1 ELIZABETH A. STRANGE 

First Assistant United States Attorney 

2 District of Arizona 

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

3 kevin.rapp@usdoj.gov 

MARGARET PERLMETER (Ariz. Bar No. 024805), 

4 margaret.perlmeter@usdoj.gov 

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

5 Peter.kozinets@usdoj.gov 

DOMINIC LANZA (Cal. Bar No. 225989), 

6 dominic.lanza@usdoj.gov 

Assistant U.S. Attorneys 

7 40 N. Central Avenue, Suite 1800 

Phoenix, Arizona 85004-4408 

8 Telephone (602) 514-7500 

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

john.kucera@usdoj.gov 

10 Special Assistant U.S. Attorney 

312 N. Spring Street, Suite 1400 

11 Los Angeles, CA 90012 

Telephone (213) 894-3391 

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BRIAN BENCZKOWSKI 

13 Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

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

15 reginald.jones4@usdoj.gov 

Senior Trial Attorney, U.S. Department of Justice 

16 Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116 

17 Washington, D.C. 20530 

Telephone (202) 616-2807 

18 Attorneys for Plaintiff 

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UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF ARIZONA 

United States of America, 

Plaintiff, 

v. 

Michael Lacey, et al., 

Defendants. 

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

NOTICE OF GOVERNMENT'S FILING 

OF RECORDED LIS PENDENS AS TO 

REAL PROPERTY LOCATED IN SONOMA 

COUNTY, CALIFORNIA 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 1 of 10
1 Plaintiff United States of America gives notice that on 

2 June 27, 2018 it recorded the attached Lis Pendens with the 

3 Sonoma County Recorder under Doc. # 2018046033, and sent copies 

4 of the recorded Lis Pendens to the titled owners and any known 

5 lienholders. A copy of the Lis Pendens is attached hereto as 

6 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, I electronically transmitte 

the attached document to the Clerk's Office using the CM/ECF Syste 

for filing and transmittal of a Notice of Electronic Filing to the 

following CM/ECF registrants: Anne Chapman, Erin Mccampbell, James 

Grant, Lee Stein, Paul Cambria, Robert Corn-Revere, Ronald London, 

Janey Henze Cook, John Littrell, Kenneth Miller, Thomas Bienart, 

Jr., Bruce Feder, Michael Kimerer, Rhonda Neff, KC Maxwell, Davi 

Wakukawa, Michael Piccarreta, Stephen Weiss. 

By: s/Krystie Sor 

U.S. Attorney's Office 

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Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 2 of 10
Recording Requested By and 

Return to: 

Name: Shannen Beckman 

Senior Paralegal 

MAILING Shannen.Beckman 

ADDRESS: 312 N. Spring St., 14th Floor 

CITY, STATE, Los Angeles, CA 

ZIP CODE: 90012 

2018046033 

Official Records Of Sonoma County William F. Rousseau 

06/27/2018 01:36 PM 

Fee:$ 29.00 6 Pages 

Document Title( s) 

Sebastopol, CA 94115 

Sonoma County 

APN: 076-10.0-0008-000 

Reason for exemption: 

D Document is subject to the imposition of documentary transfer tax and includes a declaration showing the 

amount of documentary transfer tax paid at the time of recording 

D Exempt from fee per GC 27388.1 (a) (2); recorded concunently "in connection with" a transfer subject to 

the imposition of documentary transfer tax 

D Exempt from fee per GC sec 27388.1 (a) (2); Document represents a transfer of real property that is a 

residential dwelling to an owner-occupier 

D Exempt from fee per GC 27388.1 (a) (2); recorded concmrently "in connection with" a transfer of real 

property that is a residential dwelling to an owner-occupier 

D Exempt from fee per GC 27388.l (a) (1); fee cap of $225 reached 

D Exempt from the fee per GC 27388.l (a) (1) Not related to real property 

I· Exempt from the fee per GC 27388.1 (a) (2); executed or recorded by a government agency 

I hereby declare that the information provided above is true and conect. 

~~fi~0 f/;_~ Shannen Beckman 

/Signature Printed Name 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 299 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) 1 

kevin.rapp@usdoj.gov 

DOMINIC LANZA (Cal. Bar No. 225989) 1 

dominic.lanza@usdoj.gov 

MARGARET PERLMETER (Ariz. Bar No. 024805) 1 

margaret.perlmeter@usdoj.gov 

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

john.kucera@usdoj.gov 

Assistant U.S. Attorneys 

40 N. Central Avenue, Suite 1800 

Phoenix 1 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 

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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 

Sebastopol 1 California 

Titled Owners: Finca Manzana for 

Sebastopol, LLC 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 299 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 

4 this action is located in Sebastopol, California and is more 

5 particularly described as follows: 

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Lot 2 as numbered and designated upon the map entitled 

"Plat of Subdivision of Lands of Pleasant Hill Orchard 

Company, Sonoma County, California", filed on July 21, 1905 

in Book 18 of Maps at page 13, Sonoma County Records. 

APN: 076-100-008-000 

For further information concerning the forfeiture, reference may 

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

District Court at Phoenix, Arizona. Title to the defendant property 

is held in the name of Finca Manzana for Sebastopol, LLC, a Delaware 

limited liability company. 

Dated: May~-' 2018 Respectfully submitted, 

ELIZABETH A. STRANGE 

First Assistant United States Attorney 

District of Arizona 

JOHN P. CRONAN 

Acting Assistant Attorney General 

Criminal Division, U.S. Department of 

Justice ,c,;·· 

i ', _____J _.4 

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 

2 EXHIBIT A 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 5 of 10
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A notary public or other officer completing 

this certificate verifies only the identity 

of the individual who sighed the document to 

which this certificate is attached, and not 

the truthfulness, accuracy, or validity of 

that document. 

5 STATE OF CALIFORNIA 

ss 

6 COUNTY OF LOS ANGELES 

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On this 22nd day of May, 2018, before me, Roland Hernandez, 

Notary Public, personally appeared Assistant U.S. Attorney John J. 

Kucera, who proved to me on the basis of satisfactory evidence to 

be the person whose name is subscribed to the within instrument 

and acknowledged to me that he executed the same in his authorized 

capacity, and that by his signature on the instrument the person, 

or the entity upon behalf of which the person _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. 

Public 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 6 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 

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

On June 25 1 2018, I served a copy of: 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. 

12 TO: SEE SERVICE LIST 

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

14 collection and processing correspondence for mailing. On the 

15 same day that correspondence is placed for collection and 

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

17 . the United States Postal Service in a sealed envelope with 

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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 on: June 251 2018 at Los Angeles, California. 

EXHIBIT A 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 7 of 10
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SERVICE LIST 

Finca Manzana for Sebastopol, LLC 

C/0 Corporation Service Company 

Registered Agent 

251 Little Falls Drive 

Wilmington, De 19808 

Finca Manzana for Sebastopol, LLC 

2043 Pleasant Hill Rd 

Sebastopol, CA 95472 

EXHIBIT 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 8 of 10
1 PROOF OF SERVICE BY MAILING 

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

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

4 Attorney, Central District of California. My business address 

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

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

7 OF RECORDED LIS PENDENS upon each person or entity named below 

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

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

10 at the place shown below following our ordinary office 

11 practices. 

12 TO: SEE SERVICE LIST 

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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 299 Filed 09/11/18 Page 9 of 10
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SERVICE LIST 

Finca Manzana for Sebastopol, LLC 

C/0 Corporation Service Company 

Registered Agent 

-IEll!DIIUI! IIIIL!lhw 

Wilmington, De 19808 

Finca Manzana for Sebastopol, LLC 

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Sebastopol, CA 95472 

Case 2:18-cr-00422-DJH Document 299 Filed 09/11/18 Page 10 of 10