Deputy Attorney General of the United States First Assistant United States Attorney District of Nevada Nevada Bar Number 8264 DANIEL D. HOLLINGSWORTH Assistant United States Attorney Nevada Bar No. 1925 501 Las Vegas Boulevard South, Suite 1100 Las Vegas, Nevada 89101 Tel: (702) 388-6336 Fax: (702) 388-6787 Daniel.Hollingsworth@usdoj.gov Attorneys for the United States UNITED STATES DISTRICT COURT United States of America, 3:23-CV-430-MMD-CLB Plaintiff, Order Granting Stipulation between the United States of America and Kite Isaac v. Finds the Feather, Claimant, and Order $163,500 in U.S. Currency, Defendant, Kite Isaac Finds the Feather, Claimant. The United States and Kite Isaac Finds the Feather, Claimant, through his counsel, Jacek W. Lentz, THE LENTZ LAW FIRM, P.C., stipulate as follows: 1. Kite Isaac Finds the Feather believes he can win. The government believes it can win. For the following reasons, the parties knowingly and voluntarily agree to resolve the forfeiture to avoid further litigation. Rather than expend the parties’, their lawyers’, and this Court’s scarce resources and time, Kite Isaac Finds the Feather and the government knowingly and voluntarily agree to settle this case with prejudice. Kite Isaac Finds the Feather and the government knowingly and voluntarily agree the government will return / / / / / / the $81,750 with interest as calculated by DEA with proof of the interest and the calculation and agree the government will forfeit the other $81,750.1 2. The execution of this stipulation does not constitute any admission of fact or wrongdoing by Claimant and any other party, including but not limited to, the United States of America, United States Department of Justice, United States Attorney’s Office for the District of Nevada, Drug Enforcement Administration, Department of Homeland Security, Washoe County Sheriff’s Office, Washoe County, State of Nevada Highway Patrol, State of Nevada, their agencies, their agents, and their employees. 3. Kite Isaac Finds the Feather knowingly and voluntarily agrees to fill out the Department of the United States Treasury Automated Clearing House (ACH) form accurately and correctly and submit it to the United States Attorney’s Office so the payment occurs by electronic fund transfer. 4. Kite Isaac Finds the Feather knowingly and voluntarily acknowledges, understands, and agrees that (a) federal law requires the Department of the United States Treasury and other disbursing officials to offset federal payments to collect delinquent tax and non-tax debts owed to the United States and to individual states (including past-due child support); (b) if an offset occurs to the payment to be made under this Stipulation, they will receive a notification from the Department of the United States Treasury at the last address provided by them to the governmental agency or entity to whom the offset payment is made; (c) if they believe the payment may be subject to an offset, they may contact the Treasury Department at 1-800-304-3107; (d) the terms of this Stipulation do not affect the tax obligations fines, penalties, or any other monetary obligations owed to the United States or an individual state; and (e) the exact sum delivered to Jacek W. Lentz’s IOLTA account, on his behalf, may well be a lesser sum, if the Treasury Offset Program reduces the amount in satisfaction of a debt obligation. / / / 1 United States v. Carvajal, 521 F.3d 1242, 1244-45 (9th Cir. 2008) (quoting and citing United 5. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees the $81,750 with interest may be offset by any debt owed to the United States, any agency of the United States, or any debt in which the United States is authorized to collect. 6. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees that after the United States District Court has signed the Stipulation concerning the $81,750 with interest, within a practicable time thereafter for the United States, the United States agrees to release to Kite Isaac Finds the Feather one payment of $81,750 with interest less any debt owed to the United States, any agency of the United States, or any debt in which the United States is authorized to collect, through Jacek W. Lentz’s IOLTA account. 7. Kite Isaac Finds the Feather and the government knowingly and voluntarily understand and agree (1) each party will bear its own attorneys’ fees, costs, and expenses; (2) the government settling this case is considered as substantially prevailing under 28 U.S.C. § 2465(b)(1); and (3) reasonable cause existed for the seizure and arrest of the $163,500. Kite Isaac Finds the Feather and the government knowingly and voluntarily understand and agree this case is dismissed for other reasons. 8. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive his rights to pursue this civil forfeiture case with district court judge or jury. 9. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive service of process. 10. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any further notice to him, his agents, or his attorneys regarding the $81,750 with interest. 11. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees not to file any other documents in this case or any other case or proceeding concerning the $81,750 with interest. 12. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to withdraw his verified claim filed in this case concerning the $163,500 when this Court grants this Stipulation. 13. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive all constitutional, statutory, legal, equitable rights, defenses, and claims including, but not limited to, seizing the $163,500 in any proceedings under the United States Constitution, Fourth Amendment. 14. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive the statute of limitations; the CAFRA requirements; the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rule of Civil Procedure, (Supp. R.) A, G; other Federal Rules of Civil Procedure that are not inconsistent with the Supp. Rules;2 including, but not limited to, the seizing of, and bringing the civil forfeiture in rem action against, the $163,500; service of process; the filing of a verified complaint; the filing of Kite Isaac Finds the Feather’s verified claim; Kite Isaac Finds the Feather’s identity and relationship to the Kite Isaac Finds the Feather’s Special interrogatories; this Court holding hearings, a bench trial or jury trial; this Court making factual findings; and any and all constitutional, statutory, legal, equitable rights, defenses, and claims regarding seizing, and bringing the civil forfeiture in rem action against, the $163,500 in any proceedings, including, but not limited to, double jeopardy and due process under the United States Constitution, Fifth Amendment. 15. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and claims regarding seizing, and bringing the civil forfeiture in rem action against, the $163,500 in any proceedings, including, but not limited to, a jury trial under the United States Constitution, Sixth Amendment. 16. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and claim
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Deputy Attorney General of the United States First Assistant United States Attorney District of Nevada Nevada Bar Number 8264 DANIEL D. HOLLINGSWORTH Assistant United States Attorney Nevada Bar No. 1925 501 Las Vegas Boulevard South, Suite 1100 Las Vegas, Nevada 89101 Tel: (702) 388-6336 Fax: (702) 388-6787 Daniel.Hollingsworth@usdoj.gov Attorneys for the United States UNITED STATES DISTRICT COURT United States of America, 3:23-CV-430-MMD-CLB Plaintiff, Order Granting Stipulation between the United States of America and Kite Isaac v. Finds the Feather, Claimant, and Order $163,500 in U.S. Currency, Defendant, Kite Isaac Finds the Feather, Claimant. The United States and Kite Isaac Finds the Feather, Claimant, through his counsel, Jacek W. Lentz, THE LENTZ LAW FIRM, P.C., stipulate as follows: 1. Kite Isaac Finds the Feather believes he can win. The government believes it can win. For the following reasons, the parties knowingly and voluntarily agree to resolve the forfeiture to avoid further litigation. Rather than expend the parties’, their lawyers’, and this Court’s scarce resources and time, Kite Isaac Finds the Feather and the government knowingly and voluntarily agree to settle this case with prejudice. Kite Isaac Finds the Feather and the government knowingly and voluntarily agree the government will return / / / / / / the $81,750 with interest as calculated by DEA with proof of the interest and the calculation and agree the government will forfeit the other $81,750.1 2. The execution of this stipulation does not constitute any admission of fact or wrongdoing by Claimant and any other party, including but not limited to, the United States of America, United States Department of Justice, United States Attorney’s Office for the District of Nevada, Drug Enforcement Administration, Department of Homeland Security, Washoe County Sheriff’s Office, Washoe County, State of Nevada Highway Patrol, State of Nevada, their agencies, their agents, and their employees. 3. Kite Isaac Finds the Feather knowingly and voluntarily agrees to fill out the Department of the United States Treasury Automated Clearing House (ACH) form accurately and correctly and submit it to the United States Attorney’s Office so the payment occurs by electronic fund transfer. 4. Kite Isaac Finds the Feather knowingly and voluntarily acknowledges, understands, and agrees that (a) federal law requires the Department of the United States Treasury and other disbursing officials to offset federal payments to collect delinquent tax and non-tax debts owed to the United States and to individual states (including past-due child support); (b) if an offset occurs to the payment to be made under this Stipulation, they will receive a notification from the Department of the United States Treasury at the last address provided by them to the governmental agency or entity to whom the offset payment is made; (c) if they believe the payment may be subject to an offset, they may contact the Treasury Department at 1-800-304-3107; (d) the terms of this Stipulation do not affect the tax obligations fines, penalties, or any other monetary obligations owed to the United States or an individual state; and (e) the exact sum delivered to Jacek W. Lentz’s IOLTA account, on his behalf, may well be a lesser sum, if the Treasury Offset Program reduces the amount in satisfaction of a debt obligation. / / / 1 United States v. Carvajal, 521 F.3d 1242, 1244-45 (9th Cir. 2008) (quoting and citing United 5. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees the $81,750 with interest may be offset by any debt owed to the United States, any agency of the United States, or any debt in which the United States is authorized to collect. 6. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees that after the United States District Court has signed the Stipulation concerning the $81,750 with interest, within a practicable time thereafter for the United States, the United States agrees to release to Kite Isaac Finds the Feather one payment of $81,750 with interest less any debt owed to the United States, any agency of the United States, or any debt in which the United States is authorized to collect, through Jacek W. Lentz’s IOLTA account. 7. Kite Isaac Finds the Feather and the government knowingly and voluntarily understand and agree (1) each party will bear its own attorneys’ fees, costs, and expenses; (2) the government settling this case is considered as substantially prevailing under 28 U.S.C. § 2465(b)(1); and (3) reasonable cause existed for the seizure and arrest of the $163,500. Kite Isaac Finds the Feather and the government knowingly and voluntarily understand and agree this case is dismissed for other reasons. 8. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive his rights to pursue this civil forfeiture case with district court judge or jury. 9. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive service of process. 10. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any further notice to him, his agents, or his attorneys regarding the $81,750 with interest. 11. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees not to file any other documents in this case or any other case or proceeding concerning the $81,750 with interest. 12. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to withdraw his verified claim filed in this case concerning the $163,500 when this Court grants this Stipulation. 13. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive all constitutional, statutory, legal, equitable rights, defenses, and claims including, but not limited to, seizing the $163,500 in any proceedings under the United States Constitution, Fourth Amendment. 14. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive the statute of limitations; the CAFRA requirements; the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rule of Civil Procedure, (Supp. R.) A, G; other Federal Rules of Civil Procedure that are not inconsistent with the Supp. Rules;2 including, but not limited to, the seizing of, and bringing the civil forfeiture in rem action against, the $163,500; service of process; the filing of a verified complaint; the filing of Kite Isaac Finds the Feather’s verified claim; Kite Isaac Finds the Feather’s identity and relationship to the Kite Isaac Finds the Feather’s Special interrogatories; this Court holding hearings, a bench trial or jury trial; this Court making factual findings; and any and all constitutional, statutory, legal, equitable rights, defenses, and claims regarding seizing, and bringing the civil forfeiture in rem action against, the $163,500 in any proceedings, including, but not limited to, double jeopardy and due process under the United States Constitution, Fifth Amendment. 15. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and claims regarding seizing, and bringing the civil forfeiture in rem action against, the $163,500 in any proceedings, including, but not limited to, a jury trial under the United States Constitution, Sixth Amendment. 16. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and claims regarding the seizing of, and bringing the civil forfeiture in rem action against, the $163,500 in any proceedings, including, but not limited to, excessive fines and cruel and unusual punishments under the United States Constitution, Eighth Amendment. 17. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to the conditions in this Stipulation. 18. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to waive any rights to appeal this case. 19. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to hold harmless the United States, United States Department of Justice, United States Attorney’s Office for the District of Nevada, Drug Enforcement Administration, Department of Homeland Security, the Washoe County Sheriff’s Office, Washoe County, the State of Nevada Highway Patrol, the State of Nevada, their agencies, their agents, and their employees from any claim made by him or any third party arising from the facts and circumstances of this case regarding the $163,500. 20. Kite Isaac Finds the Feather knowingly and voluntarily understands and agrees to release and forever discharge the United States, United States Department of Justice, United States Attorney’s Office for the District of Nevada, Drug Enforcement Administration, Department of Homeland Security, Washoe County Sheriff’s Office, Washoe County, State of Nevada Highway Patrol, State of Nevada, their agencies, their agents, and their employees from any and all claims, rights, or causes of action of any kind that Kite Isaac Finds the Feather now has or may hereafter have on account of, or in any way growing out of the $163,500. 21. This Stipulation contains the entire agreement between the parties. 22. Except as expressly stated in this Stipulation, no party, entity, officer, agent, employee, representative, or attorney has made any statement or representation to any other party, person, or entity regarding any fact relied upon in entering into this Stipulation, and no party, entity, officer, agent, employee, representative, or attorney relies on such statement or representation in executing this Stipulation. 23. Each party acknowledges and warrants that its execution of this Stipulation is free and is voluntary. / / / 24. The persons and entities signing this Stipulation warrant and represent that they have full authority to execute this Stipulation and to bind the entity and person on whose behalf they are signing to the terms of this Stipulation. 25. This Stipulation shall be construed and interpreted according to federal forfeiture law and federal common law. The jurisdiction and the venue for any dispute related to, and/or arising from, this Stipulation is the unofficial Northern Division of the United States District Court for the District of Nevada, located in Reno, Nevada. 26. Each party shall bear his own attorneys’ fees, expenses, and costs. The discretionary stipulation to settle this forfeiture case shall not be a basis for an award of attorneys’ fees, expenses, and costs. 27. This Stipulation shall not be construed more strictly against one party than against the other merely by virtue of the fact that it may have been prepared primarily by counsel for one of the parties; it being recognized that both parties have contributed substantially and materially to the preparation of this Stipulation. 28. The parties agree knowingly and voluntarily they may sign this Stipulation in one or more counterparts in electronic or facsimile copies of the Stipulation that will be considered as a legal original and the signatures will be legal and binding. / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / 1 IT IS HEREBY CERTIFIED, pursuant to 28 U.S.C. § 2465(a)(2), that there was reasonable and probable cause for the seizing of, and bringing the civil forfeiture in rem action against, the $163,500.
THE LENTZ LAW FIRM, P.C., ML TEFod. AO L 7a JACKK W. LENTZ Kite Isaac Finds the Feather Attorney Attorney for Kite Isaac Finds the Claimant Feather, Claimant, Dated: Deputy Attorney General of the United States First Assistant United States Attorney DANIEL D. HOLLINGSWORTH Assistant United States Attorney IT IS SO ORDERED: Dated See page 8 UNITED STATES DISTRICT JUDGE
1 IT IS HEREBY CERTIFIED, pursuant to 28 U.S.C. § 2465(a)(2), that there was reasonable and probable cause for the seizing of, and bringing the civil forfeiture in rem action against, the $163,500. Dated: Dated: THE LENTZ LAW FIRM, P.C., JACEK W. LENTZ Kite Isaac Finds the Feather Attorney Attorney for Kite Isaac Finds the Claimant Feather, Claimant, Dated:_November 12, 2025 TODD BLANCHE Il Deputy Attorney General of the United States SIGAL CHATTAH First Assistant United States Attorney /s/ Daniel D. Hollingsworth DANIEL D. HOLLINGSWORTH Assistant United States Attorney IT IS SO ORDERED: Dateg: November 14, 2025 MIRANDA M. DU UNITED STATES DISTRICT JUDGE