STIPULATED PRELIMINARY ORDER OF FORFEITURE

ROBERT H. CLELAND, District Judge.

The United States of America, by and through its attorneys, Barbara L. McQuade, United States Attorney for the Eastern District of Michigan, and Philip A. Ross, Assistant United States Attorney, together with Defendant Ali Tanana ("Defendant"), individually and by and through his attorney, James C. Thomas, Esq., hereby submit this Stipulated Preliminary Order of Forfeiture:

IT IS HEREBY ORDERED that Defendant shall forfeit to the United States Fourteen Thousand Eight Hundred Seven Dollars ($14,807.00) in U.S. Currency seized from Huntington Safe Deposit Box #34. The United States agreed to return 43 pieces of miscellaneous jewelry seized from Huntington Safe Deposit Box #34.

IT IS FURTHER HEREBY ORERED that the above described Fourteen Thousand Eight Hundred Seven Dollars ($14,807.00) IS HEREBY FORFEITED to the United States of America, for disposition in accordance with law, and any right, title or interest of Defendant in such funds, and any right, title or interest that his heirs, successors or assigns have or may have in such funds IS HEREBY AND FOREVER EXTINGUISHED.

NOW THEREFORE, based upon the Information, this Stipulation, and other Information in the record, Defendant hereby agrees to immediate entry of this Stipulated Preliminary Order of Forfeiture, and that any and all interest he has in the Subject Property is hereby forfeited to the United States for disposition according to law.

In entering into this Stipulation with respect to forfeiture, Defendant knowingly, voluntarily, and intelligently waives any challenge to forfeiture of the Subject Property based upon the Excessive Fines Clause of the Eighth Amendment to the United States Constitution, specifically acknowledges that the Subject Property was involved in or was traceable to illegal activity in violation of 18 U.S.C. § 981(A)(1)(C).

Upon entry of this Stipulated Preliminary Order of Forfeiture, the United States Attorney General or his designee is authorized to commence any applicable proceeding to comply with the statutes governing third party rights, including giving notice of this Order.

Upon entry of this Stipulated Preliminary Order of Forfeiture, the United States shall publish on www.forfeiture.gov, notice of this preliminary forfeiture order and of its intent to dispose of the Subject Property in such manner as the Attorney General may direct, pursuant to 21 U.S.C § 853(n). Said notice shall direct that any person, other than the Defendant, asserting a legal interest in the Subject Property may file a petition with the Court within thirty (30) days of the final publication of notice or of receipt of actual notice, whichever is earlier. The petition shall be for a hearing before the Court alone, without a jury and in accordance with 21 U.S.C. § 853(n), to adjudicate the validity of the petitioner's alleged interest in the Subject Property. Any petition filed by a third party asserting an interest in the Subject Property must be signed by the petitioner under penalty of perjury and must set forth the nature and extent of the petitioner's alleged right, title or interest in the Subject Property, the time and circumstances of the petitioner's acquisition of the right, title, or interest in the Subject Property, any additional facts supporting the petitioner's claim, and the relief sought. The United States may also, to the extent practicable, provide direct written notice to any person or entity known to have an alleged interest in the Subject Property.

Further, after the disposition of any motion filed under Federal Rule of Criminal Procedure 32.2(c)(1)(A) and before a hearing on the petition, the United States may conduct discovery in accordance with the Federal Rules of Civil Procedure upon a showing that such discovery is necessary or desirable to resolve factual issues.

Pursuant to Federal Rule of Criminal Procedure 32.2(b)(4)(A), this Stipulated Preliminary Order of Forfeiture shall become final as to Defendant at the time of his sentencing. If no third party files a timely claim, this Order shall become the Final Order of Forfeiture, as provided by Federal Rule of Criminal Procedure 32.2(c)(2).

The United States shall have clear title to the Subject Property following the Court's disposition of all third-party interests, or, if none, following the expiration of the period provided in 21 U.S.C § 853(n)(2) for the filing of third party petitions.

The Court retains jurisdiction to enforce this Order, and to amend it as necessary, pursuant to Federal Rule of Criminal Procedure 32.2(e). Agreed as to form and substance:

IT IS SO ORDERED.

The Court retains jurisdiction to enforce this Order, and to amend it as necessary, pursuant to Federal Rule of Criminal Procedure 32.2(e). Agreed as to form and substance:

BARBARA L. McQUADE United States Attorney s/Philip A. Ross s/James C. Thomas Philip A. Ross James C. Thomas Assistant United States Attorney Attorney for Defendant 211 W. Fort Street, Suite 2001 12900 Hall Road, Suite 350 Detroit, MI 48226 Sterling Heights, MI 48313 (313) 226-9790 (586) 726-1000 Philip.ross@usdoj.gov jthomas@orlaw.com (VA State Bar #70269) Dated: October __, 2016 Dated: October __, 2016 Ali Tanana, Defendant Dated: October ___, 2016

IT IS SO ORDERED.