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Court filing — United States v. Farah (Dkt. 904, D. Minn.)

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      CASE 0:22-cr-00124-NEB-DTS        Doc. 904   Filed 10/03/25   Page 1 of 3




                        UNITED STATES DISTRICT COURT
                           DISTRICT OF MINNESOTA

UNITED STATES OF AMERICA,
                                                    Case No. 22-cr-124 (NEB/DTS)
               Plaintiff,
                                                  FIRST MOTION FOR FIRST
       v.                                     FINAL ORDER OF FORFEITURE

2. MOHAMED JAMA ISMAIL,

               Defendant.

      The United States of America, through Joseph H. Thompson, Acting United

States Attorney for the District of Minnesota, and Craig R. Baune, Assistant United

States Attorney, respectfully moves this Court for a Final Order of Forfeiture for the

following property:

            a. $424,695.03 seized from US Bank account No. 104786619932, held in
               the name of Empire Cuisine and Market LLC;

            b. $4,000,422.57 seized from JP Morgan Chase Bank account No.
               761580833, held in the name of Empire Cuisine and Market LLC;

            c. $5,192.25 seized from Wells Fargo account No. 5674871586, held in
               the name of Mohamed Ismail;

            d. $4,000,422.57 seized from JP Morgan Chase Bank account No.
               761580833, held in the name of Empire Cuisine and Market LLC; and

            e. $5,192.25 seized from Wells Fargo account No. 5674871586, held in
               the name of Mohamed Ismail (collectively, “the Property”).

                                 I. BACKGROUND

      On September 27, 2024, this Court entered a Preliminary Order of Forfeiture

pursuant to 18 U.S.C. 981(a)(1)(C) in conjunction with 28 U.S.C. § 2461(c), and 18

U.S.C. § 982(a)(1), against Defendant Mohamed Jama Ismail. ECF No. 666. The
      CASE 0:22-cr-00124-NEB-DTS          Doc. 904    Filed 10/03/25    Page 2 of 3




Order was based on the United States’ Motion for Preliminary Order of Forfeiture, the

evidence admitted at trial, the jury’s verdict regarding guilt, and the Declaration of

Lacramioara Blackwell.

       Pursuant to 21 U.S.C. § 853(n), third parties asserting a legal interest in the

Property are entitled to a judicial determination of the validity of the legal claims or

interests they assert.

       The United States published notice of the Court’s Preliminary Order of

Forfeiture on an official government internet site (www.forfeiture.gov) for at least 30

consecutive days, beginning on October 16, 2024, in accordance with Rule

G(4)(a)(iv)(C) of the Supplemental Rules for Admiralty or Maritime Claims and Asset

Forfeiture Actions. ECF Nos. 761, 762. The notice of forfeiture advised all unknown

interested third parties of their right to petition the court within 60 days from the first

date of publication for a hearing to adjudicate the validity of the alleged legal interest

in the Property.

       The United States also served notice of the forfeiture on Defendant Ismail’s

spouse, Deqa Yusuf, who filed a petition asserting an interest in the real property

located at 13825 Edgewood Avenue, South, Savage, Minnesota. ECF No. 879.

Because a petition is pending with respect to that property, it is not included in this

motion and will instead be addressed at a later date.

       No other third-party has made any claim or declared any interest in the

Property, and the time for filing a petition has expired. Pursuant to 21 U.S.C.

§ 853(n)(7), following the disposition of all third-party petitions, or following the

                                            2
      CASE 0:22-cr-00124-NEB-DTS           Doc. 904     Filed 10/03/25    Page 3 of 3




expiration of the time period provided by law for filing such petitions, the United States

shall have clear title to the property that is the subject of the order of forfeiture.

       Accordingly, the United States moves for a Final Order of Forfeiture vesting

full right, title and interest in the Property in the United States and declaring the

Property forfeited for disposition in accordance with law.

                                                  Respectfully submitted,

Dated: 10/3/2025                                  JOSEPH H. THOMPSON
                                                  Acting United States Attorney

                                                  s/Craig Baune
                                                  BY: CRAIG R. BAUNE
                                                  Assistant U.S. Attorney
                                                  Attorney ID No. 331727
                                                  600 United States Courthouse
                                                  300 South Fourth Street
                                                  Minneapolis, MN 55415
                                                  Phone: 612-664-5600
                                                  Craig.baune@usdoj.gov




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