TODD BLANCHE Deputy Attorney General of the United States 2||SIGAL CHATTAH First Assistant United States Attorney 3|| District of Nevada Nevada Bar No. 8264 4|| DANIEL D. HOLLINGSWORTH Assistant United States Attorney Nevada Bar No. 1925 501 Las Vegas Boulevard South, Suite 1100 6|| Las Vegas, Nevada 89101 Tel: (702) 388-6336 Fax: (702) 388-6787 Daniel.Hollingsworth@usdoj.gov 8 || Attorneys for the United States 9 10 UNITED STATES DISTRICT COURT {1 DISTRICT OF NEVADA 12 || United States of America, 2:25-CV-310-APG-DJA 13 Plaintiff, Stipulation for Entry of Judgment of Forfeiture as to Oliver Jair Martinez- 14 Vv. Mendez, and Order 15 ||$755,831 in United States Currency, 16 Defendant, 17 || Oliver Jair Martinez-Mendez, 18 Claimant. 19 The United States and Oliver Jair Martinez-Mendez, Claimant, through his counsel, 20 || Richard Wynn, Wynn Law Group, and Ismail Amin, The Amin Law Group NV., Ltd., 21 || stipulate as follows: 22 1. Claimant Oliver Jair Martinez-Mendez and the government knowingly and 23 || voluntarily agree to resolve the forfeiture in this case to avoid further litigation. Rather than using this Court’s, the government’s, its attorneys’, Oliver Jair Martinez-Mendez’s, and his attorneys’ scarce resources and time, Oliver Jair Martinez-Mendez and the government 26 || knowingly and voluntarily agree to settle this case with prejudice. 27 2. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to the civil 28 || forfeiture of, and to the district court imposing the civil forfeiture of, the $755,831.
1 3. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to forfeit the 2 ||$755,831 to the United States. The parties knowingly and voluntarily agree the United 3 || States will forfeit the $755,831, return $151,166.20 of the forfeitable amount to Oliver Jair 4 || Martinez-Mendez, and retain $604,664.80 of the forfeitable amount. 5 4. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to relinquish 6 || all possessory rights, ownership rights, and all rights, titles, and interests in the property in 7 $755,831. 8 5. The execution of this Stipulation does not constitute any admission of fact or 9 || wrongdoing by Oliver Jair Martinez-Mendez, the United States of America, United States 10 || Department of Justice, United States Attorney’s Office for the District of Nevada, United 11 States Drug Enforcement Administration, the Internal Revenue Service-Cl, San 12 || Bernardino County Sheriff's Department, Bell Gardens Police Department, Riverside 13 || County Sheriff's Department, California Department of Alcoholic Beverage Control, 14 || Montclair Police Department, Ontario Police Department, Redlands Police Department, 15 || Rialto Police Department, San Bernardino Police Department, State of California, Las 16 || Vegas Metropolitan Police Department, City of North Las Vegas Police Department, 17 || Nevada Gaming Control Board Enforcement Division, the State of Nevada, their agencies, 18 || their agents, and their employees. 19 6. Oliver Jair Martinez-Mendez and his attorneys knowingly and voluntarily 20 || agree to fill out the Department of the United States Treasury Automated Clearing House 21 ||(ACH) form accurately and correctly and submit it to the United States Attorney’s Office, 22 || District of Nevada, so the payment occurs by electronic fund transfer. 23 7. Oliver Jair Martinez-Mendez knowingly and voluntarily acknowledges, 24 || understands, and agrees that (a) federal law requires the United States Department of the 25 || Treasury and other disbursing officials to offset federal payments to collect delinquent tax 26 || and non-tax debts owed to the United States and to individual states (including past-due 27 || child support); (b) if an offset occurs to the payment to be made under this Stipulation, they 28 || will receive a notification from the United States Department of the Treasury at the last
1 || address provided by them to the governmental agency or entity to whom the offset 2 || payment is made; (c) if they believe the payment may be subject to an offset, they may 3 || contact the Treasury Department at 1-800-304-3107; (d) the terms of this Stipulation do not 4 || affect the tax obligations fines, penalties, or any other monetary obligations owed to the 5 || United States or an individual state; and (e) the exact sum delivered to Richard Wynn’s 6 || LOLTA account, on his behalf, may well be a lesser sum, if the Treasury Offset Program 7 ||reduces the amount in satisfaction of a debt obligation. 8 8. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 9 || agrees the $151,166.20 may be offset by any debt owed to the United States, any agency of 10 || the United States, or any debt in which the United States is authorized to collect. 11 9. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 12 || agrees that after the United States District Court has signed and entered this Stipulation 13 || concerning the $755,831 and signed and entered the Final Judgment of Forfeiture in this 14 case, within a practicable time thereafter for the United States, the United States agrees to 15 release to Oliver Jair Martinez-Mendez one payment of $151,166.20 less any debt owed to 16 || the United States, any agency of the United States, or any debt in which the United States is 17 || authorized to collect, through Richard Wynn’s IOLTA account. 18 10. Oliver Jair Martinez-Mendez and the government knowingly and voluntarily 19 || understand and agree (1) each party will bear its own attorneys’ fees, costs, and expenses; (2 20 || the government settling this case is considered as substantially prevailing under 28 U.S.C. 21 || § 2465(b)(1); and (3) reasonable cause existed for the seizure, arrest, and forfeiture of the 22 ||$755,831. 23 11. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 24 || agrees to waive service of process and to waive any further notice to him, his agents, or his 25 || attorneys regarding the $755,831. 26 12. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 27 || agrees to waive his right to any judicial proceedings concerning the forfeiture of the 28 $755,831 (proceedings).
1 13. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 2 || agrees not to file any other documents in this case or any other case or proceeding 3 || concerning the $755,831. 4 14. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees not to contest, 5 || and not to assist any other person and entity to contest, the forfeiture in any proceedings 6 || concerning the $755,831. 7 15. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 8 || agrees to withdraw his claim and answer filed in this case concerning the $755,831 when 9 || this Court grants this Stipulation. 10 16. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 11 || agrees to waive all constitutional, statutory, legal, equitable rights, defenses, and claims 12 || including, but not limited to, the stops, searches, seizures, and forfeiture of the $755,831 in 13 || any proceedings under the United States Constitution, Fourth Amendment. 14 17. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 15 || agrees to waive the statute of limitations; the CAFRA requirements; the Supplemental 16 || Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rule of 17 || Civil Procedure, (Supp. R.) A, G; other Federal Rules of Civil Procedure that are not 18 inconsistent with the Supp.
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TODD BLANCHE Deputy Attorney General of the United States 2||SIGAL CHATTAH First Assistant United States Attorney 3|| District of Nevada Nevada Bar No. 8264 4|| DANIEL D. HOLLINGSWORTH Assistant United States Attorney Nevada Bar No. 1925 501 Las Vegas Boulevard South, Suite 1100 6|| Las Vegas, Nevada 89101 Tel: (702) 388-6336 Fax: (702) 388-6787 Daniel.Hollingsworth@usdoj.gov 8 || Attorneys for the United States 9 10 UNITED STATES DISTRICT COURT {1 DISTRICT OF NEVADA 12 || United States of America, 2:25-CV-310-APG-DJA 13 Plaintiff, Stipulation for Entry of Judgment of Forfeiture as to Oliver Jair Martinez- 14 Vv. Mendez, and Order 15 ||$755,831 in United States Currency, 16 Defendant, 17 || Oliver Jair Martinez-Mendez, 18 Claimant. 19 The United States and Oliver Jair Martinez-Mendez, Claimant, through his counsel, 20 || Richard Wynn, Wynn Law Group, and Ismail Amin, The Amin Law Group NV., Ltd., 21 || stipulate as follows: 22 1. Claimant Oliver Jair Martinez-Mendez and the government knowingly and 23 || voluntarily agree to resolve the forfeiture in this case to avoid further litigation. Rather than using this Court’s, the government’s, its attorneys’, Oliver Jair Martinez-Mendez’s, and his attorneys’ scarce resources and time, Oliver Jair Martinez-Mendez and the government 26 || knowingly and voluntarily agree to settle this case with prejudice. 27 2. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to the civil 28 || forfeiture of, and to the district court imposing the civil forfeiture of, the $755,831.
1 3. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to forfeit the 2 ||$755,831 to the United States. The parties knowingly and voluntarily agree the United 3 || States will forfeit the $755,831, return $151,166.20 of the forfeitable amount to Oliver Jair 4 || Martinez-Mendez, and retain $604,664.80 of the forfeitable amount. 5 4. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to relinquish 6 || all possessory rights, ownership rights, and all rights, titles, and interests in the property in 7 $755,831. 8 5. The execution of this Stipulation does not constitute any admission of fact or 9 || wrongdoing by Oliver Jair Martinez-Mendez, the United States of America, United States 10 || Department of Justice, United States Attorney’s Office for the District of Nevada, United 11 States Drug Enforcement Administration, the Internal Revenue Service-Cl, San 12 || Bernardino County Sheriff's Department, Bell Gardens Police Department, Riverside 13 || County Sheriff's Department, California Department of Alcoholic Beverage Control, 14 || Montclair Police Department, Ontario Police Department, Redlands Police Department, 15 || Rialto Police Department, San Bernardino Police Department, State of California, Las 16 || Vegas Metropolitan Police Department, City of North Las Vegas Police Department, 17 || Nevada Gaming Control Board Enforcement Division, the State of Nevada, their agencies, 18 || their agents, and their employees. 19 6. Oliver Jair Martinez-Mendez and his attorneys knowingly and voluntarily 20 || agree to fill out the Department of the United States Treasury Automated Clearing House 21 ||(ACH) form accurately and correctly and submit it to the United States Attorney’s Office, 22 || District of Nevada, so the payment occurs by electronic fund transfer. 23 7. Oliver Jair Martinez-Mendez knowingly and voluntarily acknowledges, 24 || understands, and agrees that (a) federal law requires the United States Department of the 25 || Treasury and other disbursing officials to offset federal payments to collect delinquent tax 26 || and non-tax debts owed to the United States and to individual states (including past-due 27 || child support); (b) if an offset occurs to the payment to be made under this Stipulation, they 28 || will receive a notification from the United States Department of the Treasury at the last
1 || address provided by them to the governmental agency or entity to whom the offset 2 || payment is made; (c) if they believe the payment may be subject to an offset, they may 3 || contact the Treasury Department at 1-800-304-3107; (d) the terms of this Stipulation do not 4 || affect the tax obligations fines, penalties, or any other monetary obligations owed to the 5 || United States or an individual state; and (e) the exact sum delivered to Richard Wynn’s 6 || LOLTA account, on his behalf, may well be a lesser sum, if the Treasury Offset Program 7 ||reduces the amount in satisfaction of a debt obligation. 8 8. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 9 || agrees the $151,166.20 may be offset by any debt owed to the United States, any agency of 10 || the United States, or any debt in which the United States is authorized to collect. 11 9. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 12 || agrees that after the United States District Court has signed and entered this Stipulation 13 || concerning the $755,831 and signed and entered the Final Judgment of Forfeiture in this 14 case, within a practicable time thereafter for the United States, the United States agrees to 15 release to Oliver Jair Martinez-Mendez one payment of $151,166.20 less any debt owed to 16 || the United States, any agency of the United States, or any debt in which the United States is 17 || authorized to collect, through Richard Wynn’s IOLTA account. 18 10. Oliver Jair Martinez-Mendez and the government knowingly and voluntarily 19 || understand and agree (1) each party will bear its own attorneys’ fees, costs, and expenses; (2 20 || the government settling this case is considered as substantially prevailing under 28 U.S.C. 21 || § 2465(b)(1); and (3) reasonable cause existed for the seizure, arrest, and forfeiture of the 22 ||$755,831. 23 11. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 24 || agrees to waive service of process and to waive any further notice to him, his agents, or his 25 || attorneys regarding the $755,831. 26 12. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 27 || agrees to waive his right to any judicial proceedings concerning the forfeiture of the 28 $755,831 (proceedings).
1 13. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 2 || agrees not to file any other documents in this case or any other case or proceeding 3 || concerning the $755,831. 4 14. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees not to contest, 5 || and not to assist any other person and entity to contest, the forfeiture in any proceedings 6 || concerning the $755,831. 7 15. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 8 || agrees to withdraw his claim and answer filed in this case concerning the $755,831 when 9 || this Court grants this Stipulation. 10 16. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 11 || agrees to waive all constitutional, statutory, legal, equitable rights, defenses, and claims 12 || including, but not limited to, the stops, searches, seizures, and forfeiture of the $755,831 in 13 || any proceedings under the United States Constitution, Fourth Amendment. 14 17. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 15 || agrees to waive the statute of limitations; the CAFRA requirements; the Supplemental 16 || Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rule of 17 || Civil Procedure, (Supp. R.) A, G; other Federal Rules of Civil Procedure that are not 18 inconsistent with the Supp. Rules;' including, but not limited to, the seizing of, bringing the 19 || civil forfeiture in rem action against the $755,831; the filing of a verified complaint; service 20 || of process; this Court holding hearings, a bench trial or jury trial; this Court making factual 21 || findings; forfeiting the $755,831; and any and all constitutional, statutory, legal, equitable 22 || rights, defenses, and claims regarding seizing, bringing the civil forfeiture in rem action 23 || against the $755,831 in any proceedings, and forfeiting the $755,831, including, but not 24 || limited to, Double Jeopardy Clause and Due Process Clause under the United States 25 || Constitution, Fifth Amendment. 26 18. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 27 || agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and 28 Supp. R. A(1)-(2); Supp. R. G.
1 claims regarding seizing, bringing the civil forfeiture in rem action against, and forfeiting 2 || the $755,831 in any proceedings, including, but not limited to, a Jury Trial under the 3 || United States Constitution, Sixth Amendment. 4 19. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 5 || agrees to waive any and all constitutional, statutory, legal, equitable rights, defenses, and 6 || claims regarding the seizing of, bringing the civil forfeiture in rem action against, and 7 || forfeiting the $755,831 in any proceedings, including, but not limited to, the Excessive 8 || Fines Clause and the Cruel and Unusual Punishments Clause under the United States 9 || Constitution, Eighth Amendment. 10 20. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to waive any 11 || and all constitutional, statutory, legal, equitable rights, defenses, and claims to the property 12 any proceedings under Honeycutt v. United States, 137 S. Ct. 1626 (2017); United States v. 13 || Thompson, 990 F.3d 680 (9th Cir. 2021); and United States v. Prasad, 18 F.4th 313 (9th Cir. 14 2021) in any proceedings concerning the $755,831. 15 21. Oliver Jair Martinez-Mendez knowingly and voluntarily agrees to the entry of 16 || a Final Judgment of Forfeiture of the $755,831 to the United States. 17 22. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 18 || agrees to waive any rights to appeal this case. 19 23. Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 20 || agrees to hold harmless the United States of America, United States Department of Justice, 21 || United States Attorney’s Office for the District of Nevada, United States Drug 22 || Enforcement Administration, the United States Department of the Treasury, the Internal 23 Revenue Service-Criminal Investigation, San Bernardino County Sheriff's Department, 24 Bell Gardens Police Department, Riverside County Sheriffs Department, California 25 || Department of Alcoholic Beverage Control, Montclair Police Department, Ontario Police 26 || Department, Redlands Police Department, Rialto Police Department, San Bernardino 27 || Police Department, State of California, Las Vegas Metropolitan Police Department, City of 28 || North Las Vegas Police Department, Nevada Gaming Control Board Enforcement
1 || Division, the State of Nevada, their agencies, their agents, and their employees, from any 2 || claim made by him or any third party arising from the facts and circumstances of this case 3 || regarding the $755,831. 4 24, Oliver Jair Martinez-Mendez knowingly and voluntarily understands and 5 || agrees to release and forever discharge the United States of America, United States 6 || Department of Justice, United States Attorney’s Office for the District of Nevada, United 7 || States Drug Enforcement Administration, the United States Department of the Treasury, 8 || the Internal Revenue Service-Criminal Investigation, San Bernardino County Sheriff's 9 Department, Bell Gardens Police Department, Riverside County Sheriff's Department, 10 || California Department of Alcoholic Beverage Control, Montclair Police Department, 11 || Ontario Police Department, Redlands Police Department, Rialto Police Department, San 12 || Bernardino Police Department, State of California, Las Vegas Metropolitan Police 13 || Department, City of North Las Vegas Police Department, Nevada Gaming Control Board 14 || Enforcement Division, the State of Nevada, their agencies, their agents, and their 15 |jemployees, from any and all claims, rights, or causes of action of any kind that Oliver Jair 16 || Martinez-Mendez now has or may hereafter have on account of, or in any way growing 17 || out of the $755,831. 18 25. Oliver Jair Martinez-Mendez and his attorneys knowingly and voluntarily 19 || understand and agree that any issue of any other potential claimant must be resolved before 20 the United States District Court Chief Judge can enter the Final Judgment of Forfeiture. 21 26. Oliver Jair Martinez-Mendez and his attorneys knowingly and voluntarily 22 || understand and agree to the conditions in this Stipulation. 23 27. This Stipulation contains the entire agreement between the parties. 24 28. Except as expressly stated in this Stipulation, no party, entity, officer, agent, 25 employee, representative, or attorney has made any statement or representation to any other 26 || party, person, or entity regarding any fact relied upon in entering into this Stipulation, and 27 |\no party, entity, officer, agent, employee, representative, or attorney relies on such 28 || statement or representation in executing this Stipulation.
1 29, Each party acknowledges and warrants that its execution of this Stipulation is 2 || free and is voluntary. 3 30. The persons and entities who sign this Stipulation warrant and represent that 4 || they have full authority to execute this Stipulation and to bind the person or entity on 5 || whose behalf they are signing to the terms of this Stipulation. 6 31. This Stipulation shall be construed and interpreted according to federal 7 || forfeiture law and federal common law. The jurisdiction and the venue for any dispute 8 related to, and/or arising from, this Stipulation is the unofficial Southern Division of the 9 || United States District Court for the District of Nevada, located in Las Vegas, Nevada. 10 32. Each party shall bear his or its own attorneys’ fees, interest, expenses, and 11 || costs. The discretionary stipulation to settle this forfeiture case shall not be a basis for an 12 || award of attorneys’ fees, expenses, costs, and interest. 13 33. This Stipulation shall not be construed more strictly against one party than 14 || against the other merely by virtue of the fact that it may have been prepared primarily by 15 || counsel for one of the parties; it being recognized that both parties have contributed 16 || substantially and materially to the preparation of this Stipulation. 17 34. The parties knowingly and voluntarily agree that they may sign this Stipulation 18 ||in one or more counterparts in electronic or facsimile copies of this Stipulation that will be 19 || considered as a legal original and the signatures will be legal and binding. 20 1/7 / 21 ||//7/ 221/77 23 7 / 24 ||/// 25 1/77 26 // 27/77 28 ||///
I IT IS HEREBY CERTIFIED, pursuant to 28 U.S.C. § 2465(a}(2), that there was 2 {|reasonable cause for the seizure and forfeiture of the $755,831.
4 Wynn Law Group LZ — 5 OLIVER MARTINEZ-MENDEZ
7 || RICHARD WYNN, ESQ. 8 Dated: Dated: _ 03/07/19 TODD BLANCHE 10 Deputy Attorney General ll The Amin Law Group NV, Ltd.
—— DANIEL D. HOLLINGSWORTH ISMAIL AMIN, ESQ. Assistant United States Attorney 14 || Attorneys for Claimant Attorneys for the United States 5 Oliver Jair Martinez-Mendez
16 17 |} IT IS SO ORDERED: 18 Dated: 19 20 ANDREW P. GORDON CHIEF UNITED STATES DISTRICT COURT 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 cause for the seizure and forfeiture of the $755,831. 3 || Dated: Dated: 4 Wynn Law Group 5 OLIVER JAIR MARTINEZ-MENDEZ 6 Claimant 7 RICHARD WYNN, ESQ. 8 Dated: March 6, 2026 9 Dated: TODD BLANCHE 10 Deputy Attorney General ll The Amin Law Group NV, Ltd.
12 . . /s/ Daniel D. Hollingsworth 13 DANIEL D. HOLLINGSWORTH ISMAIL AMIN, ESQ. Assistant United States Attorney 14 || Attorneys for Claimant Attorneys for the United States Oliver Jair Martinez-Mendez
16 17 || IT IS SO ORDERED: 18 Dated: March 9, 2026 19 20 ANDREW P. GORDON CHIEF UNITED STATES DISTRICT COURT JUDGE
22 23 24 25 26 27 28