Opinion
CASE NO. CR13 00201 DLJ PSG
05-08-2013
UNITED STATES OF AMERICA, Plaintiff, v. ALI KASHANI and YANG ZHAO, Defendant.
ROSS ANDREW NABATOFF, FL STATE BAR NO. 0460230 (PRO HAC VICE) BRAND LAW GROUP, PC CHRISTIAN E. PICONE, CA STATE BAR NO. 218275 KATHLEEN F. SHERMAN, CA STATE BAR NO. 241200 BERLINER COHEN TEN ALMADEN BOULEVARD ELEVENTH FLOOR ATTORNEYS FOR DEFENDANT ALI KASHANI
ROSS ANDREW NABATOFF, FL STATE BAR NO. 0460230
(PRO HAC VICE)
BRAND LAW GROUP, PC
CHRISTIAN E. PICONE, CA STATE BAR NO. 218275
KATHLEEN F. SHERMAN, CA STATE BAR NO. 241200
BERLINER COHEN
TEN ALMADEN BOULEVARD
ELEVENTH FLOOR
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
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.
SO STIPULATED.
BERLINER COHEN
By: ____________________
CHRISTIAN E. PICONE
KATHLEEN F. SHERMAN
ATTORNEYS FOR DEFENDANT ALI KASHANI
By:____________________
JEFFREY B. SCHENK
ASSISTANT UNITED STATES ATTORNEY
ORDER
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.
____________________
PAUL SINGH GREWAL, MAGISTRATE JUDGE OF
THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF CALIFORNIA