Exhibit A (Direct Notices and Delivery Confirmations) — USA v. Lorquet (Dkt. 143-1, S.D. Fla.)

Summary

Document 143-1, Exhibit A in United States v. Andre Lorquet, Case 1:22-cr-20326-KMM in the U.S. District Court for the Southern District of Florida, was entered on the docket July 15, 2024 and opens with a March 21, 2024 letter from Assistant United States Attorney Gabrielle Raemy Charest-Turken to Elite Motor Cars of Miami giving notice of forfeiture and of the 21 U.S.C. § 853(n) claim procedure. The enclosed notice lists a 2022 Tesla Plaid, approximately $100,358.73 in insurance proceeds for a 2019 Porsche Panamera GTS and $108,050.65 in an account of The B Murray Group LLC, and the enclosed February 23, 2023 order (Document 52) enters a forfeiture money judgment of $329,195 against the defendant.

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Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 1 of 8
U.S. Department of Justice

United States Attorney

Southern District of Florida
99 NE. 4 Street
Miami, FL 33132
Telephone (305) 961-9007
Facsimile (305) 536-4089
March 21, 2024
VIA FEDERAL EXPRESS
Fed Ex # 775640791251
Elite Motor Cars of Miami
5700 NW 27" Avenue

Miami, Florida 33142

Re: Notice of Forfeiture in: United States v. Andre Lorquet
Criminal Case No.: 22-CR-20326-KMM

To Whom It May Concern:

The U.S. District Court for the Southern District of Florida has ordered that certain property
in the above-referenced criminal case be forfeited to the United States. The enclosed published
Notice of Forfeiture and Preliminary Order of Forfeiture describe the forfeited property and the
procedure for filing a petition to claim any of the forfeited property. By receipt of this letter, you
are on actual notice of the forfeiture and of your right to assert a claim. This letter is not intended
to imply that the United States believes that you have a valid claim to any of the forfeited property.

The procedure for filing a claim is set forth more fully in 21 U.S.C. § 853(n). Under 21
U.S.C. § 853(n)\(2), a person must file a petition in the criminal case claiming forfeited property
within thirty (30) days of the receipt of this letter or within 60 days of the first date of publication
of the Notice of Forfeiture, whichever is earlier.

Sincerely,

“G. Raemy Charest-
Assistant United States Attorney
Telephone: 305-961-9365
Gabrielle.Charest-Turken@usdoj.gov

Enclosures: (1) Published Notice on Forfeiture (2) Preliminary Order of Forfeiture

GCT/ec

EXHIBIT A
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 2 of 8
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
COURT CASE NUMBER: 22-CR-20326-MOORE; NOTICE OF FORFEITURE

Notice is hereby given that on February 23, 2023, in the case of U.S. v. ANDRE
LORQUET, Court Case Number 22-CR-20326-MOORE, the United States District Court
for the Southern District of Florida entered an Order condemning and forfeiting the
following property to the United States of America:

One (1) 2022 Tesla Plaid, VIN# 5YJSA1E66NF460071. (22-ICE-002552)

Approximately $100,358.73 in insurance proceeds from Coast National Insurance
for one (1) 2019 Porsche Panamera GTS, VIN# WPO0AG2A77KL139387.
(22-ICE-002976)

$108,050.65 in U.S. currency in Bank of America account number 8981 0729
7999 in the name of The B Murray Group LLC. (23-ICE-002518)

The United States hereby gives notice of its intent to dispose of the forfeited
property in such manner as the United States Attorney General may direct. Any person,
other than the defendant(s) in this case, claiming interest in the forfeited property must
file an ancillary petition within 60 days of the first date of publication (March 21, 2024) of
this Notice on this official government internet web site, pursuant to Rule 32.2 of the
Federal Rules of Criminal Procedure and 21 U.S.C. § 853(n)(1). The ancillary petition
must be filed with the Clerk of the Court, 400 North Miami Avenue, Room 8NO9, Miami,
FL 33128, and a copy served upon Assistant United States Attorney Gabrielle Raemy
Charest-Turken, 99 N.E. 4th Street, Miami, FL 33132. The ancillary petition shall be
signed by the petitioner under penalty of perjury and shall set forth the nature and extent
of the petitioner's right, title or interest in the forfeited property, the time and
circumstances of the petitioner's acquisition of the right, title and interest in the forfeited
property and any additional facts supporting the petitioner's claim and the relief sought,
pursuant to 21 U.S.C. § 853(n).

Following the Court's disposition of all ancillary petitions filed, or if no such
petitions are filed, following the expiration of the period specified above for the filing of
such ancillary petitions, the United States shall have clear title to the property and may
warrant good title to any subsequent purchaser or transferee.

The government may also consider granting petitions for remission or
mitigation, which pardon all or part of the property from the forfeiture. A petition must
include a description of your interest in the property supported by documentation;
include any facts you believe justify the return of the property; and be signed under
oath, subject to the penalty of perjury, or meet the requirements of an unsworn
statement under penalty of perjury. See 28 U.S.C. Section 1746. For the regulations
pertaining to remission or mitigation of the forfeiture, see 28 C.F.R. Sections 9.1 - 9.9.
The criteria for remission of the forfeiture are found at 28 C.F.R. Section 9.5(a). The
criteria for mitigation of the forfeiture are found at 28 C.F.R. Section 9.5(b). The
petition for remission need not be made in any particular form and may be filed online
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 3 of 8
or in writing. You should file a petition for remission not later than 11:59 PM EST 30
days after the date of final publication of this notice. See 28 C.F.R. Section 9.3(a).
The https://www. forfeiture .gov/FilingPetition.htm website provides access to a
standard petition for remission form that may be mailed and the link to file a petition
for remission online. If you cannot find the desired assets online, you must file your
petition for remission in writing by sending it to Assistant United States Attorney
Gabrielle Raemy Charest-Turken, 99 N.E. 4th Street, Miami, FL 33132. This website
provides answers to frequently asked questions (FAQs) about filing a petition for
remission. You may file both an ancillary petition with the court and a petition for
remission or mitigation.
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 4 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. 1:22-cr-20326-KMM
UNITED STATES OF AMERICA,

V.

ANDRE LORQUET,

Defendant.

ORDER

THIS CAUSE came before the Court upon the Government’s Motion for Preliminary
Order of Forfeiture. (“Mot.”) (ECF No. 51). Therein, the Government requests this Court’s entry
of preliminary order for a forfeiture money judgment in the amount of $329,195.00, as well as the
forfeiture “of certain property in satisfaction thereof, including but not limited to: $92,000 in Bank
of America account number 8981 0729 7999 in the name of The B Murray Group; one (1) 2022
Tesla Plaid, VIN# 5YJSA1E66NF460071; and approximately $100,358.73 in insurance proceeds
for one (1) 2019 Porsche Panamera GTS, VIN4# WPOAG2A77KL139387.” Jd. at 1. Defendant
does not oppose the Government’s motion. Jd. at 7.

UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being
otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the
Motion (ECF No. 51) is GRANTED. It is further ORDERED that:

1. Pursuant to 18 U.S.C. § 982(a)(1), 21 U.S.C. § 853, and Rule 32.2 of the Federal Rules of

Criminal Procedure, a forfeiture money judgment in the amount of $329,195 is hereby

entered against the Defendant.
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 5 of 8
Case 1:22-cr-20326-KMM Document 52 Entered on FLSD Docket 02/23/2023 Page 2 of 3

2. Pursuant to 18 U.S.C. § 982(a)(1), the following specific property is hereby forfeited and
vested in the United States of America, and should be forfeited to satisfy the forfeiture
money judgment:

a. Approximately $92,000 in U.S. currency in Bank of America account number 8981
0729 7999 in the name of The B Murray Group LLC.

3. Pursuant to 21 U.S.C. § 853(p), the following substitute property is hereby forfeited and
vested in the United States of America, and should be forfeited to satisfy the forfeiture
money judgment:

a. One (1) 2022 Tesla Plaid, VIN# SYJSA1E66NF460071; and
b. Approximately $100,358.73 in insurance proceeds from Coast National Insurance
for one (1) 2019 Porsche Panamera GTS, VIN# WPOAG2A77KL1 39387.

4. Any duly authorized law enforcement agency may seize and take possession of the
forfeited property according to law.

5. The United States shall send and publish notice of the forfeiture in accordance with Rule
32.2(b)(6) of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(n).

6. The United States is authorized to conduct any discovery that might be necessary to
identify, locate, or dispose of forfeited property, and to resolve any third-party petition,
pursuant to Rule 32.2(b)(3), (c)(1)(B) of the Federal Rules of Criminal Procedure and 21
U.S.C. § 853(m).

7. Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal Procedure, this Order is final
as to the Defendant.

8. The Court shall retain jurisdiction in this matter for the purpose of enforcing this Order,

and pursuant to Rule 32.2(e)(1) of the Federal Rules of Criminal Procedure, shall amend
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 6 of 8
Case 1:22-cr-20326-KMM Document 52 Entered on FLSD Docket 02/23/2023 Page 3 of 3

this Order, or enter other orders as necessary, to forfeit additional specific property when

identified.

It is further ORDERED that upon adjudication of all third-party interests, if any, the Court
will enter a final order of forfeiture as to the property in which all interests will be addressed.
Upon notice from the United States that no claims have been filed within 60 days of the first day
of publication or within 30 days of receipt of notice, whichever is earlier, then, pursuant to Rule
32.2(c)(2) of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(n)(7), this Order shall
become a Final Order of Forfeiture and any duly authorized law enforcement agency shall dispose
of the property in accordance with applicable law.

DONE AND ORDERED in Chambers at Miami, Florida, this 23rd day of February, 2023.

Kye

K. MICHAEL MOORE
UNITED STATES DISTRICT JUDGE

Cc: All counsel of record
Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 7 of 8
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Case 1:22-cr-20326-KMM   Document 143-1   Entered on FLSD Docket 07/15/2024   Page 8 of 8
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