Agreed motion to extend third-party forfeiture petition deadline

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:24-cr-00424 · Doc. 144 · 2026-09-16 · Docket on CourtListener

Full text

   Case: 1:24-cr-00424 Document #: 144 Filed: 09/16/26 Page 1 of 3 PageID #:1226




                     UNITED STATES DISTRICT COURT
                     NORTHERN DISTRICT OF ILLINOIS
                           EASTERN DIVISION

 UNITED STATES OF AMERICA,                    )
                                              )
 vs.                                          ) No. 1:24-cr-00424
                                              )
 SARGIS URUMIEH,                              )
                                              )
                                              ) Judge Jeremy C. Daniel
                                              )
                                              )


AGREED MOTION FOR EXTENSION OF TIME FOR REZA SAFAEEJAVED
     TO FILE HIS PETITION PURSUANT TO 21 U.S.C. §853(n)(2)

       NOW    COMES      the   UNITED      STATES      OF   AMERICA       and   REZA

SAFAEEJAVED, an interested party in this action, by and through their undersigned

attorneys, and for their Agreed Motion for an Extension of Time, and respectfully

move this Court to enter an Order granting REZA SAFAEEJAVED an extension up

to and including November 15, 2026, to file a Petition with this Court for adjudication

of interest in the property located at 2911 East Chevy Chase Drive, Glendale,

California 91206, in accordance with 21 U.S.C. §853(n)(2). In support of this Motion,

REZA SAFAEEJAVED states as follows:

       1.    Mr. Safaeejaved retained Hinshaw and Culbertson, LLP as counsel on

or about September 11, 2026.

       2.    Mr. Safaeejaved’s counsel hereby requests a 60-day extension of the

current deadline of September 16, 2026, to file a Petition under 21 U.S.C. § 853(n)(2),

up to and including November 15, 2026. This additional time is needed to further

analyze the underlying facts surrounding the forfeiture of the subject property, to
   Case: 1:24-cr-00424 Document #: 144 Filed: 09/16/26 Page 2 of 3 PageID #:1227




receive and review appropriate documentation from our clients, further discuss this

matter with the U.S. Attorney’s Office as necessary, and prepare and file the Petition.

      3.     This is Mr. Safaeejaved’s first request for additional time to file such a

Petition.

      4.     Counsel for Mr. Safaeejaved contacted counsel for the United States of

America on September 11, 2026, and the government is unopposed to the relief sought

in this motion and is filing this motion as an agreed motion with an accompanying

proposed order.

      5.     This Motion is not brought for any improper purpose and granting this

Motion will not prejudice any party, nor will it delay this matter.

      For the reasons stated above, it is respectfully requested that this Court enter

an order granting Mr. Safaeejaved an extension of time, up to and including

November 15, 2026, in which to file his Petition for adjudication of interest in the

property located at 2911 East Chevy Chase Drive, Glendale, California 91206, in

accordance with 21 U.S.C. § 853(n)(2).

RESPECTFULLY SUBMITTED:

 /s/ Sarah E. King                             ANDREW S. BOUTROS
 Sarah E. King                                 United States Attorney
 Hinshaw & Culbertson LLP
 151 North Franklin Street, Suite 2500,        By: /s/Jeffrey S. Snell
 Chicago, IL 60606                             JEFFREY S. SNELL
 Attorney for Interested Party, Reza           Assistant United States Attorney
 Safaeejaved                                   219 S. Dearborn Street, Rm. 500
                                               Chicago, Illinois 60604
                                               (312) 469-6308


Dated: September 16, 2026



                                           2
   Case: 1:24-cr-00424 Document #: 144 Filed: 09/16/26 Page 3 of 3 PageID #:1228




                          CERTIFICATE OF SERVICE

      The undersigned hereby certifies that a true and correct copy of the foregoing
document was electronically filed and served electronically via the Court’s ECF
system on all parties receiving ECF notices, on this 16th day of September 2026.

                                       /s/ Jeffrey S. Snell




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