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Case 1:23-cr-00490-SHS Document 65 Filed 10/12/23 Page 18 of 44

IS EG Halal is Used to Fund Bribe Payments

31. 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.

32. For example, in or about July 2019, after the mortgage company for the residence of NADINE MENENDEZ, a/k/a “Nadine Arslanian,” the defendant, initiated foreclosure 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 ROBERT MENENDEZ, the defendant, continued taking actions to assist HANA and Egypt, including those discussed below.

33.

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 WAEL HANA, a/k/a “Will Hana,” the defendant, had not paid her what he owed her. DAIBES replied to NADINE MENENDEZ, “Nadine I personally gave Bob a check for September.”

34. 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 s000000 upset,” stating that HANA had not left her an envelope, and remarking, “I thought Fred

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