MOTION re bond 66 , forfeiture agreement 68 Motion to Exonerate Bond — USA v. Distefano (Dkt. 100)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:24-cr-00424 · Doc. 100 · 2026-01-21 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
 
NORTHERN DISTRICT OF ILLINOIS 
 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA 
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) 
No.  24 CR 424 
 
 
 
 
 
 
 
 
 
) 
 
) 
Judge Jeremy C. Daniel 
FRANCESCO DISTEFANO 
 
) 
 
 
 
 
 
 
) 
 
 
GOVERNMENT'S UNOPPOSED MOTION 
 
TO EXONERATE BOND 
 
The United States of America by its attorney, ANDREW S. BOUTROS, United 
States Attorney of the Northern District of Illinois, respectfully moves as follows: 
1. 
Pursuant to a Pre-Trial Release Order entered April 24, 2025, Sam 
Distefano and Connie Distefano, as Trustees of the Distefano Family Living Trust 
Dated the 5th day of December, 2016, posted their interest in certain real property to 
secure the defendant’s release on bond. As a result, the property was encumbered 
pending the defendant’s completion of the bond requirements.  
2. 
As the defendant’s bond was subsequently revoked, and he was 
remanded to the custody of the U.S. Marshal, the government hereby submits this 
motion to exonerate the bond. In addition, the government requests that this Court 
order the release of any liens or other encumbrances lodged against the real property 
as it relates to this bond and further order that the quit claim deeds executed in favor 
of the United States of America, currently held in the custody of the Clerk of the 
Case: 1:24-cr-00424 Document #: 100 Filed: 01/21/26 Page 1 of 2 PageID #:422

United States District Court, Northern District of Illinois, be returned to the sureties 
at the property address. 
3.  Defendant=s counsel has been contacted regarding this motion and counsel 
has no objection to the motion or the entry of the Order. 
WHEREFORE, the government respectfully requests this Court exonerate the 
bond posted in this case. 
 
Respectfully submitted, 
 
ANDREW S. BOUTROS 
United States Attorney 
 
 
By: 
/s/ Jeffrey S. Snell 
JEFFREY S. SNELL  
Assistant U.S. Attorney 
219 S. Dearborn St., Room 500 
Chicago, Illinois  60604 
(312) 469-6308 
Case: 1:24-cr-00424 Document #: 100 Filed: 01/21/26 Page 2 of 2 PageID #:423

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