Free Status Report - District Court of Arizona - Arizona

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DANIEL G. KNAUSS United States Attorney District of Arizona LISA ROBERTS Assistant U.S. Attorney Member of New York Bar Two Renaissance Square 40 North Central, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, CIV-04-363-PHX-JWS Plaintiff, v. 1. Lear Jet, Model 31A, Serial Number 31A-224, U.S. Registration # N224LJ; Defendant. Plaintiff, United States of America, by and through its attorney, DANIEL G.
STATUS REPORT

15 KNAUSS, United States Attorney for the District of Arizona, Lisa Roberts, Assistant United 16 States Attorney, of counsel, respectfully files this Status Report with regard to the above 17 action. 18 Learjet 19 All of the parties have been communicating by mail and telephone concerning the 20 proposed allocation of costs arising from the storage, maintenance, repair, and sale of the 21 captioned Lear Jet consistent with the directions set forth in this Court's order of September 8, 22 2005. Each of the parties has advised the government orally that he/she concurs with the 23 allocation proposed by the plaintiff. The plaintiff has asked each of the parties to reduce their 24 approval to writing. If and when each party approves and accepts the proposed allocation in 25 writing, the plaintiff will then take steps to transfer the proceeds of the sale of the Lear Jet, 26 which was $4.4 million at the time of the sale, minus $342,313.37, plus interest, into the 27 Registry of the Court as the substitute res in this case. $342,313.37 represents the proposed 28

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1 cost of storage, maintenance, repair, and sale that the parties to the action will agree is to be 2 deducted from the sales proceeds. 3 All of the parties have been engaging in increasingly focused discussions concerning

4 the settlement of this case. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
CERTIFICATE OF SERVICE

Respectfully submitted this 22nd day of June, 2007. DANIEL G. KNAUSS United States Attorney District of Arizona

S/Lisa Roberts LISA ROBERTS Assistant U.S. Attorney

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1 I hereby certify that on June 22, 2007, I electronically transmitted the attached document to the Clerk's 2
Office using the CM/ECF System for filing, and served the attached document by U.S. mail, on the following:

3 MICHAEL E. DAVITT, Deputy Chief 4 Asset Forfeiture and Money Laundering Section
Criminal Division 5 U.S. Department of Justice 1400 New York Avenue, N.W. 6 Washington, D.C. 20530

7 Mr. Carlos Martel, FP&F Officer 8 Department of Homeland Security 9 Miami, FL 33152-2207 10 Lawson Pedigo 11 Miller, Keffer, & Pedigo
P.O. Box 52-2207 United States Customs and Border Protection

8401 North Central Expressway, Suite 630 12 Dallas, Texas 75225

13 Douglas F. Behm
Jennings, Strouss & Salom, P.L.C.

14 The Collier Center, 11th Floor 15 Phoenix, Arizona 85004-2385 16 Geoffrey Young 17 Ruden, McClosky, Smith, Schuster & Russell, P.A. nd
150 2 Avenue, Suite 1700 St. Petersburg, FL 33701 18 201 East Washington Street

19 Cynthia Orr
Goldstein, Goldstein and Hilley

20 29th Floor Tower Life Building 21 San Antonio, Texas 78205 22 23 24 S/Victoria Tiffany 25 26 27 28
310 South St. Mary's Street

Case 2:04-cv-00363-JWS

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