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ELIZABETH A. STRANGE 

First Assistant United States Attorney 

District of Arizona 

KEVIN M. RAPP (Ariz. Bar No. 14249), 

kevin.rapp@usdoj.gov 

MARGARET PERLMETER (Ariz. Bar No. 024805), 

margaret.perlmeter@usdoj.gov 

PETERS. KOZINETS (Ariz. Bar No. 019856), 

Peter.kozinets@usdoj.gov 

DOMINIC LANZA (Cal. Bar No. 225989), 

dominic.lanza@usdoj.gov 

Assistant U.S. Attorneys 

40 N. Central Avenue, Suite 1800 

Phoenix, Arizona 85004-4408 

Telephone (602) 514-7500 

JOHN J. KUCERA (Cal. Bar No. 274184), 

john.kucera@usdoj.gov 

Special Assistant U.S. Attorney 

312 N. Spring Street, Suite 1400 

Los Angeles, CA 90012 

Telephone (213) 894-3391 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

REGINALD E. JONES (Miss. Bar No. 102806), 

reginald.jones4@usdoj.gov 

Senior Trial Attorney, U.S. Department of Justice 

Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116 

Washington, D.C. 20530 

Telephone (202) 616-2807 

Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF ARIZONA 

United States of America, 

Plaintiff, 

v. 

Michael Lacey, et al., 

No. CR 18-422-PHX-SPL (BSB) 

NOTICE OF GOVERNMENT'S FILING 

OF RECORDED LIS PENDENS AS TO 

REAL PROPERTY LOCATED IN SAN 

FRANCISCO COUNTY, CALIFORNIA 

25 Defendants. 

26 Plaintiff United States of America gives notice that on 

27 July 2, 2018 it recorded the attached Lis Pendens with the San 

28 Francisco County Recorder under Doc. # 2018K635051, and sent 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 1 of 10
1 copies of the recorded Lis Pendens to the titled owners and any 

2 known lienholders. A copy of the Lis Pendens is attached hereto 

3 as Exhibit "A". 

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DATED: September 11, 2018 ELIZABETH A. STRANGE 

First Assistant United States 

Attorney 

District of Arizona 

BRIAN BENCZKOWSKI 

Acting Assistant Attorney General 

Criminal Division, U.S. Department 

of Justice 

/s/John J. Kucera 

KEVIN RAPP 

MARGARET PERLMETER 

PETERS. KOZINETS 

DOMINIC LANZA 

JOHN J. KUCERA 

Assistant U.S. Attorneys 

REGINALD JONES 

Senior Trial Attorney 

CERTIFICATION 

I certify that on September 11, 2018, I electronicall 

transmitted the attached document to .the Clerk's Office using the 

CM/ECF System for filing and transmittal of a Notice of Electronic 

Filing to the following CM/ECF registrants: Anne Chapman, Eri 

Mccampbell, James Grant, Lee Stein, Paul Cambria, Robert CornRevere, Ronald London, Janey Henze Cook, John Littrell, Kennet 

Miller, Thomas Bienart, Jr., Bruce Feder, Michael Kimerer, Rhond 

Neff, KC Maxwell, David Wakukawa, Michael Piccarreta, Stephe 

Weiss. 

By: s/Krystie Sor 

U.S. Attorney's Office 

2 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 2 of 10
RECORDING REQUEST BY 

UNITED STATES 

WHEN RECORDED MAIL TO 

Name: Shannen Beckman 

Senior Paralegal 

MAILING 

ADDRESS: 

CITY, STATE, 

ZIP CODE: 

Shannen.beckman@usdoj.gov 

312 N. Spring St., 14th Floor 

Los Angeles, CA 

90012 

CONFORMED COPY of document reco•·ded 

~!~~~~20l8120l8K63505l 

on_ with dociuneiffno-·-· ---- 'l'hls document has not been compared with the orlgln .. f 

SA,N FRANCISCO ASSESSOR-RECORDER 

SPACE ABOVE TIIIS LINE RESERVED FOR RF..CORDER'S USE 

TITLE(S) 

Recording of Lis Pendens 

San Francisco CA 94115 

cisco County 

Assessor's Lot 057; Block: 1008 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 3 of 10
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ELIZABETH A. STRANGE 

First Assistant United States Attorney 

District of Arizona 

KEVIN M. RAPP (Ariz. Bar No. 14249), 

kevin.rapp@usdoj.gov 

DOMINIC LANZA (Cal. Bar No. 225989), 

dominic.lanza@usdoj.gov 

MARGARET PERLMETER (Ariz. Bar No. 024805), 

margaret.perlmeter@usdoj.gov 

JOHN J. KUCERA {Cal. Bar No. 274184) 1 

john.kucera@usdoj.gov 

Assistant U.S. Attorneys 

40 N. Central Avenue, Suite 1800 

Phoenix1 Arizona 85004-4408 

Telephone (602) 514-7500 

JOHN P. CRONAN 

Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

REGINALD E. JONES {Miss. Bar No. 102806), 

reginald.jones4@usdoj.gov 

Senior Trial Attorney, U.S. Department of Justice 

Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116 

Washington, D.C; 20530 

Telephone (202) 616-2807 

Attorneys for Plaintiff 15 

16 

Attorneys for Plaintiff 

17 UNITED STATES OF AMERICA 

18 UNITED STATES DISTRICT COURT 

19 FOR THE CENTRAL DISTRICT OF CALIFORNIA 

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UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

MICHAEL LACEY 

Defendant. 

No. CR-18-00422-PHX-SPL 

LIS PENDENS 

San Francisco, California 

Titled Owners: Michael G. Lacey 

and Alyson Talley 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 4 of 10
1 NOTICE IS HEREBY GIVEN that the foregoing action has been 

2 commenced and is now pending in the United States District Court for 

· 3 the District of Arizona. The real property that is the subject of 

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this action is located in San Francisco, California and is more 

particularly described as follows: 

Parcel A: 

Condominium Unit No. 343, Lot No. 57, as shown upon the 

Condominium Map and diagrammatic floor plan 

entitled, "Parcel Map of 339-341-343 Presidio Avenue, A 

Residential Condominium Project" which was filed for 

record on January 31 , 2002, in Condominium Map Book 72, .at 

Pag~s 115 through 117, inclusive, in the office of 

the Recorder of the City and County of San Francisco, State 

of California (referred to herein as 11 the Map") and as 

further defined in the Declaration of Covenants, Conditions 

and Restrictions of 339-341-343 Presidio Avenue, a 

Condominium Project, recorded on April 22, 2002 as 

Instrument/Series No. 2002-H152375-00, Official Records of 

the City and County of San Francisco, State of California 

(referred to herein as "the Declaration 11 ). 

Excepting therefrom any portion of the common area lying 

within said Unit. 

Parcel B: 

An undivided 48.15% interest in and to the Common Area as 

shown on the Map and defined in the Declaration, 

reserving therefrom the following: 

(a) Exclusive easements, other th1n those shown in Parcel 

11 c 11 herein, as shown on the Map and reserved by 

Grantor to.Units for use as defined in the Declaration; and 

(b) Nonexclusive easements appurtenant to all units for 

ingress and egress, supp~rt, repair and maintenance. 

.Parcel C: 

(a) The exclusive easement to use the Parking Area(s) 

designated a~ P-2 on the Map. 

(b) The exclusive easement to use the Planter Area(s) 

designated as None on the Map. 

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EXHIBIT A 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 5 of 10
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I I I 

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(c) The exclusive easement to use the Storage Area(s) 

designated as on the Map .. 

· ( d) The exclusive easement to use the Landing Area ( s) 

designated as None on the Map. 

Parcel D: 

A nonexclusive easement appurtenant to Parcel A above for 

support repair and maintenance, and for ingress and 

egress through the Common Area in accordance with 

California Civil Code Section 1361 (a). 

Parcel E: 

Encroachment easements appurtenant to the Unit in 

accordance with the provisions of the Declaration. 

APN: 07-1008 -057-01 

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EXHIBIT A 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 6 of 10
1 For further information concerning the forfeiture, reference may 

2 be had to the records of the Clerk of the Court for the United States 

3 District Court at Phoenix1 Arizona. Title to the defendant property 

4 is held in the name of Michael G. Laceyr a single man and Alyson 

5 Talley1 a single woman 1 as joint tenants with right of survivorship. 

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Dated: May ~ 1 2018 I 

Respectfully submitted, 

ELIZABETH A. STRANGE 

First Assistant United States Attorney 

District of Arizona 

JOHN P. CRONAN 

Acting Assistant Attorney General 

Criminal Division1 U.S. Department of Justic1/( 

KEVIN RAPP 

DOMINIC LANZA 

MARGARET PERLMETER 

JOHN J. KUCERA 

Assistant U.S. Attorneys 

REGINALD JONES 

Senior Trial Attorney 

Attorneys for Plaintiff 

UNITED STATES OF AMERICA 

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EXHIBIT A 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 7 of 10
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PROOF OF SERVICE BY MAILING 

I am over the age of 18 and not a party to the within 

action. I am employed by the Office of the United States 

4 Attorney, Central District of California. My business address 

s is 

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Floor, Los Angeles, CA 90012. 

copyof:~ 

7 upon each person or entity named below by 

8 enclosing a copy in an envelope addressed as shown below and 

9 placing the envelope for collection and mailing on the date and 

lO at the place shown below following our ordinary office 

ll practices. 

12 TO: MICHAEL G. LACEY 

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ALYSON TALLEY 

SAN FRANCISCO, CA 94115-2045 

X I am readily familiar with the practice of this office for 

collection and processing correspondence for mailing. On the 

same day that correspondence is placed for collection and 

mailing, it is deposited in the ordinary course of business with 

the United States Postal Service in a sealed envelope with 

postage fully prepaid. 

I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. 

I declare that I am employed-in the office of a member of 

the bar. of this court at whose direction the service was made. 

Executed oni MayJ..{, 2018 at Los Angeles, California. 

~---

EXHIBIT 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 8 of 10
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PROOF OF SERVICE BY MAILING 

I am over the age of 18 and not a party to the within 

action. I am employed by the Office of the United States 

Attorney, Central District of California. My business address 

is 312 North Spring Street, 14th Floor, Los Angeles, CA 90012. 

On September 11, 2018, I served a copy of: NOTICE OF FILING 

OF RECORDED LIS PENDENS upon each person or entity named below 

by enclosing a copy in an envelope addressed as shown below and 

placing the envelope for collection and mailing on the date and 

at the place shown below following our ordinary office 

practices, or forwarding a copy via e-mail as approved by 

recipient. 

TO: SEE SERVICE LIST 

X I am readily familiar with the practice of this office for 

collection and processing correspondence for mailing. On the 

same day that correspondence is placed for collection and 

mailing, it is deposited in the ordinary course of business with 

the United States Postal Service in a sealed envelope with 

postage fully prepaid. 

I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. 

I declare that I am employed in the office of a member of 

the bar of this court at whose direction the service was made. 

California. 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 9 of 10
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SERVICE LIST 

San Francisco, 94115-2045 

Alyson Talley 

c/o Martha Boersch 

Boersch Shirpiro LLP • # μ -

Oakland,~ CA·· 94612 

MBoersch@boerschshapiro.com 

Case 2:18-cr-00422-DJH Document 300 Filed 09/11/18 Page 10 of 10