Case: 5:18-cv-02286-SL Doc #: 14 Filed: 07/15/22 1 of 2.

PageID #: 63

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

UNITED STATES OF AMERICA, ) CASE NO. 5:18 CV 2286

)
Plaintiff, )
) JUDGE SARA LIOI
v. )
)
$241,266.00 IN U.S. CURRENCY, )
) GOVERNMENT’S MOTION
Defendant. ) TO LIFT STAY ORDER

NOW COMES the United States of America, by and through Michelle M. Baeppler, First

Assistant United States Attorney, and Henry F. DeBaggis, Assistant U.S. Attorney, and

respectfully submits the within Government’s Motion to Lift Stay Order.

Pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 1955(d), this is an action for the civil

forfeiture of the defendant $241,266.00 in U.S. Currency. On December 13, 2018, the Court

entered a Stay Order [non-document] in this case until such time as the parties advise the Court

that the related criminal action has been resolved.

The government respectfully advises the Court that a guilty plea was entered yesterday

by the claimant in the related criminal action (United States v. Jason Kachner; No. 5:21 CR 259;

Judge Nugent). The plea agreement includes a forfeiture provision in which the claimant agrees

to withdraw his answer (R. 6) and claim (R. 7) in the within matter and agrees that the defendant

$241,266.00 in U.S. Currency shall be forfeited to the United States.

 Case: 5:18-cv-02286-SL Doc #: 14 Filed: 07/15/22 2 of 2. PageID #: 64

The government respectfully moves the Court to lift the Stay Order so the government

may file the forfeiture agreement on the docket in this matter then file a motion for an order of

forfeiture. Once approved by the Court, these filings will resolve and finalize the within matter.

WHEREFORE, the United States respectfully submits the within Government’s Motion

to Lift Stay Order.

Respectfully submitted,

MICHELLE M. BAEPPLER
First Assistant United States Attorney

By: /s/ Henry F. DeBaggis

Henry F. DeBaggis
Reg. No. 0007561
Assistant U.S. Attorney
United States Court House
801 West Superior Avenue, Suite 400
Cleveland, OH 44113
Phone: (216) 622-3749
Henry.DeBaggis@usdoj.gov