UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA, 

Plaintiff, Civil No. 08-14611

vs. Honorable Patrick J. Duggan

Magistrate Michael J. Hluchaniuk

ELEVEN THOUSAND ONE HUNDRED THIRTY

NINE DOLLARS AND NINETY ONE CENTS IN 

U.S. CURRENCY ($11,139.91), FROM COMERICA 

BANK ACCOUNT #XXXX-XXXXXX3967;

ELEVEN THOUSAND SEVEN HUNDRED FORTY

DOLLARS AND SIXTY ONE CENTS IN U.S. CURRENCY

($11,740.61) FROM COMERICA BANK ACCOUNT 

#XXXX-XX-0355; SIXTEEN THOUSAND EIGHT HUNDRED 

SEVEN DOLLARS AND SEVENTY FIVE CENTS 

IN U.S. CURRENCY ($16,807.75) FROM COMERICA 

BANK ACCOUNT #XXXXX1535; 

Defendants In Rem.

________________________________________________/

STIPULATION AGREEING TO RELEASE FUNDS TO CLAIMANT &

WITHDRAWING CLAIMANT’S MOTION TO LIFT STAY 

AND RELEASE UNTAINTED FUNDS

Now come the Plaintiff, United States by and through its counsel, BARBARA L. 

McQUADE, United States Attorney, and PHILIP A. ROSS, Assistant United States Attorney,

and Dr. Jose Castro-Ramirez, by and through counsel, Allen M. Wolf, Esquire, who enter into

this Stipulation for entry of an Order Releasing Funds to Claimant and withdrawing Claimant's

Motion To Lift Stay For Hearing To Release Untainted Funds (Docket No. 20) as evidenced by

their signatures below, under the terms and conditions hereinafter set forth:

WHEREAS, on January 22, 2010, Claimant filed a Motion To Lift Stay For Hearing To

Release Untainted Funds seeking the release of funds seized in order to pay his defense in United

States v. Chand, et. al, (09-cr-20215, Cox, J.); 
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WHEREAS the parties wish to resolve this matter without further litigation and

expenses;

WHEREAS, the parties are aware of their respective rights in this matter; 

NOW THEREFORE IT IS HEREBY, agreed upon by the parties, the UNITED STATES

OF AMERICA, by and through its counsel, BARBARA L. MCQUADE, United States Attorney,

and PHILIP A. ROSS, Assistant United States Attorney, and Claimant, Dr. Jose CastroRamirez, by and through his counsel, ALLEN M. WOLF, to the following:

1) Claimant, Dr. Jose Castro-Ramirez, agrees to withdraw his Motion To Lift Stay

and Release Untainted Funds, Docket No. 20. 

2) The United States agrees that Eleven Thousand Seven Hundred Forty Dollars

and Sixty One Cents in U.S. Currency ($11,740.61) seized from Comerica Bank Account No.

XXXX-XX-0355 SHALL BE RETURNED to Claimant by the United States Marshals Service

through counsel for Claimant, Allen M. Wolf. 

3) Claimant, Dr. Jose Castro-Ramirez further agrees to release, remise and forever

discharge the plaintiff, United States of America, and its agents, officers, employees, past and

present, and all other persons, including but not limited to any individual local law enforcement

officers or departments or agencies assisting in any manner in the facts, events and

circumstances giving rise to the complaint filed herein, from all claims or causes of action which

claimants, and his agents, officers, employees, past and present, and which claimant and his

assigns, agents, officers employees and successors in interest hereafter can, shall or may have

for, or on account of the incidents or circumstances giving rise to the seizure of Eleven Thousand

Seven Hundred Forty Dollars and Sixty One Cents in U.S. Currency ($11,740.61) seized from
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Comerica Bank Account No. XXXX-XX-0355.

4. The parties agree that the remaining funds Eleven Thousand One Hundred ELEVEN

Thirty Nine Dollars and Ninety One Cents in U.S. Currency ($11,139.91), FROM COMERICA

BANK ACCOUNT #XXXX-XXXXXX3967 and Sixteen Thousand Eight Hundred Seven

Dollars and Seventy Dollars and Seventy-Five Cents ($16,807.75) FROM COMERICA BANK

ACCOUNT #XXXXX1535 SHALL REMAIN DEPOSITED with the United States Marshals

Service.

5. The parties agrees that the Stay imposed by order of this court on March 4, 2009,

shall remain in place until further order of this court. 

6. The parties agree that each party shall bear its own costs in this matter. 

WHEREFORE, the parties stipulate to entry of the following Order.

AGREED TO IN FORM AND SUBSTANCE.

Respectfully submitted, 

Barbara L. McQuade

United States Attorney

s/Philip A. Ross s/Allen M. Wolf, Esq. 

Philip A. Ross Allen M. Wolf, Esquire (P31759)

Assistant United States Attorney Attorney for Claimant

211 W. Fort Street, Suite 2001 436 S. Broadway, Suite C

Detroit, MI 48226-3211 Lake Orion, MI 48362

(313) 226-9790 (248) 693-6245

Email: philip.ross@usdoj.gov Email: awolf@lawwolf.com

VA State Bar No. 70269

Dated: 2/16/2010 Dated: 2/16/2010

s/Jose Castro Ramirez

Dr. Jose Castro-Ramirez

Claimant (signature page attached)

IT IS SO ORDERED.

S/Patrick J. Duggan 
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Patrick J. Duggan

United States District Judge

Dated: February 16, 2010

I hereby certify that a copy of the foregoing document was served upon counsel of record

on February 16, 2010, by electronic and/or ordinary mail.

S/Marilyn Orem 

Case Manager
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