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