STIPULATION FOR FINAL ORDER OF FORFEITURE AND ORDER THEREON

WILLIAM B. SHUBB, Senior District Judge.

IT IS HEREBY STIPULATED by and between the United States of America and potential petitioners Irina Yakovlev and Vladimir Yakovlev, to compromise and settle their interest in the following property1, and to stipulate and consent to the entry of a Final Order of Forfeiture as to the following property pursuant to 31 U.S.C. § 5317(c)(1):

This stipulation for Final Order of Forfeiture is entered into between the parties pursuant to the following terms:

1. On or about September 15, 2014, defendant Leonid Yakovlev entered into a plea agreement in which he pled guilty to a violation of 31 U.S.C. § 5324(a)(1) (structuring). In the plea agreement Leonid Yakovlev agreed to forfeit his right, title, and interest in the above-described real properties, which are more fully described in Exhibit A and Exhibit B attached hereto. The Court entered a Preliminary Order of Forfeiture on or about December 9, 2014, forfeiting defendant Leonid Yakovlev's interest in the above-described real properties. Pursuant to 31 U.S.C. § 5317(c)(1)(B) and 18 U.S.C. § 982(b)(1), incorporating 21 U.S.C. § 853(n), the United States sent direct notice to the following individuals and entities:

a. Roseville Children's Foundation Trust2: A notice letter was sent via certified mail to Roseville Children's Foundation Trust, c/o Leo Yakovlev, at 848 N. Rainbow Blvd., #910, Las Vegas, Nevada 89107 on December 18, 2014. According to USPS Tracking on the U.S. Postal Services' web site (USPS.com), the letter was delivered on December 20, 2014. A notice letter was sent via certified mail to Roseville Children's Foundation Trust, Leonid Yakovlev, c/o Christopher Haydn-Myer, Esq., at 1050 Opportunity Drive, Suite 140, Roseville, California 95678 on December 18, 2014. The PS Form 3811 (certified mail "green card" showing delivery of mail) was signed for on December 19, 2014.

b. Irina Yakovlev: A notice letter was sent via certified mail to Irina Yakovlev at 5694 Mission Center Road, #480, San Diego, California 92108-4355 on December 16, 2014. The PS Form 3811 (certified mail "green card" showing delivery of mail) was signed for on December 18, 2014.

c. Pacific Credit Exchange: A notice letter was sent via certified mail to the Law Offices of Frank G. Blundo, Jr., c/o Pacific Credit Exchange, at 15760 Ventura Blvd., #A-11, Encino, California 91436-3057 on December 18, 2014. The PS Form 3811 (certified mail "green card" showing delivery of mail) was signed for on December 22, 2014.

d. State of California Employment Development Department: A notice letter was sent via certified mail to the State of California Employment Development Dept., Benefit Overpayment Collection Section, MIC 91 at P.O. Box 826218, Sacramento, California 94230-6218 on December 18, 2014. The PS Form 3811 (certified mail "green card" showing delivery of mail) was signed for on December 22, 2014.

e. Sacramento County Department of Child Support Services: A notice letter was sent via certified mail to the Sacramento County Department of Child Support Services at P.O. Box 269112, Sacramento, California 95826-9112 on December 18, 2014. The PS Form 3811 (certified mail "green card" showing delivery of mail) was signed for on December 19, 2014.

2. Beginning on December 12, 2014, for at least 30 consecutive days, the United States published notice of the Court's Order of Forfeiture on the official internet government forfeiture site www.forfeiture.gov. Said published notice advised all third parties of their right to petition the Court within sixty (60) days from the first day of publication of the notice for a hearing to adjudicate the validity of their alleged legal interest in the forfeited property. A Declaration of Publication was filed on January 29, 2015.

3. On December 24, 2014, Vladimir Yakovlev contacted the government claiming an interest in the real property located at 1021 Vinci Avenue, Sacramento, CA, APN: 226-0080-058-0000. His wife, Irina Yakovlev, is on title to that property.

4. No other party or entity has filed a petition asserting an interest in the real properties listed above, and the time in which any person or entity may file a petition has expired.

5. The United States and potential petitioners Irina Yakovlev and Vladimir Yakovlev have reached a settlement regarding their interest in the real property located at 1021 Vinci Avenue, Sacramento, CA. The parties further stipulate that the Preliminary Order of Forfeiture remains valid to the extent it orders the forfeiture of Leonid Yakovlev's interest in the real properties.

6. Irina Yakovlev and Vladimir Yakovlev have agreed to pay the United States a sub res in the amount of $18,000.00 in lieu of the United States forfeiting the real property located at 1021 Vinci Avenue, Sacramento, California, APN: 226-0080-058-0000. The sub res shall be paid within sixty (60) days of signing this Stipulation. Irina Yakovlev and Vladimir Yakovlev shall send the $18,000.00 sub res in the form of a cashier's check, payable to the Department of the Treasury, to the following address: U.S. Attorney's Office, Att: Asset Forfeiture Unit, 501 I Street, Suite 10-100, Sacramento, California 95814. Said funds shall be forfeited to the United States pursuant to 31 U.S.C. § 5317(c)(1).

7. If the sub res of $18,000.00 is not paid within sixty (60) days of signing this Stipulation, then Irina Yakovlev and Vladimir Yakovlev forfeit all of their right, title, and interest in the real property located at 1021 Vinci Avenue, Sacramento, California, APN: 226-0080-058-0000, and the Internal Revenue Service ("IRS") shall be authorized to sell the real property.

8. Potential petitioners Irina Yakovlev and Vladimir Yakovlev agree to release and hold harmless the United States, and any agents, servants, and employees of the United States (and any involved state or local law enforcement agencies and their agents, servants, or employees), in their individual or official capacities, from any and all claims that currently exist or that may arise as a result of the Government's actions against and relating to the real property at 1021 Vinci Avenue, Sacramento, California. As against the United States and its agents, Irina Yakovlev and Vladimir Yakovlev agree to waive the provisions of California Civil Code § 1542, which provides:

9. Irina Yakovlev and Vladimir Yakovlev understand and agree that by entering into this stipulation of their interest in the property at 1021 Vinci Avenue, Sacramento, California, they waive any right to litigate further their ownership interest in the property and to petition for remission or mitigation of the forfeiture. Thereafter, if this Stipulation for Final Order of Forfeiture is approved by the Court, then unless specifically directed by an order of the Court, Irina Yakovlev and Vladimir Yakovlev shall be excused and relieved from further participation in this action.

10. If the $18,000.00 is not paid within sixty (60) days of signing this Stipulation, the parties agree to execute further documents, to the extent reasonably necessary, to convey clear title to the real property at 1021 Vinci Avenue, Sacramento, California to the United States and to implement further the terms of this Stipulation. Each party agrees to bear its own costs and attorneys' fees.

11. Within thirty days of receipt of the $18,000.00 and entry of this Final Order of Forfeiture, the United States shall send a Notice of Withdrawal of Lis Pendens to the county recorder for the property at 1021 Vinci Avenue, Sacramento, California.

12. The sale of the real property located at 8450 Sunrise Boulevard, Roseville, CA, APNs: 470-211-008 and 216-0030-002 shall be handled by the IRS in a commercially reasonable manner. The IRS shall have sole authority to select the means of sale, including sale by internet or through a licensed real estate broker, and shall have sole authority over the marketing and sale of the property. Any and all personal possessions not removed within thirty days from the entry of this Final Order of Forfeiture will be disposed of by the United States without further notice.

13. The terms of this Stipulation shall be subject to approval by the United States District Court. Violation of any term or condition herein shall be construed as a violation of an order of the Court.

14. The court shall maintain jurisdiction over this matter to enforce the terms of this stipulation.

ACKNOWLEDGMENT

A notary public or other officer completing this acknowledgment verifies only the identity of the individual who signed this document, and not the truthfulness, accuracy, or validity of this document.

On APR 02, 2015, before me, Kashmir Singh Dheensa, Notary Public, personally appeared Irina Yakovlev, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

ACKNOWLEDGMENT

A notary public or other officer completing this acknowledgment verifies only the identity of the individual who signed this document, and not the truthfulness, accuracy, or validity of this document.

On APR 02, 2015, before me, Kashmir Singh Dheensa, Notary Public, personally appeared Vladimir Yakovlev, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

ORDER

The Court having received, read, and considered the foregoing Stipulation of the parties, and good cause appearing therefrom, the Stipulated Settlement is hereby ADOPTED and APPROVED, and the Court hereby enters a Final Order of Forfeiture on the terms set forth in the parties' Stipulated Settlement. All right, title, and interest of Leonid Yakovlev, Roseville Children's Foundation Trust, Pacific Credit Exchange, State of California Employment Development Department, and Sacramento County Department of Child Support Services to the real properties located at 8450 Sunrise Boulevard, Roseville, CA, APNs: 470-211-008 and 216-0030-002 and 1021 Vinci Avenue, Sacramento, CA, APN: 226-0080-058-0000, is hereby extinguished.

IT IS SO ORDERED.

Exhibit A

Legal Description

Real property located at 8450 Sunrise Boulevard, Roseville, California

THE LAND DESCRIBED HEREIN IS SITUATED IN THE STATE OF CALIFORNIA, COUNTY OF PLACER, AND IS DESCRIBED AS FOLLOWS: UNINCORPORATED AREA

ALL THAT PORTION OF LOT 166 OF CITRUS HEIGHTS ADDITION NO. 8, ACCORDING TO THE OFFICIAL PLAT THEREOF, FILED IN THE OFFICE OF THE RECORDER OF SACRAMENTO COUNTY, CALIFORNIA ON SEPTEMBER 11, 1911, IN BOOK 12 OF MAPS, MAP NO. 42, AND FILED IN THE OFFICE OF THE RECORDER OF PLACER COUNTY, CALIFORNIA, ON SEPTEMBER 6, 1911 IN BOOK C OF MAPS, AT PAGE 53, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:

BEGINNING AT A POINT IN THE EAST LINE OF SAID LOT 166 LOCATED NORTH 0 DEGREES 01 MINUTES WEST 578.07 FEET FROM THE SOUTHEAST CORNER OF SAID LOT, SAID SOUTHEAST CORNER BEING IN THE CENTER OF TWIN OAKS AVENUE; THENCE FROM SAID POINT OF BEGINNING WEST 155.37 FEET ON A LINE PARALLEL TO THE SOUTH LINE OF SAID LOT 166 TO A 2"X2" WOOD STAKE STAMPED L.S. 2217; THENCE NORTH 3 DEGREES 00 MINUTES WEST 67.05 FEET TO A SIMILAR STAKE; THENCE SOUTH 88 DEGREES 55 MINUTES WEST 175.00 FEET TO A 3/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE CONTINUING SOUTH 88 DEGREES 35 MINUTES WEST 20.00 FEET TO A POINT IN THE CENTERLINE OF SUNRISE AVENUE AND THE WEST LINE OF LOT 166; THENCE NORTH 03 DEGREES 10 MINUTES WEST 98.00 FEET ALONG SAID WEST LINE AND SAID CENTER LINE; THENCE EAST 359.22 FEET ON A LINE PARALLEL TO THE SOUTH LINE OF SAID LOT 166 TO A POINT IN THE EAST LINE OF SAID LOT AND THENCE SOUTH 0 DEGREES 01 MINUTES EAST 160 FEET ALONG THE EAST LINE OF SAID LOT TO THE POINT OF BEGINNING.

EXCEPTING THEREFROM THAT PORTION DESCRIBED AS FOLLOWS:

BEGINNING AT A POINT IN THE CENTERLINE OF SUNRISE AVENUE, BEING THE WEST LINE OF LOT NUMBERED 166, SOUTH 3 DEGREES 10 MINUTES WEST 680.80 FEET FROM THE NORTHWEST CORNER OF LOT NUMBERED 166; THENCE FROM SAID POINT OF BEGINNING NORTH 88 DEGREES 35 MINUTES EAST 20.00 FEET, A 3/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE CONTINUING NORTH 88 DEGREES 35 MINUTES EAST 175.00 FEET TO A 2"X 2" WOOD STAKE STAMPED L.S. 2217; THENCE SOUTH 3 DEGREES 00 MINUTES EAST 67.05 FEET TO A SIMILAR STAKE; THENCE WEST 175.00 FEET TO A 3/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE CONTINUING WEST 20 FEET TO A POINT IN THE CENTERLINE OF SAID SUNRISE AVENUE AND THE WEST LINE OF LOT NUMBERED 166; THENCE NORTH 3 DEGREES 10 MINUTES WEST 62.24 FEET ALONG SAID CENTERLINE OF SUNRISE AVENUE TO THE POINT OF BEGINNING.

ALSO EXCEPTING THEREFROM ALL THAT PORTION GRANTED TO THE COUNTY OF PLACER BY DEED RECORDED JUNE 27, 1952 IN BOOK 661, AT PAGE 496, OFFICIAL RECORDS OF PLACER COUNTY.

ALSO EXCEPTING THAT PORTION LYING WITHIN SACRAMENTO COUNTY.

APN: 470-211-008

PARCEL B:

THE LAND DESCRIBED HEREIN IS SITUATED IN THE STATE OF CALIFORNIA, COUNTY OF SACRAMENTO, CITY OF CITRUS HEIGHTS, AND IS DESCRIBED AS FOLLOWS:

ALL THAT PORTION OF LOT 166, AS SHOWN ON THE APLAT OF CITRUS HEIGHTS ADDITION NO.8", RECORDED IN BOOK 12 OF MAPS, MAP NO. 42, RECORDS OF SAID COUNTY, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

BEGINNING AT A POINT IN THE EAST LINE OF SAID LOT 166, LOCATED NORTH 0 DEGREES 01 MINUTES WEST 578.07 FEET FROM SOUTHEAST CORNER OF SAID LOT, SAID SOUTHEAST CORNER BEING IN THE CENTER OF TWIN OAKS AVENUE; THENCE FROM SAID POINT OF BEGINNING WEST 155.37 FEET ON A LINE PARALLEL TO THE SOUTH LINE OF SAID LOT 166 TO A 2"X2" WOOD STAKE STAMPED L.S. 2217; THENCE NORTH 3 DEGREES 00 MINUTES WEST 67.05 FEET TO A SIMILAR STAKE; THENCE SOUTH 88 DEGREES 55 MINUTES WEST 175.00 FEET TO A 3/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE CONTINUING SOUTH 88 DEGREES 35 MINUTES WEST 20.00 FEET TO A POINT IN THE CENTERLINE OF SUNRISE AVENUE AND THE WEST LINE OF LOT 166; THENCE NORTH 03 DEGREES 0 MINUTES WEST 98.00 FEET ALONG SAID WEST LINE AND SAID CENTER LINE; THENCE EAST 359.22 FEET ON A LINE PARALLEL TO THE SOUTH LINE OF SAID LOT 166 TO A POINT IN EAST LINE OF SAID LOT AND THENCE SOUTH 0 DEGREES 01 MINUTES EAST 160 FEET ALONG THE EAST LINE OF SAID LOT TO THE POINT OF BEGINNING.

EXCEPTING THEREFROM ALL THAT PORTION THEREOF SITUATED WITHIN PLACER COUNTY.

ALSO EXCEPTING THEREFROM THAT PORTION DESCRIBED AS FOLLOWS:

BEGINNING AT A POINT IN THE CENTERLINE OF SUNRISE AVENUE, BEING THE WEST LINE OF LOT NUMBERED 166; LOCATED SOUTH 3 DEGREES 10 MINUTES WEST 680.00 FEET FROM THE NORTHWEST CORNER OF LOT NUMBERED 166; THENCE FROM SAID POINT OF BEGINNING NORTH 88 DEGREES 35 MINUTES EAST 20.00 FEET, A 1/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE, CONTINUING NORTH 88 DEGREES 35 MINUTES EAST 175.00 FEET TO A 2"X2" WOOD STAKE STAMPED L.S. 2217; THENCE SOUTH 3 DEGREES 00 MINUTES EAST 67.05 FEET TO A SIMILAR STAKE; THENCE WEST 175.00 FEET TO A 3/4 INCH IRON PIPE DRIVEN FLUSH WITH THE GROUND; THENCE CONTINUING WEST 20 FEET TO A POINT IN THE CENTERLINE OF SAID SUNRISE AVENUE AND THE WEST LINE OF LOT NUMBERED 166; THENCE NORTH 3 DEGREES 10 MINUTES WEST 62.24 FEET ALONG SAID CENTERLINE OF SUNRISE AVENUE TO THE POINT OF BEGINNING.

APN: 216-0030-002

Exhibit B

Legal Description

Real property located at 1021 Vinci Avenue, Sacramento, California

THE WEST ONE-HALF OF LOT 245 AND THE EAST 117.00 FEET OF LOT 236 OF ACME ACRES, ACCORDING TO THE OFFICIAL PLAT THEREOF, FILED IN THE OFFICE OF THE RECORDER OF SACRAMENTO COUNTY, CALIFORNIA, ON MAY 24, 1913, IN BOOK 14 OF MAPS, MAP NO. 27.

APN: 226-0080-058-0000