May 8, 2013
UNITED STATES OF AMERICA, Plaintiff,
ALI KASHANI and YANG ZHAO, Defendant.
ROSS ANDREW NABATOFF, FL STATE BAR NO. 0460230, (PRO HAC VICE) BRAND LAW GROUP, PC, WASHINGTON, DC, firstname.lastname@example.org CHRISTIAN E. PICONE, CA STATE BAR NO. 218275, KATHLEEN F. SHERMAN, CA STATE BAR NO. 241200 BERLINER COHEN, SAN JOSE, CALIFORNIA, email@example.com, firstname.lastname@example.org, Attorneys for Defendant ALI KASHANI.
SECOND STIPULATION AND [PROPOSED] ORDER EXTENDING TIME PERIOD FOR ALI KASHANI TO LODGE THE PROPERTY PACKET WITH THE CLERK OF COURT
PAUL SINGH GREWAL, Magistrate Judge.
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 lodged with the Clerk of the Court by April 16, 2013.
2. On April 10, 2013, ALI KASHANI recorded the Deed of Trust and Assignment of Rents with the Santa Clara County Recorder that was necessary for posting the property bond.
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).
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 entry was fixed; however the second entry appears to require the recording of a deed of reconveyance and substitution of trustee. ALI KASHANI has made the request to the interested 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
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.
The time period for ALI KASHANI to Lodge the property bond packet with the Clerk of the Court is extended to June 6, 2013. All other conditions of ALI KASHANI's pretrial release remain the same.
PURSUANT TO STIPULATION, IT IS SO ORDERED.