and dedicated out of the jurisdiction of any explicit State or district of america,
FARHAD SHAKERI, CARLISLE RIVERA, a/ok/a “Pop,” and JONATHAN LOADHOLT, the
defendants, and others recognized and unknown, at the least certainly one of whom is anticipated to be first introduced
to and arrested within the Southern District of New York, knowingly and willfully did mix,
conspire, accomplice, and agree collectively and with one another to commit murder-for-hire, in
violation of Title 18, United States Code, Part 1958.
6. It was an element and an object of the conspiracy that FARHAD SHAKERI,
CARLISLE RIVERA, a/ok/a “Pop,” and JONATHAN LOADHOLT, and others recognized and
unknown, would and did knowingly journey in and trigger others to journey in interstate and overseas
commerce, and would and did use and trigger one other to make use of a facility of interstate and overseas
commerce, with intent {that a} homicide be dedicated in violation of the legal guidelines of the State of New
York or america as consideration for the receipt of and as consideration for a promise or
settlement to pay something of pecuniary worth, to wit, SHAKERI, RIVERA, and LOADHOLT
participated in an settlement whereby RIVERA and LOADHOLT would kill Sufferer-1 in trade
for cost, and used cellphones and digital messaging purposes to speak in
furtherance of the scheme.
(Title 18, United States Code, Sections 1958 and 3238.)
COUNT FIVE
(MONEY LAUNDERING CONSPIRACY)
7. From at the least in or about December 2023, as much as and together with the date of
this Criticism, in Iran, the Southern District of New York, and elsewhere, and in an offense begun
and dedicated out of the jurisdiction of any explicit State or district of america,
FARHAD SHAKERI, CARLISLE RIVERA, a/ok/a “Pop,” and JONATHAN LOADHOLT, the
defendants, and others recognized and unknown, at the least certainly one of whom is anticipated to be first introduced
to and arrested within the Southern District of New York, knowingly and willfully did mix,
conspire, accomplice, and agree collectively and with one another to commit cash laundering, in
violation of Title 18, United States Code, Part 1956.
8. It was additional an element and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/ok/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others recognized and unknown, in an offense involving and affecting interstate and overseas
commerce, realizing that the property concerned in sure monetary transactions represented the
proceeds of some type of illegal exercise, would and did conduct and try to conduct such
monetary transactions which in truth concerned the proceeds of specified illegal exercise, to wit,
the proceeds of the murder-for-hire offenses charged in Counts Three and 4 of this Criticism,
realizing that the transactions have been designed in complete and partially to hide and disguise the
nature, location, supply, possession, and management of the proceeds of stated specified illegal exercise,
in violation of Title 18, United States Code, Part 1956(a)(1)(B)(i).
9. It was additional an element and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/ok/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others recognized and unknown, would and did transport, transmit, and switch, and try to
transport, transmit, and switch, financial devices and funds to a spot in america
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