UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 

IN RE: ONE 2002 26-FOOT PURSUIT VESSEL, 

KNOWN AS M/V HIGH TROLLERS WITH 

HULL IDENTIFICATION NUMBER SSUJ6060K10

AND, REGISTRATION NUMBER DO1140020, 

REGISTERED IN FLORIDA.

(CATS NO. 19-ICE-002696)

__________________________________________/

JOINT MOTION TO ENLARGE TIME IN WHICH TO FILE 

CIVIL FORFEITURE COMPLAINT OR CRIMINAL FORFEITURE

Pursuant to 18 U.S.C. § 983(a)(3)(A), the United States of America (“United States”) and 

Raidel Lechuga (“Claimant”) (collectively, the “Parties”) file this Joint Motion To Enlarge Time 

in Which To File Civil Forfeiture Complaint or Criminal Forfeiture. In support of this Motion, the 

Parties state as follows:

1. On or about April 11, 2019, U.S. Immigration and Customs Enforcement (ICE), 

Homeland Security Investigations (HSI) seized the following go-fast vessel and inventory 

(collectively, the “Seized Assets”):

a. M/V High Trollers, hull identification number SSUJ6060K102, registered in 

Florida with registration number DO1140020;

b. One Iridium Satellite Phone (IMEI# 300115060140420 with SIM card # 

8988169326002226433);

c. One Apple iPhone (white);

d. One Apple iPhone (black); and

e. One Garmin GPSmap 7612xsv (Serial# 401008666 with two micro SD cards).

2. U.S. Customs and Border Protection (CBP) 1 initiated administrative forfeiture 

proceedings, and sent written notices of seizure to potential claimantsin accordance with 18 U.S.C. 

 1 CBP processes administrative forfeiture proceedings for HSI and ICE.

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§ 983(a)(1)(A). 

3. On February 7, 2020, CBP received a claim filed by Mr. Lechuga to the Seized 

Assets (dated February 4, 2020). CBP subsequently referred this matter to the U.S. Attorney’s 

Office for the Southern District of Florida. 

4. The Department of Justice assigned CATS No. 19-ICE-002696 to the Seized 

Assets. 

5. The time has expired for any person to file a claim to the Seized Asset under 18 

U.S.C. § 983(a)(2)(A)-(E). No other person has filed a claim to the property as required by law in 

the non-judicial civil forfeiture proceeding.

6. Pursuant to 18 U.S.C. § 983(a)(3), within 90 days after a claim is filed, the United 

States is required to file a civil forfeiture complaint or obtain a criminal indictment containing an 

allegation that the property is subject to forfeiture. However, the Court may extend the period for 

filing a civil forfeiture complaint for good cause shown or upon agreement of the Parties.

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7. Pursuant to 18 U.S.C. § 983(a)(3)(A)-(C), the deadline for the United States to file 

a civil forfeiture complaint or to obtain an indictment alleging that the Seized Asset is subject to 

forfeiture is May 7, 2020. The Parties now have agreed to extend this deadline by 32 days, until 

June 8, 2020.

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 The statute, in relevant part, reads:

(A) Not later than 90 days after a claim has been filed, the Government shall file 

a complaint for forfeiture in the manner set forth in the Supplemental Rules 

for Certain Admiralty and Maritime Claims or return the property pending 

the filing of a complaint, except that a court in the district in which the 

complaint will be filed may extend the period for filing a complaint for good 

cause shown or upon agreement of the parties.

18 U.S.C. § 983(3)(A).

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8. Claimant, through its undersigned counsel, has knowingly, intelligently, and 

voluntarily agreed to give up any right it may have under 18 U.S.C. § 983(a)(3)(A)-(C) to require 

the United States to file a complaint for forfeiture against the property and/or to obtain an 

indictment alleging that the property is subject to forfeiture no later than June 8, 2020, and any 

right Claimant may have to seek dismissal of any complaint and/or any indictment on the ground 

that it was not filed or returned on or before May 7, 2020. 

9. In addition, there is good cause to extend the deadline from May 7, 2020, to June 

8, 2020, as the Parties currently are in settlement negotiations, and the requested extension would 

afford the Parties additional time to resolve this matter without litigation.

WHEREFORE, the Parties respectfully request that the Court grant this motion. A 

proposed order is attached.

Respectfully submitted,

By: /s/ Martin J. Beguiristain Date: April 27, 2020

Martin J. Beguiristain, P.A.

Counsel for Claimant

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

By: /s/ Joshua Paster Date: April 27, 2020

Joshua Paster

Assistant United States Attorney

Court ID No. A5502616

U.S. Attorney’s Office 

99 NE 4th Street

Miami, Florida 33132-2111

Telephone: (305) 961-9342

Facsimile: (305) 536-4089

Email: Joshua.Paster@usdoj.gov

Counsel for the United States

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