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United States of America v. Ali Kashani and Yang Zhao

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


April 16, 2013

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
ALI KASHANI AND YANG ZHAO,
DEFENDANT.

The opinion of the court was delivered by: Paul Singh Grewal, Magistrate Judge OF The United States District Court For The Northern District OF California

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME PERIOD FOR ALI KASHANI TO LODGE THE PROPERTY PACKET WITH THE CLERK OF COURT

1. At the detention hearing on April 2, 2013, counsel for Defendant, ALI KASHANI informed the Court that the Property Packet for posting bond for ALI KASHANI would be 3 lodged with the Clerk of the Court by April 16, 2013.

2. ALI KASHANI has recorded the Deed of Trust and Assignment of Rents with the Santa Clara County Recorder that was necessary for posting the property bond. However, ALI KASHANI does not have a current preliminary title report showing the priority of the Deed of Trust and Assignment of Rents in favor of the Clerk of the District Court. 8

3. Due to difficulty in obtaining a current preliminary title report for the property pledged as bond in this case, the parties agree, subject to the court's approval, to extend the time 10 period for ALI KASHANI to lodge the Property Packet to the Clerk of the Court. 11

4. ALI KASHANI shall lodge the Property Packet with the Clerk of the United States District Court by May 9, 2013.

SO STIPULATED.

DATED: APRIL 12, 2013 BERLINER COHEN BY: /S/CHRISTIAN E. PICONE CHRISTIAN E. PICONE 9 KATHLEEN F. SHERMAN ATTORNEYS FOR DEFENDANT ALI KASHANI 10 11 DATED: APRIL 12, 2013 12 13 BY: /S/J B. EFFREY SCHENK JEFFREY B. SCHENK 14 ASSISTANT UNITED STATES ATTORNEY the court is extended to May 9, 2013.

All other conditions of ALI KASHANI's pretrial release 18 remain the same.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

The time period for ALI KASHANI to Lodge the property bond packet with the clerk of

20130416

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