Notice of Recording of Lis Pendens - Document 11, Gurjeet Bath (Eastern District of California, 11/20/24)

Summary

This is a second Notice of Recording of Lis Pendens filed 11/20/24 in United States v. Gurjeet Bath, Case No. 1:24-CR-00198-JLT-SKO, in the Eastern District of California. Assistant United States Attorney Jeffrey A. Spivak states that on November 14, 2024, the United States recorded a Lis Pendens with the Fresno County Recorder for real property in Fresno County, near Laton, California. The attached Lis Pendens Notice of Pending Action names Gurjeet Singh Bath as the recorded owner and gives the object of the action as criminal prosecution and criminal forfeiture of the property to the United States. It includes a legal description of two tracts with exceptions for oil, gas and mineral rights. The certificate of service by certified mail lists Terra dos Sonhos, LLC and C.L. Services, Inc.

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Text recognized from a scanned document; may contain errors. Page 3 of 9 is not shown because the text could not be recognized reliably.

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Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Pageiof9

PHILLIP A. TALBERT

United States Attorney
JEFFREY A. SPIVAK
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, CA 93721

Telephone: (559) 497-4000
Facsimile: (559) 497-4099

Attorneys for Plaintiff
United States of America

IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,
Plaintiff,
v.
GURJEET BATH,
Defendant.

CASE NO. 1:24-CR-00198-JLT-SKO
NOTICE OF RECORDING OF LIS PENDENS

NOTICE IS HEREBY GIVEN, that on November 14, 2024, the United States recorded a Lis

Pendens with the Fresno County Recorder, as Document Number 2024-0105754 for real property

located in Fresno County at 18670 South Elm Avenue, Laton, California, APNs: 055-310-15 and 055-

021-18.

A true and correct copy of the recorded Lis Pendens is attached hereto as Exhibit A.

Dated: November 20, 2024

NOTICE OF RECORDING OF LIS PENDENS

PHILLIP A. TALBERT
United States Attorney

/s/ Jeffrey A. Spivak
JEFFREY A. SPIVAK
Assistant U.S. Attorney
Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Page 2of9

CERTIFICATE OF SERVICE BY MAIL

The undersigned hereby certifies that she is an employee in the Office of the United States
Attorney for the Eastern District of California and is a person of such age and discretion to be competent
to serve papers.

That on November 20, 2024, she served a copy of the Notice of Recording of Lis Pendens by
placing said copy ina postpaid envelope addressed via first class mail to the persons hereinafter named,
at the places and addresses stated below, which are the last known addresses, and by depositing said

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envelope and contents in the United States Mail at Fresno, California.

Addressee(s):

Jesse P. Silva Jr.
Joseph V. Silva
Helena M. Silva
760 N. Cherry Lane
Clovis, CA 93611

William L. Alexander
Alexander & Association, PLC
1925 G Street
Bakersfield, CA 93301
[Attorney for Terra dos Sonhos, LLC]

C.L. Services, Inc.
a Georgia Corporation
c/o Nikole E. Cunningham
McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
7647 N. Fresno Street
Fresno, CA 93720

Adriana Martinez
Felipe Gallegos Barrios
18648 S. Elm Avenue
Riverdale, CA 93656

NOTICE OF RECORDING OF LIS PENDENS
Case 1:24-cr-00198-JLT-SKO Document 11FreSiledolihtvNedbrdeP age 4 of 9
Paul Dictos, CPA

Recording Requested by Recorded at the request of:
Simplifile on behalf of: SIMPLIFILE, PROVO
UNITED STATES 11/14/2024 02:55 55
Titles: 1 Pages: 6
Fees: $34.00
Original prepared by: CA SB2 Fees:$0.00
. , . Taxes: $0.00
United States Attorney’s Office Total: $34.00

NAME: Attn: Asset Forfeiture Unit

ADDRESS 2500 Tulare Street, Suite 4401

CITY, Fresno, California 93721
STATE, ZIP (559) 497-4000

Exempt from fees per Government Code Sections 6103 and 27383

WA Exempt from SB2 fees per Government Code Section 27388.1(a)(2)(D)

LIS PENDENS NOTICE OF PENDING ACTION
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DOC #2024-0105754 Page 2 of 6
Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Page5of9

PHILLIP A. TALBERT

United States Attorney
JEFFREY A. SPIVAK
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, CA 93721

Telephone: (559) 497-4000
Facsimile: (559) 497-4099

Attorneys for Plaintiff
United States of America

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, CASE NO. 1:24-CR-00198-JLT-SKO

Plaintiff, LIS PENDENS NOTICE OF PENDING ACTION
[California Code of Civil Procedure § 405]

Recorded Owner: Gurjeet Singh Bath
GURJEET BATH,

Defendant.

NOTICE IS HEREBY GIVEN, pursuant to Section 405 of the California Code of Civil
Procedure, that the above-entitled action concerns and affects the following real property located at
18670 South Elm Avenue, Laton, California, Fresno County, APNs: 055-310-15 and 055-021-18, and
more fully described in Exhibit A, attached hereto.

Said action was commenced on August 15, 2024, in the above-named court by the United States
of America, plaintiff, against Gurjeet Bath. Said action is now pending in the above-named court.

The object of plaintiffs action is the criminal prosecution of Gurjeet, and the criminal forfeiture
of the above-referenced real property to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) and 28

U.S.C. § 2461(c). Gurjeet Singh Bath is the recorded owner of the above-referenced real property.

If the plaintiffs action is successful, title to the subject property will vest in the United States

LIS PENDENS NOTICE OF PENDING ACTION
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DOC #2024-0105754 Page 3 of 6
Case 1:24-cr-00198-JLT-SKO Document11 Filed 11/20/24 Page6of9

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

Dated: __/'| o /7 & PHILLIP A. TALBERT
Po United States Attorney

By: A + Zao za

JEFFREYA. SPIVAK
Assistant United States Attorney

ACKNOWLEDGMENT

A notary public or other officer completing this certificate verifies only the identity of the individual
who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or
validity of that document.

State of California )

County of Fresno )

On_|! | u| aH , before me, (gvh a2 (Che AS ;
Notary Public, personally appeared Jeffrey A. Spivak, who proved to me on the basis of satisfactory
evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged
to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by
his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the
person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct.

WITNESS my hand and official seal.

Signature

COMM. #2873324
Notary Public - California’

Fresno Gounty
Comm: Expires Sap. 2, 2026

LIS PENDENS NOTICE OF PENDING ACTION
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DOC #2024-0105754 Page 4 of
Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Page/7of9

Exhibit A

THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE COUNTY OF FRESNO,
STATE OF CALIFORNIA, AND IS DESCRIBED AS FOLLOWS:

TRACT ONE: (APN: 055-310-15)

THAT PORTION OF SECTION 15, IN TOWNSHIP 17 SOUTH, RANGE 20 EAST, MOUNT
DIABLO BASE AND MERIDIAN, IN THE COUNTY OF FRESNO, STATE OF CALIFORNIA,
LYING NORTHERLY AND EASTERLY OF LAGUNA DE TACHE GRANT, AND WESTERLY OF
A LINE DESCRIBED AS BEGINNING 772.72 FEET EASTERLY OF THE NORTHWEST OF SAID
SECTION THENCE SOUTH 8° 06' 51" WEST 575,83 FEET TO THE NORTHERLY LINE OF
LAGUNA DE TACHE GRANT ALSO THAT PORTION OF SECTION 10, IN TOWNSHIP 17
SOUTH, RANGE 20 EAST, MOUNT DIABLO BASE AND MERIDIAN, LYING NORTHERLY OF
MURPHY SLOUGH DESCRIBED AS FOLLOWS: BEGINNING AT THE SOUTHWEST CORNER
OF SAID SECTION 10, THENCE NORTH 1650 FEET TO A POINT ON THE SOUTH LINE OF
THE NORTH HALF OF THE SOUTH HALF OF THE NORTHWEST QUARTER OF THE
SOUTHWEST QUARTER OF SAID SECTION 10, THENCE EAST 1688 FEET THENCE
SOUTHERLY 1650 FEET THENCE WEST 1691 FEET TO THE POINT OF BEGINNING.

EXCEPTING THEREFROM THAT PORTION LYING EASTERLY OF THE WESTERLY
BOUNDARY LINE OF THAT CERTAIN PARCEL OF LAND GRANTED TO THE STATE OF
CALIFORNIA IN DEEDS RECORDED MAY 1, 1963 AS DOCUMENT NO. 35812 IN BOOK 4855
PAGE 29 AND AS DOCUMENT NO. 35813 IN BOOK 4855, PAGE 32, OFFICIAL RECORDS.

ALSO EXCEPTING THEREFROM, 100% OF ALL OIL, GAS, GEOTHERMAL STEAM,
CASINGHEAD GAS, ASPHALTUM AND OTHER HYDROCARBONS AND CHEMICAL GAS
NOW OR HEREAFTER FOUND, SITUATED OR LOCATED IN ALL OR ANY PORTION OF THE
LANDS DESCRIBED HEREIN LYING MORE THAN FIVE HUNDRED FEET (500*) BELOW THE
SURFACE THEREOF, TOGETHER WITH THE RIGHT TO SLANT DRILL FOR AND REMOVE
ALL OR ANY OF SAID GAS, OIL, CASINGHEAD GAS, ASPHALTUM AND OTHER
HYDROCARBONS OR CHEMICAL GAS LYING BELOW A DEPTH OF MORE THAN FIVE
HUNDRED FEET (500') BELOW THE SURFACE THEREOF INCLUDING THE RIGHT TO
GRANT LEASES FOR ALL OR ANY OF SAID PURPOSES, BUT WITHOUT ANY RIGHT
WHATSOEVER TO ENTER UPON THE SURFACE OF SAID LANDS OR ANY PORTION
THEREOF WITHIN FIVE HUNDRED FEET (500') VERTICAL DISTANCE BELOW THE
SURFACE THEREOF.

TRACT TWO: (APN: 055-021-18)

THE EAST THREE-FOURTHS OF THE EAST HALF OF THE SOUTHEAST QUARTER OF
SECTION 9, TOWNSHIP 17 SOUTH, RANGE 20 EAST, MOUNT DIABLO BASE AND
MERIDIAN, ACCORDING TO THE PLAT OF LAGUNA DE TACHE GRANT, RECORDED IN
BOOK 1 PAGE 70, OF RECORD OF SURVEYS, FRESNO COUNTY RECORDS.

EXCEPTING THEREFROM AN UNDIVIDED 1/2 INTEREST IN AND TO ALL OIL, GAS, AND

MINERAL RIGHTS AS RESERVED IN THE DEED RECORDED DECEMBER 16, 1948, IN BOOK
2681 PAGE 212, OFFICIAL RECORDS.

LIS PENDENS NOTICE OF PENDING ACTION
Oo CO SN DH

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DOC #2024-0105754 Page 5 of 6
Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Page 8of9

ALSO EXCEPTING THEREFROM AN UNDIVIDED 1/4 INTEREST IN AND TO ALL OIL GAS,
AND MINERAL RIGHTS, AS RESERVED IN THE DEED RECORDED DECEMBER 30, 1952,
DOCUMENT NO. 66178, OFFICIAL RECORDS

ALSO EXCEPTING THEREFROM ALL REMAINING OIL, GAS AND MINERAL RIGHTS, AS
RESERVED IN THE DEED RECORDED NOVEMBER 15, 1993 AS DOCUMENT NO. 93176469,
OFFICIAL RECORDS.

LIS PENDENS NOTICE OF PENDING ACTION
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DOC #2024-0105754 Page 6 of 6
Case 1:24-cr-00198-JLT-SKO Document11_ Filed 11/20/24 Page9of9

CERTIFICATE OF SERVICE BY CERTIFIED MAIL

The undersigned hereby certifies that she is a employee in the Office of the United States
Attorney for the Eastern District of California and is a person of such age and discretion to be competent

to serve papers.

That on November !8 , 2024, she served a copy of the Lis Pendens Notice of Pending Action
by placing said copy in a postpaid envelope addressed via certified mail to the persons hereinafter
named, at the places and addresses stated below, which are the last known addresses, and by depositing
said envelope and contents in the United States Mail at Fresno, California.

Addressee(s):

Gurjeet Singh Bath
c/o Michael McNeely
Attorney at Law
2300 Tulare Street
Fresno, CA 93721
[Attorney for Gurjeet Singh Bath|

Jesse P. Silva Jr.
Joseph V, Silva
Helena M. Silva
760 N. Cherry Lane
Clovis, CA 93611

Terra dos Sonhos, LLC
a California Limited Liability
Company

c/o Robert W. Gin

Griswold, LaSalle, Cobb,
Dowd & Gin, LLP

111 East Seventh Street

Hanford, CA 93230

C.L. Services, Inc.
a Georgia Corporation
c/o Nikole E. Cunningham
McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
7647 N. Fresno Street
Fresno, CA 93720

Adriana Martinez
Felipe Gallegos Barrios
18648 S. Elm Avenue

Riverdale, CA 93656 <)>

LIS PENDENS NOTICE OF PENDING ACTION


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