GOVERNMENT’S SENTENCING RECOMMENDATION
Based on a review of the § 3553(a) factors, the government recommends that
the Court impose sentence Jaberian to 2 years of probation.
Jaberian played a minor role in a complex securities fraud scheme. His coconspirators Mark Miller and Christopher Rajkaran were active penny stock traders
and promoters. They concocted and carried out a scheme to hijack and assume control
over shell companies and use their control to carry out a pump-and-dump scheme.
Jaberian aided and abetted this fraud scheme by allowing his co-conspirators to
appoint him as the “new” CEO of the Bell Buckle Holdings. This allowed his coconspirators to assume control of the company and issue fraudulent and misleading
public filings on behalf of the company.
Jaberian should have known better. Though he was not an active penny stock
promoter like Miller and Rajkaran, he knew his friends were up to no good. But he
went along with it, let them use his name and family story for their bogus press
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release, and took advantage of their efforts to profit from his own fraudulent stock
trading. It was mistake. And it was a crime. That being said, Jaberian’s role in the
scheme was limited. He did not participate in the fraudulent stock promotion. And
he did not participate in his co-conspirators efforts to hijack other companies.
Jaberian’s participation in the scheme lasted about two weeks in February
2018—more than five years ago. Outside of that period, Jaberian has otherwise lived
a productive and law-abiding life. In light of age of the conduct, and Jaberian’s limited
participation in the scheme, the government believes two years of probation is
sufficient, but not greater than necessary, to comply with the § 3553(a) factors.
