Case 1:10-cr-00200-LMB Document 380

Filed 02/24/12 Page 1 of 1 PageID# 6209

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA
,

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Criminal Case No. 1:10-C.R.200-LMB

Lee Bentley Farkas

Motion to Amend Preliminary Order of Forfeiture

COMES NOW Defendant, Lee Bentley Farkas, ProSe, and moves to amend the Preliminary Order of Forfeiture in
the case as follows:

A) The Court should deny the Government's January 26, 2102 motion to amend the preliminary order offorfeiture. The Government seeks to add three real properties located at 2014 NE 18St., 2019 NE 17 Ct., and 2022 NE 18St., all In Ft Lauderdale, Florida. The Government's motion further seeks to release 815 S. Pine Ave, Ocala, FL from said order. It also seeks forfeiture of a 1954 Cadillac Eldorado convertible. The three real properties are not currently owned, nor

have they ever been owned by Lee Bentley Farkas. They were originally purchased by and are owned by Thunderflower, LLC, an Illinois Limited Liability Company. The Government is seeking forfeiture of assets not owned by Lee Bentley
Farkas. Release ofthe 815 S. Pine Ave property, although not requested by Farkas, is acceptable.

The 1954 Cadillac is an irreplaceable, unique asset. Fewer than 700 were ever produced, a handful remain, and virtually none in the condition of this asset. It is impossible to replace. The proceeds that the Government may eventually get will never be able to replace this asset. Farkas prays that the Court stay any forfeiture of this asset pending Farkas'
appeals being exhausted.

B) In addition, the proper venue for the forfeiture case against Farkas is the MIDDLE DISTRICT OF FLORIDA, the location
of Farkas' primary residence priorto incarceration. Farkas hereby moves that the forfeiture action be transferred to the

Middle District of Florida immediately. Federal law gives the defendant in a case such as this one the opportunity to have the case heard in the district overseeing his legal address. Lee Bentley Farkas is a resident of Marion County,
Florida for these purposes, and hereby makes the request to transfer the case there.

WHEREFORE Defendant, Lee Bentley Farkas, Pro Se, respectfully requests this Court deny the Government's motion amending the preliminary order of forfeiture to include the 1954 Eldorado and the real properties located at
2014 NE 18 St, 2019 NE 17 Ct, and 2022 NE 18 St, in Ft Lauderdale, Florida; to grant the Government's motion to release 815 S. Pine Ave, Ocala, FL, and to immediately transfer these forfeiture proceedings to the Middle District of Florida as is
called for under the law.

Respectfully submitted,

Lee Bentley Farkas mVS^c -o\S

FCI Buttner 2

P.O. Box 1500

Buttner, NC 27509