United States v. 2018 Maserati Gran Turismo, License Number 8EOX182, VIN: ZAM45VLA3J0253945 et al

Filing 12

STIPULATION and ORDER extending Time for filing a complaint for forfeiture and/or to obtain an Indictment alleging forfeiture signed by Chief District Judge Kimberly J. Mueller on 5/13/2024. (Filing Deadline: 10/25/2024). (Lundstrom, T)

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PHILLIP A. TALBERT
United States Attorney
KEVIN C. KHASIGIAN
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

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Attorneys for the United States

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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

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Plaintiff,

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v.
2018 MASERATI GRAN TURISMO,
LICENSE NUMBER 8EOX182, VIN:
ZAM45VLA3J02539451,

Case No. 1:23-MC-00086-NODJ
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $68,119.88 SEIZED
FROM E*TRADE ACCOUNT NUMBER
5147-0717, HELD IN THE NAME OF
VIKEN YEPREMIAN, and
APPROXIMATELY $71,207.76 SEIZED
FROM GOLDMAN SACHS, MARCUS
ONLINE SAVINGS ACCOUNT NUMBER
300007772619, HELD IN THE NAME OF
VIKEN YEPREMIAN,
Defendants.

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It is hereby stipulated by and between the United States of America, potential claimants Viken

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25 Yepremian and Sonia Yepremian (“Viken” and “Sonia”), by and through their respective counsel, and
26 potential claimant and Mardig Yepremian (“Mardig”), appearing in propria persona (collectively
27 “claimants”) as follows:
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This asset was returned to Viken and Mardig Yepremian in exchange for $50,250.00 and is the substitutes res.

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Stipulation and Order to Extend Time

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1.

On or about June 6, 2023, claimants Viken and Sonia filed claims in the administrative

2 forfeiture proceeding with the Federal Bureau of Investigation (“FBI”) with respect to the Approximately
3 $71,207.76 seized from Goldman Sachs, Marcus Online Savings account number 300007772619, held in
4 the name of Viken Yepremian and Approximately $68,119.88 seized from E*Trade account number
5 5147-0717, held in the name of Viken Yepremian which were seized on March 10, 2023. Claims were
6 filed by Viken and Mardig on or about June 6, 2023, in the administrative forfeiture proceeding with the
7 FBI with respect to the 2018 Maserati Gran Turismo, License Number 8EOX182, VIN:
8 ZAM45VLA3J0253945, which was seized on March 16, 2023 (hereafter collectively the “defendant
9 assets”).
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2.

The FBI has sent the written notice of intent to forfeit required by 18 U.S.C. §

11 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the
12 defendant assets under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimants have filed a
13 claim to the defendant assets as required by law in the administrative forfeiture proceeding.
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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for

15 forfeiture against the defendant assets and/or to obtain an indictment alleging that the defendant assets are
16 subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
17 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
18 That deadline was September 4, 2023.
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4.

By Stipulation and Order filed August 30, 2023, the parties stipulated to extend to

20 November 30, 2023, the time in which the United States is required to file a civil complaint for forfeiture
21 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject
22 to forfeiture.
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5.

By Stipulation and Order filed November 8, 2023, the parties stipulated to extend to

24 February 28, 2024, the time in which the United States is required to file a civil complaint for forfeiture
25 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject
26 to forfeiture.
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6.

By Stipulation and Order filed February 27, 2024, the parties stipulated to extend to May

28 28, 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
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Stipulation and Order to Extend Time

1 defendant assets and/or to obtain an indictment alleging that the defendant assets are subject to forfeiture.
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7.

As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to

3 October 25, 2024, the time in which the United States is required to file a civil complaint for forfeiture
4 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject
5 to forfeiture.
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8.

Accordingly, the parties agree that the deadline by which the United States shall be required

7 to file a complaint for forfeiture against the defendant assets and/or to obtain an indictment alleging that
8 the defendant assets are subject to forfeiture shall be extended to October 25, 2024.
9 Dated: May 9, 2024

PHILLIP A. TALBERT
United States Attorney

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By:

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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant United States Attorney

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14 Dated: May 8, 2024
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/s/ Alaleh Kamran
ALALEH KAMRAN
Attorney for potential claimants
Viken Yepremian and Sonia Yepremian
(Signature authorized by email on 5/8/24)

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18 Dated: May 8, 2024
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/s/ Mardig Yepremian
MARDIG YEPREMIAN
Potential Claimant
Appearing in propria persona
9544 N. Larkspur Avenue
Fresno, CA 93720
(Original signature retained by attorney)

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IT IS SO ORDERED.

24 DATED: May 13, 2024.
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Stipulation and Order to Extend Time