation). At the time of the meeting, the Candidate was an attorney in private practice, and
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the purpose of his meeting with MENENDEZ was to consider a potential candidacy for U.S.
Attorney in New Jersey. In that meeting, MENENDEZ criticized the U.S. Attorney’s Office for
the District of New Jersey’s prosecution of FRED DAIBES, the defendant, and said that he
hoped that the Candidate would look into DAIBES’s case if the Candidate became the U.S.
Attorney. MENENDEZ did not mention any other case in the meeting. After the meeting, the
Candidate informed MENENDEZ that he might have to recuse himself from the DAIBES
MENENDEZ subsequently informed the Candidate that MENENDEZ would not put forward the
Candidate’s name to the White House for a recommendation to be nominated by the President
for the position of U.S. Attorney. MENENDEZ also told the Candidate that MENENDEZ would
different individual for U.S. Attorney. FRED DAIBES, the defendant, believed that different
individual would likely be sympathetic to him. In or about the spring of 2021, a series of news
41. During that time period, in or about the spring of 2021, an individual (the
“Advisor”) associated with ROBERT MENENDEZ, the defendant, spoke to the Candidate and
discussed, among other things, the possibility of the Candidate recusing from the prosecution of
FRED DAIBES, the defendant. Subsequently, the Advisor informed MENENDEZ that the
Advisor believed that the Candidate would likely not have to recuse from the prosecution of
recommendation of the Candidate, the Advisor texted MENENDEZ, “I think if you call [the
28
42. On or about October 17, 2021, ROBERT MENENDEZ and NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” the defendants, returned from Egypt as described in
paragraph 29.f, landing at John F. Kennedy International Airport. Upon their arrival, a driver for
FRED DAIBES, the defendant (“DAIBES’s Driver”), picked up MENENDEZ and NADINE
MENENDEZ from the airport and drove them to their home in New Jersey. The next day,
MENENDEZ performed a web search for “how much is one kilo of gold worth.” As discussed
herein, multiple gold bars provided by DAIBES were found during the court-authorized June
43. Following the events set forth in paragraph 41, ROBERT MENENDEZ, the
defendant, recommended to the President that the Candidate be nominated for the position of
U.S. Attorney for the District of New Jersey, and the Candidate was nominated by the President,
confirmed by the Senate, and sworn in as U.S. Attorney in or about December 2021 (hereinafter,
Official-3).
44. Shortly after the swearing in, on the basis of information that Official-3 provided
to the U.S. Department of Justice to determine whether a recusal was warranted, Official-3 was
informed that Official-3 was recused from the prosecution of FRED DAIBES, the defendant.
Official-3 and the U.S. Attorney’s Office for the District of New Jersey implemented that
recusal. After Official-3 became the U.S. Attorney, the following events took place, among
others:
previously been scheduled for January 2022, was adjourned for reasons related to the COVID-19
pandemic. Later that day, DAIBES texted NADINE MENENDEZ, a/k/a “Nadine Arslanian,”
the defendant, and asked how ROBERT MENENDEZ, the defendant, who had recently
sustained a shoulder injury, was doing. NADINE MENENDEZ responded that MENENDEZ
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was doing better having heard that the trial date was adjourned, and that MENENDEZ was
“FIXATED on it.” DAIBES responded, “Good I don’t want him to be upset over it. This is not
his fault he was amazing in all he did he’s an amazing friend and as loyal as they come. How is
the shoulder is he sleeping. Let me know if I can get him a recliner it helped me sleep.”
the identity of Official-3’s First Assistant U.S. Attorney (“Official-4”). As a result of Official-
3’s recusal, Official-4 had supervisory responsibility over the prosecution of DAIBES.
DAIBES’s lawyer to complain that the lawyer had not been aggressive enough in attempting to
calls with NADINE MENENDEZ. NADINE MENENDEZ then texted DAIBES, writing,
“Thank you. Christmas in January.” DAIBES’s Driver’s fingerprints were later found on an
envelope containing thousands of dollars of cash recovered from the residence of MENENDEZ
and NADINE MENENDEZ in New Jersey. This envelope also bore DAIBES’s DNA and was
marked with DAIBES’s return address. In or about the early afternoon of January 24, 2022—
i.e., approximately two hours after NADINE MENENDEZ had texted DAIBES thanking him
approximately 15 seconds. This was MENENDEZ’s first phone call to Official-4. On or about
January 29, 2022—i.e., several days after NADINE MENENDEZ had texted DAIBES, thanking
him and writing “Christmas in January”—MENENDEZ performed a Google search for “kilo of
gold price.”
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e. On or about January 31, 2022, MENENDEZ again called Official-4, in a
call lasting for approximately one minute and 24 seconds. Within minutes of the end of his call
MENENDEZ directed the Advisor to ask Official-3, who was at the time the U.S. Attorney for
the District of New Jersey, why he had recused himself from the prosecution of DAIBES, when
MENENDEZ had previously believed that he would not recuse himself. The Advisor declined
to do so.
that he was planning to have lunch with Official-3. MENENDEZ told the Advisor, in sum and
substance, that he was frustrated with the way the U.S. Attorney’s Office was handling the
prosecution of DAIBES, and further told the Advisor to tell Official-3 to give DAIBES “all due
process,” notwithstanding that, as MENENDEZ knew, Official-3 was recused from the matter.
The Advisor had the lunch with Official-3, but did not pass on the message from MENENDEZ.
h. On or about March 30, 2022, NADINE MENENDEZ met for lunch with
DAIBES. Following the lunch, NADINE MENENDEZ texted DAIBES, “THANK YOU Fred
����.” The next day, NADINE MENENDEZ met with a jeweler (the “Jeweler”), who
was friends with DAIBES and WAEL HANA, a/k/a “Will Hana,” the defendant, and texted with
DAIBES about the fact that she was meeting the Jeweler. At that meeting, NADINE
MENENDEZ provided the Jeweler two one-kilogram gold bars to be sold. At that time, the spot
market price for gold was over $60,000 per kilogram. NADINE MENENDEZ falsely told the
Jeweler, in sum and substance, that the gold came from her mother. A court-authorized search of
NADINE MENENDEZ’s phone later found a photograph, taken the day of NADINE
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MENENDEZ’s meeting with the Jeweler, of two one-kilogram gold bars marked with serial
numbers indicating they had previously been possessed by DAIBES. A portion of this
photograph is below:
45. Official-3 and Official-4 did not pass on to the prosecution team the fact that
ROBERT MENENDEZ, the defendant, had contacted them as described in the above
paragraphs, and they did not treat the case differently as a result of the above-described contacts.
In or about April 2022, FRED DAIBES, the defendant, pled guilty pursuant to a plea agreement
46. As noted above, in or about June 2022, a court-authorized search of the residence
defendants, revealed, among other things, approximately two one-kilogram gold bars and nine
one-ounce gold bars that had serial numbers indicating they had previously been possessed by
FRED DAIBES, the defendant. The search also revealed that the residence contained, among
other things, hundreds of thousands of dollars of cash, including approximately ten envelopes of
cash, with tens of thousands of dollars, bearing the fingerprints and/or DNA of DAIBES. One of
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those envelopes also bore, in addition to the fingerprints of DAIBES, the fingerprints of
MENENDEZ.
47. At all times relevant to this Indictment, ROBERT MENENDEZ, the defendant,
was required as a U.S. Senator to file annual financial disclosure forms listing, among other
things, income received by him or his spouse in each calendar year. At all times relevant to this
Indictment, MENENDEZ did not disclose, among other things, the receipt of any payments
towards the Mercedes-Benz Convertible for the benefit of him or of NADINE MENENDEZ,
a/k/a “Nadine Arslanian,” the defendant, or the receipt of any cash or gold bars by him or by
COUNT ONE
(Conspiracy to Commit Bribery)
(As to All Defendants)
48. The allegations contained in paragraphs one through 47 of this Indictment are
49. From at least in or about January 2018 through at least in or about June 2022, in the
Southern District of New York and elsewhere, ROBERT MENENDEZ, NADINE MENENDEZ,
a/k/a “Nadine Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES,
the defendants, and others known and unknown, willfully and knowingly combined, conspired,
confederated, and agreed together and with each other to commit bribery of a federal employee, in
violation of Title 18, United States Code, Sections 201(b)(1)(A) and (C) and (b)(2)(A) and (C).
50. It was a part and an object of the conspiracy that ROBERT MENENDEZ, the
defendant, and others known and unknown, being a public official, directly and indirectly, would
and did corruptly demand, seek, receive, accept, and agree to receive and accept something of
value personally and for another person and entity, in return for being influenced in the
33
performance of an official act and for being induced to do an act and omit to do an act in violation
of his official duty, in violation of Title 18, United States Code, Section 201(b)(2)(A) and (C).
51. It was further a part and an object of the conspiracy that NADINE MENENDEZ,
a/k/a “Nadine Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES,
the defendants, and others known and unknown, directly and indirectly, would and did corruptly
give, offer, and promise something of value to a public official, and offer and promise a public
official to give something of value to another person and entity, with intent to influence an official
act and to induce such public official to do an act and omit to do an act in violation of the lawful
duty of such official, in violation of Title 18, United States Code, Section 201(b)(1)(A) and (C).
Overt Acts
52. In furtherance of the conspiracy and to effect its illegal objects, the following overt
acts, among others, were committed and caused to be committed in the Southern District of New
MENENDEZ, a/k/a “Nadine Arslanian,” and WAEL HANA, a/k/a “Will Hana,” the defendants,
2 to make a payment from a corporate bank account that had been opened at a bank branch in the
Bronx.
34
e. On or about March 31, 2022, NADINE MENENDEZ provided to a jeweler
two one-kilogram gold bars that had been provided by DAIBES, which gold bars were sold in
Manhattan.
COUNT TWO
(Conspiracy to Commit Honest Services Fraud)
(As to All Defendants)
53. The allegations contained in paragraphs one through 47 of this Indictment are
54. From at least in or about January 2018 through at least in or about June 2022, in the
Southern District of New York and elsewhere, ROBERT MENENDEZ, NADINE MENENDEZ,
a/k/a “Nadine Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES,
the defendants, and others known and unknown, willfully and knowingly combined, conspired,
confederated, and agreed together and with each other to commit honest services wire fraud, in
violation of Title 18, United States Code, Sections 1343 and 1346.
55. It was a part and an object of the conspiracy that ROBERT MENENDEZ, NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and
FRED DAIBES, the defendants, and others known and unknown, having devised and intending to
devise a scheme and artifice to defraud, and to deprive the public of its intangible right to ROBERT
MENENDEZ’s honest services as a U.S. Senator and the Chairman and Ranking Member of the
SFRC, would and did transmit and cause to be transmitted by means of wire, radio, and television
communication in interstate and foreign commerce, writings, signs, signals, pictures, and sounds
35
for the purpose of executing such scheme and artifice, in violation of Title 18, United States Code,
COUNT THREE
(Conspiracy to Commit Extortion Under Color of Official Right)
(As to ROBERT MENENDEZ and NADINE MENENDEZ)
56. The allegations contained in paragraphs one through 47 of this Indictment are
57. From at least in or about January 2018 through at least in or about June 2022, in the
Southern District of New York and elsewhere, ROBERT MENENDEZ and NADINE
MENENDEZ, a/k/a “Nadine Arslanian,” the defendants, and others known and unknown, willfully
and knowingly combined, conspired, confederated, and agreed together and with each other to
commit extortion under color of official right, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), and thereby would and did obstruct, delay, and affect commerce and
the movement of articles and commodities in commerce, as that term is defined in Title 18, United
FORFEITURE ALLEGATIONS
58. As a result of committing one or more of the offenses alleged in Counts One and
Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES, the
defendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any and all property, real and
personal, that constitutes or is derived from proceeds traceable to the commission of said offenses,
36
including but not limited to a sum of money in United States currency representing the amount of
proceeds traceable to the commission of said offenses and the following specific property:
number WDDWK8EB7KF873859.
d. A sum of $79,760 in U.S. currency seized from safe deposit box no. 13 at
Chase Bank located at 50 Grand Avenue, Englewood, NJ 07631 on or about June 16, 2022.
e. Two one-kilogram gold bars seized from the Englewood Cliffs Premises on
f. Eleven one-ounce gold bars seized from the Englewood Cliffs Premises on
g. Any and all funds on deposit in an account with an account number ending
in 8817, held in the name of Strategic International Business Consultants, LLC, at PNC Bank.
59. As a result of committing the offense alleged in Count Three of this Indictment,
ROBERT MENENDEZ and NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendants,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C)
and Title 28, United States Code, Section 2461(c), any and all property, real and personal, that
constitutes or is derived from proceeds traceable to the commission of said offense, including but
not limited to a sum of money in United States currency representing the amount of proceeds
traceable to the commission of said offense and the following specific property:
37
b. A 2019 Mercedes-Benz C-Class C300 automobile, vehicle identification
number WDDWK8EB7KF873859.
d. A sum of $79,760 in U.S. currency seized from safe deposit box no. 13 at
Chase Bank located at 50 Grand Avenue, Englewood, NJ 07631 on or about June 16, 2022.
e. Two one-kilogram gold bars seized from the Englewood Cliffs Premises on
f. Eleven one-ounce gold bars seized from the Englewood Cliffs Premises on
g. Any and all funds on deposit in an account with an account number ending
in 8817, held in the name of Strategic International Business Consultants, LLC, at PNC Bank.
60. If any of the property described above as being subject to forfeiture, as a result of
Arslanian,” WAEL HANA, a/k/a “Will Hana,” JOSE URIBE, and FRED DAIBES, the
defendants:
e. has been commingled with other property which cannot be subdivided without
difficulty;
38
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), and
Title 28, United States Code, Section 2461, to seek forfeiture of any other property of the
(Title 18, United States Code, Section 981; Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)
})(J,}l'AA~ vJ \UA'~
DAMIAN WILLIAMS
United States Attorney
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