United States of America v. TWELVE THOUSAND ONE HUNDRED EIGHTY SIX DOLLARS ($12,186.00) IN U.S. CURRENCY et al

Filing 22

STIPULATION AND ORDER STAYING CASE Signed by District Judge Robert H. Cleland. (LWag)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,

Civil No. 15-13766
Honorable Robert Cleland

vs.
TWELVE THOUSAND ONE HUNDRED
EIGHTY SIX DOLLARS ($12,186.00)
IN U.S. CURRENCY, et al;
Defendants in Rem.
__________________________________________/
STIPULATION AND ORDER TO STAY
CIVIL FORFEITURE PROCEEDING
Plaintiff, the United States of America, by and through United States
Attorney Barbara L. McQuade, and Assistant United States Attorney Paul A.
Kuebler, and Claimants, Mohamad Karim Altabba, individually and as President of
Behavioral Infermiera Care Solutions, Inc., by and through his attorney, David
Griem, and Mamoun Dabbagh, M.D., by and through his attorney, Kristina Joseph,
(collectively, “the Parties”), hereby acknowledge that there is an ongoing criminal
investigation related to this civil forfeiture case, and stipulate to the entry of an
order for a stay of the above-captioned civil forfeiture proceeding pursuant to 18
U.S.C. § 981(g)(1), or alternatively, 18 U.S.C. § 981(g)(2), on the grounds that

continuation of the civil proceeding may negatively impact one or more Parties in
the manner described in the cited statutes; and that the stay continue for a period of
90 days from the date this order is entered, or until further order of the Court.
BARBARA L. McQUADE
United States Attorney
S/ PAUL A. KUEBLER
PAUL A. KUEBLER
Assistant United States Attorney
211 W. Fort St., Ste. 2001
Detroit, MI 48226
[phone]
[e-mail]
(NY 4268561)

S/ DAVID GRIEM
DAVID GRIEM
Attorney for Claimant Mohamad
Karim Altabba, individually and as
President of Behavioral Infermiera
Care Solutions, Inc.,
21 Kercheval Ave., Suite 363
Grosse Pointe Farms, MI 48236
[phone]
[e-mail]
(P23187)

Dated: February 2, 2016

Dated: February 2, 2016
S/ KRISTINA JOSEPH
KRISTINA JOSEPH
Attorney for Claimant Mamoun
Dabbagh, M.D.
21 Kercheval Ave., Suite 363
Grosse Pointe Farms, MI 48236
[phone]
[e-mail]
(P79668)
Dated: February 2, 2016

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Civil No. 15-13766
Honorable Robert Cleland

Plaintiff,

vs.
TWELVE THOUSAND ONE HUNDRED
EIGHTY SIX DOLLARS ($12,186.00)
IN U.S. CURRENCY, et al;
Defendants in Rem.
_____________________________________/
ORDER TO STAY
CIVIL FORFEITURE PROCEEDING
This matter having come before the Court on the Government and
Claimants’ stipulation, and the Court being fully advised in the premises;
IT IS HERBY ORDERED that this case shall be stayed for a period of 90
days from the date this order is entered, or until further order of the Court.

_s/Robert H. Cleland
HONORABLE ROBERT CLELAND
United States District Court
Dated: February 4, 2016
3