Exhibit A — Case 5:23-cv-00393, Document 19-1

Summary

Exhibit A to Document 19-1 in Case 5:23-cv-00393 contains emails between John A. Carr and Chris R. Arthur, an Assistant United States Attorney, Southern District of West Virginia, under the subject Bailey Forfeiture. In a June 20, 2023 email, Carr states a wish to be clear about the requirements to file the claim for both and their companies, and says both are doing so. Arthur recommends a joint stipulation giving the clients 60 days to respond, and says the deadline is technically 30 days from date of service but that there are no issues extending it. A later message from Arthur attaches a Ross Joint Stipulation and says that on these cases the court is often moved to stay due to a criminal proceeding.

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“Exhibit A — Case 5:23-cv-00393, Document 19-1.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-wvsd-236863-19-1-d4b39788ce/, SHA-256 efe05fdf9eb1e11c25aa7f3a17d806dc37614bf6f4e4a217759452857dd56ba4.

Full text

Case 5:23-cv-00393   Document 19-1   Filed 12/16/24   Page 1 of 3 PageID #: 88




                     Exhibit A
           Case 5:23-cv-00393              Document 19-1        Filed 12/16/24      Page 2 of 3 PageID #: 89


Arthur, Chris (USAWVS)

From:                                  Arthur, Chris (USAWVS)
Sent:                                  Tuesday, June 20, 2023 8:1 1 AM
To:                                    John A. Carr
Cc:                                    Goes, Erik (USAWVS)
Subiect:                               re: Bailey Forfeiture


Sorry I did not have chance to return your call on Friday, took day off. lt is on my due list. To simplify, I recommend we
file a joint stipulation giving your clients 60 days to respond from today, 8119/23. Technically, the deadline is 30 days
from date of service. But, I have no issues extending that date for how much time you need to respond.

Letmeknowifthatworksandlwill preparejointstipulation. lhavebriefdeadlinethatlneedtowrapuptodaysolmay
not get the stipulation to you until tomorrow.

Chris R. Arthur
Assistant United States Attorney
Southern District of West Virginia
300 Virginia Street East, # 4000
Charleston, West Virginia 25301

-----Origina I Message-----
From: John A. Carr <jcarr@jcarrlaw.com>
Sent: Tuesday, June 20,2023 7:53 AM
To : Arth u r, Ch ris ( USAWVS) <ca rth u r@ usa.d oj.gov>
Cc: Goes, Erik (USAWVS) <EGoes@usa.doj.gov>
Subject: [EXTERNAL] Bailey Forfeiture

Chris,

lrealizeyoumightbeoutoftheofficetoday. ltriedtogetaholdofyoulastweekconcerningtheforfeitureonthe
Baileys. I also have been trying to contact Erik for the last 10 days. I wanted to be clear about the requirements to file the
claim for both and their companies on filing the claim to trigger the answer deadlines. Both are doing so.

Please let me know,

John A. Carr
Attorney at Law, PLLC
179 Summers St. Ste 209
Charleston, WV 25301
304-344-4822 (work)
s7L-259-6796 (cell)
304-41.4-2266 (fax)
https://protect2.fireeye.comlvtlurl?k=2c9d6ac8-73065384-2c9a4e2d-0cc47adca7cc-
2681090b8b4ed431&q=1&e=96c949cc-cb11-4536-a6ae-790d1cf50680&u                =hltp%3A%2F%2Fwww.jcarrlaw.com%2F

*This message is sent from a handheld device. Please excuse any typos or formatting errors.




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          Case 5:23-cv-00393          Document 19-1           Filed 12/16/24    Page 3 of 3 PageID #: 90


Arthur, Chris (USAWVS)

From:                             Arthur, Chris (USAWVS)
Sent:                             Thursday, June22,2023 8:39 AM
To:                               John Carr
Subject:                          Ross Joint Stipulation.docx
Attachments:                      Ross Joint Stipu lation.docx



Extends deadline to8/21,. On these cases, we often move the court to stay due to criminal proceeding. lf that is
desirable in the future, I will prepare and jointly move for the stay, assuming criminal indictment is filed.

Let me know if I can file




                                Chris Anhur
                                Assistant U.S. Attorney
                                Southern District of West Virginia
                                Roben C. Byrd U.S. Counhouse
                                300 Virginia Street Easr
                                tuite 40OO
                               Charleston, WV 25301
                                Direcl: 304-34S7851
                                Ema il: Chris.Anhur@   us&j.gw




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