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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


May 8, 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

SECOND STIPULATION AND [PROPOSED] ORDER EXTENDING TIME 15 PERIOD FOR ALI KASHANI TO LODGE THE PROPERTY PACKET WITH THE 17 CLERK OF COURT 19

1. At the detention hearing on April 2, 2013, counsel for Defendant, ALI KASHANI 2 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. 4 2. On April 10, 2013, ALI KASHANI recorded the Deed of Trust and Assignment 5 of Rents with the Santa Clara County Recorder that was necessary for posting the property bond. 6 3. On April 16, 2013, this Court extended the time for ALI KASHAN to post the Property Packet with the Clerk of the Court (see docket no. 9). 8 4. On April 22, 2013, ALI KASHANI received a Preliminary Title Report for the Property Packet. The Preliminary Title Report had two entries that required modification. One 10 entry was fixed; however the second entry appears to require the recording of a deed of 11 reconveyance and substitution of trustee. ALI KASHANI has made the request to the interested 12 party to record a deed of reconveyance and substitution of trustee.

5. Therefore, ALI KASHANI requires a second extension to lodge the Property Packet with the Clerk of the United States District Court 15

6. The Parties stipulate that ALI KASHANI shall lodge the Property Packet with the

Clerk of the United States District Court by June 6, 2013. 3

SO STIPULATED.

DATED: MAY 7, 2013 BERLINER COHEN 6 7 BY: /S/CHRISTIAN E. PICONE CHRISTIAN E. PICONE 8 KATHLEEN F. SHERMAN ATTORNEYS FOR DEFENDANT ALI KASHANI 9 10 DATED: MAY 7, 2013 11 12 BY: / /JEFFREY B. S S CHENK JEFFREY B. SCHENK 13 ASSISTANT UNITED STATES ATTORNEY 14

ORDER

the Court is extended to June 6, 2013. All other conditions of ALI KASHANI's pretrial release 17 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

20130508

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