United States of America v. $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.
| United States of America |
| $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc. |
| RAM Investment Group, Inc. doing business as American International Export |
| Mohammad Awad and Ramon Martinez |
| 4:2021cv03973 |
| December 6, 2021 |
| US District Court for the Southern District of Texas |
| Alfred H Bennett |
| Forfeit/Penalty: Other |
| 18 U.S.C. § 0981 |
| None |
Docket Report
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This docket was last retrieved on December 22, 2021. A more recent docket listing may be available from PACER.
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| Filing 39 CERTIFICATE OF INTERESTED PARTIES by RAM Investment Group, Inc., filed.(Rohatgi, Poorav) |
| Filing 38 CERTIFICATE OF INTERESTED PARTIES by United States of America, filed.(Fyffe, Brandon) |
| Filing 37 NOTICE of attorney substitution by United States of America. Attorney Brandon L. Fyffe added. Attorney Cynthia Beckwith Smith terminated, filed. (Fyffe, Brandon) |
Filing 36
ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 3/11/2022 at 09:00 AM in Courtroom 8C before Judge Alfred H Bennett( Judge Alfred H Bennett) Parties notified.(BrendaLacy, 4)
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| Filing 35 Case transferred in from Georgia Northern. Case Number 1:21-cv-00740; certified copy of transfer order, certified docket sheet, and transfer letter received |
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Filing 34
ORDER granting #33 Motion to Change Venue. It is hereby ORDERED that his case be TRANSFERRED to the Southern District of Texas. Signed by Judge Mark H. Cohen on 12/3/21. (jpa)
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| Filing 33 Joint MOTION to Change Venue with Brief In Support by United States of America. (Attachments: #1 Brief In Support, #2 Text of Proposed Order)(Smith, Cynthia) |
| Civil Case Terminated. (jpa) |
| Filing 32 Notice for Leave of Absence for the following date(s): December 23, 2021, December 27, 2021 and December 29, 2021 through January 10, 2022, by Cynthia Beckwith Smith. (Smith, Cynthia) |
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Filing 31
ORDER granting #30 Motion to Stay. It is ORDERED that the above-referenced civil forfeiture action be stayed for ninety days. Signed by Judge Mark H. Cohen on 9/9/21. (jpa)
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| Filing 30 Joint MOTION to Stay Proceedings with Brief In Support by United States of America. (Attachments: #1 Brief Memorandum of Law in Support, #2 Text of Proposed Order)(Smith, Cynthia) |
| Filing 29 ANSWER to Complaint for Forfeiture by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. Discovery ends on 1/10/2022.(Maloy, W.) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. |
| Filing 28 TRANSCRIPT of the Motion to Dismiss Hearing Proceedings held on July 29, 2021, before Judge Mark H. Cohen. Court Reporter/Transcriber Judith M. Wolff. A full directory of court reporters and their contact information can be found at www.gand.uscourts.gov/directory-court-reporters. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/23/2021. Redacted Transcript Deadline set for 9/2/2021. Release of Transcript Restriction set for 11/1/2021. (Attachments: #1 Notice of Filing of Official Transcript) (kac) |
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Filing 27
ORDER DENYING the #19 Motion to Dismiss. Signed by Judge Mark H. Cohen on 7/29/21. (jpa)
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| Filing 26 Minute Entry for proceedings held before Judge Mark H. Cohen: Motion Hearing held on 7/29/2021 re #19 MOTION to Dismiss. The Court heard argument of the parties on the motion to dismiss. The Court took the matter under advisement and an order will be forthcoming. (Court Reporter Judith Wolff)(jpa) |
| Filing 25 Notice for Leave of Absence for the following date(s): 4/3/2022-4/25/2022, by W. Bruce Maloy. (Maloy, W.) |
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Filing 24
ORDER GRANTING the #20 Motion for Oral Argument. Oral argument shall be held on Claimant's #19 Motion to Dismiss & for Return of Property in Courtroom 1905 of the Richard B. Russell United States Courthouse, 75 Ted Turner Drive, S.W., Atlanta, Georgia, on July 29, 2021, at 10:30 a.m. Signed by Judge Mark H. Cohen on 6/29/21. (jpa)
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| NOTICE of Hearing on Motion re: #19 MOTION to Dismiss and for Return of Property. Motion Hearing set for 7/29/2021 at 10:30 AM in ATLA Courtroom 1905 before Judge Mark H. Cohen. (jpa) |
| Submission of #19 MOTION to Dismiss MOTION for Return of Property, #20 MOTION for Oral Argument , to District Judge Mark H. Cohen. (jpa) |
| Filing 23 REPLY to Response to Motion re #19 MOTION to Dismiss MOTION for Return of Property filed by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. (Maloy, W.) |
| Filing 22 RESPONSE in Opposition re #20 MOTION for Oral Argument , #19 MOTION to Dismiss MOTION for Return of Property filed by United States of America. (Smith, Cynthia) |
| Filing 21 Notice for Leave of Absence for the following date(s): June 7, 2021 through June 13, 2021; July 19, 2021 through July 23, 2021, by Cynthia Beckwith Smith. (Smith, Cynthia) |
| Notification of Docket Correction re #19 MOTION to Dismiss MOTION for Return of Property. Two part motion docketed as one. Added Motion for Return of Property. (jpa) |
| Filing 20 MOTION for Oral Argument by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. (Maloy, W.) |
| Filing 19 MOTION to Dismiss and MOTION for Return of Property by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc. (Maloy, W.) . Added MOTION for Return of Property on 5/4/2021 (jpa). |
| Clerks Notation re #17 Certificate of Interested Persons reviewed by MHC. (lwb) |
| Clerk's Certificate of Mailing re Order on Application for Admission PHV to Poorav Kumar Rohatgi. (adg) |
| APPROVAL by Clerks Office re: #15 APPLICATION for Admission of Poorav Kumar Rohatgi Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10896841). Attorney Poorav Kumar Rohatgi added appearing on behalf of RAM Investment Group, Inc. (cdg) |
| APPROVAL by Clerks Office re: #16 APPLICATION for Admission of David Benjamin Gerger Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10896879). Attorney David Gerger added appearing on behalf of RAM Investment Group, Inc. (cdg) |
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MINUTE ORDER granting #15 Application for Admission Pro Hac Vice of Poorav Kumar Rohatgi; and granting #16 Application for Admission Pro Hac Vice of David Benjamin Gerger by CRD at the direction of the Court. Approved by Judge Mark H. Cohen on April 15, 2021. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(lwb)
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MINUTE ORDER granting #14 Application for Admission Pro Hac Vice of Gus A. Saper by CRD at the direction of the Court. Approved by Judge Mark H. Cohen on April 14, 2021. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(lwb)
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| APPROVAL by Clerks Office re: #14 APPLICATION for Admission of Gus A. Saper Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10893857).. Attorney Gus A. Saper added appearing on behalf of RAM Investment Group, Inc. (nmb) |
| Filing 18 Verified Claim of American International Export by RAM Investment Group, Inc.. (Maloy, W.) Modified on 4/14/2021 to edit text (rlb). |
| Filing 17 Certificate of Interested Persons by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. (Maloy, W.) |
| Filing 16 APPLICATION for Admission of David Benjamin Gerger Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10896879).by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. (Maloy, W.) Documents for this entry are not available for viewing outside the courthouse. |
| Filing 15 APPLICATION for Admission of Poorav Kumar Rohatgi Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10896841).by $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc.. (Maloy, W.) Documents for this entry are not available for viewing outside the courthouse. |
| Filing 14 APPLICATION for Admission of Gus A. Saper Pro Hac Vice (Application fee $ 150, receipt number AGANDC-10893857) by RAM Investment Group, Inc.. (Maloy, W.) Documents for this entry are not available for viewing outside the courthouse. Modified on 4/13/2021 to edit filer and text (tmf). |
| Filing 13 NOTICE of Appearance by W. Bruce Maloy on behalf of claimant RAM Investment Group, Inc. d/b/a American International Export. (Maloy, W.) Modified on 4/13/2021 to edit filers, parties, and text(tmf). |
| Filing 12 NOTICE Of Filing Complaint for Forfeiture by United States of America sent to RAM Investments at Houston address (Smith, Cynthia) |
| Filing 11 NOTICE Of Filing Complaint for Forfeiture by United States of America sent to Ramon Martinez at Tomball Address (Smith, Cynthia) |
| Filing 10 NOTICE Of Filing Complaint for Forfeiture by United States of America sent to American International Export via Bruce Maloy (Smith, Cynthia) |
| Filing 9 NOTICE Of Filing Complaint for Forfeiture by United States of America sent to American International Export via David Gerger (Smith, Cynthia) |
| Filing 8 NOTICE Of Filing Complaint for Forfeiture by United States of America sent to Mohammad Awad at Houston address (Smith, Cynthia) |
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Filing 7
ELEVENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 03/09/2021 (adg) (ADI)
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| Filing 6 Return of Service Executed on 3/1/2021 for Warrant for Arrest in Rem. (Smith, Cynthia) |
| Filing 5 DOCUMENT FILED IN ERRORReturn of Service Executed on 3/1/2021 for Warrant for Arrest in Rem. (Sneed, Sekret) Per call from attorney 3/2/21, doc. to be re-filed. (fem). |
| Filing 4 WARRANT FOR ARREST IN REM as to Defendant $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc. filed by United States of America. (aaq) |
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Filing 3
STANDING ORDER regarding civil litigation. Signed by Judge Mark H. Cohen on 2/23/21. (jpa)
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Filing 2
TENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 1/27/21. (ddm)
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| Filing 1 COMPLAINT for Forfeiture filed by United States of America. (Attachments: #1 Civil Cover Sheet)(ddm) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. |
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| Plaintiff: United States of America | |
| Represented By: | Cynthia Beckwith Smith |
| Represented By: | Brandon L. Fyffe |
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| Defendant: $2,744,739.17 in funds seized from Bank of America Account Number XXXXXX4215 in the name American International Export, Inc. | |
| Represented By: | W. Bruce Maloy |
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| Claimant: RAM Investment Group, Inc. doing business as American International Export | |
| Represented By: | David Gerger |
| Represented By: | Gus A Saper |
| Represented By: | Poorav Kumar Rohatgi |
| Represented By: | W. Bruce Maloy |
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| Interested party: Mohammad Awad | |
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| Interested party: Ramon Martinez | |
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