Case 2:24-cr-00383-HCN-CMR Document 54 Filed 08/11/25 PageID.230 Page 1
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FELICE JOHN VITI, Acting United States Attorney (7007)
CAROL A. DAIN, Assistant United States Attorney (10065)
TRAVIS K. ELDER, Assistant United States Attorney (11987)
Attorneys for the United States of America
111 South Main Street, Suite 1800, Salt Lake City, Utah 84111
(801) 524-5682 | Carol.Dain@usdoj.gov | Travis.Elder@usdoj.gov
UNITED STATES DISTRICT COURT
DISTRICT OF UTAH
UNITED STATES OF AMERICA, JOINT STIPULATION REGARDING
FORFEITURE DETERMINATION
Plaintiff,
Case No. 2:24-cr-00383-RJS
vs.
Chief Judge Robert J. Shelby
BRENT RICHARD JOHNSON,
Defendant.
The United States of America and Defendant Brent Richard Johnson agree as follows:
1. The Indictment includes a forfeiture notice advising the defendants that the
United States is seeking forfeiture of specific property. ECF 1.
2. Under Rule 32.2(b)(5) of the Federal Rules of Criminal Procedure, either plaintiff
or defendant may request to have the jury retained to determine the forfeitability of specific
property upon a guilty verdict. The “court must determine before the jury begins deliberating
whether either party requests that the jury be retained to determine the forfeitability of specific
property if it returns a guilty verdict.” Rule 32.2(b)(5)(A).
3. The parties agree that the Court may decide whether the United States has
established the requisite nexus between the forfeitable property and the offenses, and the jury
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does not need to be retained to determine forfeitability. Since a forfeiture phase of the trial will
not be necessary, the parties will not provide forfeiture jury instructions to the Court.
4. Within a reasonable time after a verdict of guilt, the United States will submit a
motion for order of forfeiture, which can be resolved in the ordinary course of post-trial
proceedings.
Respectfully submitted,
FELICE JOHN VITI
Acting United States Attorney
/s/ Travis K. Elder
TRAVIS K. ELDER
CAROL A. DAIN
Assistant U.S. Attorneys
/s/ Craig R. Johnson
CRAIG R. JOHNSON
Attorney for Mr. Johnson
(signed with permission)
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