United States v. Approximately $3,801,034.94 in U.S. Currency Seized From Citibank Account Number 206054579 Held in the Name of Arthur Ave. Consulting, Inc.

INTRODUCTION

2200 The United States, claimant The Federal Republic of Nigeria (“Government of Nigeria”), and 2211 claimants Ara G. Dolarian, Arthur Ave. Consulting, Inc., Martel 3D LLC, and Dolarian Capital, Inc. (the 2222 “Dolarian Claimants” and together with Government of Nigeria, collectively, the “Claimants”), hereby 2233 stipulate that a stay of the instant action is necessary, and request that the Court enter an order staying all 2244 further civil forfeiture proceedings in this case in favor on ongoing criminal forfeiture proceedings 2255 ongoing in the related criminal case United States v. Ara G. Dolarian, 1:19-CR-00138-JLT-SKO. The 2266 seized assets in the related criminal case are the same assets that are the subject of this civil forfeiture 2277 case and, thus, resolution of the criminal forfeiture case will be dispositive of this civil asset forfeiture 11 FACTS 22 On March 8, 2023, Defendant Ara G. Dolarian was sentenced in his criminal case. As a matter of law, the amended preliminary order of forfeiture, filed on January 29, 2020, became final as to the 33 defendant at sentencing and, as a result, his interest in…