Motion by Francesco Distefano for return of property Unopposed — USA v. Distefano (Dkt. 69, N.D. Ill.)

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An Unopposed Motion for Return of Property, Document #: 69, filed 04/30/25 by Defendant Francesco Distefano in United States of America v. Francesco Distefano, No. 24-cr-00424, Northern District of Illinois, Eastern Division. The motion states that on September 11, 2024 the Defendant was arrested at O'Hare airport by agents of the FBI, who seized and inventoried personal property. It states that a Freedom of Information Request filed in 2021 kept the FBI from returning the property without a withdrawal, and that a letter withdrawing it is attached as Exhibit 2. The listed items include cash [$2,125], an Apple laptop, an Apple iPhone and a wallet. The motion states that Assistant United States Attorney Jeffrey Snell does not oppose it, and /s/ Robert A. Fisher signs it.

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Case: 1:24-cr-00424 Document #: 69 Filed: 04/30/25 Page 1 of 2 PagelD #:293

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
-v- ) No. 24-cr-00424
) Judge Daniel
FRANCESCO DISTEFANO, ) Magistrate Judge Cole
)
Defendant. )

UNOPPOSED MOTION FOR RETURN OF PROPERTY

NOW COMES the Defendant, FRANCESCO DISTEFANO, by and through counsel,
and moves this honorable court for an Order for return of personal property which was seized at
the time of his arrest. In support of his Morion, defendant states as follows:

1. On September 11, 2024, Defendant was arrested at O’Hare airport by agents of
the FBI. At the time of his arrest agents seized and inventoried defendant’s personal property.
A list of defendant’s property inventoried by the FBI is attached to this motion and marked as
Exhibit 1.

2. In 2021 while under investigation, defendant filed a Freedom of Information
Request for information related to the investigation. As a result of that FOIA request, the FBI
is unable to return the property without a defendant withdrawing the FOIA request.
Defendant’s counsel provided, a letter withdrawing the FOIA request, which included
language requested by FBI counsel. The letter withdrawing the FIOA request is attached and
marked as Exhibit 2.

3. Counsel for the defendant has now been informed that a court Order to return the

property would facilitate its return. Among the items contained in the property is defendant’s

wallet which contains his identification, necessary to get medical attention and even to enter
Case: 1:24-cr-00424 Document #: 69 Filed: 04/30/25 Page 2 of 2 PagelD #:294

the Dirksen building to attend court. The items to be returned are as follows:

item # Description

1B10 (U) Cash [$2,125]

1B9 (U) 9 Laptop Case
10 Apple Laptop and Cord - Serial HT4J7QV7NG, model A2681

1B8 (U) 8 Wallets and credit cards

1B7 (U) 6 Apple iPhone - Francesco Distefano

1B6 (U) 1 Illinois Identification Card for Francesco Distefano
2 Illinois Driver's License for Francesco Distefano

1B5 (U) Black Louis Vuitton Duffle Bag containing clothing and other general
miscellaneous items.

4. The government, through Assistant United States Attorney Jeffrey Snell does not
oppose the court granting the relief requested in this Motion. AUSA Snell has discussed the
property return with the case agent from the FBI.

WHEREFORE, Defendant respectfully requests that the Court enter an Order
authorizing the FBI to return defendant’s property listed above in Paragraph 3, to

defendant or his counsel.

Respectfully submitted,

/s/ Robert A. Fisher

Robert A. Fisher

One of the attorneys for
FRANCESCO DISTEFANO

Robert A. Fisher

FISHERLEVINE LAW GROUP LLP
20 South Clark Street, Suite 700
Chicago, Illinois 60603

(312) 372-8888
raf@fisherlevinelaw.com

Barry A. Spevack

MONICO & SPEVACK LLC

53 West Jackson Blvd. Suite 1315
Chicago, Illinois 60604
312-782-8500
bspevack@monicolaw.com


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